Morningstar Sustainalytics is committed to fair dealing with its customers, prospective customers, vendors, and other stakeholders, without bias or discrimination and complying with applicable global and regional laws and regulations in the jurisdictions in which it operates.
To support those commitments, it has established a Complaints Handling Policy that implements appropriate reporting channels and designates the teams and functions responsible for providing support so that unethical, illegal, or non-compliant activities are identified, investigated, addressed and remediated.
1. What is in scope?
Information provided herein applies to Morningstar Sustainalytics products and services and to all Morningstar Sustainalytics personnel.
2. What may be considered a Complaint?
Any relevant communication received through the relevant reporting channels, other than matters relating to litigation, arbitration, other legal proceedings, or communications from government agencies, regulatory authorities or legislative bodies (each in such capacity), that has been analyzed by the examiner, in consultation with the Chief Compliance Officer of Morningstar Sustainalyitcs (CCO), and determined to be a Complaint.
Complaint means any relevant communication received by Morningstar Sustainalytics containing an allegation of:
- a business practice or conduct by Morningstar Sustainalytics personnel not complying with Morningstar Code of Ethics, or
- a breach or failure by Morningstar Sustainalytics:
a. to adhere to the applicable Morningstar Sustainalytics methodologies in connection with one or more of its products, or
b. to comply with applicable laws or any Morningstar Sustainalytics policies and procedures, including those on avoidance and management of potential conflicts of interest, protection of confidential information, destruction or falsification of business records.
What is not a Complaint?
Any communication received through the relevant 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:
- Inquiries or questions about the performance of Morningstar Sustainalytics products, services and delivery channels
- Employment-related issues such as disagreements between colleagues or between Morningstar Sustainalytics personnel and their manager regarding compensation arrangements, time off requests or similar matters.
3. Who can send a Complaint?
The following parties can address a Complaint to Morningstar Sustainalytics:
- a researched company or a company with which Morningstar Sustainalytics engages in any capacity for the provision of its products or services
- a prospective, current, or former client of Morningstar Sustainalytics
- a current vendor or supplier of Morningstar Sustainalytics
- Morningstar Sustainalytics personnel
- a non-governmental organization and trade association
- a market participant with access to Morningstar Sustainalytics research
- any other stakeholder, other than a government agency, regulatory authority or legislative body (each in such capacity)
4. Where can a Complaint be sent?
- By email at [email protected].
- 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.
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
Sending a Complaint through any channel will not have any negative effect on how Morningstar Sustainalytics performs research or engages with the sender, if applicable, nor on how it will provide its products and services to the sender. Retaliation against a sender is strictly prohibited, even if the investigation concludes no wrongdoing has occurred.
7. 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].