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Related Issuers
Beijing Energy Holding Co., Ltd.
Beijing Enterprises Group (BVI) Company Ltd
Beijing Enterprises Holdings Limited
Beijing Gas Group Company Limited
Beijing Gas Singapore Capital Corporation
Binhai Investment Company Limited
Castle Peak Power Company Limited (CAPCO)
Castle Peak Power Finance Company Limited
CGNPC International Limited
Charter Style International Limited
China Clean Energy Development Limited
China General Nuclear Power Corporation
China Huadian Corporation LTD.
China Huadian Overseas Development 2018 Ltd.
China Huadian Overseas Dvp. Mgt. Co. Ltd.
China Huaneng Group (HK) Treasury Mgmt Hldg
China Huaneng Group Co., Ltd.
China Longyuan Power Group Corporation Ltd.
China Oil and Gas Group Limited
China Resources Gas Group Limited
China Resources Power Holdings Co., Ltd
China Southern Power Grid Co., Ltd.
China Southern Power Grid Intl Fin (BVI 2018)
China Southern Power Grid Int'l Finance (BVI)
China Three Gorges Corporation
China Water Affairs Group Limited
China Yangtze Power Co., Ltd
CLP Holdings Limited
CLP Power HK Finance Ltd.
CLP Power Hong Kong Financing Limited
CLP Power Hong Kong Limited
Coastal Emerald Limited
ENN Clean Energy International Investment Ltd
ENN Energy Holdings Limited
ENN Natural Gas Co., Ltd.
Gansu Province Electric Power Invt. Gp.
Guangdong Hengjian Investment Holding Co Ltd
Hangzhou Water Group Co., Ltd
Hanwha Energy USA Holdings Corporation
HKCG (Finance) Limited
Huaneng Power International, Inc.
Korea District Heating Corporation
Korea East-West Power Co., Ltd.
Korea Electric Power Corporation
Korea Gas Corporation
Korea Hydro & Nuclear Power Co., Ltd.
Korea Midland Power Co., Ltd.
Korea South-East Power Co., Ltd.
Korea Southern Power Co., Ltd.
Korea Water Resources Corporation
Korea Western Power Co., Ltd.
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State Grid Europe Development (2014) Plc
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State Grid Overseas Investment (2013) Limited
State Grid Overseas Investment (2014) Limited
State Grid Overseas Investment (BVI) Limited
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Announcement of Periodic Review:

Moody's announces completion of a periodic review for a group of Utilities and Power issuers in North Asia

01 Jun 2022

New York, June 01, 2022 -- Moody's Investors Service ("Moody's") has completed a periodic review of the ratings -and other ratings that are associated with the same analytical units for the rated entity(entities) listed below.

The review was conducted through a portfolio review discussion held on 25 May 2022 in which Moody's reassessed the appropriateness of the ratings in the context of the relevant principal methodology(ies), recent developments, and a comparison of the financial and operating profile to similarly rated peers. A possible outcome from periodic reviews is a referral of a rating to a rating committee.

This publication does not announce a credit rating action and is not an indication of whether or not a credit rating action is likely in the near future. Credit ratings and outlook/review status cannot be changed in a portfolio review and hence are not impacted by this announcement.

Key Rating Considerations

The principal methodology used for these rated entities was Government-Related Issuers Methodology published in February 2020. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Government-Related Issuers Methodology

Assigning a Baseline Credit Assessment (BCA): The majority of Government-Related Issuers (GRIs) begin with an assessment of the GRI's standalone strength (i.e. BCA) – its ability to service and repay outstanding debt without recourse to extraordinary support from the supporting government - using the published sector-specific methodology that is most suitable for the predominant activities of the GRI. Our assessment of standalone strength includes any day-to-day support received from the government that can be clearly distinguished from extraordinary support. Support mechanisms, such as an obligation of the government to ensure the GRI's solvency and liquidity, are reflected in the BCA when they are legally or contractually documented.

