Credit Policy

Cross-Sector
Global

The Rating Process

How Fitch Assigns Credit Ratings

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 Credit Policy
Cross-Sector
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The Rating Process

How Fitch Assigns Credit Ratings

Fitch Ratings’ credit ratings provide opinions on relative

Fitch Ratings’ credit ratings provide opinions vulnerability to default or loss. To arrive at the rating opinion, Fitch
follows standardised procedures, as described in this report, to
on relative vulnerability to default or loss. ensure a globally consistent approach to its rating processes.
For the purposes of this report, a “credit rating” refers only to an
international scale credit rating and the rating process described
This report replaces the report of the same title dated relates solely to Fitch’s international credit ratings. References to
24 February 2022. an “issuer” may mean an issuer, entity or transaction.

Initiating the Ratings Process

The rating process usually begins when an issuer, sponsor/arranger
or underwriter – or, in any of these cases, its agent – contacts a
member of Fitch’s Business and Relationship Management (BRM)
group with a request to engage Fitch to provide a credit rating.
Alternatively, Fitch may initiate rating coverage on an unsolicited
basis, where sufficient public information is available, to broaden
industry coverage or provide insight to market participants.

Assignment of the Analytical Team

Managers’ Role: Managers leading the relevant credit rating group will
assign a primary and secondary analyst to lead the analysis, formulate a
rating recommendation and bring the recommendation to a rating
committee. These analysts are usually responsible for the monitoring
or surveillance of the credit rating after it is assigned.
Structured Finance Ratings: For structured finance, once an initial
credit rating is assigned, surveillance is typically transferred from the
primary analyst to a dedicated surveillance analyst, although day-to-
day surveillance activities may remain with the primary analyst for
Related Research some structured finance asset types.
Rating Definitions U.S. Public Finance Ratings: For U.S. public finance, the primary analyst
Rating Criteria is responsible for leading the analysis and formulating a rating
recommendation but surveillance responsibilities vary by sector.
Code of Conduct and Ethics
Analysts’ Role: Fitch analysts conduct their reviews in a manner
consistent with published criteria applicable to the issuer and asset
class, which may vary by region. Analysts and committee members
Analysts are required to consider relevant qualitative and quantitative
factors as defined in applicable criteria and methodologies.
Richard Hunter, Chief Credit Officer, Fitch Ratings
+44 20 3530-1102 Analyst coverage may be rotated over time as deemed appropriate
[email protected] by analytical group managers and in accordance with Fitch’s policies
and procedures, reflecting applicable laws and regulations.
Julie Solar, Regional Credit Officer, U.S. & Canada
+1 312 368-5472
[email protected]

Darryl Osojnak, Global Head of Policy & Operations

+1 212 908-0602
[email protected]

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are analysed in accordance with Fitch’s criteria and methodologies, the

Information Used to Determine a Credit Rating primary and secondary analyst will form a rating recommendation and
Analysts base their rating analysis on a thorough review of information document their analysis and rationale in a committee package.
known to them and believed to be relevant to the analysis and the
rating decision in accordance with the applicable criteria. Committees consider the information and rating recommendation
presented in the committee package and discuss the recommendation.
The rating process incorporates information provided directly to Fitch The committee package must contain sufficient content, consistent
by the issuer, arranger/sponsor or other third party. This may include with the methodology and criteria that apply to the analysis, to provide
background data, management forecasts, risk reports, performance a solid basis for the recommended credit rating.
information or other proprietary information.
The package must include a summary of key rating drivers, sensitivity
In most cases the issuer’s management or transaction sponsor analysis, criteria variations, if any, and details of reasonable
participates in the ratings process via in-person management and investigation, among certain other minimum content.
treasury meetings, on-site visits, teleconferences, and other
correspondence. Voting members are chosen based on relevant experience, with
seniority and experience thresholds reflected in Fitch’s committee
Analysts also consider macroeconomic data, market events and any quorum requirements. The minimum committee voting quorum for
other information deemed relevant for rating analysis, such as data credit rating decisions is five, subject to limited exceptions, and a
regarding an issuer’s peers, data provided by other analytical maximum of nine, although committees often include non-voting
groups within Fitch or publicly available information. observers.
The analytical team conducting the analysis will determine if sufficient The committee’s voting quorum must include:
information is available to form a view on the creditworthiness of the
issuer. The rating committee will also consider whether there is • A chair that moderates the committee and ensures it is
sufficient information to assign a credit rating. conducted in accordance with Fitch’s policies and
procedures; and
If Fitch believes that the information available, both public and private,
is insufficient to form a rating opinion, no credit rating will be assigned • At least one independent member from outside the
or maintained. Fitch will withdraw that credit rating if sufficient immediate asset class, sub-sector or geographic area of the
information ceases to be available in relation to an existing credit rating. entity under review, subject to limited exceptions.

