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Complaints and Reasoned Concerns Handling Framework

Morningstar Sustainalytics is committed to dealing fairly with prospects, clients, vendors, and other stakeholders, without bias or discrimination, and complying with applicable laws and regulations in the jurisdictions in which it operates.

To support those commitments, it has established a Complaints and Reasoned Concerns Handling Global Policy.

This Policy sets out the reporting channels and roles and responsibilities for the timely and fair investigation and resolution of Complaints and Reasoned Concerns.

This is underpinned by the principles of objectivity, independence, fairness, transparency of process, integrity, and, where practical and appropriate, confidentiality.

1. What is in scope?

Information provided herein applies to Morningstar Sustainalytics products and services and to all Morningstar Sustainalytics Covered Personnel globally.

2. What may be considered a Complaint?

Any Relevant Communication may constitute a Complaint.

Relevant Communication means any verbal or written communication by a natural or legal person, which is addressed to Morningstar Sustainalytics, received through dedicated or non-dedicated reporting channels, and which expresses dissatisfaction or concern(s) about an ESG rating.

Complaint means a Relevant Communication from an Eligible Complainant in respect of the following:

  • the sources of data used for an individual ESG rating, factual errors and mistakes;
  • the way in which the rating methodology in relation to an individual ESG rating has been applied;
  • whether an individual ESG rating is representative of the rated item or the issuer of the rated item.

What is not a Complaint?

Any communication received through the dedicated or non-dedicated reporting channels that has been analyzed and that does not meet any of the elements above to be classified as a Complaint.

Examples of what is not a Complaint:
  1. General disagreement with certain products/services and their methodologies/models, including ESG Ratings;
  2. Advice on products/services improvement and enhancements, including ESG Ratings;
  3. Inquiries on the performance of products/services, including ESG Ratings.
  4. Applications defects (i.e., disruption or issue of applications), including those used in relation to the provision of ESG Ratings.

3. Who can send a Complaint?

A Complaint can be addressed to Morningstar Sustainalytics by an Eligible Complainant.

Eligible Complainant means a natural or legal person qualifying as (i) a licensed user of an ESG rating, (ii) a rated item to which an ESG rating relates, or (iii) an issuer of the rated item to which an ESG rating relates.

4. Where can a Complaint be sent?

  1. By email at [email protected].
  2. Online or by phone, through Morningstar Ethics Hotline available at https://secure.ethicspoint.com/domain/media/en/gui/82848/index.html

For anonymous Complaints, the Morningstar Ethics Hotline should be used: Morningstar Code of Ethics (Board Approved Effective 6.1.25).pdf.

5. Ombudsperson Services

As part of its complaints handling framework, Morningstar Sustainalytics has appointed an Ombudsperson who is independent of it and its business. The role of the Ombudsperson is to engage with certain third parties avail themselves of the Ombudsperson services, to facilitate the resolution of any complaints or inquiries from such third parties and to act as a liaison between such third parties and Morningstar Sustainalytics in connection with such resolution.

Ombudsperson services are available to a third party that is not a researched company or a company with which Morningstar Sustainalytics engages in any capacity for the provision of its products or services, a current, former or prospective customer of Morningstar Sustainalytics or a party with unauthorized access to Morningstar Sustainalytics research, products or services.

Any such third party may avail itself of Ombudsperson services by emailing [email protected], following which the Ombudsperson will determine if the matter is one that is appropriate for the Ombudsperson services or should be otherwise handled.

6. No Retaliation

Retaliation against any Sender is strictly prohibited. Sending a Relevant Communication will not have any negative effect on how Morningstar Sustainalytics performs research or engages with a Sender, if applicable, nor on how it will provide its products and services to the Sender.

Sender means any natural or legal person who sends a Relevant Communication.

7. Confidentiality

All Complaints and Reasoned Concerns are treated confidentially, and investigations are undertaken in accordance with the need-to-know principle.

8. More information about this Policy

For more information on how Complaints are managed by Morningstar Sustainalytics, please contact the Compliance Team of Morningstar Sustainalytics by sending an email to [email protected].