ESG rating provider conduct must ensure independence, manage conflicts, and maintain transparency to protect investor interests. An ESG rating provider must protect investor interests by exercising due diligence, independent professional judgment and consistent rating standards, maintain records supporting ratings, monitor issuer ESG factors and material changes, disclose and avoid conflicts of interest, preserve privileged information, prohibit public investment advice on rated entities, and follow governance requirements including an internal code of conduct, empowered compliance officer, arm's length operations and restrictions against unfair competition or market manipulation.