Fitch relies on information in its analysis from sources it believes to be The rating committee considers relevant quantitative and qualitative
credible. The agency conducts a reasonable investigation of factual factors, as defined in Fitch’s established criteria and methodologies, to
information relied upon in its analysis by obtaining reasonable arrive at the credit rating that most appropriately reflects both current
verification of that information from independent sources to the extent and prospective performance.
such sources are available. Issuers, or arrangers/sponsors, may choose A rating committee may adjust, or vary, the application of the criteria to
not to share certain information with external parties, including rating reflect the risks of a specific transaction or entity. All such criteria
agencies, at any time. variations are disclosed in the respective rating action commentaries,
While Fitch expects that each participating issuer in the rating process, including their impact on the credit rating, if any.
or its agents, will supply promptly all information relevant for A variation can be approved by a rating committee where the variation
evaluating both the credit ratings of the issuer and all relevant is in relation to a risk, feature or other factor that is relevant to the
securities, Fitch neither has, nor would it seek, the right to compel the assignment of a credit rating and where this and the methodology
disclosure of information by any issuer or any agents of the issuer. applied to it are both already included within the scope of the criteria.

Pre-Committee Process Where the analysis described in the criteria would require modification
to address the risk, feature or factor specific to the particular
Where a debt issue or financial structure is deemed to have unique transaction or entity, approval would then be sought for new or
or complex features or does not appear to have a fundamental amended criteria.
economic purpose, a screening committee (SC) may be held to
determine whether and how a rating process may proceed. Analysts maintain a dialogue with the participating issuer during the
rating process to resolve any outstanding questions and to request
An SC is not a rating committee but is rather a cross-sector additional information. A credit rating is assigned if the committee
committee that provides an initial layer of review to consider such agrees on a rating level and that the information supporting that rating
rating proposals early in the rating process. decision is sufficient and robust.
The primary purpose of the SC is to determine the feasibility of Committee decisions are reached by consensus, while individual
assigning a credit rating to such proposals, which may need a cross- committee member votes and individual views expressed are not
sector review to assess how certain credit risks should be recorded, except in the case that a member of the quorum appeals
considered and which rating criteria may be applied. against a credit rating.

The Committee Process If a committee member is not able to accept the consensus opinion,
then they must initiate an internal appeal. In addition, an internal appeal
Credit ratings are assigned and reviewed through a committee process. must be launched by the chair if a consensus view cannot be reached.
Once information has been collected and the issuer and/or securities

