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Vivo Energy plc
(Incorporated in England and Wales)
(Registration number: 11250655)
(Share code: VVO)
LEI: 213800TR7V9QN896AU56
ISIN: GB00BDGT2M75
NOT FOR RELEASE, PUBLICATION OR DISTRIBUTION, IN WHOLE OR IN PART, IN OR
INTO ANY JURISDICTION WHERE TO DO SO WOULD CONSTITUTE A VIOLATION OF THE
RELEVANT LAWS OF SUCH JURISDICTION
FOR IMMEDIATE RELEASE
8 July 2022
RECOMMENDED CASH OFFER
for
Vivo Energy plc
by
VIP II Blue B.V.
(a newly formed company (“BidCo”), being a wholly-owned indirect subsidiary
of Vitol Investment Partnership II Limited, itself being an investment
vehicle advised by employees of the Vitol Group)
to be effected by way of a scheme of arrangement under Part 26 of the UK
Companies Act 2006 (the “Act”)
SATISFACTION OF REGULATORY AND ANTITRUST CONDITIONS, 2022 SPECIAL DIVIDEND
AND UPDATED EXPECTED TIMETABLE OF PRINCIPAL EVENTS
On 25 November 2021, the boards of Vivo Energy plc (the “Company” or “Vivo”)
and BidCo announced that they had reached agreement on the terms of a
recommended cash offer for all of the issued and to be issued ordinary share
capital of the Company not already owned by the Existing Vitol Shareholders
(the “Offer”). The Offer is to be effected by means of a Court-sanctioned
scheme of arrangement under Part 26 of the Act (the “Scheme”). Full details
of the Offer are set out in the Scheme Document published on 17 December
2021 (the “Scheme Document”). Unless otherwise defined, capitalised terms
used in this Announcement have the same meanings as set out in the Scheme
Document.
On 20 January 2022, Vivo announced that the requisite majorities of eligible
Scheme Shareholders had approved the Scheme at the Court Meeting and the
Special Resolution to implement the Scheme at the General Meeting.
The Offer is subject to the Conditions set out in Part III of the Scheme
Document, including the receipt of certain regulatory and antitrust
approvals. Vivo and BidCo are pleased to announce that all of the Conditions
relating to regulatory and antitrust approvals have now been satisfied.
Accordingly, and as set out in more detail below, it is now expected that
the Scheme will become effective on 25 July 2022.
2022 Special Dividend
As the Effective Date is expected to occur prior to the 2022 Interim Dividend
Record Date, in line with the terms of the Offer set out in the Scheme
Document, the Company is pleased to declare (subject to the sanctioning of
the Scheme by the Court) the 2022 Special Dividend of USD $0.02 per Vivo
Share.
The 2022 Special Dividend will be payable (subject to the sanctioning of the
Scheme by the Court and without any consequential reduction in the
Consideration) on or before 8 August 2022 to all Vivo Shareholders on the
register of members of the Company as at 6.00 p.m. on 22 July 2022 (except
the Helios Entities, which have each agreed to waive the right to receive
the 2022 Special Dividend). The 2022 Special Dividend will be paid from
distributable reserves.
The default currency for payment of dividends by the Company is in US dollars.
However, Vivo Shareholders who hold their Vivo Shares through the London
Stock Exchange can elect to have dividends paid in pound sterling (“GBP”) by
completing a Dividend Currency Election Form (the “Form”). A copy of the
Form can be found on the Company's website at
http://investors.vivoenergy.com/shareholder-information/dividend-
information. The option to elect a GBP dividend payment for the 2022 Special
Dividend will be available to shareholders until 22 July 2022, by which date
the Form needs to be returned duly completed to Equiniti Limited
(“Equiniti“), Aspect House, Spencer Road, Lancing, West Sussex, BN99 6DA,
United Kingdom. All enquiries regarding the Form should be sent to the same
address or by telephone to Equiniti on: 0371 384 2030 (and if outside the
United Kingdom (UK) on: +44 371-384-2030). Calls are charged at the standard
geographic rate and will vary by provider. Calls outside the UK will be
charged at the applicable international rate. Lines are open Monday-Friday
08:30-17:30 (BST) except public holidays in England and Wales.
CREST shareholders must elect via CREST.
The GBP equivalent dividend payment will be announced on or around 27 July
2022.
