Rating Action: Moody's affirms Iceland's rating at A2, stable outlook
20 Aug 2021
London, 20 August 2021 -- Moody's Investors Service ("Moody's") has today affirmed the government of
Iceland's local and foreign-currency issuer rating at A2. The senior unsecured foreign-currency rating has also
been affirmed at A2, and the foreign-currency senior unsecured MTN program has been affirmed at (P)A2. The
outlook on the ratings remains stable.
The rating affirmation at A2 balances the following key drivers:
1. The Icelandic economy is expected to post a solid recovery helped by a strong and pro-active policy
response; over the coming years economic growth will be supported by strong investment and the continuing
recovery in the tourism sector;
2. Institutions have been strengthened significantly and their credibility has materially improved over the past
years; Moody's considers this driver to be a Governance consideration under its ESG framework;
3. The limited diversification of the economy due to its small size implies a high growth volatility and exposure
to sector-specific shocks; while diversification efforts are ongoing this is unlikely to materially change over the
coming years.
The stable outlook reflects broadly balanced risks. Apart from a solid economic recovery and a robust growth
outlook, the government's strong track record on debt reduction gives confidence that it will manage to reverse
the pandemic-induced fiscal deterioration over the coming years. Moreover, Iceland's relatively high public
debt level is partly the result of an accounting reclassification in late 2020, which does not change thegovernment's fundamental fiscal profile.
The local-currency ceilings remain unchanged at Aa1, set at four notches above the sovereign rating. The Aa1
local currency ceiling balances Iceland's very predictable and reliable institutions, low political risk and external
imbalances and the relatively moderate footprint of the government in the economy with a very volatilecurrency. Its volatility exposes all issuers in the country to a higher level of exchange rate risks than is standard
in most other advanced economies. Similarly, the limited diversification of the economy leads to a higher
exposure to sector-specific shocks than in many other countries.
The foreign-currency ceilings have been raised to Aa2 from Aa3, to reflect the full abolition of capital controls
with the updated Foreign Currency Act No 70/2021 in late June 2021. That said, Moody's maintains a onenotch gap between the local currency and the foreign currency ceiling because the Central Bank of Iceland(CBI) retains the option to reintroduce capital controls in an emergency situation in order to maintain economic
and financial stability. As such, capital controls remain as a policy option in a situation of extreme stress.
RATINGS RATIONALERATIONALE FOR AFFIRMING THE A2 RATINGSOLID ECONOMIC RECOVERY HELPED BY STRONG AND PRO-ACTIVE POLICY RESPONSE
The first driver relates to Iceland's solid economic recovery helped by a strong and pro-active policy response,
and the country's robust medium-term growth prospects. Iceland was hit hard by the collapse in tourism lastyear, recording a contraction in real GDP of 6.6%. That said, the contraction was less severe than initiallyfeared as other sectors of the economy proved more resilient. The economy is now showing signs of recovery,
supported by the authorities' large and swift policy action as well as a recovery in the tourism sector.
The Icelandic authorities used all available levers to support household incomes, protect employment andprovide liquidity to enterprises in a coordinated and swift manner. The overall fiscal response is estimated by
the International Monetary Fund (IMF) at over 9% of GDP, larger than in many other high-income countries,
and many measures have been extended -- albeit in a more targeted fashion - until later this year. Other
supportive measures include the central bank's monetary easing and regulatory measures to keep credit
flowing. In contrast to the 2008 crisis, the Icelandic currency stabilized quickly and financial conditions

remained favourable. The current account remained in a small surplus.
As of Q1 2021, private consumption was nearly 10% higher than at the trough in Q2 2020 in real terms, helpedby the above-mentioned measures but also real wage increases of around 6% due to pre-pandemic wage
agreements and tax cuts. Unemployment has started to decline again in recent months although it remains
elevated for Icelandic standards at 6.1% in July (in non-seasonally adjusted terms) compared to the peak of
11.6% in January and 3.6% on average between 2015 and 2019. Moody's expects real GDP growth of 3.4%
this year, accelerating to around 5% in 2022. Over the coming years, the Icelandic economy will benefit fromstrong investment, helped by the large public investment programme and tax incentives for private investment,in particular for R&D. The continuing recovery in the tourism sector should also support GDP growth.
