Code of Professional Conduct

Code of Professional Conduct

Code of Professional Conduct

GCR has established and implemented policies, procedures, and internal controls in order to ensure that we conduct our business with objectivity, integrity, transparency and in line with the King III report on corporate governance.

The GCR Code of Professional Conduct, which is a key component of the Code of Ethics, reflects the IOSCO principals for Credit Rating Agencies.  The current version of each of GCR’s policies that represent GCR’s Code of Ethics is available below.

All Investing Public, Issuers, market participants and the public are welcome to have a voice regarding GCR’s Ratings and its policies, including raising questions, concerns, or complaints.


Key contacts for complaints, questions, or concerns

Marc Joffe
Chief executive officer
.(JavaScript must be enabled to view this email address)

Riana Theorides
Compliance officer
.(JavaScript must be enabled to view this email address)

Riana Theorides
Compliance Officer

Code oF Professional Conduct PDF index


  • Foreword
  • Section 1: Definitions for Policies and Procedures
  • Section 2: Code of Professional Conduct
  • Section 2.1 Quality and Integrity of the Rating Process
  • Section 2.2 Independence and Avoidance and/or Management of Conflicts of Interest
  • Section 2.3 Responsibilities to the Investing Public Rated Entities, Obligors, Originators, Underwriters and Arrangers
  • Section 2.4 Governance, Risk management, and Employee Training
  • Section 2.5 Disclosure and Communication with Market Participants
  • Section 3: Credit Rating Process Policy
  • Section 3.1 Initiation of a Credit Rating
  • Section 3.2 Allocation of Analyst
  • Section 3.3 Gathering of Information and Conducting of Meetings
  • Section 3.4 Analysis of the Information and According of the Credit Rating
  • Section 3.5 Communication of draft Credit Rating report to the Rated Entity/Issuer
  • Section 3.6 Communication of Credit Rating Actions to the Rated Entity/Issuer
  • Section 3.7 Appeal of a Credit Rating
  • Section 3.8 Monitoring of Credit Ratings
  • Section 3.9 Credit Rating Process Flow Chart
  • Section 3.10 Credit Rating Dissemination
  • Section 3.11 Limitations of Credit Ratings
  • Section 3.12 Other
  • Section 4: Ratings Committee Policy
  • Section 5: Ratings Communication Policy
  • Section 6: Prevention and Management of Conflicts of Interest
  • Section 6.1: Identification and Management of Conflicts of Interest
  • Section 6.2: Analyst Rotation Policy
  • Section 6.3: Ancillary and Other Services Policy
  • Section 6.4: Business and Relationship Management Policy
  • Section 6.4.1 Fee Negotiations and Initiating the Rating Process
  • Section 6.4.2 Revenue, Budget and Market Share Information
  • Section 6.5: Confidential & Sensitive Information/Avoiding Selective Disclosure Policy
  • Section 6.6: General Nature of Compensation Arrangements for Ratings Accorded
  • Section 6.7: Gift and Business Visit Policy
  • Section 6.8: Limitations and Restrictions on Advising Issuers & Others Policy
  • Section 6.9: Look-Back Review Policy
  • Section 6.9.1 Periodical Look-Back Reviews
  • Section 6.9.2 Exit Look-Back Reviews
  • Section 6.10: Solicited Credit Ratings Policy
  • Section 6.11: Unsolicited Credit Ratings Policy
  • Section 6.12: Remuneration and Employee Independence Policy
  • Section 7: File Maintenance and Recordkeeping Policy: Analytics
  • Section 8: Commercial File Maintenance and Recordkeeping Policy
  • Section 9: Procedure for Managing Analytical Complaints
  • Section 10: Whistleblowing Policy and Procedure
  • Section 10.1 Policy Statement
  • Section 10.2 What is whistleblowing?
  • Section 10.3. Who does the policy apply to?
  • Section 10.4. The Whistleblowing Procedure