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An internal appeal involves a new committee being held typically within Fitch evaluates this feedback from issuers while retaining full editorial
two business days of the original committee and with at least two new control over its commentaries. The primary analyst records the issuer’s
committee members in the quorum to consider the original committee response in Fitch’s publishing application before a rating action
package, the consensus recommendation and a summary of the appeal. commentary is released.
A further internal appeal is possible if one is launched by a new However, if the issuer provides verbal feedback, the primary analyst
committee member, such a second internal appeal committee will be will contact the issuer representative in writing to confirm the nature
decided by majority if no consensus is reached. of his/her feedback and that the credit rating will be published.
In the event that the chair determines that further analysis or Fitch typically aims to publish rating actions on existing public credit
information is required before the committee can move to a vote, the ratings by the end of the next business day following the conclusion of
committee will be suspended to allow this material to be gathered. the committee, unless the credit rating is subject to external appeal or
Committee members and the chair must also make certain attestations subject to other conditions, such as regulations governing the
with respect to the independence and objectivity of the rating process notification time period. The notification period must be at least 24
that was followed. hours before publication of the rating decision or outlook.
In limited circumstances, credit ratings that have been determined by a If the issuer provides feedback within the notification period that it has
rating committee may be applied to new debt issues without holding a no outstanding comments, the credit rating may be published before
further rating committee, provided that the class of debt concerned waiting for the specific notification period to elapse. Fitch aims to publish
was considered by the previous committee and the credit rating is new public credit ratings shortly after the rating committee and subject
applicable to that class of debt or is pari passu with the class of debt. to the same considerations as outlined above.
In all such cases, Fitch identifies the date of the relevant prior rating However, the exact timing of new credit rating announcements can be
committee in the new debt issue rating announcement. By contrast, if affected by other factors. For example, if the credit rating relates to a
the class of debt has not previously been considered in a rating new debt issue, Fitch’s procedures require it to delay its rating
committee, then a rating committee must be held to assign the credit announcement until materials with respect to the debt issue are in the
rating to the new issue. public domain.
There are also other limited circumstances where rating committees All rating actions for new or existing publicly rated issuers/securities
may not be required, for example, converting an expected credit rating are published on Fitch’s website and released to major newswire
to final, provided nothing substantial has changed. services. These rating action commentaries provide a rationale for the
rating decision based on key rating drivers and sensitivities, identify the
Issuer Notification and Rating Dissemination criteria applied in the rating process, detail any material sources of
information used to prepare the credit rating (other than those
Once the committee concludes, the outcome is communicated in
described in criteria), indicate if an issuer did not participate in the
writing to the issuer or, where applicable, its arranger/sponsor/agent.
credit rating and describe any criteria variations that were applied,
The issuer notification requirement is subject to certain exceptions
among certain other disclosures.
(except where the lead analyst is based in an EU-registered entity or a
branch of an EU-registered entity). The timing of publication reflects the important balance between
allowing sufficient time for the issuer to review the rating rationale for
Such exceptions include:
factual accuracy, the presence of confidential information and
i. to address time-sensitive, event-driven rating actions, for providing users of credit ratings with timely and objective opinions.
example, in response to the announcement of a merger or
In addition to Fitch’s rating action commentaries, a research report may
acquisition; in such cases, issuer notification is given as soon as
be published about issuers individually or by industry and made
practical after publication of the credit rating;
available to subscribers to Fitch’s website.
ii. to address bulk rating action reviews in U.S. structured finance;
External Appeals
iii. to address cases where Fitch does not have an appropriate
An issuer may request an appeal of a rating decision, referred to as an
contact, e.g. certain non-participating issuers; and
external appeal, but there is no specific right to an appeal. Appeals will
iv. to address rating actions taken on certain dependent credit only be granted when an issuer provides new or additional information
ratings. in a timely manner that Fitch believes is relevant to the credit rating.
In communicating the credit rating to the issuer, or arranger/ Where such an external appeal request is received, an appeal review
sponsor/agent, the rating action and the principal grounds on which the panel will be convened to review any additional information provided
credit rating is based must be explained. Typically, analysts use a draft and determine whether it warrants granting an external appeal of the
rating action commentary or a draft presale report, which includes the rating decision.
committee’s ratings decisions, to convey this information.
Where an external appeal is granted, a new committee is convened to
The primary analyst provides the issuer, or arranger/sponsor/agent, reconsider the rating decision. This committee is composed of the chair
with the opportunity to review Fitch’s draft rating action commentary, of the original committee, senior-level analysts who did not attend the
or presale report, to allow the issuer, or arranger/sponsor/agent, to previous committee and certain members of the original committee.
check for factual accuracy and the presence of non-public information.

