Training on sovereign risk credit analysis, October 24

2017 Transparency Report of ACRA (JSC)

“We are committed to providing the Russian rating services market with high-quality products by building up a highly professional, technologically advanced and transparent business, consistently vested with confidence by the investment community.”

The Analytical Credit Rating Agency team

The Transparency Report contains information on operations of Analytical Credit Rating Agency over the period from January 1, 2017 to December 31, 2017.

The Transparency Report has been prepared in accordance with requirements of Part 4, Article 13 of Federal Law No 222-FZ. This document is subject to publication in the Compliance section of ACRA’s website.

CEO Address

Dear partners, clients, shareholders, and market participants!

We are pleased to present the second transparency report of the Analytical Credit Rating Agency (JSC).

At the end of 2017, the Agency celebrated its second anniversary; a year has passed since the first rating was assigned. It was a year of rapid growth and new achievements. ACRA has fully complied with the requirements of the Russian rating regulator, the Central Bank of Russia, and significantly strengthened its leading position in the financial market. Over the two years, the board of directors and the shareholders have remained unchanged, this reflects the support and trust in our approach based on integrity, transparency and uncompromising quality. In past year, the number of ratings assigned by ACRA grew significantly (over 300 ratings were assigned). By the end of 2017, in the Russian bond market, the share of banks rated by ACRA was 76% and regions was 71%. An important event in November 2017 was the signing of a memorandum of cooperation between ACRA and Golden Credit, a Chinese rating agency, which opened up new opportunities for our development.

This year we made significant progress in the development of the rating methodologies: we published the Methodology for Reliability Ratings Assignment to Asset Management Companies, the Methodology for Credit Ratings Assignment to Non-State Pension Funds, and the Methodology for Credit Ratings Assignment for Structured Finance Instruments and Obligations. ACRA analysts published multiple analytical researches and forecasts, spoke at major business events, and gave numerous comments to business and profile media, held more than 100 meetings and calls with domestic and international investors. We also published the Principles of Calculating the Financial Stress Index for the Russian Federation (ACRA FSI). Our research on debt market ‘maps’ for Russia and Kazakhstan is a real breakthrough: The ‘maps’ were developed bringing partial information of debt relations by official statistics. ACRA analysts were the first to collect data from official diversified sources and created an integrated product. Kazakhstan's financial stress index was also established using the data collected in the ‘mapping’ process.

The Agency has training programs covering all sectors of credit analysis. Many professionals from Russia and abroad have joined our analytical team. This indicates our personnel stability and strong reputation. We see a growing interest in our activities both in Russia and abroad, as evidenced by our website statistics. For more convenience of our customers, we launched a social media page; the number of subscribers has been constantly growing.

I am grateful to all ACRA team members, who are committed professionals. Thanks to their efforts, we can achieve new successes and reach new heights. We strive to create the most favorable conditions for our employees, because we understand that the core asset of ACRA is qualified and dedicated personnel.

ACRA mission is to develop best practices in the Russian financial market that contribute to its effectiveness and the quality of credit and investment decisions. Our intention is to maximize the quality of analytical products through  profound professional expertise, high analytical standards, and strict compliance. Independence, prevention of conflicts of interest, integrity, quality and transparency of the rating process are the pivotal principles ACRA follows in its drive for stronger leading positions in the Russian rating services market and trusted relations with our customers and public. I hope that this report will be regarded as yet another confirmation of our adherence to the highest possible quality standards.


Ekaterina Trofimova


1. About ACRA

1.1. Shareholder Structure

Analytical Credit Rating Agency (ACRA) was founded on November 20, 2015, with its 27 shareholders being Russian corporate and financial institutions each contributing a 3.7037% stake to its charter capital, which totals RUB 3,000,024 thousand.