Iceland could afford such a large and swift response because it had accumulated significant buffers in theyears prior to the pandemic, including low government debt (at below 30% of GDP in 2019) and overallbudgetary surpluses in most years between 2014 and 2018. Moreover, the very large foreign-currency
reserves at the central bank -- of around 26% of GDP -- allowed the central bank to contain currency volatility
while accommodating capital outflows from foreign investors which amounted to around 2.6% of GDP between
March and December 2020. The country's pension funds refrained from investments abroad between midMarch and mid-September 2020, to support the central bank's effort at limiting currency volatility. The verylarge pension savings, amounting to close to 200% of GDP, provide an important buffer for households in a
shock. The government authorized a temporary withdrawal from voluntary third-pillar pension savings,
amounting to around 0.9% of GDP last year and somewhat less this year in support of household incomes andconsumption.
SIGNIFICANTLY STRENGTHENED INSTITUTIONS WHICH HAVE GAINED CREDIBILITY IN PAST YEARSThe second driver for the rating affirmation is the significant strengthening of Iceland's institutions over the past
several years, which Moody's expects to be maintained in the coming years. Most recently, Iceland's
institutions have proven their solidity in the pandemic with a well-thought out and coordinated policy response
from the government, central bank and other key economic actors. The response to preserve public health was
exemplary with fast containment measures, solid progress on vaccination and transparent policies andguidelines. In recent weeks, cases have risen again though, similar to other countries.
Following wholesale changes in banking supervision and regulation and an overhaul of the monetary policy
framework and governance at the CBI in the wake of the 2008 banking crisis, the central bank's credibility has
materially improved. Longer-term inflation expectations are well anchored, notwithstanding the recent
acceleration in inflation above the upper target threshold of 4%. In the broader context, inflation has beenclose to target since 2014, in sharp contrast to Iceland's historic inflation performance. The CBI has beeneffective in limiting ISK volatility, while successfully managing the full liberalization of the capital accountwithout disruptive capital outflows.
In early 2020, the banking regulator was merged with the CBI, with the aim to achieve greater efficiency,
operational independence, and powers in financial oversight. Macro-prudential tools are actively used andcontribute to financial stability, such as strong capital and liquidity buffers for banks (including a countercyclicalcapital buffer, which has been reduced to zero last year), limits on foreign currency exposure of bank balance
sheets, a loan-to-value limit for mortgages, and restrictions on foreign currency borrowing by unhedged
domestic agents.
In a similar vein, fiscal policy credibility has materially improved in recent years, with the largest reduction in
public debt in Europe between 2011 and 2019 on the back of primary surpluses since 2012, and theintroduction of transparent and credible fiscal rules in 2015. Last autumn, parliament authorized the temporary
suspension of the rules until 2025, and the government continues to provide targeted fiscal support this year todeal with the economic fallout of the pandemic. That said, the government has already presented andparliament approved a medium-term fiscal strategy to reduce the budget deficit significantly from 2022
onwards and to stabilize the net public debt ratio by 2025 at around 54% of GDP, which shows that the fiscal
rules provide an important medium-term anchor for Iceland's fiscal policy. The rules are supported across thepolitical spectrum, giving confidence that the current fiscal deterioration and debt increase will again bereversed over the coming years. Also, the revenue and spending measures required for the fiscal consolidation
plan are manageable.
LIMITED ECONOMIC DIVERSIFICATION WHICH IMPLIES CONTINUED HIGH GROWTH VOLATILITY ANDEXPOSURE TO SECTOR-SPECIFIC SHOCKSThe third driver of today's rating affirmation is Moody's view that Iceland's structural economic constraints areunlikely to change materially over the medium term, namely the concentration on a limited number of sectors todrive economic growth. Tourism, fishing and aluminium smelting together accounted for 75% of total exports
and 14% of Gross Value Added before the pandemic (2019 data).