Vivo Shareholders who hold shares through the Johannesburg Stock Exchange
will receive their dividend in South African rand. The South African rand
equivalent dividend payment will be announced on or around 20 July 2022.
Vivo Shareholders on the South African Register should note that, in
accordance with the requirements of Strate, the last day to trade cum-
dividend will be Friday 22 July 2022.
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Next steps and timetable
The Scheme remains subject to certain other Conditions, including sanction
by the Court at the Court Hearing (scheduled to take place on 22 July 2022)
and the delivery of a copy of the Court Order to the Registrar of Companies.
Subject to the Scheme receiving the sanction of the Court and the delivery
of a copy of the Court Order to the Registrar of Companies, the Scheme is
expected to become effective on 25 July 2022.
The expected timetable of principal events for the implementation of the
Scheme is set out below. If any changes to the key dates and/or times set
out in the timetable are made, Vivo and BidCo will give notice of this change
by issuing an announcement through a Regulatory Information Service and by
making such announcement available on Vivo’s website at www.vivoenergy.com.
Principal events in the UK
Event Expected date and time (UK time)
Last time and date for transfers 4.00 p.m. on 18 July 2022
between the UK Register and the
South African Register
Court Hearing 22 July 2022
Last day of dealings in, and for 22 July 2022
registration of transfers of, and
disablement in CREST of, Vivo
Shares
Last day for receipt of Form of 1.00 p.m. on 22 July 2022
Election for Currency Election /
Election Return Time relating to
the Scheme
Last day for receipt of Dividend 5.00 p.m. on 22 July 2022
Currency Election Form relating to
the 2022 Special Dividend
Scheme and 2022 Special Dividend 6.00 p.m. on 22 July 2022
Record Time
Suspension of listing and dealings 7.30 a.m. on 25 July 2022
in Vivo Shares
Effective Date of the Scheme 25 July 2022
Cancellation of listing of Vivo By 8.00 a.m. on 26 July 2022
Shares
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Latest date for despatch of 8 August 2022
cheques/settlement through CREST
Principal events in South Africa
Event Expected date and time (SAST)
Latest time and date for transfers 5.00 p.m. on 18 July 2022
between the South African Register
and the UK Register
Application for the delisting of 19 July 2022
shares lodged with the JSE
Currency Exchange Announcement 20 July 2022
Court Hearing 22 July 2022
Finalisation Announcement 22 July 2022
Last date to trade for the Scheme 22 July 2022
and the 2022 Special Dividend on
the JSE
Effective Date of the Scheme 25 July 2022
Suspension of Vivo Shares on the 9.00 a.m. on 25 July 2022
JSE
Record date on the JSE (Scheme and 27 July 2022
2022 Special Dividend)
Last date to credit accounts with 28 July 2022
the Consideration and the 2022
Special Dividend through the Strate
system (or in the case of
Certificated SA Shareholders, by
electronic funds transfer into
their South African bank accounts)
Cancellation of listing of Vivo 29 July 2022
Shares on the JSE
A further announcement will be made when the Court sanctions the Scheme.
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Enquiries:
BidCo +44 20 7973 4230 /
Andrea Schlaepfer +44 7525 403796
Head of Corporate Communications
HSBC (Financial adviser to BidCo) +44 20 7991 8888
Keith Welch
Alex Thomas
James Novelli
Joe Weaving
Brunswick LLP (public relations adviser to BidCo)+44 20 7404 5959
Patrick Handley
Vivo Energy plc +44 20 3034 3735
Giles Blackham
Head of Investor Relations
Rob Foyle
Head of Communications
J.P. Morgan Cazenove +44 20 7742 4000
(Joint financial adviser and corporate broker to Vivo)
Dwayne Lysaght
James Janoskey
Richard Walsh
Rothschild & Co
(Joint financial adviser to Vivo) +44 20 7280 5000
John Deans
Edoardo Fassati
Numis Securities (Corporate broker to Vivo) +44 207 260 1000
Stuart Dickson
George Price
JSE Sponsor to Vivo:
J.P. Morgan Equities South Africa Proprietary Limited
Tulchan Communications
(public relations adviser to Vivo) +44 207 353 4200
Martin Robinson
Harry Cameron
Akin Gump LLP is acting as legal adviser to BidCo as to English law.
Freshfields Bruckhaus Deringer LLP is acting as legal adviser to Vivo as to
English Law. Bowmans is acting as legal adviser to BidCo as to South
African Law and Werksmans is acting as legal adviser to Vivo as to South
African law.
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Important notices relating to financial advisers
HSBC, which is authorised by the Prudential Regulation Authority (the “PRA”)
and regulated by the PRA and the Financial Conduct Authority (the “FCA”) in
the United Kingdom, is acting exclusively for Vitol and BidCo and no one
else in connection with the Offer and will not be responsible to anyone other
than Vitol and BidCo for providing the protections afforded to clients of
HSBC nor for giving advice in relation to the Offer or any matter or
arrangement referred to in this announcement. Neither HSBC, nor any of its
group undertakings or affiliates, owes or accepts any duty, liability or
responsibility whatsoever (whether direct or indirect, whether in contract,
in tort, under statute or otherwise) to any person who is not a client of
HSBC in connection with this announcement, any statement contained herein or
otherwise. HSBC has given, and not withdrawn, its consent to the inclusion
in this announcement of the references to its name in the form and context
in which they appear.
J.P. Morgan Securities plc, which conducts its UK investment banking business
as J.P. Morgan Cazenove (“J.P. Morgan Cazenove”), is authorised in the United
Kingdom by the PRA and regulated in the United Kingdom by the PRA and the
FCA. J.P. Morgan Cazenove is acting as financial adviser exclusively for Vivo
and no one else in connection with the matters set out in this announcement
and will not regard any other person as its client in relation to such matters
and will not be responsible to anyone other than Vivo for providing the
protections afforded to clients of J.P. Morgan Cazenove or its affiliates,
or for providing advice in relation to any matter or arrangement referred to
herein.
J.P. Morgan Equities South Africa Proprietary Limited is acting exclusively
as JSE sponsor to Vivo and no one else in connection with the matters set
out in this announcement, and will be subject to the requirements imposed on
such a sponsor under the JSE Listings Requirements.
N.M. Rothschild & Sons Limited (“Rothschild & Co”), which is authorised and
regulated by the FCA in the United Kingdom, is acting exclusively for Vivo
and no one else in connection with the matters described in this announcement
and will not be responsible to anyone other than Vivo for providing the
protections afforded to clients of Rothschild & Co nor for providing advice
in connection with any matter referred to herein. Neither Rothschild & Co
nor any of its affiliates (nor their respective directors, officers,
employees or agents) owes or accepts any duty, liability or responsibility
whatsoever (whether direct or indirect, whether in contract, in tort, under
statute or otherwise) to any person who is not a client of Rothschild & Co
in connection with this announcement, any statement contained herein or
otherwise.
Numis Securities Limited (“Numis”), which is authorised and regulated in the
United Kingdom by the Financial Conduct Authority, is acting as Corporate
Broker exclusively for Vivo and no one else in connection with the matters
set out in this announcement and will not regard any other person as its
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client in relation to the matters in this announcement and will not be
responsible to anyone other than Vivo for providing the protections afforded
to clients of Numis, nor for providing advice in relation to any matter
referred to herein.
This announcement is for information purposes only. It is not intended to
and does not constitute, or form part of, any offer or invitation or the
solicitation of any offer to sell or purchase any securities or the
solicitation of any offer to otherwise acquire, subscribe for, sell or
otherwise dispose of any security pursuant to the Offer or otherwise. The
Offer shall be made solely by means of the Scheme Document, which, together
with the Forms of Proxy and the Form of Election (if applicable), shall
contain the full terms and conditions of the Offer, including details of how
to vote in respect of the Offer. Any vote in respect of, acceptance or other
response to the Offer should be made only on the basis of the information
contained in the Scheme Document read in its entirety.
This announcement does not constitute a prospectus or prospectus equivalent
document.
Overseas Shareholders
The availability of the Offer to Vivo Shareholders who are not resident in
and citizens of the United Kingdom or South Africa may be affected by the
laws of the relevant jurisdictions in which they are located or of which
they are citizens. Persons who are not resident in the United Kingdom or
South Africa should inform themselves of, and observe, any applicable legal
or regulatory requirements of their jurisdictions. Any failure to comply with
the applicable restrictions may constitute a violation of the securities laws
of any such jurisdiction. To the fullest extent permitted by applicable law,
the companies and persons involved in the Offer disclaim any responsibility
or liability for the violation of such restrictions by any person. Further
details in relation to Overseas Shareholders are contained in the Scheme
Document.
