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MAS Publishes Code Of Conduct For Providers Of ESG Rating And Data Products

The Monetary Authority of Singapore (MAS) has published its finalised Code of Conduct for ESG (environmental, social and governance) Rating and Data Product Providers (CoC), and an accompanying Checklist for providers to self-attest their compliance to the CoC (Checklist), following a public consultation conducted from June to August 2023.

The CoC aims to establish baseline industry standards for transparency in methodologies and data sources, governance, and management of conflicts of interest that may compromise the reliability and independence of the products. It builds upon the International Organisation of Securities Commissions’ (“IOSCO”) recommendations for good practices for such providers. Respondents to the consultation have expressed strong support for the CoC. Users also agree that providers’ self-attestation on the Checklist should, where feasible, undergo third-party assurance or audit.

MAS encourages providers to disclose their adoption of the CoC and publish their completed Checklist within 12 months from publication of the CoC. To enable users to easily identify providers which have publicly adopted the CoC, MAS has worked with the International Capital Market Association1 (“ICMA”) to host a list of such providers on ICMA’s website.

“The Code of Conduct will help build market confidence in the use of ESG rating and data products,” says Lim Tuang Lee, Assistant Managing Director (Capital Markets), MAS. “Its baseline transparency standards for rating methodologies and data sources will improve the comparability of ratings and data products. The Code also encourages disclosures on how forward-looking elements are considered in such products, which will improve investors’ assessments of investee entities’ responses to transition risks and opportunities.”

“Overall, the Code will support informed decision making by investors keen on funding the climate transition. We welcome adoption by ESG rating and data product providers as soon as they are ready,” adds Mr Lim.

MAS will continue to monitor developments in the industry and the global regulatory landscape when considering any further enhancements to the regulatory regime for such providers.


The Checklist, labelled as “Annex D”, is available on the MAS website.

According to the instructions, the Checklist guides the posture of, and progress on full compliance with the Code. ESG rating and data product providers are encouraged to disclose, in detail, their compliance to each best practice; publish the Checklist on their websites for their self-attestation; and update ICMA via email.

ICMA will host the list of providers which have adopted the Code on its website. The Checklist is designed to clearly identify (i) the good practices set out in IOSCO’s Call for Action Paper 2, and (ii) the additional Singapore-specific best practices (highlighted in yellow in the Checklist). This enables providers to use the Checklist for cross-jurisdictional comparison of standards for their operations, which facilitates interoperability with the codes of conduct in other jurisdictions.

1 ICMA, a not-for-profit membership association, promotes well-functioning cross-border capital markets. It provides industry-driven standards and recommendations. It also works with regulatory and governmental authorities to support financial regulation with the objective of promoting stable and efficient capital markets.

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