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Regulatory Compliance

Clarity AI Complaints and Reasoned Concerns

Clarity AI leverages technology to provide high quality ESG ratings, that are based on independent and transparent methodologies, and on a thorough analysis of reliable and up to date information.

In the unlikely event that you believe our ESG ratings do not satisfy the above criteria, you may reach out to us and we will investigate the issue impartially and respond with our conclusion in due course, in line with our Complaints and Reasoned Concerns Handling Policy.

1. What’s the area of application of this policy?

This policy applies to all ESG ratings activities and ESG ratings products of Clarity AI within the scope of the ESG ratings regulation (EU Regulation 3005/2024). It does not apply to any other activity of Clarity AI.

2. What’s in scope?

This policy applies to Complaints and Reasoned concerns submitted to Clarity AI, in respect to the products and activities in its area of application.

A Complaint is an allegation of dissatisfaction, communicated to Clarity AI, regarding a group of or an individual ESG rating, on at least one the following topics:

  1. the sources of data used for an individual ESG rating, factual errors and mistakes;
  2. the way in which the rating methodology in relation to an individual ESG rating has been applied;
  3. whether an individual ESG rating is representative of the rated item or the issuer of the rated item.

A Reasoned concern is an allegation of dissatisfaction, communicated to Clarity AI on matters related to the provision of ESG ratings that:

  1. are not a complaint; AND
  2. is in respect to any non-compliance with the ESG ratings regulation.

3. Who can reach out?

You may file a Complaint, if you are a natural or legal person, and are:

  1. a User of ESG ratings; and/ or
  2. a Rated item or a representative thereof; and/ or
  3. an issuer of rated items or a representative thereof.

You may file a Reasoned concern if you are a natural or legal person who is:

  1. A Clarity AI member of the Group Personnel, Group Senior management or Group shareholders;
  2. A client or a user of ESG ratings;
  3. A rated item or an issuer of a rated item
  4. A person accessing Clarity AI publicly available information
  5. Any stakeholder/ industry organization

4. How to reach out?

If you want to submit a complaint,  or a reasoned concern, email us at compliance@clarity.ai

5. How do we handle your submission?

Assessment and resolution of your complaint or reasoned concern are subject to the following principles:

Independence and Fair handling: Investigations are carried out independently, under Compliance independent oversight and coordination. Relevant impartial and free from conflicts of interest experts may also support the investigation.

Timely resolution: Investigation and resolution timelines depend on the complexity of each Complaint or Reasoned Concern. Clarity AI is committed to investigate and communicate the outcome of such investigation within a reasonable period of time, unless such communication is contrary to applicable law. Where not prescribed otherwise by applicable law, the reasonable period of time is estimated at 4 weeks from the date of confirming the receipt of such Complaint of Reasoned Concern.

Confidentiality: Complaints and Reasoned Concerns are subject to confidentiality rules and the identity of the Complainant and/ or Relevant Stakeholder is protected, according to the relevant legislation. Handling thereof is also subject to whistleblowing protections rules, if and where applicable.

No retaliation: Retaliation against a sender is strictly prohibited, even if the investigation does not confirm any wrongdoing.

6. What is not scope?

The following communications are not in scope for this policy:

  1. Standard requests for information or general inquiries.
  2. General disagreement with the methodology or products that do not allege error or non-compliance.
  3. Communication in respect to any other activities carried out by Clarity AI, that are not related to the provision of ESG ratings
  4. Contractual disputes and claims relating to technical malfunction of Clarity AI services.
  5. Communications from Regulators/Public Authorities acting in their official capacity.

7. Want to know more?

If you have further questions about our Complaints and reasoned concerns handling policy, you may contact our Compliance department.