Conflicts of Interest

Updated March 2024

Actual Conflicts of Interest

CI discloses the following actual conflicts of interest in accordance with its General Policy on the Identification, Management and Disclosure of Conflicts of Interest and in accordance with Point 1 of Annex I Section B of EU Regulation 1060/2009 on Credit Rating Agencies:

Name of Rated Entity:	Saudi Awwal Bank (formerly known as "The Saudi British Bank")
Conflict of Interest:	A rating analyst owns financial instruments of an entity related to the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity. The related entity is not rated by CI.
Additional Action Required:	None

Name of Rated Entity:	Saudi Awwal Bank (formerly known as "The Saudi British Bank")
Conflict of Interest:	A member of senior management owns financial instruments of an entity related to the above named rated entity.
Management/Mitigation:	The member of senior management may not participate in rating committee meetings or be directly involved in determining the credit rating of any rated entities. May not have access to non-public information concerning a rated entity or a potential or pending rating action. May not contact employees of the Company directly for information on individual clients or rated entities. May not provide advisory or consultancy services to a rated entity or related third party regarding corporate or legal structure, assets, liabilities or the activities of the rated entity or related third party.
Additional Action Required:	None

Name of Rated Entity:	Bank of Communications
Conflict of Interest:	A rating analyst owns financial instruments of an entity related to the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity. The related entity is not rated by CI.
Additional Action Required:	None

Name of Rated Entity:	Bank of Communications
Conflict of Interest:	A member of senior management owns financial instruments of an entity related to the above named rated entity.
Management/Mitigation:	The member of senior management may not participate in rating committee meetings or be directly involved in determining the credit rating of any rated entities. May not have access to non-public information concerning a rated entity or a potential or pending rating action. May not contact employees of the Company directly for information on individual clients or rated entities. May not provide advisory or consultancy services to a rated entity or related third party regarding corporate or legal structure, assets, liabilities or the activities of the rated entity or related third party.
Additional Action Required:	None

Name of Rated Entity:	Bank of Cyprus
Conflict of Interest:	A rating analyst owns financial instruments of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Bank of Cyprus
Conflict of Interest:	A person associated to the rating analyst owns financial instruments of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Bank of Cyprus
Conflict of Interest:	A member of senior management owns financial instruments of an entity related to the above named rated entity.
Management/Mitigation:	The member of senior management may not participate in rating committee meetings or be directly involved in determining the credit rating of any rated entities. May not have access to non-public information concerning a rated entity or a potential or pending rating action. May not contact employees of the Company directly for information on individual clients or rated entities. May not provide advisory or consultancy services to a rated entity or related third party regarding corporate or legal structure, assets, liabilities or the activities of the rated entity or related third party.
Additional Action Required:	None

Name of Rated Entity:	Hellenic Bank
Conflict of Interest:	A person associated with the rating analyst is a member of the managing body of a subsidiary of a rated entity that is a competitor of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Hellenic Bank
Conflict of Interest:	A member of senior management owns financial instruments of an entity related to the above-named rated entity.
Management/Mitigation:	The member of senior management may not participate in rating committee meetings or be directly involved in determining the credit rating of any rated entities. May not have access to non-public information concerning a rated entity or a potential or pending rating action. May not contact employees of the Company directly for information on individual clients or rated entities. May not provide advisory or consultancy services to a rated entity or related third party regarding corporate or legal structure, assets, liabilities or the activities of the rated entity or related third party.
Additional Action Required:	None

Name of Rated Entity:	National Bank of Greece
Conflict of Interest:	A person associated with the rating analyst is a member of the managing body of a subsidiary of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Attica Bank S.A.
Conflict of Interest:	A person associated with the rating analyst is a member of the managing body of a subsidiary of a rated entity that is a competitor of the of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Eurobank S.A.
Conflict of Interest:	A person associated with the rating analyst is a member of the managing body of a subsidiary of a rated entity that is a competitor of the of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Piraeus Bank S.A.
Conflict of Interest:	A person associated with the rating analyst is a member of the managing body of a subsidiary of a rated entity that is a competitor of the of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None

Name of Rated Entity:	Alpha Bank S.A.
Conflict of Interest:	A person associated with the rating analyst is a member of the managing body of a subsidiary of a rated entity that is a competitor of the of the above-named rated entity.
Management/Mitigation:	The rating analyst has no analytical responsibility for the above-named rated entity. The rating analyst did not participate in the rating committee that assigned credit ratings to the above-named rated entity and did not in any other way influence the determination of the ratings of the above-named rated entity.
Additional Action Required:	None