ACRA shareholders are:

  • VTB Bank (PJSC)
  • “Bank “Saint-Petersburg” PJSC
  • Bank GPB (JSC)
  • Renova Group (JSC)
  • ONEXIM Group (LLC)
  • Kommersant (JSC)
  • Leader AM (CJSC)
  • PJSC “Moscow Exchange MICEX-RTS”
  • Credit Bank of Moscow (PJSC)
  • Blagosostoyanie NSPF
  • Otkritie Holding (JSC)
  • Promsvyazbank PJSC
  • Industrial Investors Group (LLC)
  • AO Raiffeisenbank
  • Rosgosstrakh Insurance Company (PJSC)
  • JSC Russian Agricultural Bank
  • PJSC Future FG
  • Sberbank of Russia (PJSC)
  • PAO Severstal
  • PJSC Sovcombank
  • TMK (PJSC)
  • AO UniCredit Bank

1.2. Governing Bodies and Management

ACRA’s governing bodies are the General Meeting of Shareholders, the Board of Directors and the CEO.

ACRA shareholders are listed in Par. 1.1 above.

The Board of Directors comprises five members, with four of them being independent directors. The fifth board member is the CEO of ACRA.

The Board of Directors includes:

  • Karl Johansson (USA), Chairman of the Board of Directors, independent director;
  • Thomas Missong (Austria), independent director;
  • Anouar Hassoune (Luxembourg), independent director;
  • Vincent Truglia (USA), independent director;
  • Ekaterina Trofimova (Russia), Member of the Board of Directors, Chief Executive Officer.

General management of ACRA activities is carried out by the Board of Directors, with the exception of issues referred to the General Meeting of Shareholders by the Charter of ACRA and the Federal Law "On Joint-Stock Companies."

The day-to-day operations of ACRA are managed by the sole executive body of the Company, the Chief Executive Officer, who is accountable to the Board of Directors and the General Meeting of Shareholders.

1.3. Company Structure

Structurally, ACRA consists of the following business units:

  • Analytical Unit;
  • Methodology Group;
  • Compliance and Internal Control Service;
  • Operational Unit;
  • Business Development Directorate;
  • Analytical Services Group.

The Analytical Unit includes research groups focusing on specific types of rated objects:

  • Corporate Ratings Group;
  • Financial Institutions Ratings Group;
  • Sovereign and Regional Ratings Group;
  • Structured Finance  Ratings Group.

The Analytical Unit also includes the Research and Forecasting Group, which, among other things, is responsible for the preparation of macroeconomic and industry research materials.

2. Internal Control

Internal control at ACRA is carried out by the governing bodies, Compliance and Internal Control Service, rating committees, methodology committees, and ACRA employees within the scope of their competences and in line with ACRA’s internal documents.

The governing bodies and all ACRA employees are subject to  Federal Law No 222-FZ1, other statutory acts of the Russian Federation, the Charter of ACRA, and ACRA’s internal documents.

ACRA’s internal control pursues the following objectives:

  • Ensuring credibility of assigned credit ratings and the independence of credit rating activities from any political and/or economic influence;
  • Identifying and preventing conflicts of interest, as well as managing them;
  • Ensuring the completeness, reliability and timeliness of compiling and providing reports to internal and external users;
  • Risk management in the course of ACRA’s activities, including regulatory risk;
  • Ensuring the effectiveness of ACRA’s activities.

Federal Law of 13 July 2015 No 222-FZ On the Activities of Credit Rating Agencies in the Russian Federation, On the Amendment to Article 76.1 of the Federal Law ‘On the Central Bank of the Russian Federation (Bank of Russia)’ and the invalidation of certain provisions of legal acts of the Russian Federation

2.1. Code of Ethics and Professional Conduct, and documentation supporting ACRA’s activities

ACRA’s Board of Directors approved the Code of Ethics and Professional Conduct, which outlines the fundamental principles the Agency’s employees adhere to while performing rating activities and providing additional services.

The requirements of the Code of Ethics and Professional Conduct are taken into account in the course of preparing internal policies, regulations and procedures at ACRA.