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Fitch endeavors to complete the appeal review of new credit ratings as

quickly as possible, preferably within two business days. In cases where
Rating Process Timeframe
the review of an existing credit rating is not finalised during the two-day The time required to assign a new credit rating varies and will partly
timeframe, the credit rating may be placed on Rating Watch. depend on the time required by the issuer, or arranger/sponsor, to
respond to information requests from Fitch, along with the time it takes
In the event that an external appeal committee results in a rating the issuer to review Fitch’s draft research for factual errors and the
decision that is different from the original committee decision, this will presence of non-public information. Depending on the sector and type
be disclosed in the rating action commentary. The commentary will of credit analysis involved, Fitch typically assumes a timeframe of four to
note the original rating outcome was subject to appeal and that, eight weeks to provide a full corporate, financial institution, sovereign or
following the appeal, the rating outcome is different from the original structured finance credit rating.
decision. The original rating committee decision will not be included in
the published commentary.
Rating Withdrawals
Rating Surveillance Fitch’s credit ratings remain its property at all times. As such, Fitch has
Fitch’s credit ratings are typically monitored on an ongoing basis and full discretion to determine if and when to withdraw a credit rating.
the review process is a continuous one. Monitored credit ratings are Fitch can withdraw a credit rating at any time and for any reason and
also subject to a review by a rating committee, at least once annually. does not withdraw credit ratings simply in response to a request from
an issuer.
Certain sovereign and international public finance credit ratings are
reviewed at least every six months, according to a calendar of However, it may be appropriate for Fitch to withdraw the credit rating
scheduled review dates. Point-in-time credit ratings are not monitored following such a request if there are other reasons for withdrawal, such
on a continuous basis. Such credit ratings are usually private, but where as a lack of information, a lack of market interest or regulatory
they are published, they are clearly disclosed as point-in-time in the constraints. Some rating withdrawals may be initiated by Fitch’s BRM
accompanying rating action commentary. group for commercial reasons. Proposals to withdraw credit ratings are
generally subject to review by a rating committee in accordance with
Analysts will convene a committee to review the credit rating instead of Fitch’s established procedures, subject to certain exceptions.
waiting for the next scheduled review if a business, financial, economic,
operational or other development can reasonably be expected to result It is Fitch’s policy in such cases to publish a rating action commentary
in a rating action. For example, operational or fiscal deterioration, an that includes the credit rating(s) at the point of withdrawal and states
acquisition, a divestiture or the announcement of a major share that the credit rating(s) has been withdrawn and the rationale for the
repurchase may be events that trigger an immediate rating review. withdrawal. However, announcements are not issued for credit ratings
that relate to obligations that have matured, been redeemed or paid in
Peer analysis is a surveillance method that may be primarily used to full.
assess the relative performance of comparable entities and
transactions over time. Peer groups are created based on similar Criteria Reports
fundamentals and rating levels, among other factors. All credit ratings must be assigned according to the applicable criteria.
Results of Fitch’s peer analysis are included in research, such as a Criteria describe Fitch’s assessment of the rating drivers affecting a
Ratings Navigator, a peer comparison tool used with respect to certain given sector and the analytical approach and assumptions used to
sectors that provides a graphical representation of key rating drivers analyse those drivers to assign and maintain credit ratings.
against peer expectations for a given rating category. Fitch may choose Criteria can be classified as:
to conduct portfolio reviews for peer entities whereby all the entities
are subject to a rating review at the same time. • Master criteria that describe the basic foundation for our credit
ratings within an asset group;
Scenarios for structured finance are generally based on quantitative
metrics. In addition, ratings performance may be monitored with • Cross-sector criteria that explain Fitch’s approach to discrete
surveillance tools to evaluate the effect of stress scenarios on topics that relate to multiple areas; and
transactions.
• Sector-specific criteria that describe the rating drivers and
Such tools will typically track data from surveillance reports provided assumptions applicable to a particular sector or asset class.
by the trustee and compare the information against original and
Bespoke criteria may be developed for analysis of individual, or small
stressed expectations to flag transactions where performance has
groups of, transactions or entities. The consistent application of criteria
diverged from established parameters.
facilitates the comparability of Fitch’s credit ratings across regions and
Forward-Looking Ratings sectors. Each criteria report scope specifies the category of obligor,
security or instrument to which the criteria can be applied and its
Credit ratings reflect Fitch’s views of future performance based on geographical reach.
historical performance through various economic cycles, and Fitch’s
opinion as to how future performance may evolve. Event risk is not Criteria identify key rating drivers relevant to each rating sector and
considered in most credit ratings and, as a result, credit ratings may describe their relative importance to analysis. Criteria reports also
change due to events, such as a merger, an acquisition, fraud, litigation, include a description of the expected sensitivity of credit ratings to key
sudden weather events or political events that alter expected financial rating drivers, whether qualitative or quantitative. Where part of the
performance in the near term. analysis described in a criteria report is implemented using a rating

