Anti-Spam Global Policy
Effective Date: August 1, 2014
Owner:
Global Technology
Applies to:
All DBRS Covered Personnel
I.
PURPOSE
DBRS is committed to protecting DBRS data, which includes Confidential Information. Spam poses
significant problems to the integrity of DBRS data. As such, in accordance with applicable regulations1 and
the DBRS Employee Code of Conduct, DBRS has developed this Anti-Spam Global Policy (Policy).
II.
SCOPE
This Policy applies to all DBRS Covered Personnel, globally, and should be read in conjunction with any
regional Anti-Spam Procedures in effect, as applicable, as well as any Global Technology policies or
procedures that govern the use of messaging services, and other services that may be used to generate Spam.
Terms capitalized throughout this Policy are defined in the Appendix.
III.
POLICY
Covered Personnel are prohibited from using DBRS Technology to send unsolicited, non-business related
emails and Spam, which includes, but is not limited to chain letters, pyramid schemes, “junk” mail, nonDBRS related advertising, harassing or other illegal, non-ethical, threatening, discriminatory, disruptive or
harmful messages and/or information.
DBRS utilizes a third-party vendor for the specific purpose of protecting DBRS Technology against Spam,
viruses and inappropriate content, in addition to the DBRS messaging systems that automatically scan all
incoming and outgoing email messages and filter out messages that appear to be Spam.
If DBRS believes that unauthorized or improper use is being made of any service, it may, without notice
and in its sole discretion, take action as it deems appropriate. This may include, but not be limited to,
blocking messages from a particular internet domain, mail server or IP address.
1. The European Directive on Privacy and Electronic Communications of 2002, the United States CAN-SPAM (Controlling the
Assault of Non-Solicited Pornography & Marketing) Act of 2003, and the CASL (Canadian Anti-Spam Legislation) Act of 2014.
Rating and Other Information: Anti-Spam Global Policy
© 2014, DBRS Limited, DBRS, Inc. and DBRS Ratings Limited (collectively DBRS). All rights reserved.
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IV.
VIOLATIONS
Covered Personnel who violate this Policy may be subject to disciplinary action by the firm, up to and
including termination of employment. Depending on the nature of the violation, administrative, civil or
criminal penalties may also ensue.
V.
QUESTIONS
Covered Personnel who have questions about this Policy or any of the components within should contact
the IT Help Desk at [email protected].
VI.
APPENDIX
A. Definitions
“Confidential Information” means information DBRS receives from an Issuer or its authorized agent
in connection with the rating process which DBRS knows or should reasonably know is confidential
information of the Issuer. It may also refer to information developed by DBRS, including a pending
credit rating action that has not yet been published on the DBRS website or through another readily
accessible means, as well as information about DBRS. Confidential Information includes a class of
price-sensitive information, known as Material, Non-Public Information (MNPI) that DBRS may
receive and/or create as part of its rating activities.
“Covered Personnel” means all full-time or part-time DBRS employees, interns, co-ops, contract
employees, contractors and consultants. This includes Analytical and Non-Analytical Personnel.
“Spam” means the transmission, distribution or delivery of any unsolicited bulk or unsolicited
commercial email sent by a known or unknown entity.
Rating and Other Information: Anti-Spam Global Policy
© 2014, DBRS Limited, DBRS, Inc. and DBRS Ratings Limited (collectively DBRS). All rights reserved.
DBRS Rating Policies 2