All ACRA employees are required to familiarize themselves at the moment of hiring and on an annual basis with the Code of Ethics and Professional Conduct (, and applicable policies and regulations.

2.2. Board of Directors

In terms of internal control, the Board of Directors has been vested with the following powers:

  1. Evaluation of effectiveness of systems controlling credibility of assigned credit ratings;

  2. Evaluation of effectiveness of measures and procedures established to prevent, identify, manage, and disclose conflicts of interests;

  3. Control over compliance with  Federal Law No 222-FZ and the regulations of the Bank of Russia adopted in accordance with this Federal Law, and the documents of the credit rating agency, including the effectiveness of the methodology review function.

2.3. Compliance and Internal Control Service

The Compliance and Internal Control Service is an ACRA structural unit organizationally subordinate to the CEO and functionally subordinate and accountable for its activities to ACRA’s Board of Directors. The Service is headed by the Director for Compliance.

The Service is an internal control body in accordance with the requirements of  Federal Law No. 222-FZ.

ACRA’s CEO provides the conditions for unimpeded and efficient performance of the Compliance and Internal Control Service. The Service operates based on several principles, which include:

1. Independence and impartiality

  • ACRA makes sure that the Compliance and Internal Control Service is able to perform its functions without bias and without interference by ACRA employees who are not Service officers, governance bodies, as well as shareholders and persons who exercise control over or have a significant influence on ACRA;
  • The Compliance and Internal Control Service officers may not combine their activities with work in other ACRA units that may affect their independence, nor can such employees be employed in the governance bodies. The Service officers shall not be allowed any part-time employment in other organizations;
  • The Director for Compliance has the right to freely interact with the Board of Directors (or independent members of the Board, if necessary) and to report on his/her own initiative to the Board of Directors (or independent members of the Board, if necessary) about issues and problems arising in the course of Service functioning, coupled with proposals for their solution;
  • The Compliance and Internal Control Service controls the effectiveness of measures taken by the business units and governance bodies of ACRA as a result of inspections and aimed at reducing identified risks;
  • The Compliance and Internal Control Service does not perform activities subject to inspections, except an independent inspection by an audit organization or an inspection by the Board of Directors;
  • ACRA ensures that the Compliance and Internal Control Service performs its duties without interference by the governance bodies, business units and employees of ACRA who are not Service officers, as well by shareholders and persons exercising control over or having significant influence on ACRA;
  • The remuneration of the Compliance and Internal Control Service officers shall not depend on ACRA’s financial results;
  • The Compliance and Internal Control Service develops internal documents, plans, methods and processes for carrying out verification activities independently and shall not coordinate them with inspected units.

2. Objectivity and ethical standards

  • The Compliance and Internal Control Service officers carry out their activities based on the Code of Ethics and Professional Conduct of ACRA and should avoid any influence that a potential conflict of interest may have on objectivity of their professional judgment in the course of internal control implementation.

3. Continuity of activities

  • The Compliance and Internal Control Service operates on a permanent basis and is part of ACRA’s organizational structure;
  • The Compliance and Internal Control Service has permanent personnel only and includes only full-time employees;
  • The number of officers working for the Compliance and Internal Control Service and the latter’s technological support and structure must be in line with the scale of ACRA’s business.

4. Professional competence

  • Upon the appointment and during the entire tenure the Director for Compliance must comply with business reputation requirements established by Part 1 of Article 7 of  Federal Law No. 222-FZ;
  • Professional competence of the Compliance and Internal Control Service officers is maintained at a proper level by means of regular mandatory training in accordance with the training plan for employees at ACRA.

The Compliance and Internal Control Service reports to the Board of Directors on a regular basis on the results of inspections and identified risks and violations requiring appropriate measures.

2.4. Methodology Group and Methodology Committee

The Methodology Group is an ACRA permanent structural unit responsible for development, testing, validating and updating  methodologies, as well as for supervision over the application of methodologies in the course of rating activities, and for assessing the accuracy of such implementation. The Methodology Group is organizationally subordinate to the CEO and functionally subordinate and accountable for its activities to the Board of Directors.