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model, the criteria report describes the use of the rating model and all to be approved by a CRC, led by a Criteria Review and Approval Group
the credit-related assumptions and their value ranges, how the (CRAG), which is fully independent of the analytical groups.
assumptions are applied and the significance of the model outputs.
The CRC evaluates the sufficiency, transparency and rigor of criteria
Criteria reports include an explanation of differences between new for credit ratings, and any related models used in the rating process.
ratings analysis and surveillance analysis, if any. Alternatively, when Models are subject to full independent validation once every three
surveillance analysis differs from new issue rating criteria, Fitch may years by a Model Validation Group (MVG), with any changes in the
publish surveillance criteria as a standalone report. Such criteria are interim also subject to review by the MVG. All new and material
subject to the same procedures as all other criteria. changes to rating criteria and models must be reviewed and approved
by Fitch’s board of directors following the CRC’s review and approval.
Criteria may contain a description of the type and source of the data
used to derive the key rating assumptions detailed in the report. For Criteria are developed and maintained by analytical groups and
structured finance, this includes those assumptions applied in the submitted to CRAG for review and approval by CRC. The analytical
portfolio default analysis, portfolio loss analysis and cash flow analysis. group will propose amendments to existing criteria where new and
For non-structured finance, this includes data used to assign credit significant rating drivers emerge or previous rating drivers or
ratings, such as accounting statements, data provided by issuers and/or assumptions change. Rationale and rating effect analysis for any
industry data. proposed changes to criteria are prepared and presented in a CRC.
Criteria reports describe limitations in the criteria used to assign a Criteria are subject to back-testing, which consists of a review of the
credit rating, where applicable, supplementing the limitations included appropriateness of the criteria considering the historical performance
in the Ratings Definitions section on Fitch’s website at of credit ratings under the criteria, and historical quantitative and
www.fitchratings.com. qualitative observations relative to criteria assumptions.
Fitch’s criteria are designed to be used in conjunction with analytical Analytical groups are responsible for the rigorous justification of
judgment exercised through individual analysts and the committee proposals to change (or continue the use of) their criteria. CRCs review
process. The combination of transparent criteria, analytical judgment the adequacy of the justification, evaluate the proposals considering
applied on a transaction-by-transaction or issuer-by-issuer basis and the analytical group’s ratings performance and other factors, and
full disclosure via rating commentary underpins Fitch’s rating process determine whether the data presented to support the justification is
and assists market participants in understanding the analysis behind appropriate and sufficiently robust.
our credit ratings.
Criteria Change Communication and
Criteria Assumptions
Application
The rating analysis applies both qualitative and quantitative
assumptions. Exposure drafts must be published for approved proposals that
materially change existing rating criteria, including assumptions and
Criteria reports specify the quantitative assumptions, or describe the models, and for approved proposals for new criteria, models or key
assumption setting process to derive them, applied in credit analysis, rating assumptions, which could have an effect on one or more credit
including credit-risk-related assumptions contained within models used ratings. Exposure drafts for proposed new criteria and any proposed
in the rating process. changes to existing criteria, models or key rating assumptions are
published on Fitch’s website with an invitation to third parties to submit
Where Fitch’s rating analysis applies different quantitative values in the
comments.
analysis of different credit ratings, criteria may provide a description of
the rating-specific assumption-setting process. The exposure draft includes an explanation of the reasons for, and the
implications of, the proposed changes, including the anticipated effect
Criteria also describe how macroeconomic or other financial data
on existing credit ratings. During the exposure period, existing criteria
relate to assumptions made in criteria or influence credit ratings, where
continue to be applied to outstanding and new credit ratings. Approval
appropriate. Derivations of specific assumptions by geographical area
of final criteria occurs only after Fitch has assessed the responses, when
are provided, where appropriate. Where default and loss assumptions
it will also publish the results of the consultation and a summary of the
or routine adjustments to externally sourced data – such as financial
content of written responses unless the respondent has requested
accounting ratios – are used, these are specified in the criteria report.
confidentiality.
Quantitative ratios used in the rating analysis are included in the
Rating criteria will be published on Fitch’s website at
criteria, along with a description of how these ratios relate to each
www.fitchratings.com. Publication of new or revised criteria will be
other, such as correlation. Any averages, medians, ranges or measures
accompanied by a press release describing the changes made, including
of dispersion used for key assumptions are described where relevant.
any effect of the criteria change on outstanding credit ratings.
Qualitative assumptions are also specified, including the extent to
which such assumptions influence rating outcomes. Following the publication of the new or revised criteria report after an
exposure draft, all credit ratings that could incur rating changes as a
Developing and Maintaining Criteria result of the application of the new or revised criteria will be indicated
All criteria, including models and assumptions, are reviewed and as Under Criteria Observation (UCO).
approved by a Criteria Review Committee (CRC) at least annually and
proposals to amend criteria between annual reviews are also required

