Recusal Requirements A. Divestment Requirement AG / Pre-Clearance AG / Efeed Fitch Ratings Inc. / Fitch Ratings Inc. / Global Compliance Group Fitch Ratings Inc. / Securities Transactions Securities / Securities Holdings Securities / D. Outside Employment Fitch’s Human Resources / Entertainment Policy A. Business Events AG / Prohibitions Securities trading / Permitted Permitted Permitted Fitch / B. 30-Day Holding Period Restriction A / E. Group / Group Investment Restrictions Fitch Ratings Inc. / Insider Trading / E. Group Investment Restrictions AG / Rated Entity / /
Country
United States / /
Currency
USD / / /
Event
Security Buyback / /
IndustryTerm
beverage / food/beverage / food / /
Organization
European Union / Extend Business Event Attend Business Entertainment Extend Business Entertainment Analytical Employee BRM Employee / /
Position
board member / Broker in reportable Accounts / officer / director / Global Group Head / Broker / speaker / Managing Director / Executive / President / Chief Executive Officer / Chief Risk Officer / and Global Analytical Head / director / board member / investment advisors / officer / /
Bulletin: 13 Global Securities Trading and Conflicts of Interest Policy Effective Date: March 3, 2015 Version: 19 Author: Global Compliance Group