Moodys.com
Please Note
We brought you to this page based on your search query. If this isn't what you are looking for, you can continue to Search Results for ""
The maximum number of items you can export is 3,000. Please reduce your list by using the filtering tool to the left.
Close
Close
Email Research
Recipient email addresses will not be used in mailing lists or redistributed.
Recipient's
Email

Use semicolon to separate each address, limit to 20 addresses.
Enter the
characters you see
Close
Email Research
Thank you for your interest in sharing Moody's Research. You have reached the daily limit of Research email sharings.
Close
Thank you!
You have successfully sent the research.
Please note: some research requires a paid subscription in order to access.
Already a customer?
LOG IN
Don't want to see this again?
REGISTER
OR
Accept our Terms of Use to continue to Moodys.com:

PLEASE READ AND SCROLL DOWN!

 

By clicking “I AGREE”, you indicate that you understand and intend these terms and conditions to be the legal equivalent of a signed, written contract and equally binding, and that you accept such terms and conditions as a condition of viewing any and all Moody’s information that becomes accessible to you (the “Information”). References herein to “Moody’s” include Moody’s Corporation. and each of its subsidiaries and affiliates..

 

Terms of One-Time Website Use

 

1.             Unless you have entered into an express written contract with www.moodys.com to the contrary and/or agreed to the Terms of Use at www.moodys.com or ratings.moodys.com, you agree that you have no right to use the Information in a commercial or public setting and no right to copy it, save it, print it, sell it, or publish or distribute any portion of it in any form.                   

 

2.             CREDIT RATINGS AND MOODY’S MATERIALS FOUND ON WWW.MOODYS.COM OR SITES OTHER THAN RATINGS.MOODYS.COM MAY NOT BE DISPLAYED IN REAL TIME. FOR REAL-TIME DISPLAYS OF CREDIT RATINGS AND OTHER INFORMATION REQUIRED TO BE DISCLOSED BY MIS PURSUANT TO APPLICABLE LAW OR REGULATION, PLEASE USE RATINGS.MOODYS.COM.           

 

3.             You acknowledge and agree that Moody’s credit ratings: (i) are current opinions of the future relative creditworthiness of securities and address no other risk; and (ii) are not statements of current or historical fact or recommendations to purchase, hold or sell particular securities. Moody’s credit ratings and publications are not intended for retail investors, and it would be reckless and inappropriate for retail investors to use Moody’s credit ratings and publications when making an investment decision. No warranty, express or implied, as the accuracy, timeliness, completeness, merchantability or fitness for any particular purpose of any Moody’s credit rating is given or made by Moody’s in any form whatsoever.

 

4.             To the extent permitted by law, Moody’s and its directors, officers, employees, representatives, licensors and suppliers disclaim liability for: (i) any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with use of the Information; and (ii) any direct or compensatory damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud or any other type of liability that by law cannot be excluded) on the part of Moody’s or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with use of the Information.     

 

5.             You agree to read and be bound by the more detailed disclosures regarding Moody’s ratings and the limitations of Moody’s liability included in the Information.​​​

 

6.             You agree that any disputes relating to this agreement or your use of the Information, whether in contract, tort, statute or otherwise, shall be governed by the laws of the State of New York and shall be subject to the exclusive jurisdiction of the courts of the State of New York located in the City and County of New York, Borough of Manhattan.​​​

I AGREE
Rating Action:

Moody's places Tunisia's Caa1 ratings on review for downgrade

30 Sep 2022

London, September 30, 2022 -- Moody's Investors Service ("Moody's") has today placed the Government of Tunisia's Caa1 long-term foreign-currency and local-currency issuer ratings on review for downgrade. Prior to this rating action, Tunisia's rating was Caa1 with a negative outlook.

Moody's has also placed the Central Bank of Tunisia's Caa1 senior unsecured rating and (P)Caa1 senior unsecured shelf rating on review for downgrade. The Central Bank of Tunisia is legally responsible for the payments on all of the government's bonds. These debt instruments are issued on behalf of the government. Prior to this rating action, the Central Bank of Tunisia's rating was Caa1 with a negative outlook.

