MSCI Supplier Code of Conduct

This Code of Conduct must be read in conjunction with applicable law and relevant contractual arrangements. Suppliers must comply with all applicable laws, regulations and industry standards where each such Supplier is located and conducts business. In addition, MSCI expects its Suppliers to comply with applicable United Nations Conventions. Suppliers have a duty to protect and safeguard confidential (including personal) information and to take precautions before sharing with anyone. All Suppliers shall respect all intellectual property rights of MSCI and third parties. If compliance with any provision of this Code of Conduct would result in a legal or regulatory violation, Suppliers must follow the law or rule. Where the Code of Conduct and a Supplier agreement conflict, the Supplier agreement prevails.

Supplier evaluation and selection procedures include an assessment of Supplier’s business practices and corporate values, including the following reviews:

• Supplier Business Review – Best-fit products and services to meet our needs.
• Commercial Review – Best value vs. expenditure.
• Security Review – Security architecture review.
• Legal Review – Terms and conditions review.
• Financial Review – Economic value and funding review.

Where appropriate, MSCI may invite Suppliers to participate in a competitive bidding process. MSCI expects Suppliers to agree to MSCI’s form of standard contractual documentation but may elect in its sole discretion to adopt part or all of specific Suppliers’ agreements.

MSCI is committed to the protection of human rights globally and to providing a fair and ethical workplace. We respect the standards embodied in the United Nations Universal Declaration of Human Rights (“UDHR”) and the International Labor Organization conventions. Specifically, MSCI is strongly opposed to slavery and human trafficking and will not knowingly support or conduct business with any organization involved in such activities. MSCI expects its Suppliers to act in accordance with the following principles:

• All employment must be freely chosen – We will not tolerate the use of involuntary, trafficked or forced labor.
• Freedom of association for all employees – Suppliers must uphold this right.
• All employees must be of a specified age respecting all local laws at all times – Suppliers must comply with age employment standards.¹
• Compliance with wage laws including working hours and salaries MSCI requires all Suppliers to provide a living wage to its employees – a wage which enables employees to enjoy acceptable living conditions. Employees must not be required to work more than the maximum hours allowed per local law. Any overtime must take place with the prior consent of the individual and must be compensated appropriately as established per local law.
• Humane treatment of all employees – All Suppliers must provide and maintain a safe work environment and integrate reliable health and safety policies for conducting its business. Suppliers’ premises and facilities must comply with relevant legal and regulatory requirements. Any unfair disciplinary practices or corporal punishment by any of its Suppliers will not be tolerated by MSCI.
• Appropriate emergency plan in place – Suppliers must ensure that their office and plant facilities have an appropriate emergency plan in place.
• Adequate ethical and human rights standards in place – Appropriate procedures must be in place and enforced to deal with any breaches of these standards.
• Protect the privacy of personal information – Suppliers must ensure that a rigorous security process is in place to protect employees’ personal information and any MSCI information from unauthorized use, access, or disclosure.
• Antidiscrimination – It is the policy of MSCI to ensure that equal employment opportunity exists for all persons, without discrimination or harassment and in strict accordance with applicable laws and regulations.
• Treat people with respect and dignity – Suppliers must act in accordance with the guiding principles of the UDHR.

¹The Minimum Age Convention, 1973 (No.138) set by International Labor Standards on Child Labor sets the general minimum age for admission to employment or work at 15 years (13 for light work) and the minimum age for hazardous work at 18 (16 under certain conditions). It provides for the possibility of initially setting the general minimum age at 14 (12 for light work) where the economy and educational facilities are insufficiently developed. Suppliers employing children of school age must offer the children compensating programs, including education and financial support in co-operation with the child and its family or next of kin.

MSCI is committed to protecting the environment and expects its Suppliers to implement appropriate standards to do likewise in accordance with the MSCI Environmental Policy found at https://www.msci.com/who-we-are/corporate-responsibility/operate-sustainably. MSCI reserves the right to actively engage with its Suppliers to improve their environmental and sustainability performance. We are also a signatory to the United Nations supported Principles for Responsible Investment Initiative, which is designed to act in the long-term interests of its signatories, of the financial markets and economies in which they operate, and ultimately of the environment and society. Accordingly, MSCI expects Suppliers to meet or exceed the below set of principles:

• To develop, adopt, monitor and disclose climate and carbon-related policies and strategies – Suppliers are expected to take steps to understand their climate risks, to minimize their environmental impact and to implement policies to reduce Greenhouse Gas (GHG) emissions.
• Compliance with applicable environmental laws, regulations and standards – Suppliers must be aware of and adhere to the laws relevant to the Supplier’s activities for the entire sourcing and production cycle: material sourcing – manufacturing – logistics – disposal.
• SMART (e.g., specific, measurable, achievable, realistic, time-bound) environmental goals and reporting – Suppliers need to be able to identify, measure and report significant environmental impacts, including GHG emissions.
• Responsible stewardship of natural resources – Suppliers must actively implement processes to reduce, reuse and recycle materials throughout their production/service cycles.
• Waste management – Suppliers are expected to handle waste in a responsible way and maintain separate hazardous and non-hazardous waste management processes.

The highest standards of ethics and integrity are to be adhered to by its Suppliers in all dealings with MSCI. MSCI also expects its Suppliers to have zero-tolerance for corruption and comply with all United Nations Conventions and applicable laws against corruption. Suppliers may not:

• offer, promise, or give bribes or facilitation payments, or anything that could be construed or perceived as a bribe or facilitation payment; or
• request, agree to accept, or accept bribes or facilitation payments or anything that could be construed or perceived as a bribe or facilitation payment in connection with MSCI.

The terms “bribe” and “facilitation payment” are broadly defined and includes anything of value, such as a payment, gift or benefit of any kind, offered or given with the purpose of influencing a decision or action.

This Code of Conduct is not and should not be interpreted to circumvent or undermine laws, rules or regulations. This Code of Conduct establishes minimum standards, which MSCI expects Suppliers to meet or exceed. MSCI will not accept any attempt to use this Code of Conduct’s requirements to lower existing or future standards that apply to MSCI or that we have implemented. Failure to meet these principles and standards may be cause for termination of a relationship or agreement with a Supplier.