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However, credit ratings may be placed on Rating Watch where rating Feedback is provided in writing, including a list of the circumstances
implications for relevant credit ratings can be clearly anticipated. and limitations applied in the assessment. Outcomes from a RAS are
The decision to apply Rating Watch instead of UCO is determined by not made public as they are based on hypothetical, rather than actual,
the analytical group. UCO or Rating Watch status will be resolved no circumstances.
later than six months from the publication of the criteria.
However, in accordance with EU regulatory requirements, Fitch will
disclose cases where it has provided such a service to a rated entity or
Quality Standards for Credit Ratings related third parties, where the primary analyst is based in an
To ensure the quality of its product, a common process for assigning EU-registered entity or a branch of an EU-registered entity.
international credit ratings to entities/securities applies globally within
all Fitch Ratings offices, irrespective of size or location. Fitch also provides Credit Opinions (COs) on entities and transactions
where one or more characteristics of a credit rating are omitted or
Fitch’s Chief Risk Officer (CRO) is organisationally at Fitch Group and meet a different standard. This opinion may be based on more limited
therefore independent from analytical groups. The CRO has each of the information and is subject to a less extensive committee process.
second lines of defense as direct reports including Fitch’s Credit Policy
Group (CPG), CRAG and Compliance Group. Together, these groups COs are delineated by lower-case characters and either an asterisk, e.g.
act to ensure that Fitch’s ratings criteria, policies and procedures are ‘bbb+*’, or the suffix (cat), indicating that the opinion is conditional and
consistently executed, that credit ratings are consistent across the not comparable in all regards to credit ratings at that level.
company and that Fitch complies with applicable laws and regulations. COs are not credit ratings and should not be employed by rating users
CPG is a global, centralized function with a cross-sector mandate to without consideration of any limitations that they may have or any
strengthen Fitch’s credit analysis, ratings and research by identifying conditions attached to their use. Further details can be found in the
credit risks that require additional focus and ensuring those risks are report Credit Opinions.
considered by analytical teams in the ratings process. The group includes In addition to credit ratings on the international scale, Fitch offers
the Chief Credit Officer and Group Credit Officers for each asset class. credit ratings on national scales that offer an opinion of
The Compliance Group identifies and provides advice on compliance creditworthiness, relative to the universe of issuers and issues within a
risks facing Fitch, conducts testing to ensure management’s internal single country or monetary union.
controls achieve compliance with laws, regulations, guidelines and Unlike international scale credit ratings, national scale credit ratings
specifications relevant to Fitch’s business and monitors employee are not intended to be comparable across jurisdictions and can only be
activity to ensure effectiveness of controls, including those to mitigate compared with other national credit ratings on the relevant country
conflicts of interest. national scale.
Within Fitch’s Compliance Group, the Compliance Testing & The procedures and process for national scale credit ratings differ in
Monitoring (CTM) group assesses Fitch’s compliance with Fitch’s Code certain aspects to those for international scale credit ratings and are
of Conduct and other established policies, procedures and controls not described in this report. Fitch offers a number of non-credit
with respect to Fitch’s credit ratings and related activities. products, including non-credit ratings. The procedures and process for
non-credit products differ to those for international scale credit ratings
Unsolicited Credit Ratings and are not described in this report.
Fitch believes that investors benefit from increased rating coverage by
Fitch, whether such credit ratings are solicited by issuers or investors Errors
or are unsolicited. The criteria, committee procedures and minimum
information standards are no different for unsolicited and solicited Fitch has established procedures to address instances where an error
credit ratings. Therefore, credit ratings assigned to issuers with similar is suspected in a methodology or model or where a methodology or
credit characteristics are comparable. The solicitation status has no model is suspected of being misapplied to credit ratings during the
effect on the level of the credit ratings assigned. rating process. Procedures describe the escalation, review,
remediation and notification requirements for errors.
Other Credit Products Fitch’s procedures describe the process for reviewing the affected
In addition to published credit ratings, Fitch offers several additional methodology, model and/or credit ratings, including error correction,
services within the core rating business. model revalidation and subsequent rating committee review.
Depending on the nature and magnitude of the error, affected credit
Fitch prepares a limited number of private credit ratings, i.e. unpublished ratings may be placed on Rating Watch until the issues are resolved.
credit ratings, for entities if a credit rating is requested. Private credit
ratings undergo the same analysis, committee process, surveillance and
procedural standards as published credit ratings, unless otherwise
Fees
disclosed as point-in-time in nature (see the Rating Surveillance section). Fitch has a dedicated BRM group that is responsible for managing the
commercial aspects of issuer relationships. All discussions with issuers
Fitch also provides a rating assessment service (RAS) under certain and intermediaries concerning rating fees and commercial matters are
circumstances. A RAS indicates the rating level that an issuer and its handled exclusively by Fitch’s BRM team. In addition, references to any
obligations would likely receive given a set of hypothetical commercial aspect of Fitch’s relationship with issuers are similarly not
circumstances provided by the assessed entity. This assessment is permitted during any analytical discussion.
conducted under the same procedural standards as credit ratings and
is performed by the analytical group responsible for that entity.