The decision to place the ratings on review for downgrade reflects Moody's assessment that in the absence of timely agreement on a new International Monetary Fund (IMF) programme, Tunisia's increasingly elevated government liquidity risks and fragile external position raise the risk of default. Tunisia's large fiscal and external imbalances and elevated refinancing risks represent significant credit weaknesses, which alongside social tensions have been exacerbated by the global implications of the Russia-Ukraine military conflict. The review period will focus on evaluating the authorities' progress in securing Executive Board approval of a new IMF programme - key to alleviating financing and external vulnerability risks, and ultimately social risks - before the end of the year; and the likelihood of maintaining sufficient official financing sources in the coming years to avert a balance of payments or fiscal crisis with negative social implications.

Tunisia's ceilings remain unchanged at B1 for the local-currency ceiling and B3 for the foreign-currency ceiling. The three-notch gap between the local currency ceiling and the sovereign rating reflects a broad public sector footprint, external imbalances and a challenging political and social environment which hampers the business environment; balanced against relatively predictable, albeit weakened, institutions. The two-notch gap of the foreign currency ceiling to the local currency ceiling reflects persistent external imbalances and reliance on foreign inflows which increase firms' exposure to potential transfer and convertibility risks.

RATINGS RATIONALE / FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS

RATIONALE FOR INITIATING THE REVIEW FOR DOWNGRADE

Very tight domestic and external funding conditions and the Tunisian government's challenging debt-service profile elevate refinancing risks. Moody's estimates the government's gross financing needs for this year at around 17% of GDP, remaining above 15% of GDP in 2023 as a result of rising debt amortization payments and a still-high fiscal deficit. In the absence of international market access at affordable costs - sovereign spreads have remained extremely wide for more than a year - and in view of domestic financing constraints, meeting these levels is in Moody's view achievable only through the concessional financing that would be unlocked by a new IMF programme. Beyond the financing provided by the IMF itself, further funds would likely be catalyzed through a broad base of multilateral and bilateral partners. Because Tunisia's financing needs will stay close to 15% of GDP for the foreseeable future, without access to market financing at affordable costs it will remain reliant on a steady and timely flow of sizeable official sector financing.

The successful signing of an IMF programme has remained elusive since the previous four-year arrangement was terminated in April 2020. The publication of a reform programme by the government in June, and the conclusion on 15 September of a salary agreement with social partners implying some containment of the public sector wage bill in real terms over the next three years, represent important signs of progress in that direction. However, the Fund is likely to seek further commitments on other reform areas to be covered under a programme, including the restructuring of loss-making state-owned enterprises and the gradual phasing out of consumption subsidies in favour of more targeted financial transfers. The degree of consensus among stakeholders and social interest groups on the government's reform agenda remains uncertain, while a track record of past reform delays dims expectations of success in a less conducive political and economic environment.

Tunisia's foreign exchange reserves, which stood at $7.7 billion as of August, have remained relatively resilient to date and represent an important, but finite, backstop for external debt principal repayment needs amounting to $2.1 billion in 2023 alone. However, challenging balance of payments dynamics could rapidly pressure the foreign exchange buffer in the absence of prompt agreement on a new IMF programme. Moody's expects the current account deficit to reach close to 10% of GDP this year and remain around 8% of GDP in 2023, from 5.9% of GDP in 2021. The external vulnerability indicator (the ratio between the sum of external debt payments due over the next year and non-resident deposits, and foreign exchange reserves) will remain above 200% this year and next, indicating significant exposure to potential balance of payments disruptions to meet upcoming external liabilities. High global energy and food prices have exacerbated external imbalances by widening Tunisia's import bill and need for external financing, and also risk making the pursuit of reform even more difficult under a more challenging social environment.

