I.S.Rating is the world's first rating company specialized in information security.

Action guideline for rating
I.S.Rating Co., Ltd.

This action guideline for rating stipulates the involvement of stockholders, officers and employees in decisions on rating symbols, management of confidential information and the obligation of officers and employees, etc. to ensure neutrality, fairness and independency of information security rating implemented by I.S.Rating.
I.S.Rating pledges to ensure that all its employees and officers make efforts to act in accordance with this action guideline for rating.

1. Decision regarding rating symbol
The rating symbol shall be determined by the Rating Committee, independent from interested parties such as officers, employees and stockholders. Interested parties including officers, employees and stockholders shall not be involved with the decision regarding the rating symbol.
The stockholder equity ratio of any group shall be less than 20%.
In addition, employees temporarily transferred to I.S.Rating from any one group company shall be less than 20% of the total number of employees.
Furthermore, we shall aim for a ratio of sales to any one group company of our total sales of less than an average of 20% over a five-year period.
2. Management of confidential information
All officers and employees of I.S.Rating shall appropriately manage confidential information obtained from entities subject to our evaluation. In addition, confidential information regarding such entities shall be used solely for the purpose of conducting rating operations and shall not be disclosed or transferred to any third party.
If the disclosure and/or transfer of information to a third party is deemed necessary for the making of a decision on a rating symbol, a confidentiality agreement shall be concluded with such third party and the status of management of confidential information at the third party shall be confirmed by us.
3. Prohibition of security transaction, etc.
All officers and employees of I.S.Rating shall observe the Financial Instruments and Exchange Law, applicable laws and regulations and internal regulations, etc. and shall not trade any equity shares, etc. based on information acquired about entities subject to I.S.Rating's evaluation through the evaluation process.
In addition, no information security rating analyst or his or her direct relatives may trade equity shares of entities etc. subject to our rating.
4. Other policy
Retiring officers and employees are obliged to comply with this policy and internal regulations, etc. for one year after leaving or retiring from office as well as observe the separately stipulated agreement submitted at the time of leaving or retiring from office.

October 24, 2008
Makoto Miyoshi
I.S.Rating Co., Ltd.

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