The economy is among the smallest in our rated universe with a nominal GDP of just below $22 billion in 2020,
and its limited diversification leads to high growth volatility and makes the country vulnerable to sector-specificshocks. Iceland represents the smallest currency area in the world, exposing the economy to the risk of highexchange rate volatility and imported inflation, although these risks are well understood by the authorities andeffectively managed.
That said, the government has outlined an ambitious public investment programme, amounting to around 0.5%
of GDP per year over the 2020-2025 period. Its overarching aim is to help the economy diversify and transition
to a knowledge-based economy, emphasizing biotechnology, aquaculture and information technology andcommunication. Iceland has a tradition in the first two, with exports growing vigorously in both sectors over the
past few years. For the latter, a key comparative advantage is Iceland's cheap renewable energy and cool,windy climate which is important for data processing and storage.
The IMF notes that Iceland is well ahead of many other advanced economies in terms of digital skills,
infrastructure and ICT adoption, and thus has scope to boost value added in ICT sectors further. The
government's tax incentives for private-sector R&D investment and the recently created public venture capitalfund should also help in this regard.
RATIONALE FOR STABLE OUTLOOKThe stable outlook reflects broadly balanced risks. Firstly, last year's contraction was less severe than initiallyfeared also because other key sectors beyond tourism of the economy proved more resilient. That said, theIcelandic economy was hit hard by the collapse in tourism last year; the sector accounted for 40% of export
revenues and 14% of employment prior to the pandemic, but is recovering now. Tourist arrivals have been
rising lately -- helped by a successful vaccination campaign and the early reopening to its main markets. Yet, afull recovery of the sector and the economy at large will likely only happen next year and rising infection rates
in key countries of origin remain a key risk.
Secondly, the government's strong track record on debt reduction gives confidence that it will manage toreverse the pandemic-induced fiscal deterioration and debt increase again over the coming years. Iceland's
public debt ratio remains higher than similarly rated peers at 79.9% of GDP as of end-2020, having risen by 11
percentage points of GDP last year. But the high debt level is to an important extent due to the reclassificationof 24 public companies' debt into general government debt implemented in late 2020, which raised thegovernment debt ratio by around 32 percentage points of GDP. Prior to the reclassification Iceland's public
debt burden was below 30% of GDP and had declined by over 70 percentage points of GDP between the peakin 2011 and 2018, one of the largest debt reductions globally. The risks associated with this additional debt
now captured are low and had already been incorporated into Moody's analysis as contingent liabilities.
While the government's plan for a large public investment programme and tax cuts will keep the budget deficit
elevated this year at close to 10% of GDP, Moody's expects the public debt ratio to start declining from 2023
onwards, on the back of solid fiscal consolidation efforts and robust GDP growth.
ENVIRONMENTAL, SOCIAL, GOVERNANCE CONSIDERATIONS
Iceland's ESG Credit Impact Score is neutral to low (CIS-2), reflecting moderate exposure to environmental
risk which is balanced by neutral-to-low exposure to social risks and very strong institutions which also
contribute to its relatively strong resilience to E and S risks.
Iceland's overall E issuer profile score is moderately negative (E-3) and primarily reflects that the economy
relies to an important extent on its unique geological features, particularly its key sectors of tourism and fishing,which exposes its credit profile to physical climate risks. The presence of active volcanoes on the island helps
to attract tourism but could potentially also disrupt economic activity. Furthermore, warming seas can lead tothe possible migration of fish stocks outside of Iceland's waters, as seen with the decline in valuable capelinfish stocks in 2019. However, Iceland's effective management of its fish stocks -- including temporary
suspension of fishing quotas to help stocks recover -- is an important mitigating factor. Around 11% of
Iceland's land mass consists of glaciers which also exposes the country to risks from rising temperatures. Its
overall E issuer profile score is therefore moderately negative (E-3).