Government uplift: The GRI's ratings include any uplift due to systemic support and typically focus on three structural factors and three factors explaining the level of the government's willingness to provide support. Structural factors address the legal and quasi-legal aspects of the government's relationship with the GRI and include: (1) guarantees, (2) ownership level and (3) barriers to support. The factors underlying willingness consider the softer connections between the two entities and include (4) the likelihood of government intervention, (5) political linkages and (6) economic importance. Support is determined using a joint default analysis framework which considers an estimate of the likelihood of extraordinary support, an assessment of the credit quality of the supporting government, and default correlation between the two entities.

GRIs without a BCA: In limited instances, it is not possible or meaningful to assign a BCA. The GRI is so inextricably linked to the government that a meaningful standalone BCA cannot be derived. In such cases, a top-down analytical approach is used that chiefly considers the ability and willingness of the government to provide timely support, instead of the usual bottom-up approach of starting with the BCA and then considering uplift towards the government's rating.

• China General Nuclear Power Corporation

• China Huadian Corporation LTD.

• China Huaneng Group Co., Ltd.

• China Southern Power Grid Co., Ltd.

• China Three Gorges Corporation

• Gansu Province Electric Power Invt. Gp.

• Guangdong Hengjian Investment Holding Co Ltd

• Korea District Heating Corporation

• Korea Electric Power Corporation

• Korea Gas Corporation

• Korea Water Resources Corporation

• Shenergy (Group) Co., Ltd.

• State Grid Corporation of China

• State Power Investment Corporation Limited

• Zhejiang Provincial Energy Group Co. Ltd

The principal methodology used for these rated entities was Investment Holding Companies and Conglomerates published in July 2018. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Investment Holding Companies and Conglomerates

For Investment Holding Companies we consider the following factors:

Investment Strategy: Investment strategy is considered because transparent and more conservative investment strategies can provide a longer-term view of an investment holding company's business profile, which is particularly relevant given the tendency for investment holding companies to acquire and divest assets. Greater visibility over the evolution of the company's investment portfolio is supported by clearly defined investment strategies in terms of the types of assets the company seeks to invest in, the intended tenure of its investments and the targeted composition of its investment portfolio. We assess the investment holding company's investment policies and guidelines, as well as management track record. The existence of publicly communicated goals and a commitment to adhere to these is also helpful in our assessment, particularly when a proven track record is present.

Asset Quality: The asset quality of the investment portfolio represents one of the drivers of the company's credit risk. Our assessment considers investment concentration, geographic and business diversity, and portfolio transparency. The transparency and consistency of management in communicating information is a key element of our analysis. Listed investments in markets where regulatory disclosure requirements are strong can help to provide more reliable information.

Financial Policy: Management and board tolerance for financial risk is considered as it directly affects debt levels, credit quality, and the risk of adverse changes in financing and capital structure. This is important given an investment holding company's exposure to equity risks, which can result in greater volatility in leverage metrics relative to other corporates. The acquisition and divestiture activities of investment holding companies also make it more challenging to estimate future leverage. Our assessment of financial policies includes the perceived tolerance of a company's governing board and management for financial risk and the future direction for the company's capital structure. Considerations also include a company's public commitments in this area, its track record for adhering to commitments, and our views on the ability for the company to achieve its targets.

Estimated Market Value-Based Leverage (MVL): The majority of an investment holding company's assets are typically equity participations in subsidiaries and associates. In the event that the holding company decides to lever its equity returns by funding part of the investments through the issuance of debt, the credit risk of this debt is significantly impacted by asset values available to cover potential fixed debt charges. The MVL is measured as Net Debt/Estimated Market Value of Portfolio Assets.

Debt Coverage and Liquidity: Operational cash flows that can regularly cover interest expenses reflect positively on the investment holding company's financial flexibility and long-term viability. Investment holding companies that do not have a sufficiently mature portfolio paying an adequate level of dividends to cover their interest and debt payments are more reliant upon cash and credit facilities, which we believe should be reserved for a market downturn. The timing of debt repayments can play a particularly significant role in the credit profile of an investment holding company as the concentration of maturities can present liquidity challenges and heighten refinancing risk. Debt Coverage and Liquidity is measured by ratios such as Funds from Operations plus Interest/ Interest Expense and Liquidity/Debt maturities.

