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    S&P Global has a Securities Disclosure Policy that applies to employees who influence products and services or have access to non-public information due to their role. The policy also applies to immediate family members. Employees are assigned a securities disclosure profile based on their influence on products/services or access to non-public information. Within 15 days of starting, employees and immediate family must divest restricted securities and use an approved electronic broker if applicable. The policy requires pre-clearance of trades, prohibits short-term trading within 30 days, and allows blind trusts and third-party discretionary accounts in some cases.

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    S&P Global has a Securities Disclosure Policy that applies to employees who influence products and services or have access to non-public information due to their role. The policy also applies to immediate family members. Employees are assigned a securities disclosure profile based on their influence on products/services or access to non-public information. Within 15 days of starting, employees and immediate family must divest restricted securities and use an approved electronic broker if applicable. The policy requires pre-clearance of trades, prohibits short-term trading within 30 days, and allows blind trusts and third-party discretionary accounts in some cases.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    Download as pdf or txt
    32 views1 page

    Candidate Information Securities Disclosure Policy

    Uploaded by

    prince
    S&P Global has a Securities Disclosure Policy that applies to employees who influence products and services or have access to non-public information due to their role. The policy also applies to immediate family members. Employees are assigned a securities disclosure profile based on their influence on products/services or access to non-public information. Within 15 days of starting, employees and immediate family must divest restricted securities and use an approved electronic broker if applicable. The policy requires pre-clearance of trades, prohibits short-term trading within 30 days, and allows blind trusts and third-party discretionary accounts in some cases.

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    © All Rights Reserved
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    Securities Disclosure Candidate Information Sheet

    S&P Global has a worldwide reputation for integrity and objectivity. With that reputation, there is a responsibility to
    deliver products and services in accordance with professional standards that are not influenced inappropriately by
    Conflicts of Interest.

    This Policy is designed to promote compliance with applicable securities laws in all the jurisdictions in which S&P
    Global operates regardless of the fact that you may not be obliged by the laws of certain jurisdictions to provide
    information and take other steps as required by this Policy.

    We have a Securities Disclosure Policy that applies to Employees who influence S&P Global products and services
    and/or who have access or potential access to Material Non-Public Information, in fact or appearance by virtue of their
    role and responsibilities. It also applies to the Immediate Family Members of S&P Global Employees of which this
    policy applies. Each Divisions management will further define the conditions under which Workers Engaged Through
    Vendors may be subject to securities disclosure obligations. Employees and Workers Engaged Through Vendors who
    are covered by the Policy will be notified by Securities Disclosure.

    The extent of your restrictions will depend on your role and responsibilities. Employees are assigned a
    Securities Disclosure Profile based on the following criteria:

    (1) Their influence on S&P Global products and services, in fact or appearance, by virtue of their role and
    responsibilities, and/or

    (2) Their access or potential access to Material Non-Public Information, in fact or appearance, by virtue of their role
    and responsibilities.

    Within 15 days of your start date, you and your immediate family (as defined in the Policy) will be required to divest
    any restricted securities and move to an Electronic Broker (if applicable).

    Electronic Brokers are required in certain offices. In order to help U.S. based Covered Employees fulfill the initial
    and ongoing Reporting requirements of the Policy and any Divisional Addendum S&P Global has identified certain
    broker-dealers (“Electronic Brokers”), which feed Investment Account activity to the S&P Global system of record. U.S.
    based Covered Employees and their Immediate Family Members are required to use these Electronic Brokers.

    Covered Employees and their Immediate Family Members, if notified by Securities Disclosure Compliance, must transfer
    within thirty (30) calendar days of receiving notification from Securities Disclosure Compliance their Investment Accounts
    to an Electronic Broker and designate the Investment Account as an S&P Global Investment Account.

    You must get approval before executing trades. The Policy requires that prior to Employees or Immediate Family
    Members placing a Trade in Equity, Fixed income Security, or Private Investment, Employees must Pre-Clear the
    Trade. The approval process is done online, and it is designed to be quick and easy.

    Short-Term Trading is prohibited. Having made an investment in a Security or a derivative of a publicly traded
    company or fund, an Employee or his or her Immediate Family member may not take a profit from the investment within
    thirty (30) calendar days of the original Trade.

    Blind Trusts and Third Party Discretionary accounts, in some cases, can be used to help address restrictions.
    Please let us know if you would like more information regarding these accounts.

    For more information, contact your recruiter to put you in touch with someone in our Compliance department.

    Securities Disclosure Compliance | 212-438-4218

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