Iceland has pledged to fulfil the EU emission reduction target of 55% below 1990 levels by 2030 and achievecarbon neutrality by 2040. However, greenhouse gas emissions are higher than in comparable EU countries in
per-capita terms, with aluminium-related industries the largest source of greenhouse gases. The government
has announced a climate action plan which emphasized clean transport, technologies for carbon capture andtax incentives for low-emission vehicles, among others.
Moody's assesses Iceland's S issuer profile score as neutral to low (S-2). The country's demographic profile ismore favourable than in many other advanced nations — particularly in continental Europe — because of
exceptionally long working lives, higher fertility rates, high share of women who work and the flexibility of thelabour force. Iceland also benefits from high-quality education, high housing availability, and good quality
healthcare and basic services. That said, social risks exert themselves through intensive wage negotiations
between employers and trade unions every four years which can impact on Iceland's competitiveness.
Iceland's very high institutions and governance strength is reflected in a positive G issuer profile score (G-1).
This is underpinned by its strong scores in most of the Worldwide Governance Indicators, which reflects thehigh credibility of its institutions and the country's well-developed macroeconomic policy environment. This
contributes to its relatively strong resilience to E and S risks, along with very high wealth levels.
GDP per capita (PPP basis, US$): 55,966 (2020 Actual) (also known as Per Capita Income)Real GDP growth (% change): -6.6% (2020 Actual) (also known as GDP Growth)
Inflation Rate (CPI, % change Dec/Dec): 3.6% (2020 Actual)Gen. Gov. Financial Balance/GDP: -7.3% (2020 Actual) (also known as Fiscal Balance)
Current Account Balance/GDP: 1.1% (2020 Actual) (also known as External Balance)
External debt/GDP: [not available]
Economic resiliency: a2
Default history: No default events (on bonds or loans) have been recorded since 1983.
On 17 August 2021, a rating committee was called to discuss the rating of the Iceland, Government of. The
main points raised during the discussion were: The issuer's economic fundamentals, including its economic
strength, have not materially changed. The issuer's institutions and governance strength, has somewhat
increased. The issuer's fiscal or financial strength, including its debt profile, has decreased. The issuer has
become less susceptible to event risks.
FACTORS THAT COULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATINGS
WHAT COULD CHANGE THE RATINGS UP
The outlook on Iceland's rating could move to positive and the rating could eventually be upgraded in case of
faster-than-expected progress in restoring the government's fiscal buffers. Moreover, a push towards increased
diversification which would lead to a less volatile economic performance would be positive for the rating.
WHAT COULD CHANGE THE RATING DOWN
Conversely, outlook and rating would come under downward pressure if the authorities deviated significantly
from their current medium-term fiscal consolidation plans that target a stabilisation of the public debt ratio by
the middle of the decade, resulting in a material increase in the public debt ratio. An economic shock which
would lead to a large and permanent damage to the tourism industry, or to substantial capital outflows,
weakening Iceland's external position and threatening financial stability, would also be credit negative,
although the latter is not a likely scenario.
The principal methodology used in these ratings was Sovereign Ratings Methodology published in November
2019 and available at https://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1158631 .
Alternatively, please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.
The weighting of all rating factors is described in the methodology used in this credit rating action, if applicable.
REGULATORY DISCLOSURES

For further specification of Moody's key rating assumptions and sensitivity analysis, see the sections
Methodology Assumptions and Sensitivity to Assumptions in the disclosure form. Moody's Rating Symbols andDefinitions can be found at: https://www.moodys.com/researchdocumentcontentpage.aspx?
docid=PBC_79004.
For ratings issued on a program, series, category/class of debt or security this announcement provides certain
regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series,
category/class of debt, security or pursuant to a program for which the ratings are derived exclusively fromexisting ratings in accordance with Moody's rating practices. For ratings issued on a support provider, thisannouncement provides certain regulatory disclosures in relation to the credit rating action on the support
provider and in relation to each particular credit rating action for securities that derive their credit ratings fromthe support provider's credit rating. For provisional ratings, this announcement provides certain regulatory
disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be
assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms
have not changed prior to the assignment of the definitive rating in a manner that would have affected therating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on
www.moodys.com.