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DISCLAIMER & DISCLOSURES

All Fitch Ratings (Fitch) credit ratings are subject to certain limitations and disclaimers. Please read these limitations and disclaimers by following this link:
https://www.fitchratings.com/understandingcreditratings. In addition, the following https://www.fitchratings.com/rating-definitions-document details
Fitch's rating definitions for each rating scale and rating categories, including definitions relating to default. Published ratings, criteria, and methodologies
are available from this site at all times. Fitch's code of conduct, confidentiality, conflicts of interest, affiliate firewall, compliance, and other relevant policies
and procedures are also available from the Code of Conduct section of this site. Directors and shareholders’ relevant interests are available at
https://www.fitchratings.com/site/regulatory. Fitch may have provided another permissible or ancillary service to the rated entity or its related third parties.
Details of permissible or ancillary service(s) for which the lead analyst is based in an ESMA- or FCA-registered Fitch Ratings company (or branch of such a
company) can be found on the entity summary page for this issuer on the Fitch Ratings website.
In issuing and maintaining its ratings and in making other reports (including forecast information), Fitch relies on factual information it receives from issuers and underwriters and from other sources Fitch
believes to be credible. Fitch conducts a reasonable investigation of the factual information relied upon by it in accordance with its ratings methodology, and obtains reasonable verification of that information
from independent sources, to the extent such sources are available for a given security or in a given jurisdiction. The manner of Fitch's factual investigation and the scope of the third-party verification it obtains
will vary depending on the nature of the rated security and its issuer, the requirements and practices in the jurisdiction in which the rated security is offered and sold and/or the issuer is located, the availability
and nature of relevant public information, access to the management of the issuer and its advisers, the availability of pre-existing third-party verifications such as audit reports, agreed-upon procedures letters,
appraisals, actuarial reports, engineering reports, legal opinions and other reports provided by third parties, the availability of independent and competent third- party verification sources with respect to the
particular security or in the particular jurisdiction of the issuer, and a variety of other factors. Users of Fitch's ratings and reports should understand that neither an enhanced factual investigation nor any third-
party verification can ensure that all of the information Fitch relies on in connection with a rating or a report will be accurate and complete. Ultimately, the issuer and its advisers are responsible for the accuracy
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