Approvals and revisions of methodologies are subject to decisions taken by the Methodology Committee, a permanent collegial body formed by members of the Methodology Group.

Validation and testing of methodologies are performed by a Methodology Group member, who is not part of the Methodology Committee and does not participate in the development of methodologies.

The Methodology Group regularly reports on its activities to the Board of Directors.

3. Results of annual inspection of ACRA carried out by the internal control body

The rating activities performed by ACRA are in line with Russian legislation and ACRA’s own internal documents.

The rating process is subject to control procedures aimed at identifying conflicts of interest and independence of rating activities from political or economic influence, as required by Federal Law No. 222-FZ, the Bank of Russia regulations, and ACRA’s internal documents. The control procedures currently in place are assessed as adequate. No conflicts of interest have been discovered in the course of the rating process.

The inspection revealed certain deficiencies in terms of the composition and structure of control procedures, with these deficiencies being related to the fact that operating and analytical processes at the Agency are still in the development stage. A relevant plan aimed at eliminating those deficiencies has been approved by the Board of Directors and is being implemented.

4. Rating analysts allocation statistics

Table 1. Number of rating analysts grouped by rated entity types by end-2017 (all analysts employed full-time)



Financial institutions


Sovereign, regional and municipal authorities


Structured finance products





Table 2. Number of rating analysts grouped by rating actions (credit ratings assignment and review) over the reporting period


Corporate Ratings Group

Financial Institutions Ratings Group

Sovereign and Regional Ratings Group

Structured Finance Instrument Ratings Group

Credit rating assignment





Credit rating reviews





All ACRA rating analysts may participate in credit rating assignments and reviews.

5. Rating analyst rotation

5.1. Requirements to rotate lead rating analysts

ACRA ensures a procedure of rotation (replacement of lead rating analysts who participate in preparation of a credit rating or credit rating outlook with regard to one rated entity).

Lead rating analysts are not allowed to participate in rating actions pertaining to a given rated entity for more than four consecutive years and for more than five consecutive years in relation to sovereign credit ratings.

Lead rating analysts who have terminated their participation in rating actions related to one rated entity due to rotation are not allowed to participate in rating actions related to this rated entity for two years following the rotation.

5.2. Data on rotation of lead rating analysts in 2017

There was no mandatory rotation of lead rating analysts in 2017, as mandatory rotation time has not yet come

6. Documentation storage policy

ACRA stores internal data and documents used in the course of credit rating assignment as long as required by the Bank of Russia, but not less than 5 years, ensuring integrity, accuracy, and reliability of these documents in order to provide for verifiability of rating actions accuracy. All internal data and documents are kept on file to ensure objectivity of ACRA’s rating activities, as well as to back up the processes of internal audit, compliance control, and quality control.

ACRA ensures storage of information within the timeframes defined by the Bank of Russia’s requirements, including the following information and data:

•      Information on composition of rating committees, sets of documents and data related to the resolution on implementation of a rating action, as well as rating committees’ meeting minutes;

•      All initial information upon which lay the basis for rating analysis, including documents and information provided by rated entities, emails, rating meeting minutes, and other information;

•      All versions of methodologies, models, validation reports;

•      Data related to interaction with clients in the framework of concluding agreements, as well as agreements on rating actions, and agreements on additional services;

•      Communications with regulatory bodies;

•      Documentation of governing bodies;

•      ACRA’s internal documents.

7. Information on revenues

Table 3. Information on revenues for the period from January 1 to December 31, 2017

ACRA revenues from rating activities, RUB th


ACRA revenues from additional services2, RUB th


ACRA 2017 revenues (total), RUB th



2The List of Additional Services is available at

8. Mandatory training of rating analysts

To ensure the necessary competence level, rating analysts completed the required number of mandatory training hours in 2017, as outlined in ACRA’s internal documents.

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