MSCI Whistleblower Hotline

The success of our Firm depends in large part on the integrity of our employees. We have established a Whistleblower Hotline where you may report without fear of retaliation any conduct -- whether by another employee, manager, a client, consultant, agent, supplier, or other third party -- that you believe may violate the law, a regulation, Firm policy, or is otherwise unethical or improper. Examples include fraud or financial misconduct, failure of internal controls, insider trading, harassment or discrimination, and misuse of company resources.  The Hotline aims to promote a culture of transparency and accountability.

The Whistleblower Hotline is hosted by an independent third party vendor. Communications may be submitted anonymously.

When making a report, provide as much detail as possible to facilitate the Firm’s ability to investigate the matter, including:

• the nature and specific details of the misconduct
• dates and locations of incidents
• names of individuals involved
• any supporting evidence

On being notified of a concern reported using the Whistleblower Hotline, we will review the concern and decide what action (if any) needs to be taken, which may include an investigation or action under other relevant Firm policies.

We will endeavor maintain confidentiality of the concern as appropriate. However, complete confidentiality cannot be guaranteed if disclosure is required by law or necessary to conduct a thorough investigation.

Retaliation against individuals who report suspected misconduct in good faith is strictly prohibited. Any employee found to engage in retaliatory behavior will face disciplinary action, up to and including termination.

Your ability to use the Whistleblower Hotline is additional to any right you may have to report matters which are of concern to you directly to any applicable governmental, regulatory, administrative or similar body.