For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of thiscredit rating action, and whose ratings may change as a result of this credit rating action, the associatedregulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following
disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated
entity.
The ratings have been disclosed to the rated entity or its designated agent(s) and issued with no amendment
resulting from that disclosure.
These ratings are solicited. Please refer to Moody's Policy for Designating and Assigning Unsolicited Credit
Ratings available on its website www.moodys.com.
Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related
rating outlook or rating review.
Moody's general principles for assessing environmental, social and governance (ESG) risks in our credit
analysis can be found at http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBC_1288435 .
At least one ESG consideration was material to the credit rating action(s) announced and described above.
The Global Scale Credit Rating on this Credit Rating Announcement was issued by one of Moody's affiliates
outside the EU and is endorsed by Moody's Deutschland GmbH, An der Welle 5, Frankfurt am Main 60322,
Germany, in accordance with Art.4 paragraph 3 of the Regulation (EC) No 1060/2009 on Credit Rating
Agencies. Further information on the EU endorsement status and on the Moody's office that issued the credit
rating is available on www.moodys.com.
Please see www.moodys.com for any updates on changes to the lead rating analyst and to the Moody's legal
entity that has issued the rating.
Please see the ratings tab on the issuer/entity page on www.moodys.com for additional regulatory disclosuresfor each credit rating.
Kathrin Muehlbronner
Senior Vice President
Sovereign Risk Group
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454
Alejandro Olivo
Associate Managing Director

Sovereign Risk GroupJOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653
Releasing Office:
Moody's Investors Service Ltd.
One Canada Square
Canary Wharf
London E14 5FA
United Kingdom
JOURNALISTS: 44 20 7772 5456
Client Service: 44 20 7772 5454

© 2021 Moody’s Corporation, Moody’s Investors Service, Inc., Moody’s Analytics, Inc. and/or their licensors andaffiliates (collectively, “MOODY’S”). All rights reserved.

CREDIT RATINGS ISSUED BY MOODY'S CREDIT RATINGS AFFILIATES ARE THEIR CURRENTOPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR
DEBT OR DEBT-LIKE SECURITIES, AND MATERIALS, PRODUCTS, SERVICES AND
INFORMATION PUBLISHED BY MOODY’S (COLLECTIVELY, “PUBLICATIONS”) MAY INCLUDE
SUCH CURRENT OPINIONS. MOODY’S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY
MAY NOT MEET ITS CONTRACTUAL FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY
ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT OR IMPAIRMENT. SEE APPLICABLE
MOODY’S RATING SYMBOLS AND DEFINITIONS PUBLICATION FOR INFORMATION ON THE
TYPES OF CONTRACTUAL FINANCIAL OBLIGATIONS ADDRESSED BY MOODY’S CREDITRATINGS. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT
LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS,NON-CREDIT ASSESSMENTS (“ASSESSMENTS”), AND OTHER OPINIONS INCLUDED IN
MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT.
MOODY’S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF
CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY’SANALYTICS, INC. AND/OR ITS AFFILIATES. MOODY’S CREDIT RATINGS, ASSESSMENTS,
OTHER OPINIONS AND PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR
FINANCIAL ADVICE, AND MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND
PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL,OR HOLD PARTICULAR SECURITIES. MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER
OPINIONS AND PUBLICATIONS DO NOT COMMENT ON THE SUITABILITY OF AN INVESTMENT
FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS, ASSESSMENTS
AND OTHER OPINIONS AND PUBLISHES ITS PUBLICATIONS WITH THE EXPECTATION AND
UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY ANDEVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE,HOLDING, OR SALE.
MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS, AND PUBLICATIONS ARE NOTINTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FORRETAIL INVESTORS TO USE MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS OR
PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACTYOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER.
ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO,
COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE
REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED,REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN
WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSONWITHOUT MOODY’S PRIOR WRITTEN CONSENT.

MOODY’S CREDIT RATINGS, ASSESSMENTS, OTHER OPINIONS AND PUBLICATIONS ARE NOTINTENDED FOR USE BY ANY PERSON AS A BENCHMARK AS THAT TERM IS DEFINED FOR
REGULATORY PURPOSES AND MUST NOT BE USED IN ANY WAY THAT COULD RESULT IN THEM
BEING CONSIDERED A BENCHMARK.
All information contained herein is obtained by MOODY’S from sources believed by it to be accurate andreliable. Because of the possibility of human or mechanical error as well as other factors, however, allinformation contained herein is provided “AS IS” without warranty of any kind. MOODY'S adopts all necessary
measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources
MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However,
MOODY’S is not an auditor and cannot in every instance independently verify or validate information received
in the rating process or in preparing its Publications.
To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives,
licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or
incidental losses or damages whatsoever arising from or in connection with the information contained herein or
the use of or inability to use any such information, even if MOODY’S or any of its directors, officers, employees,
agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses ordamages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage
arising where the relevant financial instrument is not the subject of a particular credit rating assigned by
MOODY’S.
To the extent permitted by law, MOODY’S and its directors, officers, employees, agents, representatives,
licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any
person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any
other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any
contingency within or beyond the control of, MOODY’S or any of its directors, officers, employees, agents,
representatives, licensors or suppliers, arising from or in connection with the information contained herein or theuse of or inability to use any such information.
NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS,
MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY CREDIT RATING,ASSESSMENT, OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY’S IN ANY FORM OR
MANNER WHATSOEVER.
Moody’s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody’s Corporation(“MCO”), hereby discloses that most issuers of debt securities (including corporate and municipal bonds,
debentures, notes and commercial paper) and preferred stock rated by Moody’s Investors Service, Inc. have,prior to assignment of any credit rating, agreed to pay to Moody’s Investors Service, Inc. for credit ratings
opinions and services rendered by it fees ranging from $1,000 to approximately $5,000,000. MCO and Moody’s
Investors Service also maintain policies and procedures to address the independence of Moody’s InvestorsService credit ratings and credit rating processes. Information regarding certain affiliations that may exist
between directors of MCO and rated entities, and between entities who hold credit ratings from Moody’s
Investors Service and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, isposted annually at www.moodys.com under the heading “Investor Relations — Corporate Governance —Director and Shareholder Affiliation Policy.”
Additional terms for Australia only: Any publication into Australia of this document is pursuant to the AustralianFinancial Services License of MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399
657AFSL 336969 and/or Moody’s Analytics Australia Pty Ltd ABN 94 105 136 972 AFSL 383569 (asapplicable). This document is intended to be provided only to “wholesale clients” within the meaning of section
761G of the Corporations Act 2001. By continuing to access this document from within Australia, you represent
to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and thatneither you nor the entity you represent will directly or indirectly disseminate this document or its contents to“retail clients” within the meaning of section 761G of the Corporations Act 2001. MOODY’S credit rating is an
opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or
any form of security that is available to retail investors.
Additional terms for Japan only: Moody's Japan K.K. (“MJKK”) is a wholly-owned credit rating agency subsidiaryof Moody's Group Japan G.K., which is wholly-owned by Moody’s Overseas Holdings Inc., a wholly-owned
subsidiary of MCO. Moody’s SF Japan K.K. (“MSFJ”) is a wholly-owned credit rating agency subsidiary ofMJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization (“NRSRO”). Therefore, credit
ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by anentity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment
under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services
Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively.
MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate andmunicipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (asapplicable) have, prior to assignment of any credit rating, agreed to pay to MJKK or MSFJ (as applicable) for
credit ratings opinions and services rendered by it fees ranging from JPY125,000 to approximately
JPY550,000,000.
MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements.