Policy on Review/ Appeal of Ratings by Rated Entities

Objective & Scope

Brickwork Ratings (BWR) is committed to maintaining independence, transparency, and analytical integrity in its credit rating process. This policy governs how a rated entity (issuer/client) may appeal a rating decision, whether for an initial rating or a periodic surveillance review, in accordance with the regulatory framework established by the Securities and Exchange Board of India (SEBI).

Eligibility & Basis for Appeal

1. A rated entity that disagrees with a credit rating decision or the rating rationale provided by BWR has the right to request a formal review.
2. An appeal request must be accompanied by new or additional relevant information supported by adequate documentation. The information submitted must be material to the rating evaluation and directly address the specific key factors or analytical drivers impacting the rating outcome.
3. Appeal requests may not be entertained under the following circumstances:
   1. No additional or new material information is provided by the rated entity
   2. The additional information provided is unlikely to impact the rating decision.
   3. The appeal request is determined to be submitted solely for delaying the publication of the rating action.
4. An appeal request for a rating decision will be accepted only once and is granted at the sole discretion of BWR.

Submission Timelines & Requirements

Appeal requests and supporting documents must be submitted in writing (via an authorized signatory letter or official email using the template in Annexure A) within the following timelines:

Appeal Review Process

To ensure a fair and unbiased review, every appeal is evaluated in two stages by separate, independent committees:

Stage 1 - Appeal Screening Committee (ASC)

ASC handles the initial screening to evaluate whether the appeal meets basic eligibility criteria before it can be forwarded to the Appeal Committee.

1. Composed of two senior rating officers, who decide whether to accept or reject the appeal request. These members must not have been involved in assigning the original rating.
2. In the event of any disagreement among ASC members, the appeal is escalated to the Chief Ratings Officer (CRO) or a designated senior analyst who was not involved in the original rating decision.

Stage 2 - Appeal Committee

This committee serves as the final authority to review admitted appeal requests. Its decision is final and binding on the rated entity.

1. Composed mostly of members separate from the original Rating Committee, with at least one- third being external members.
2. Requires a quorum of three members.
3. Allows the rated entity an opportunity to present its views directly to the committee, upon request.

Publication of Appeal Outcomes

The publication of ratings decisions after an appeal must strictly adhere to the following regulatory timelines:

1. Accepted Ratings:

   1. When the client accepts the appeal outcome, BWR must publish the Rating Rationale on its website within 2 working days from the date of acceptance.

2. Non-Accepted Initial Ratings:

   1. If the client does not accept the initial rating following the appeal (or if the appeal is rejected by the ASC), the rating is disclosed under the “Non-Accepted Ratings” section of the website within regulatory timelines, typically within one (1) month from the date of initial communication of the draft rationale.

3. Surveillance Ratings & Security Receipts:

   1. For surveillance ratings, issuer acceptance is not required. Ratings and rationales are published within seven (7) working days of the original Rating Committee meeting, regardless of acceptance status.

   2. For Security Receipt (SR) ratings, appropriate rating letters or reaffirmation notices are communicated to the client in accordance with applicable regulatory guidelines.

Annexure A - Format for Appeal Request

Subject: Appeal Request for Rating Decision – [Company Name] | [BLR / NCD / Instrument Type]

To: [Lead Analyst]

CC: [Sector Head, BCRISP]

Dear Sir/Madam,

Ref: Credit Rating Decision for [Company Name] communicated on [Date of Email]

We request a formal review/appeal of the credit rating decision referenced above. To assist the Appeal Screening Committee, our additional information and supporting evidence are summarized below:

We request the committee to consider these additional details and re-evaluate the assigned rating.

Thank you.

Best regards,

[Authorized Signatory Name]

[Designation]