Other Considerations: Other considerations may include, but are not limited to, corporate governance, financial controls, liquidity management, group complexity, degree of influence over dividends of investees, event risk as well as parental and institutional support.

For conglomerates we incorporate a balanced view of the credit risk in each business segment, with further consideration of the potential overall risk reduction due to industry and country diversification of assets and cashflows, portfolio stability, together with the ownership structure and the relationship between subsidiaries and the broader group.

Credit Risk of Each Business Segment: We assess the individual business and credit risk profile of each major industry segment of a conglomerate by applying the scorecard from the respective industry sector methodology. In most cases, it is most meaningful to do this only for the two or three largest industry segments. Where necessary, this approach includes an allocation of the conglomerate's Holdco debt to its subsidiary businesses in order to estimate individual ratios which allow for a weighted average calculation for the total group. The weighting is usually centered around cash flow metrics (such as each major segment's contribution to EBITDA) since this can represent an approximation for the debt capacity of the various subsidiaries.

Risk Reduction from Industry/Country Diversification: Business diversification within a conglomerate can bring potential benefits for creditors. At the same time, diversification exists only to the extent that correlation is low across the various businesses. We therefore take a very pragmatic and cautious approach to diversification.

Portfolio Stability: The stability of a conglomerate's portfolio during a certain time period is assessed by analyzing the stability of investments in assets and their asset mix (e.g. by sector, country, or revenue vs. cash flow focus), the number of acquisitions, spin-offs, and "greenfield" developments. Strong discipline with clear guidance on a balanced investment strategy and limited event risk is considered as a positive step for the overall credit risk of the conglomerate.

Ownership Structure: The type of ownership might be a potential source of benefit for the credit assessment of the conglomerate. For example, a conglomerate with stable ownership (possibly majority remaining with a family) and a clear succession plan is assessed positively. Conversely, unclear ownership influences or weak governance structures may impair the overall rating outcome, and is assessed negatively.

Relationship Between Subsidiaries and the Broader Group: There might be circumstances under which the parent holding provides specific financial support to a business which is part of the overall conglomerate. This may be accomplished, for example, through intercompany loans, equity top-ups, asset transfers, granting of financial guarantees or debt forgiveness. The overall strength of support depends on the type of measure and our assessment of the willingness and ability of the parent to grant this support.

• Beijing Enterprises Group (BVI) Company Ltd

The principal methodology used for these rated entities was Rating Transactions Based on the Credit Substitution Approach: Letter of Credit-backed, Insured and Guaranteed Debts published in May 2017. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Rating Transactions Based on the Credit Substitution Approach: Letter of Credit-backed, Insured and Guaranteed Debts

Third-party credit support: The goal of third-party credit support is to substitute the credit risk of the support provider for the credit risk of the issuer. For credit substitution to be achieved, investors must be insulated from the risk of payment default by the underlying obligor. Generally, the long-term ratings on credit-supported transactions track the long-term rating assigned to the credit provider.

Additional Considerations: Credit substitution requires more than just the presence of a credit support instrument from a third-party credit provider. The transaction documentation provides clear instructions to ensure that payments under the credit support facility are made when due and that there are no impediments to the timely payment of debt service. The key elements evaluated include: mitigation of bankruptcy risk of issuer; sufficiency of credit support; structural provisions which provide for the timely payment of debt service; bondholders to be paid in full if credit support expiration or termination will result in a change.

• Hanwha Energy USA Holdings Corporation

The principal methodology used for these rated entities was Regulated Electric and Gas Networks published in April 2022. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Regulated Electric and Gas Networks

Revenue Generation and Recovery Cost Framework: Metrics may include but are not limited to monopoly status; rate setting flexibility; strength of customer base and service area as measured by resource base, population, wealth, economic diversity, and growth projections; length and quality of customer contracts and contractor credit quality; scale; market framework and market diversification; structural and creditor protections; and ownership model.

