PACRA Policy on Announcement and Dissemination of Ratings

Sr. # Contents Page #
1 Objective 1
2 Applicability 1
3 Standard Rating Announcement 1
4 Fair Disclosure 2
5 Dissemination | Timeliness & Mechanism 2 6 Tasks 4 7 Policy Administration 4 8 Regulatory Framework 5 THE PAKISTAN CREDIT RATING AGENCY LIMITED Awami Complex, FB-1, Usman Block, New Garden Town Lahore Phone: +92 42 3586 9504 - 6 Web: www.pacra.com Approved by Chief Executive Officer Approval Date July 28, 2025 Effective Date July 28, 2025 Signing Authority _________________________ USMAN HAIDER Chief Executive Officer POLICY | ANNOUNCEMENT / DISSEMINATION OF RATINGS

The Pakistan Credit Rating Agency Limited POLICY | ANNOUNCEMENT / DISSEMINATION OF RATING PACRA POLICY Page 1 of 5 July 2025 www.pacra.com

1. OBJECTIVE 1.1 To enable PACRA to publicly disseminate its Rating Actions in a manner
   facilitating fair disclosure and mitigating the risk of selective disclosure of the rating opinion.
   1.2 To oversee that all Public Ratings are announced / disseminated as per this
   Policy.
2. APPLICABILITY 2.1 This policy is applicable on Rating Analysts and MIT Function.
3. STANDARD
   RATING
   ANNOUNCEMENT
   3.1 Press Release: PACRA standard announcement / dissemination of Rating is
   a press release disseminated on PACRA’s website. A press release is required whenever PACRA takes a rating action for any of its public ratings including initial public ratings. Every press release contains at least the following information:
   i Date of press release. ii Contact details of rating analyst. iii Applicable criteria and web link thereon to instantly access the said document. iv Relevant sector study along with website link. v Rating rationale providing a ground/reasoning for allocated rating. Rating action pertaining to period under review and previous period. vi Long term rating of current and previous period. vii Short term rating of current and previous period. viii Outlook of current and previous period. ix An overview about the entity, fund or as the case may be. x A disclaimer which reads as follows; “This press release is being transmitted for the sole purpose of dissemination through print/electronic media. The press release may be used in full or in part without changing the meaning or context thereof with due credit to PACRA”
   3.2 Rating Report: PACRA supplements the Press Release with additional
   information on the Rating Action in a Rating Report released along with the Press Release. The Rating Report contains information under the following heads:
   i Rating Analysis:
   a. Rating History for at least five years in case of entity rating and for the full tenure in case of instrument rating b. Rating rationale and key rating drivers
   c. Brief assessment of rating factors
   ii Financial Information: Key financial information iii Rating Scale: Rating scale symbols and definitions iv Regulatory & Supplementary Disclosure: Disclosures as per SECP’s Credit Rating Companies Regulations, 2016, Chapter III | 14-3-(f)

The Pakistan Credit Rating Agency Limited POLICY | ANNOUNCEMENT / DISSEMINATION OF RATING PACRA POLICY Page 2 of 5 July 2025 www.pacra.com
4. FAIR
DISCLOSURE
4.1 Rating actions, before dissemination, are categorized as confidential
information. PACRA is committed to fair disclosure of such information. Public rating, that is required to be publicly disseminated, is notified to client through a formal letter along with respective press release and rating report. Dissemination of the same is achieved within one working day through the following:
i Disseminating the press release through the website for all users (PACRA website refreshes twice everyday once at 10:00AM and then at 5:00 PM). ii PACRA releases its Press Release to Associated Press of Pakistan and All Pakistan Newspapers Society. a. Regulation 14-(1) of the SECP Credit Rating Companies Regulations, 2016 requires PACRA to ensure dissemination through Associated Press of Pakistan and All Pakistan Newspapers Society. b. Regulation 14-(2) of the SECP Credit Rating Companies Regulations, 2016 requires PACRA to immediately disseminate all ratings to the securities exchanges, the State Bank of Pakistan, the Commission, Mutual Fund Association of Pakistan, Pakistan Banking Association, NBFI and Modaraba Association of Pakistan.
5. DISSEMINATION -
TIMELINES &
MECHANISM
5.1 Considerations: Key considerations regarding Dissemination of the various
kinds of Rating Actions are as follows:
5.1.1 Rating Actions include dissemination of maintain or change in
rating or rating modifiers.
Ref: Glossary (89): For definition of Rating Modifiers.
5.1.2 PACRA would immediately disseminates its opinion if it considers
conclusively that a Selective Disclosure has occurred.
“Def: Selective disclosure: Intentional or unintentional release of Confidential Information to a select individual / group.

• From PACRA’s point of view: Selective disclosure constitutes
  divulging the rating opinion to anyone other than the Client before Public Dissemination. The release of such information to the Client doesn’t constitute selective disclosure.
• From Client’s point of view: Selective disclosure constitutes
  divulging the rating opinion to anyone else before Public Dissemination by PACRA”.
  5.1.3 Review all the outstanding ratings periodically on annual basis and
  public dissemination of annual review is mandatory via press release along with rating report in case of Public Ratings.
  5.1.4 PACRA shall surveil / review all the outstanding ratings on semi￾annual basis or upon occurrence of such an event which requires to do so;
  Provided that public dissemination of Semi-annual review/ Surveillance will be required only in case of any change in underlying rating action.
  5.1.5 In case of Initial Rating Actions, PACRA provides an opportunity
  to the client to decide whether to disseminate the rating opinion assigned by PACRA or keep it private. However, once a rating is made public in case of

The Pakistan Credit Rating Agency Limited POLICY | ANNOUNCEMENT / DISSEMINATION OF RATING PACRA POLICY Page 3 of 5 July 2025 www.pacra.com annual, semi-annual /surveillance or interim reviews, PACRA reserves the right to disseminate its opinion immediately upon elapse of designated pre￾publication issuer review period.
5.1.6 PACRA may disseminate its opinions without a formal
consent/response from the client or may consider it appropriate to not solicit any comments. [Reference: CRC Regulations 2016; clause 19(1)]
5.1.7 PACRA is authorized, in case of dual private rating, to make public
the private rating assigned by it, in case the CLIENT approaches another credit rating company, during the life of rating agreement with PACRA to make public the private rating assigned by such other credit rating company. [Reference: CRC Regulations 2016; clause 16(3)].
5.2 Rating Actions and their Dissemination Specifics: All rating Dissemination
from PACRA are Rating Actions pertaining to either: (i) Initial ratings (ii) Preliminary Ratings (iii) Update ratings: (a) Reviews; (b) Interim Review. The dissemination specifics of these are as follows:
Rating Actions and their Dissemination Specifics Ratings Description Right to Disseminate Rests With:
Pre-publication
Issuer Review
Preliminary
The rating assigned to a debt instrument yet to be issued based upon its proposed terms and conditions. Client Yes Initial The rating assigned by PACRA for the first time. Ratings are also termed “Initial” when a previously:

• Private Rating
  converts into a
  Public Rating.
• Preliminary Rating
  is finalized.
• Withdrawn rating
  comes back to
  PACRA with a fresh
  Agreement.
• Defaulted rating
  emerges from default and assigned a rating.
• A rating restored
  from suspension may also be termed as initial.
  The Client Yes

The Pakistan Credit Rating Agency Limited POLICY | ANNOUNCEMENT / DISSEMINATION OF RATING PACRA POLICY Page 4 of 5 July 2025 www.pacra.com Update Review The updated ratings resulting from the Semi-Annual /Surveillance or Annual Review PACRA Yes Interim Review The updated ratings resulting from the Interim Review PACRA Yes
5.3 PACRA Policy for Announcement / Dissemination of Rating comes into play
as soon as PACRA RC finalizes its decision on the Rating Action. Thereafter, a synchronized sequence unfolds culminating in Announcement / Dissemination of ratings:
5.3.1 Pre-publication Issuer Review: PACRA shall where feasible and
appropriate prior to issuing or revising a rating inform the issuer of the critical information and principal considerations, via a draft press release and rating report, upon which a rating will be based and provide the issuer an opportunity to clarify any likely factual misperception or other matter that PACRA must know in order to produce a fair rating .Such review, however, doesn’t preclude PACRA from retaining complete control over the editorial and analytical content of its documents.
5.3.2 Rating Notification & Dissemination: These two steps usually take
place simultaneously:
(a) Rating Notification: The Client is formally informed of the assigned rating through a Rating Notification Letter. (b) Public Dissemination: The rating is released in the public domain through a Press Release placed on PACRA’s website.
6. TASKS 6.1 The Rating Analyst generates a Rating Notification through the system. The
Rating Notification isn’t generated till all formalities pertaining to the Press Release are not in order.
6.2 The system, maintained by the Management Information Technology
function, is in synch with PACRA’s website and e-mail server and updates twice a day at 10:00 AM and 5:00 PM.
7. POLICY
ADMINISTRATION
7.1 Interpretation: Competent Authority is responsible for interpreting and
applying the policy to specific situations when questions arise.
7.2 Review: This Policy is subject to review as follows:
Reviewed by Scope Frequency
(Minimum)
CRC Regulations,
2016
Compliance
Officer
Appropriateness
& sufficiency
Annual Chapter III | 11-B-
(k)
Firm of Chartered
Accountants
Actual vs. policy Semi￾Annual
Chapter III | 11-F-
(g)
7.3 Policy Approval: This policy is required to be approved by the Board of
Directors.
7.4 Investigations of Suspected Violations: All reported violations shall be
promptly investigated and treated confidentially to the extent reasonably possible.

The Pakistan Credit Rating Agency Limited POLICY | ANNOUNCEMENT / DISSEMINATION OF RATING PACRA POLICY Page 5 of 5 July 2025 www.pacra.com
7.5 Disciplinary Protocol: Compliance with all codes of conduct and PACRA
policies, including this policy, is a condition for employment. Compliance with the codes and PACRA Policies shall be monitored on periodic basis:

• Those who come within the bounds of this policy shall cooperate fully to
  provide truthful, accurate information
  Capitalized terms used herein are defined in PACRA Glossary. Moreover, current version of this policy is available on the website:
  www.pacra.com

8. REGULATORY
   FRAMEWORK
   8.1 PACRA’s compliance to SECP’s regulatory requirements in terms of the
   Policy for Announcement / Dissemination of Rating is as follows:
   PACRA’s Compliance for Policy Announcement / Dissemination of Rating CRC Regulations, 2016 Policy Reference Regulation Chapter III | 14-(1): Save as provided in sub-regulation (3) of regulation 16 of these Regulations, the credit rating company shall immediately disseminate all ratings assigned by it, whether solicited or unsolicited, except the private ratings, by way of press release through Associated Press of Pakistan and All Pakistan Newspapers Society. Clause 4.1(ii)a Regulation Chapter III | 14-(2): The credit rating company shall immediately disseminate all ratings to the Securities Exchanges, the State Bank of Pakistan, the Commission, Mutual Fund Association of Pakistan, Pakistan Banking Association, NBFI and Modaraba Association of Pakistan. Clause 4.1(ii)b Regulation Chapter III | 17-(a): A credit rating company shall monitor all the outstanding ratings continuously and any potential change therein due to any event associated with the issuer, the security arrangement, the industry etc., is disseminated to the market, immediately and in effective manner, after appropriate consultation with the entity/issuer;
   Section 4; Clause
   5.1.2
   Regulation Chapter III | 17-(b): A credit rating company shall review all the outstanding ratings periodically, on annual basis; ; Provided that public dissemination of annual review and, in an instance of change in rating will be required Clause 5.1.3 Regulation Chapter III | 19-(1): A credit rating company shall, where feasible and appropriate, prior to issuing or revising a rating inform the issuer of the critical information and principal considerations upon which a rating will be based and provide the issuer an opportunity to clarify any likely factual misperception or other matter that the credit rating company must know in order to produce a fair rating
   Section 3
   Annexure H: List of Policies to be developed & disclosed by a credit rating company / agency | Policy for Announcement / Dissemination of Rating Policy developed & disclosed on website