On October 5, ISDA responded to the UK’s environmental, social and governance (ESG) data and ratings working group’s (DRWG) draft voluntary code of conduct for ESG ratings and data product providers. In the response, ISDA highlights its support for the introduction of a code of conduct as an interim solution ahead of the implementation of a regulatory regime in the UK for ESG ratings providers. ISDA supports the use of the International Organization of Securities Commissions (IOSCO) recommendations to ensure the code is internationally interoperable, noting that the EU, Hong Kong, Japan, Singapore and India have since developed (or are developing) codes of conduct and/or regulation of ESG data and ratings providers based on IOSCO’s policy recommendations. ISDA encourages the UK financial services regulators and industry to continue to coordinate with their international counterparts to avoid a fragmented approach.