Unless otherwise determined by BidCo or required by the Takeover Code, and
permitted by applicable law and regulation, the Offer will not be made
available, directly or indirectly, in, into or from a Restricted Jurisdiction
where to do so would violate the laws in that jurisdiction. Copies of this
announcement and any formal documentation relating to the Offer are not
being, and must not be, directly or indirectly, mailed or otherwise
forwarded, distributed or sent in or into or from any Restricted Jurisdiction
and persons receiving such documents (including custodians, nominees and
trustees) must not mail or otherwise forward, distribute or send it in or
into or from any Restricted Jurisdiction. Doing so may render invalid any
related purported acceptance in respect of the Offer. The Offer may not be
made directly or indirectly, in or into, or by the use of mails or any means
or instrumentality (including, but not limited to, facsimile, e-mail or other
electronic transmission, telex or telephone) of interstate or foreign
commerce of, or of any facility of a national, state or other securities
712
exchange of any Restricted Jurisdiction and the Offer may not be capable of
acceptance by any such use, means, instrumentality or facilities.
In accordance with the Takeover Code, normal United Kingdom market practice
and Rule 14e-5(b) of the US Exchange Act, HSBC and its respective affiliates
will continue to act as exempt principal trader in Vivo securities on the
London Stock Exchange. These purchases and activities by exempt principal
traders which are required to be made public in the United Kingdom pursuant
to the Takeover Code will be reported to a Regulatory Information Service
and will be available on the London Stock Exchange website at
www.londonstockexchange.com. This information will also be publicly
disclosed: (i) in the US to the extent that such information is made public
in the United Kingdom, and (ii) in South Africa, on the Stock Exchange News
Service of the JSE, to the extent that it is reported to a Regulatory
Information Service on the London Stock Exchange’s website.
This announcement has been prepared for the purpose of complying with English
law, the Takeover Code, the Market Abuse Regulation (EU) no. 596/2014, the
Market Abuse Regulation (EU) no. 596/2014 (as it forms part of the laws of
the UK by virtue of the European Union (Withdrawal) Act 2018 (as amended)),
the Disclosure Guidance and Transparency Rules, and the Listing Rules, and
information disclosed may not be the same as that which would have been
disclosed if this announcement had been prepared in accordance with the laws
of jurisdictions outside of England and Wales.
The information contained in this announcement constitutes factual
information as contemplated in section 1(3)(a) of the South African Financial
Advisory and Intermediary Services Act, 37 of 2002, as amended (“Fais Act”)
and should not be construed as an express or implied advice, recommendation,
guide or proposal that any particular transaction in respect of the Offer,
is appropriate to the particular investment objectives, financial situations
or needs of a shareholder or offeree, and nothing in this announcement should
be construed as constituting the canvassing for, or marketing or advertising
of, financial services in South Africa. BidCo is not a financial services
provider licensed as such under the Fais Act.
Nothing in this announcement should be viewed, or construed, as “advice”, as
that term is used in the South African Financial Markets Act, 19 of 2012, as
amended.
Notice to U.S. investors in Vivo
The Offer relates to shares of a UK company and is proposed to be effected
by means of a scheme of arrangement under the laws of England and Wales. A
transaction effected by means of a scheme of arrangement is not subject to
the tender offer rules or the proxy solicitation rules under the US Exchange
Act.
Accordingly, the Offer is expected to be made subject to the disclosure and
procedural requirements and practices applicable in the United Kingdom and
to schemes of arrangement under the laws of England and Wales which differ
812
from the disclosure and other requirements of the United States tender offer
and proxy solicitation rules. Neither the US Securities Exchange Commission,
nor any securities commission of any state of the United States, has approved
the Offer, passed upon the fairness of the Offer or passed upon the adequacy
or accuracy of this document. Any representation to the contrary is a criminal
offence in the United States.
However, if BidCo were to elect (with the consent of the Panel) to implement
the Offer by means of a takeover offer, such takeover offer shall be made in
compliance with all applicable United States laws and regulations, including
any applicable exemptions under the US Exchange Act. Such a takeover would
be made in the United States by BidCo and no one else.
