Our integrity - copy
Our integrity is the framework for how we do business. We expect employees at all levels to meet the highest standards of business conduct, which are embodied in our Code of Business Conduct and Ethics, and to comply with all applicable laws and regulations. We also expect our suppliers to act consistently with our corporate values and in accordance with our Supplier Code of Conduct.
Our employees are bound by a Code of Conduct (which is based on the Code of Ethics and Business Conduct found on our Corporate Governance page) and related Compliance policies. Our Compliance program and polices are overseen by our Head of Compliance and implemented and enforced by Legal and Compliance staff in regional offices globally. Our Compliance program and policies aim to deter wrongdoing and promote the conduct of all MSCI business in accordance with the highest standards of integrity. The Code also enumerates the values MSCI expects its employees to live by, including: put the client first, work as one team, pursue excellence, champion bold ideas, act with integrity and take personal responsibility. Critical elements of the program and policies relating to protecting and promoting the company’s integrity and ethical standards include:
- The MSCI Global Anti-Bribery Policy sets forth rules and guidelines to comply with applicable anti-bribery laws and regulations, including the US Foreign Corrupt Practices Act and the UK Bribery Act.
- MSCI prohibits (i) offering, promising or giving bribes or anything that could be construed or perceived as a bribe; and (ii) requesting, agreeing to accept or accepting bribes or anything that could be construed or perceived as a bribe, in connection with MSCI business.
- MSCI’s global anti-bribery policy also prohibits “facilitation payments” which MSCI defines as minimal gratuities provided to low-level officials to perform routine, nondiscretionary functions, such as customs clearance, vehicle registration, visa renewal, police protection, and utility services. In extremely rare circumstances and where permitted by applicable law, employees may seek and the MSCI Legal and Compliance Department may grant exceptions (in writing and in advance) to the facilitation payment prohibition.
- Gifts to or entertainment involving government officials are prohibited without the prior approval of the MSCI Legal and Compliance Department. Careful consideration is given to any applicable anti-bribery laws. Additionally, employees are required to log received gifts and entertainment with the Compliance Department to evaluate any potential conflicts of interest.
- At least annually, MSCI conducts targeted anti-corruption training to applicable employees that includes the use of third-party agents that may engage with government entities on MSCI’s behalf. MSCI emphasizes here and in general compliance training that the use of such third parties requires management and compliance approval.
- MSCI does not engage in or have oversight of any client trading activity, as we do not offer or maintain client trading accounts or have custody over client assets. Additionally, MSCI does not execute transactions on behalf of clients nor do we offer a platform for clients to make any transactions, including both institutional and retail. Nor do we invest on our own behalf. Nonetheless, we do maintain a global anti-money laundering policy to ensure that we only do business with reputable clients who are engaged in legitimate businesses and who derive their income, wealth, funds and investable assets from legitimate sources.
- Under the MSCI ESG Research Regulatory Code of Ethics, relevant employees of MSCI ESG Research are subject to restrictions on political contributions in order to comply with SEC pay-to-play rules applicable to Registered Investment Advisers. MSCI has not historically used corporate resources to fund political activities. View the Political Activities Policy Statement.
Preventing or Managing Potential Conflicts of Interest
- Employees are required to promptly report any personal investment activity, interest or relationship (including those involving family members) that could give rise to a conflict of interest, or the appearance of a conflict of interest.
- Employees are also required to disclose and obtain pre-approval from the Legal and Compliance Department for any personal outside business activities, as well as activities related to seeking political office, holding elected or appointed political posts, serving on a public or municipal board or similar public body, or serving as an officer of a political campaign committee.
- Additionally, employees must disclose and obtain pre-approval from the applicable member of MSCI’s Executive Committee and the Legal and Compliance Department to serve as a representative of MSCI on a board or committee or in another position constituting a leadership role in industry associations or groups.
- Further, employees are prohibited from trading in options on MSCI stock, purchasing MSCI stock on margin or holding MSCI stock in a margin account, holding MSCI stock in a managed account (where discretion is given to a broker), pledging MSCI stock as collateral for a loan, and from engaging in short sales, hedging transactions and stop or limit orders with a duration greater than one day.
- MSCI is subject to independent audits, which test certain compliance practices, such as certification of the Code of Conduct.
Awareness, Training and Certification
- Annually, all employees are required to complete training on the Code of Conduct and related Compliance policies, as well as certify that they have read and agree to adhere to them. As part of our onboarding process, all new employees of the company are trained on the Code of Conduct and related Compliance policies and are required to certify to them. Our directors are also required to annually certify to the MSCI Inc. Code of Ethics and Business Conduct.
- The Compliance staff conducts periodic testing of applicable policies and procedures to ensure availability and effectiveness. On at least an annual basis, the Head of Compliance provides an update on the overall Compliance program to the Nominating & Corporate Governance Committee of the MSCI Board of Directors, including with respect to any policy changes, areas of emphasis, known issues or concerns, projects, investigations and violations, statistical trends, and overall program health. Our Nominating & Corporate Governance Committee also annually reviews our Code of Ethics and Business Conduct.
Employee Whistleblower Hotline
- We offer a whistleblower hotline which is available through an independent online portal that is available to our employees 24/7. Employees are reminded of the existence of the whistleblower hotline periodically throughout the year. Senior members of the Legal and Compliance Department are responsible for directing issues to the appropriate members of senior management.
- Additionally, we have a specific whistleblower policy and procedure for reporting any potential misconduct in benchmark administration, including suspected manipulation of an MSCI index. Communications regarding such concerns can be made 24/7 through a whistleblower hotline available through an independent online portal. Employees are made aware of this policy through the company’s intranet and Compliance training, and instructions for reporting an issue are provided on the company’s intranet.
- MSCI prohibits acts of retaliation against any person for reporting a possible violation or participating in an investigation involving possible misconduct in good faith. All reports will be investigated promptly and thoroughly, consistent with applicable law.
MSCI’s commitment to operating at the highest levels of integrity extends beyond our company. Our suppliers are expected to live up to the spirit of our Supplier Code of Conduct. MSCI may audit suppliers for compliance with the code and/or request suppliers to furnish a self-assessment of adherence to the code.