Our commitment to operating in an ethical and lawful manner, including helping to protect human rights, serves as the foundation for our relationships with employees, customers and suppliers, as well as the people in the countries and communities in which we operate.
All employees must complete compliance and ethics training as an integral part of their professional development. Upon hiring and annually thereafter, our employees receive mandatory training on the Code of Business Conduct and other policies, which set forth our expectation that employees comply with all applicable laws, regulations and company policies. The training addresses various topics, including health and safety, human rights, sexual harassment and discrimination. Employees must certify annually that they have read and will abide by the Code of Business Conduct.
In addition to complying with all relevant codes, policies, laws and regulations, employees are expected to display the highest standards of professionalism and appropriate judgment in their decision-making.
Our employees receive training upon hiring and annually thereafter on our Anti-Bribery and Anti-Corruption Policy, which sets forth the expectation that employees comply with all applicable anti-bribery and anti-corruption laws. Additional training is required for employees whose roles put them at greater risk of encountering bribery and corruption practices. We also offer guidance through our internal Anti-Bribery Resource Center. The anti-bribery and anti-corruption program are periodically reviewed by our Internal Audit department. For more information, see Moody’s Anti-Bribery and Anti-Corruption Policy.
We update our disclosures periodically, and if there are any material developments or matters that we believe we should disclose, we do so on a timely basis.
We comply with all applicable anti-money laundering (AML) laws and related Know Your Customer (KYC) and Enhanced Due Diligence (EDD) requirements as required in the jurisdictions where we operate. While our business activities do not generally expose us to the risk of involvement in third-party money laundering activity as we are not involved in financial transactions, where required, we have established an appropriate AML program. In such jurisdictions, we have implemented appropriate AML policies and programs, including annual policy certification for all applicable employees.
We give our employees a number of channels to report concerns, including directly to managers via our Open Door Policy, or to the People Team, the Compliance department or the Legal department. Employees can also report concerns via Moody’s Integrity Hotline. The Integrity Hotline is available via telephone or internet 24 hours per day, 365 days per year. Reports to the Integrity Hotline may be made anonymously and in multiple languages. Those reports are forwarded to our Legal and Compliance departments for follow-up.
All reports of suspected policy violations, whether received via the Integrity Hotline or any other channel, are promptly investigated. At the conclusion of each investigation, findings are summarized in a final written report that is reviewed by a committee comprised of senior executives from the Legal and Compliance departments. These executives make recommendations for remedial action or discipline based on the factual findings of the investigation and the risk the activity poses to Moody’s from a regulatory and legal perspective. The committee’s recommendations and the investigation reports are shared with the People team and business management, which are responsible for implementing disciplinary actions.
In addition, the Compliance department provides periodic reports to our Board on investigations, including concerns raised through the Integrity Hotline.
Violations of law, regulation, our Code of Business Conduct or other company policies may result in disciplinary action, up to and including termination of employment. We prohibit, and do not tolerate, any form of retaliation against those who raise issues or report concerns in good faith.
Our commitment to operating in an ethical and lawful manner includes protecting the basic dignity and human rights of our employees and the people in our supply chain. Our Human Rights Statement provides an overview of how we endeavor to meet our responsibility with respect to human rights, in addition to the principles and requirements within our Code of Business Conduct. We also issue a Modern Slavery and Human Trafficking Statement annually that details our approach to preventing human rights violations in our workforce and supply chain. Internal and external stakeholders can anonymously report suspected human rights wrongdoing via the Integrity Hotline.
In addition, our standard due diligence process for every majority acquisition includes a human rights risk assessment. For example, target companies must confirm whether they comply with all applicable anti-slavery and human trafficking laws, and whether they have procedures in place to assess their own suppliers, subcontractors and other participants in their supply chain for slavery and human trafficking risks. All target companies’ customers and vendors are also subject to sanctions screens.
We engage in public policy, advocating for issues important to our stakeholders in compliance with all lobbying laws and regulations. Our Political Engagement & Public Policy Statement outlines our approach to advocacy, lobbying, and political activities. We report lobbying expenses and maintain transparency in our engagements.
We do not maintain a political action committee (PAC). We prohibit the use of corporate funds to support any political candidates, political parties and committees (including super PACs), ballot initiatives and section 527 entities, and to make political contributions to 501(c)(4) organizations. We do not use corporate funds for electioneering communications or independent expenditures.
In the U.S., federal lobbying expenses are reported in compliance with the U.S. Lobbying Disclosure Act. In 2023, we reported $500,000 in annual lobbying expenses at the federal level. The public filing can be accessed here and here. In addition, we reported $261,697 in lobbying expenses at the state level in the U.S. In line with European law, Moody’s Shared Services U.K. Ltd is registered on the EU’s transparency register and, for 2023, has reported €500,000–€599,000 in activities related to engaging with EU institutions. The public filing can be accessed here.
We are also a member of various interest groups and engage with think tanks globally. These organizations provide venues for policy discussions and opportunities for advocacy on common areas of interest, including capital markets, macroeconomics, financial stability, geopolitics, sustainability, credit rating agencies and digital assets. Total fees paid to principal U.S. and EU trade organizations for membership in 2023 were approximately $866,0001. Based upon information reported to us for 2023, the amount of our payments to these organizations attributable to lobbying was approximately $95,0002.
The principal U.S. and EU-based trade associations to which we belong include:
1 Total membership dues paid in 2023 to principal US and EU trade organizations defined as those whose annual membership dues are at least USD 20,000.
2 Reflects amount of our 2023 membership dues used for lobbying expenses by US-based principal trade organizations, as defined previously.