Cost Recovery: Metrics may include but are not limited to transparency and timeliness of rate setting process by governing board or regulatory body including support for setting appropriate rates and charges to service debt; exposure to potential rate shocks; cash flow predictability.

Generation and Procurement Risk: Metrics may include but is not limited to ability to meet power supply commitments; the fuel mix; power price hedging; the diversity, cost and reliability of power supply sources; exposure to additional debt needs or regulatory risk; scale and complexity of the capex programme.

Competitiveness: Metrics may include but are not limited to market position, average system retail rate relative to regional peers or state average and material cost pressure that could lead to higher rates.

Financial Position, Policy and Ownership: Metrics may include but are not limited to corporate financial policy, days cash on hand; debt service coverage ratio measured by debt service and other fixed charges by net revenue, adjusted debt ratio of debt and ANPL (adjusted net pension liability) to net assets and working capital; ratio of debt to cash flow; interest coverage metrics and debt to asset metrics. Assessments may include but are not limited to an Issuer's desired capital structure / credit profile, and its adherence to its commitments and our views on the ability of the company to achieve its targets, an assessment of the likelihood and potential negative impact of M&A or other types of balance-sheet-transforming events, and the likelihood of uncontracted financial support being provided by owners; and the protective terms of debt documentation including but limited to restrictions on business activities, use of debt and revenue distributions; and control and liquidity afforded to creditors.

• State Grid International Development Limited

The principal methodology used for these rated entities was Regulated Electric and Gas Utilities published in June 2017. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Regulated Electric and Gas Utilities

Revenue Generation and Recovery Cost Framework: Metrics may include but are not limited to monopoly status; rate setting flexibility; strength of customer base and service area as measured by resource base, population, wealth, economic diversity, and growth projections; length and quality of customer contracts and contractor credit quality; scale; market framework and market diversification; structural and creditor protections; and ownership model.

Cost Recovery: Metrics may include but are not limited to transparency and timeliness of rate setting process by governing board or regulatory body including support for setting appropriate rates and charges to service debt; exposure to potential rate shocks; cash flow predictability.

Generation and Procurement Risk: Metrics may include but is not limited to ability to meet power supply commitments; the fuel mix; power price hedging; the diversity, cost and reliability of power supply sources; exposure to additional debt needs or regulatory risk; scale and complexity of the capex programme.

Competitiveness: Metrics may include but are not limited to market position, average system retail rate relative to regional peers or state average and material cost pressure that could lead to higher rates.

Financial Position, Policy and Ownership: Metrics may include but are not limited to corporate financial policy, days cash on hand; debt service coverage ratio measured by debt service and other fixed charges by net revenue, adjusted debt ratio of debt and ANPL (adjusted net pension liability) to net assets and working capital; ratio of debt to cash flow; interest coverage metrics and debt to asset metrics. Assessments may include but are not limited to an Issuer's desired capital structure / credit profile, and its adherence to its commitments and our views on the ability of the company to achieve its targets, an assessment of the likelihood and potential negative impact of M&A or other types of balance-sheet-transforming events, and the likelihood of uncontracted financial support being provided by owners; and the protective terms of debt documentation including but limited to restrictions on business activities, use of debt and revenue distributions; and control and liquidity afforded to creditors.

• Beijing Gas Group Company Limited

• Binhai Investment Company Limited

• China General Nuclear Power Corporation

• China Oil and Gas Group Limited

• China Resources Gas Group Limited

• China Southern Power Grid Co., Ltd.

• China Three Gorges Corporation

• China Yangtze Power Co., Ltd

• CLP Holdings Limited

• ENN Natural Gas Co., Ltd.

• Korea District Heating Corporation

• Korea Electric Power Corporation

• Korea Gas Corporation

• Kunlun Energy Company Limited

• Shenergy (Group) Co., Ltd.

