MSCI SUPPLIER CODE OF CONDUCT

MSCI expects its Suppliers to act consistently with our organization’s core values:

1. Put the client first
2. Work as one team
3. Champion bold ideas
4. Pursue excellence
5. Act with integrity
6. Take personal responsibility

Supplier evaluation and selection may 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 products and services.  
• Security Review – Security architecture review process.
• Legal Review – Agreement and terms and conditions validation process.    
• Financial Review – Economic value review and funding approval process.

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

MSCI is committed to the protection of human rights globally and to fair and ethical workplaces in its global Supplier network. MSCI respects the standards embodied in the Universal Declaration of Human Rights (UDHR) and the International Labor Organization conventions (ILO). MSCI expects its Suppliers to meet or exceed such standards, and 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 as legally required.
• All employees must be of a specified age respecting all local laws at all times – The Minimum Age Convention, 1973 (No.138) set by International Labor Standards on Child Labor states: 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.  If the Supplier is employing children of school age, it must offer the children compensating programs, including education and financial support in co-operation with the child and its family or next of kin.
• Compliance with wage laws including working hours and salaries – 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. All Supplier premises and facilities must comply with relevant health and safety standards and law at all times.
• Appropriate emergency plan in place – All Suppliers must ensure that all 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 at all times 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 of members of any legally protected class, in accordance with applicable laws and regulations.
• Treat people with respect and dignity – All Suppliers at all times must act as per the guiding principles of the UDHR.

MSCI is committed to protecting the environment and therefore expects its Suppliers to implement appropriate standards to minimize harm to the environment caused by their activities. MSCI expects Suppliers to meet or exceed the below set of principles:

• 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 (specific, measureable, achievable, realistic, time-bound) environmental targets and reporting – Suppliers need to be able to identify, measure and report at all times all significant environmental impacts, with an emergency action plan in place.
• Waste management – Suppliers are expected to handle waste in a responsible way and have separate hazardous and non-hazardous waste management processes at all times.
• Recycling – Suppliers must actively implement processes in order to recycle material through the E2E process of its production/service cycle.
• Suppliers should avoid:

- The use of scarce natural resources
- Soil contamination
- Dangerous substance issues – (design, packaging, transport, use, recycling).

Each Supplier must comply with all laws, regulations and industry standards applicable to where it is located and conducts business. MSCI expects its Suppliers to comply with applicable United Nations Conventions. All Suppliers shall respect all intellectual property rights of MSCI and third parties.

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

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

The term “bribe” is 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 presented by MSCI is not and should not be interpreted as a means to circumvent or undermine laws, rules or regulations. This code establishes minimum standards, which MSCI generally expects Suppliers to meet or exceed. MSCI will not accept any attempt to use this Code’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.