Supervisory Protocol

Supervisory Protocol of the Code of Conduct

The member of staff in charge of internal compliance (hereinafter referred to as the Compliance Officer), who cannot be a Director of the company, is appointed by the Board. He will receive a three-year renewable contract and will be responsible for ensuring that any decision made by the Directors of the Company and specifically any contract concerning Ratings, is made in accordance with the Code of Conduct (hereafter hereinafter referred to as CoC).

In undertaking this role, it is agreed that the Compliance Officer:

• May have access to all documentation of the Company that he deems necessary to carry out his controlling and supervisory role.
• All Directors, Managers, Auditors or staff members of the Company must provide any information requested by the Compliance Officer as quickly as possible, treating this as a priority over all other duties.
• Will communicate the outcome first to the member of Board in charge of guaranteeing compliance with the CoC secondly to the Board of Directors and thirdly to the Auditors and the Shareholders’ Meeting or directly to all Shareholders.
• Can independently report likely conflicts of interest not specifically considered in the CoC, but deemed to be significant according to the beliefs and wishes of the Shareholders and the Company.
• Will keep a record of checks carried out and of their outcome, and maintain a special register (available and easily accessible to shareholders) concerning the information requested from the company bodies according to the CoC.
• In compliance with the principle "comply or explain", he has the power to externally communicate discrepancies or delays in the execution of plans and projects previously communicated.

This Protocol, approved by the company bodies and by the Shareholders’ Meeting is an integral part of the Code of Conduct.

Standard Ethics Board of Directors
London, 15th July 2013