• State Grid Corporation of China

• The Hong Kong and China Gas Company Limited

• Zhongyu Energy Holdings Limited

The principal methodology used for these rated entities was Regulated Water Utilities published in June 2018. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Regulated Water Utilities

Revenue Generation and Recovery Cost Framework: Metrics may include but are not limited to monopoly status; rate setting flexibility; strength of customer base and service area as measured by resource base, population, wealth, economic diversity, and growth projections; length and quality of customer contracts and contractor credit quality; scale; market framework and market diversification; structural and creditor protections; and ownership model.

Cost Recovery: Metrics may include but are not limited to transparency and timeliness of rate setting process by governing board or regulatory body including support for setting appropriate rates and charges to service debt; exposure to potential rate shocks; cash flow predictability.

Generation and Procurement Risk: Metrics may include but is not limited to ability to meet power supply commitments; the fuel mix; power price hedging; the diversity, cost and reliability of power supply sources; exposure to additional debt needs or regulatory risk; scale and complexity of the capex programme.

Competitiveness: Metrics may include but are not limited to market position, average system retail rate relative to regional peers or state average and material cost pressure that could lead to higher rates.

Financial Position, Policy and Ownership: Metrics may include but are not limited to corporate financial policy, days cash on hand; debt service coverage ratio measured by debt service and other fixed charges by net revenue, adjusted debt ratio of debt and ANPL (adjusted net pension liability) to net assets and working capital; ratio of debt to cash flow; interest coverage metrics and debt to asset metrics. Assessments may include but are not limited to an Issuer's desired capital structure / credit profile, and its adherence to its commitments and our views on the ability of the company to achieve its targets, an assessment of the likelihood and potential negative impact of M&A or other types of balance-sheet-transforming events, and the likelihood of uncontracted financial support being provided by owners; and the protective terms of debt documentation including but limited to restrictions on business activities, use of debt and revenue distributions; and control and liquidity afforded to creditors.

• China Water Affairs Group Limited

• Hangzhou Water Group Co., Ltd

• Korea Water Resources Corporation

The principal methodology used for these rated entities was Unregulated Utilities and Unregulated Power Companies published in May 2017. Please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

Key rating considerations on a forward-looking basis may include but are not limited to the following summarized below.

Unregulated Utilities and Unregulated Power Companies

Revenue Generation and Recovery Cost Framework: Metrics may include but are not limited to monopoly status; rate setting flexibility; strength of customer base and service area as measured by resource base, population, wealth, economic diversity, and growth projections; length and quality of customer contracts and contractor credit quality; scale; market framework and market diversification; structural and creditor protections; and ownership model.

Cost Recovery: Metrics may include but are not limited to transparency and timeliness of rate setting process by governing board or regulatory body including support for setting appropriate rates and charges to service debt; exposure to potential rate shocks; cash flow predictability.

Generation and Procurement Risk: Metrics may include but is not limited to ability to meet power supply commitments; the fuel mix; power price hedging; the diversity, cost and reliability of power supply sources; exposure to additional debt needs or regulatory risk; scale and complexity of the capex programme.

Competitiveness: Metrics may include but are not limited to market position, average system retail rate relative to regional peers or state average and material cost pressure that could lead to higher rates.

Financial Position, Policy and Ownership: Metrics may include but are not limited to corporate financial policy, days cash on hand; debt service coverage ratio measured by debt service and other fixed charges by net revenue, adjusted debt ratio of debt and ANPL (adjusted net pension liability) to net assets and working capital; ratio of debt to cash flow; interest coverage metrics and debt to asset metrics. Assessments may include but are not limited to an Issuer's desired capital structure / credit profile, and its adherence to its commitments and our views on the ability of the company to achieve its targets, an assessment of the likelihood and potential negative impact of M&A or other types of balance-sheet-transforming events, and the likelihood of uncontracted financial support being provided by owners; and the protective terms of debt documentation including but limited to restrictions on business activities, use of debt and revenue distributions; and control and liquidity afforded to creditors.

• Beijing Energy Holding Co., Ltd.

• China Huadian Corporation LTD.

• China Huaneng Group Co., Ltd.

• China Longyuan Power Group Corporation Ltd.