In the event that the Offer is implemented by way of a takeover offer, in
accordance with normal United Kingdom practice, BidCo or its nominees, or
its brokers (acting as agents), may from time to time make certain purchases
of, or arrangements to purchase, shares or other securities of Vivo outside
of the United States, other than pursuant to the Offer, until the date on
which the Offer and/or Scheme becomes effective, lapses or is otherwise
withdrawn. These purchases may occur either in the open market at prevailing
prices or in private transactions at negotiated prices. Any information about
such purchases or arrangements to purchase shall be disclosed as required in
the UK, shall be reported to a Regulatory Information Service and shall be
available on the London Stock Exchange website at
www.londonstockexchange.com. This information will also be publicly
disclosed in South Africa, on Stock Exchange News Service of the JSE, to the
extent that it is reported to a Regulatory Information Service on the London
Stock Exchange’s website.
Each Vivo Shareholder is urged to consult their independent professional
adviser immediately regarding the tax consequences of the Offer applicable
to them, including under applicable United States state and local, as well
as overseas and other, tax laws.
Financial information relating to Vivo included in this announcement and the
Scheme Document has been or shall have been prepared in accordance with
accounting standards applicable in the United Kingdom and may not be
comparable to financial information of US companies or companies whose
financial statements are prepared in accordance with generally accepted
accounting principles in the United States.
Vivo is organised under the laws of a country other than the United States.
Some or all of the officers and directors of Vivo, respectively, are residents
of countries other than the United States. In addition, most of the assets
of Vivo are located outside the United States. As a result, it may be
difficult for US shareholders of Vivo to effect service of process within
the United States upon Vivo or its officers or directors or to enforce against
them a judgment of a US court predicated upon the federal or state securities
laws of the United States.
912
Forward-looking statements
This announcement (including information incorporated by reference in this
announcement), oral statements made regarding the Offer, and other
information published by BidCo contain statements which are, or may be deemed
to be, "forward-looking statements". Forward-looking statements are
prospective in nature and are not based on historical facts, but rather on
current expectations and projections of the management of BidCo about future
events, and are therefore subject to risks and uncertainties which could
cause actual results to differ materially from the future results expressed
or implied by the forward-looking statements.
The forward-looking statements contained in this announcement include
statements relating to the expected effects of the Offer on BidCo, the Vitol
Group, the Vivo Group and Vivo (including their future prospects,
developments and strategies), the expected timing and scope of the Offer and
other statements other than historical facts. Often, but not always, forward-
looking statements can be identified by the use of forward-looking words such
as "plans", "expects" or "does not expect", "is expected", "is subject to",
"budget", "projects", "strategy", "scheduled", "estimates", "forecasts",
"intends", "anticipates" or "does not anticipate", or "believes", or
variations of such words and phrases or statements that certain actions,
events or results "may", "could", "should", "would", "might" or "will" be
taken, occur or be achieved. Although BidCo believes that the expectations
reflected in such forward-looking statements are reasonable, BidCo can give
no assurance that such expectations will prove to be correct. By their nature,
forward-looking statements involve risk and uncertainty because they relate
to events and depend on circumstances that will occur in the future. There
are a number of factors that could cause actual results and developments to
differ materially from those expressed or implied by such forward-looking
statements.
These factors include, but are not limited to: the ability to complete the
Offer; the ability to obtain requisite regulatory and shareholder approvals;
future market conditions; changes in general economic and business
conditions; the behaviour of other market participants; the anticipated
benefits from the proposed transaction not being realised as a result of
changes in general economic and market conditions in the countries in which
each of the Vitol Group and the Vivo Group operates; weak, volatile or
illiquid capital and/or credit markets; changes in tax rates; interest rate
and currency value fluctuations; the degree of competition in the geographic
and business areas in which each of the Vitol Group and the Vivo Group
operates; and changes in laws or in supervisory expectations or requirements.
Other unknown or unpredictable factors could cause actual results to differ
materially from those in the forward-looking statements. Such forward-looking
statements should therefore be construed in the light of such factors.
Neither BidCo, nor any persons acting in concert with it, nor any of its
associates or directors, officers or advisers, provide any representation,
assurance or guarantee that the occurrence of the events expressed or implied
in any forward-looking statements in this announcement will actually occur.
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You are cautioned not to place any reliance on these forward-looking
statements. Other than in accordance with its legal or regulatory
obligations, BidCo is not under any obligation, and expressly disclaims any
intention or obligation, to update or revise any forward-looking statements,
whether as a result of new information, future events or otherwise.
