This Code of Conduct has been created by an industry-led working group and was launched on 14 December 2023. It is grounded in the recommendations published by the International Organization of Securities Commissions (IOSCO), with a focus on promoting transparency, good governance, management of conflicts of interest, and robust systems and controls. As such, it is intended to be internationally interoperable and could be used by jurisdictions where no local Code or regulation is in place.
Signing up to and applying the Code of Conduct
- Signing up to the Code (expressing the intention to apply the Code)
Following the launch in December 2023, providers are encouraged to sign up to this voluntary Code by notifying ICMA via ESGCode@icmagroup.org. In addition, providers might want to announce this on their website.
- Applying the Code
Once an ESG ratings and/or data products provider has signed up to the Code of Conduct, this will be followed by an implementation period*. At the end of this period, providers are expected to publish a statement of how they have applied the Code (“Statement of Application”) on their website and to notify ICMA about this via ESGCode@icmagroup.org providing the following information in the email:
- Name of the organisation
- Area(s) of application (ESG ratings and/or data products)
- Preparer(s) of the statement (name, title, role, contact information)
- The URL where the statement of application is published
The Statement of Application should be reviewed at least annually (updating it where appropriate).
*The implementation period for ESG ratings providers is six months and the implementation period for ESG data products providers is twelve months. At the end of this, the Code should be embedded within the provider’s organisation.
ICMA is compiling the list of signatories and once received, including links to the annual statements published on the providers’ websites.
Due to the voluntary nature of the Code, there is no specific format for the Annual Statement of Application that providers should follow. However, signatories are expected to publish a statement explaining their approach to the implementation of the six Principles of the Code of Conduct.
On 31 January 2024, the market welcomed the December 2023 launch of the Code of Conduct with a hybrid event at the London Stock Exchange Group. The event started with a keynote from IOSCO and featured two panels: one on “The Code in Practice” and a second one on “The International Context”. Regulators from the FCA, JFSA and MAS participated in the latter one.
The recording of the launch event is available here.
List of providers who signed up to the Code of Conduct for ESG ratings and data products providers*
Providers who signed up to the Code are listed below (links to the providers’ websites will be added once Statements of Application become available).
- Clarity AI
- ESGi Global
- ESG Book
- London Stock Exchange Group (LSEG)
- MSCI ESG Research
- S&P Global Sustainable1
- Vested Impact
*Please note that ICMA does not investigate or confirm adoption of the Code of Conduct for ESG ratings and data products providers, nor does it recommend, endorse or make any representations regarding the ESG ratings and data products providers listed above.
For further information, please contact ICMA via ESGCode@icmagroup.org.
Following the release of the IOSCO report on ESG ratings and data products providers in November 2021, the FCA appointed, in 2022, ICMA and the International Regulatory Strategy Group (IRSG) to convene an industry group to develop a globally consistent voluntary Code under a joint Secretariat. An initial draft of the Code was published on 5 July 2023 which was then followed by a 3-month consultation period. A feedback statement summarising the comments received during the public consultation as well as how they have been incorporated in the final Code, can be found here.
With publication of the final Code on 14 December 2023, ICMA assumed ownership.