Fiscal trends have been relatively favourable in the year to date, with preliminary execution data showing a small budget deficit – equivalent to around 0.3% of GDP – in the first half of the year on the back of strong revenue gains and relative containment of the public-sector wage bill. However, Moody's expects the budget deficit to widen over the remainder of the year, reaching 8.6% of GDP for 2022 as a whole, as the significant impact of high global energy and food prices on the subsidy bill materializes. This underscores the importance of securing an IMF agreement to avert fiscal stress, a development that Moody's expects to gain greater visibility of during the review period. Subject to an IMF programme being agreed, Moody's expects the budget deficit to begin narrowing from next year but remain elevated, at 6.8% of GDP in 2023. Tunisia's public debt burden would continue to increase over the next few years from 79.2% of GDP in 2021 and reach close to 88% of GDP by the end of 2023.

Moody's expects risks to Tunisia's credit profile to remain skewed to the downside even under an eventual IMF agreement. Access to international capital markets is likely to remain closed over 2023, and official sector financing prospects would remain dependent on timely implementation of the reforms targeted under a programme. Tunisia's performance under past IMF programmes has been mixed, and recurring social tensions over the past decade against a backdrop of weak growth and employment creation, weakening governance and a fragmented political landscape have challenged successive governments' capacity to implement economic reforms and address fiscal imbalances. Protracted delays in reforms and reform-dependent funding would erode foreign exchange reserves through drawdowns for debt service payments, thereby exacerbating balance of payment risks and the probability of a debt restructuring that would entail losses for private sector creditors. The review will assess the likelihood of Tunisia maintaining sufficient official financing sources in the coming years to avert a balance of payments or fiscal crisis with negative social implications.

ENVIRONMENTAL, SOCIAL, GOVERNANCE CONSIDERATIONS

Tunisia's ESG Credit Impact Score is very highly negative (CIS-5), reflecting very high exposure to social risks and a weak governance profile. While remittances partially compensate for weak income prospects, the sovereign's capacity to respond to social risks is increasingly threatened by the government's balance-sheet constraints.

Tunisia's credit profile is moderately exposed to environmental risks, reflected in its E-3 issuer profile score and driven by its exposure to rising sea levels in coastal areas and to increasing water and desertification risks in internal regions. Coastal regions account for 80% of total output, driving exposure. Climate variability, erratic precipitation patterns and severe droughts pose threats to Tunisia's agricultural sector, which accounts for around 15% of total employment. Physical climate risk is moderately negative, carbon transition risks and waste and pollution risks are neutral-to-low while natural capital and water management risks are highly negative.

Exposure to social risks is very high (S-5), driven by risks related to labour and income. Rigid labour markets and weak employment generation result in high unemployment rates, including among young graduates. These constraints make it difficult to absorb the well-educated workforce, contributing to negative net migration flows every year and to brain drain. Resilient remittances are a supportive factor and partially compensate for weak income prospects, but the issuer's shock resilience is increasingly threatened by the government's balance sheet constraints. More generally, progress on reforms, and as a result, fiscal strength, liquidity risks and to some extent external vulnerability risks, are shaped by social considerations and the capacity of the government and civil society stakeholders to align behind credible policy plans or not.

Tunisia's governance is weak (G-4 issuer profile). Although the country's consensus-building orientation has been instrumental in securing the successful democratic transition with all stakeholders involved, in recent years the policy decision making process has been significantly impaired. Recurring social tensions inhibit policy effectiveness by reducing political consensus for reform, including from the part of civil society institutions. Moreover, the quality of executive and legislative institutions has weakened through successive governments failing to adopt and deliver a coherent policy agenda. Tunisia's institutional structure is highly negative, while policy credibility & effectiveness and budget management are moderately negative and transparency and disclosure is neutral-to-low.

WHAT COULD CHANGE THE RATINGS DOWN

A downgrade of the rating would be likely if the sovereign were unable to secure in a timely manner multilateral financing, through the conclusion of an IMF agreement that is sustained and large enough to materially and durably ease liquidity pressures. Increased external vulnerability risks that result in currency depreciation pressures that keep the debt burden rising higher and for longer than Moody's currently expects would raise debt sustainability concerns, exacerbate social risks, and increase the likelihood of a debt restructuring that would entail losses for private sector creditors.

WHAT COULD LEAD TO CONFIRMATION OF THE RATINGS AT THE CURRENT LEVEL

The rating would likely be confirmed at the current Caa1 level if the review concluded with sufficient evidence in Tunisia's ability to secure funding to meet its upcoming debt service payments in the next few years at affordable costs. Relatedly, confidence that the government's economic and fiscal reform implementation capacity will lead to a stabilisation and eventual reduction in the debt trajectory, alongside a material reduction in financing needs, would support confirmation of the rating at the current level.

GDP per capita (PPP basis, US$): 11,424 (2021) (also known as Per Capita Income)

Real GDP growth (% change): 3.3% (2021) (also known as GDP Growth)

Inflation Rate (CPI, % change Dec/Dec): 6.6% (2021)

Gen. Gov. Financial Balance/GDP: -7.5% (2021) (also known as Fiscal Balance)

Current Account Balance/GDP: -5.9% (2021) (also known as External Balance)

External debt/GDP: 91.6% (2021)

Economic resiliency: b1

Default history: No default events (on bonds or loans) have been recorded since 1983.

On 27 September 2022, a rating committee was called to discuss the rating of the Tunisia, Government of. The main points raised during the discussion were: The issuer's economic fundamentals, including its economic strength, have not materially changed. The issuer's institutions and governance strength, have not materially changed. The issuer's fiscal or financial strength, including its debt profile, has not materially changed. The issuer has become increasingly susceptible to event risks.

The principal methodology used in these ratings was Sovereign Ratings Methodology published in November 2019 and available at https://ratings.moodys.com/api/rmc-documents/63168. Alternatively, please see the Rating Methodologies page on https://ratings.moodys.com for a copy of this methodology.

The weighting of all rating factors is described in the methodology used in this credit rating action, if applicable.

REGULATORY DISCLOSURES

For further specification of Moody's key rating assumptions and sensitivity analysis, see the sections Methodology Assumptions and Sensitivity to Assumptions in the disclosure form. Moody's Rating Symbols and Definitions can be found on https://ratings.moodys.com/rating-definitions.

For ratings issued on a program, series, category/class of debt or security this announcement provides certain regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series, category/class of debt, security or pursuant to a program for which the ratings are derived exclusively from existing ratings in accordance with Moody's rating practices. For ratings issued on a support provider, this announcement provides certain regulatory disclosures in relation to the credit rating action on the support provider and in relation to each particular credit rating action for securities that derive their credit ratings from the support provider's credit rating. For provisional ratings, this announcement provides certain regulatory disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms have not changed prior to the assignment of the definitive rating in a manner that would have affected the rating. For further information please see the issuer/deal page for the respective issuer on https://ratings.moodys.com.

For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this credit rating action, and whose ratings may change as a result of this credit rating action, the associated regulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated entity.

The ratings have been disclosed to the rated entity or its designated agent(s) and issued with no amendment resulting from that disclosure.

These ratings are solicited. Please refer to Moody's Policy for Designating and Assigning Unsolicited Credit Ratings available on its website https://ratings.moodys.com.

Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related rating outlook or rating review.

Moody's general principles for assessing environmental, social and governance (ESG) risks in our credit analysis can be found at https://ratings.moodys.com/documents/PBC_1288235.

The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody's affiliates outside the EU and is endorsed by Moody's Deutschland GmbH, An der Welle 5, Frankfurt am Main 60322, Germany, in accordance with Art.4 paragraph 3 of the Regulation (EC) No 1060/2009 on Credit Rating Agencies. Further information on the EU endorsement status and on the Moody's office that issued the credit rating is available on https://ratings.moodys.com.

Please see https://ratings.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal entity that has issued the rating.

Please see the issuer/deal page on https://ratings.moodys.com for additional regulatory disclosures for each credit rating.

Mickael Gondrand
Analyst
Sovereign Risk Group
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London, E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454

Marie Diron
MD - Sovereign Risk
Sovereign Risk Group
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454

Releasing Office:
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London, E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454

No Related Data.
© 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.

MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS, AND PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS OR PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.

ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY’S PRIOR WRITTEN CONSENT.

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.

Moodys.com