Publication on website and availability of hard copies
A copy of this Announcement and the documents required to be published
pursuant to Rule 26 of the Takeover Code is and will be available (subject
to certain restrictions relating to persons resident in Restricted
Jurisdictions) for inspection free of charge on Vivo’s website at
www.vivoenergy.com and Vitol’s website at www.vitol.com by no later than 12
noon London time on the Business Day following the Announcement.
Neither the contents of those websites nor the content of any other website
accessible from hyperlinks on those websites is incorporated into, or forms
part of, this Announcement.
Vivo Shareholders except Vivo Shareholders on the South African Register may
request a hard copy of this Announcement by contacting Equiniti Limited
during business hours on 0371 384 2320 (from within the UK) or on +44 371
384 2320 (from outside the UK) or by submitting a request in writing to
Equiniti Limited at Aspect House, Spencer Road, Lancing, West Sussex BN99
6DA.
Vivo Shareholders on the South African Register may request a hard copy of
this Announcement by contacting JSE Investor Services on 0861 472 644 (from
within South Africa) or +27 11 029 0112 (from outside South Africa) or by
submitting a request in writing to JSE Investor Services (Pty) Ltd, 13th
Floor, 19 Ameshoff Street Braamfontein, 2001 or PO Box 10462, Johannesburg,
2000.
If you have received this Announcement in electronic form, copies of this
Announcement and any document or information incorporated by reference into
this document will not be provided unless such a request is made.
Disclosure requirements of the Takeover Code
Under Rule 8.3(a) of the Takeover Code, any person who is interested in 1%
or more of any class of relevant securities of an offeree company or of any
securities exchange offeror (being any offeror other than an offeror in
respect of which it has been announced that its offer is, or is likely to
be, solely in cash) must make an Opening Position Disclosure following the
commencement of the offer period and, if later, following the announcement
in which any securities exchange offeror is first identified. An Opening
Position Disclosure must contain details of the person’s interests and short
positions in, and rights to subscribe for, any relevant securities of each
of (i) the offeree company and (ii) any securities exchange offeror(s). An
Opening Position Disclosure by a person to whom Rule 8.3(a) applies must be
1112
made by no later than 3.30 pm (London time) on the 10th business day following
the commencement of the offer period and, if appropriate, by no later than
3.30 pm (London time) on the 10th business day following the announcement in
which any securities exchange offeror is first identified. Relevant persons
who deal in the relevant securities of the offeree company or of a securities
exchange offeror prior to the deadline for making an Opening Position
Disclosure must instead make a Dealing Disclosure.
Under Rule 8.3(b) of the Takeover Code, any person who is, or becomes,
interested in 1% or more of any class of relevant securities of the offeree
company or of any securities exchange offeror must make a Dealing Disclosure
if the person deals in any relevant securities of the offeree company or of
any securities exchange offeror. A Dealing Disclosure must contain details
of the dealing concerned and of the person’s interests and short positions
in, and rights to subscribe for, any relevant securities of each of (i) the
offeree company and (ii) any securities exchange offeror(s), save to the
extent that these details have previously been disclosed under Rule 8. A
Dealing Disclosure by a person to whom Rule 8.3(b) applies must be made by
no later than 3.30 p.m. (London time) on the business day following the date
of the relevant dealing.
If two or more persons act together pursuant to an agreement or understanding,
whether formal or informal, to acquire or control an interest in relevant
securities of an offeree company or a securities exchange offeror, they will
be deemed to be a single person for the purpose of Rule 8.3.
Opening Position Disclosures must also be made by the offeree company and by
any offeror and Dealing Disclosures must also be made by the offeree company,
by any offeror and by any persons acting in concert with any of them (see
Rules 8.1, 8.2 and 8.4).
Details of the offeree and offeror companies in respect of whose relevant
securities Opening Position Disclosures and Dealing Disclosures must be made
can be found in the Disclosure Table on the Takeover Panel’s website at
www.thetakeoverpanel.org.uk, including details of the number of relevant
securities in issue, when the offer period commenced and when any offeror
was first identified. You should contact the Panel’s Market Surveillance Unit
on +44 (0)20 7638 0129 if you are in any doubt as to whether you are required
to make an Opening Position Disclosure or a Dealing Disclosure.
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