2021 Stakeholder Sustainability Report
A MESSAGE FROM OUR
PRESIDENT & CEO
2021 SUSTAINABILITY
HIGHLIGHTS
ABOUT MOODY'S
BETTER BUSINESS
BETTER LIVES
BETTER SOLUTIONS
APPENDIX
Moody's 2021 Stakeholder Sustainability Report
26
REPORTING MECHANISMS
The Integrity Hotline, which allows employees, suppliers
and members of the public to report any suspected
wrongdoing anonymously, is staffed by a third party and
is available at all times and in multiple languages. Reports
made via the Integrity Hotline are forwarded to our Legal
and Compliance departments for follow-up, and all reports
of suspected violations are promptly investigated and
remediated. We take appropriate disciplinary action, up to
and including termination of employment, against those
who violate the law, regulations, our Code of Business
Conduct or other company policies. We prohibit, and do
not tolerate, any form of retaliation against those who raise
issues or report concerns in good faith.
In addition, our employees have a number of other channels
to report concerns, including via our Open Door Policy,
or directly to Human Resources, Compliance or the
Legal department.
PUBLIC POLICY
We believe that greater transparency, more informed
decisions and equity around information access open the
door to shared progress. Consequently, public policy is
an integral part of our engagement strategy and core to
our business. We regularly engage with policymakers and
regulators globally on issues that are important to us and
our stakeholders. We provide insights to governments on a
host of market issues, principally those relating to capital
markets, macroeconomics, ESG and sustainable finance,
trade and economic recovery. Our lobbying positions
support our purpose, policies and positions.
In 2021, we published our Political Engagement & Public
Policy Statement, outlining our governance and approach to
advocacy, lobbying, political contributions and employees'
political activities. Moody's does not maintain a political
action committee (PAC) or make any political contributions,
including in-kind contributions. We do not currently engage
in grassroots lobbying.
In the United States, federal lobbying expenses are reported
in compliance with the U.S. Lobbying Disclosure Act. In
the fourth quarter of 2021, we registered as a lobbying
entity for the first time and reported $520,000 in lobbying
expenses for that quarter. For the first three quarters of
2021, external lobbyists reported $180,000 in lobbying
expenses on behalf of Moody's. We also reported $284,000
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 2021,
has reported €500,000 €599,000 in activities related to
engaging with E.U. institutions.
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 COVID-19
and economic recovery, capital markets, sustainability and
credit rating agencies. Total fees paid to principal U.S. trade
organizations in the fiscal year 2021 were approximately
$855,000.
For more information on our policies regarding ethics and
integrity, see Additional Resources.View entire presentation