• China Resources Power Holdings Co., Ltd

• Coastal Emerald Limited

• Gansu Province Electric Power Invt. Gp.

• Guangdong Hengjian Investment Holding Co Ltd

• Huaneng Power International, Inc.

• Korea East-West Power Co., Ltd.

• Korea Hydro & Nuclear Power Co., Ltd.

• Korea Midland Power Co., Ltd.

• Korea South-East Power Co., Ltd.

• Korea Southern Power Co., Ltd.

• Korea Western Power Co., Ltd.

• SK E&S Co. Ltd.

• State Power Investment Corporation Limited

• Zhejiang Provincial Energy Group Co. Ltd

This announcement applies only to Rated Entities with EU rated, UK rated, EU endorsed and UK endorsed ratings. Rated Entities, with Non EU rated, non UK rated, non EU endorsed and non UK endorsed ratings may be referenced herein to the extent necessary, if they are part of the same analytical unit.

Please see the Issuer page on https://ratings.moodys.com for each of the ratings covered, most updated credit rating action, rating history, and Credit Rating action Press Release including the rating rationale and factors that could lead to a rating upgrade or downgrade.

This publication does not announce a credit rating action.

For any credit ratings referenced in this publication, please see the issuer/deal page on https://ratings.moodys.com

for the most updated credit rating action information and rating history.


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© 2023 Moody’s Corporation, Moody’s Investors Service, Inc., Moody’s Analytics, Inc. and/or their licensors and affiliates (collectively, “MOODY’S”). All rights reserved.

CREDIT RATINGS ISSUED BY MOODY'S CREDIT RATINGS AFFILIATES ARE THEIR CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MATERIALS, PRODUCTS, SERVICES AND INFORMATION PUBLISHED BY MOODY’S (COLLECTIVELY, “PUBLICATIONS”) MAY INCLUDE SUCH CURRENT OPINIONS. MOODY’S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT OR IMPAIRMENT. SEE APPLICABLE MOODY’S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY’S CREDIT RATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS, NON-CREDIT ASSESSMENTS (“ASSESSMENTS”), AND OTHER OPINIONS INCLUDED IN MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. MOODY’S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY’S ANALYTICS, INC. AND/OR ITS AFFILIATES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS, ASSESSMENTS AND OTHER OPINIONS AND PUBLISHES ITS PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE.

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MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOT INTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM BEING CONSIDERED A BENCHMARK.

All information contained herein is obtained by MOODY’S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided “AS IS” without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY’S is not an auditor and cannot in every instance independently verify or validate information received in the credit rating process or in preparing its Publications.

To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY’S.

To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY’S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information.

NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING, ASSESSMENT, OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY’S IN ANY FORM OR MANNER WHATSOEVER.

Moody’s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody’s Corporation (“MCO”), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody’s Investors Service, Inc. have, prior to assignment of any credit rating, agreed to pay to Moody’s Investors Service, Inc. for credit ratings opinions and services rendered by it fees ranging from $1,000 to approximately $5,000,000. MCO and Moody’s Investors Service also maintain policies and procedures to address the independence of Moody’s Investors Service credit ratings and credit rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold credit ratings from Moody’s Investors Service, Inc. and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at www.moodys.com under the heading “Investor Relations — Corporate Governance — Charter Documents - Director and Shareholder Affiliation Policy.”

Additional terms for Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399 657AFSL 336969 and/or Moody’s Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (as applicable). This document is intended to be provided only to “wholesale clients” within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to “retail clients” within the meaning of section 761G of the Corporations Act 2001. MOODY’S credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors.

Additional terms for Japan only: Moody's Japan K.K. (“MJKK”) is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly-owned by Moody’s Overseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody’s SF Japan K.K. (“MSFJ”) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization (“NRSRO”). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.

MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any credit rating, agreed to pay to MJKK or MSFJ (as applicable) for credit ratings opinions and services rendered by it fees ranging from JPY100,000 to approximately JPY550,000,000.

MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.