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Permissible Conflicts of Interest in the Company's Opinion

Permissible Conflicts of Interest in the Company's Opinion

The Company states permissible conflicts of interest in its licensing registration application, under the requirements of Sec. 15(2) of the Law. For each of the situations described in this list, as detailed below, the Company shall determine as necessary the requisite arrangement for the sake of disclosure, management and treatment of the potential conflict of interest that could arise pursuant to the circumstances listed there.
1. Receipt of payment from issuers or underwriters in order to set credit ratings for financial instruments they are issuing or for which they are supplying underwriting services, as applicable.
2. Receipt of payment from borrowers in order to assign credit ratings to them for the purpose of obtaining financing from a financing entity.
3. Receipt of payment from financing entities in order to assign credit ratings to an entity to which they wish to extend financing, or a project they wish to finance or in which they wish to invest.
4. Receipt of payment from investors in order to assign credit ratings to financial instruments in which they wish to invest.
5. Provide ancillary services that are not credit ratings for payment to any of the entities listed above (issuers, underwriters, financing entities or investors).
6. Receiving cost reimbursement from rated entities, under agreement with them and against documentation.
7. Publishing market research papers, macroeconomic analyses or articles on the areas in which the Company engages.
8. Employing employees who may have prior employee-employer relationships with rated borrowers or issuers, or with other entities that are clients of the Company today or that will be its clients in the future.
9. Analysts employed at the Company may terminate their employment and be employed by a rated issuer or borrower or a client of the Company.
10. Company employees may have personal relationships with people who work at a rated body or a client of the Company, or have a personal or business relationship with these entities.
11. Company employees may hold certain financial instruments, in compliance with the Company's procedures.
12. Insofar as the Company has or will have subsidiaries, the clients of these companies may be entities to which the Company supplies credit rating services or ancillary services.
13. Buying standard goods or services from rated entities or entities that receive rating services (such as insurance, travel services, technological services, office equipment and so on).
14. Contracting for the purposes of pension insurance or a study fund or provident fund for Company employees, under the standard terms at these institutions.
15. Inviting employees of rates entities or public servants to lecture, sometimes for a fee.
16. Issuing credit ratings to entities that own shares in the Company or to third parties, which do not own a controlling interest in the Company, for such entities.
17. The Company's directors may have personal or business ties with rated entities and/or entities that have an interest in the rating such as underwriters, banks and investors, and may serve as directors at these entities.
18. Issuing credit ratings to entities in which directors of the Company have personal or business ties or in which they serve as directors.

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