Elliott Management Corporation Disclaimer

Persons who access the information made available on the Elliott Management Corporation and its affiliates (collectively, “Elliott”) website (the “website”) agree to the following:

While the material on this website is often about investments, none of it is offered as investment advice. For members of the public, this means that neither the receipt nor the distribution of information through this website constitutes the formation of an investment advisory relationship, or any similar client relationship. The materials on this website are for informational purposes only and may not be relied on by any person for any purpose and are not, and should not be construed as investment, financial, legal, tax or other advice, recommendation or research.

The information contained herein does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction in which such distribution or offer is not authorized.

This website may contain forward-looking statements on our current expectations and projections about future events. Statements that are predicative in nature, that depend upon or refer to future events or conditions or that include words such as “expects,” “anticipates,” “intends,” “plans,” “believes,” “estimates,” “thinks,” “seeks,” “targets,” “forecasts,” “could” or the negative of such terms or other variations on such terms or comparable terminology. Similarly, statements that describe Elliott’s objectives, plans or goals are forward-looking. Any forward-looking statements are based on Elliott’s current intent, belief, expectations, estimates and projections. These statements are not guarantees of future performance and involve risks, uncertainties, assumptions and other factors that are difficult to predict and that could cause actual results to differ materially. These factors include, among other things, (1) general economic and business conditions; (2) new governmental regulations and changes in, or the failure to comply with existing governmental regulation, (3) legislative proposals that impact our industry or the way we do business, (4) competition, and (5) our ability to attract and retain qualified personnel. Accordingly, you should not rely upon forward-looking statements as a prediction of actual results and actual results may vary materially from what is expressed in or indicated by the forward-looking statements.

No representation or warranty is given in respect of the correctness of the information contained herein as at any future date. Certain information included in this communication is based on information obtained from third-party sources considered to be reliable. Any projections or analysis provided to assist the recipient of this communication in evaluating the matters described herein may be based on subjective assessments and assumptions and may use one among alternative methodologies that produce different results. Accordingly, any projections or analysis should not be viewed as factual and should not be relied upon as an accurate prediction of future results. In addition, this website may contain performance and other data. Past performance is not indicative of future performance.

This website contains hyperlinks to websites operated by Elliott and other parties. Elliott does not control the content or accuracy of information on third-party websites and does not otherwise endorse the material placed on such sites.

All information and content on this website is furnished “AS IS,” without warranty of any kind, express or implied. Elliott will not assume any liability for any loss or damage of any kind arising, whether direct or indirect, caused by the use of any part of the information provided. Elliott and its licensors do not warrant that the content is accurate, reliable or correct; that the website will be available at any particular time or location; that any defects or errors will be corrected; that unauthorized access to or misappropriation of the content will not occur; or that the content is free of viruses or other harmful components. Your use of the website is solely at your risk.

The entire website is subject to copyright with all rights reserved. No permission is granted to copy, distribute, modify, post or frame any text, graphics, video, audio, software code, or user interface design or logos. The information contained in www.elliottmgmt.com shall not be published, rewritten for broadcast or publication or redistributed in any medium without prior written permission from Elliott.

Elliott Advisors (UK) Limited Disclaimers

Modern Slavery Act 2015 Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. EAUK does not tolerate any slavery or human trafficking practices within its business or within its supply chains.

Whilst it is acknowledged that risk factors are present in all global supply chains and across all sectors, EAUK considers that there is a relatively low risk of slavery, human trafficking and forced labour occurring within its business as a regulated, sub-investment advisor or within its supply chain.

EAUK has detailed below the following areas where it sees potential risks that need to be assessed and managed:

Direct Risk: EAUK complies with all applicable employment and human rights laws. EAUK’s employees are highly skilled professionals and EAUK has implemented robust procedures to ensure that the risk of employing a trafficked or exploited person within the business either directly, or through a subcontractor, recruitment agency or as a consultant is low.

Indirect Risk: EAUK’s supply chain primarily consists of regulated financial services providers, professional advisors (lawyers, accountants etc) and IT infrastructure and office services. EAUK regards each of these supplier categories to be at low risk of contravening the Act.

Additionally, when providing advice in respect of the acquisition of a controlling interest in a company, EAUK will seek to ensure that its risk assessment and due diligence process will include inquiries regarding the steps that any target company takes to combat modern slavery.

Actions:  EAUK will seek to require that new and, on renewal of a relevant contract, existing suppliers provide confirmation of their compliance with the Modern Slavery Act.

EAUK will continue to work to refine its risk assessment and due diligence process as they relate to advising entities on the acquisition of controlling interests in companies to include inquiries relating to how those companies go about combating modern slavery.

This Statement was approved by EAUK’s Board of Directors on 26 April 2019

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA’s Conduct of Business Sourcebook, Elliott Advisors (UK) Ltd. and Elliott Advisors (London) LLC (the “Firm") are required to include on this website a disclosure about the nature of their commitment to the UK Financial Reporting Council’s Stewardship Code (the “Code") or, where they do not commit to the Code, their alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with certain aspects of the Code, in which case they are required to explain their non-compliance.

The Firm pursues a multi-strategy investment approach, including strategies that involve investing in global equities, including UK equities. The Code is therefore only relevant to some aspects of the Firm’s trading. While the Firm generally supports the objectives that underlie the Code, the Firm has chosen not to commit to the Code. The Firm invests in a variety of asset classes and in a variety of jurisdictions. The approach/policies of the Firm in relation to engagement with issuers and their management are therefore determined globally, on a group wide basis. The Firm takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction.

Information for Disclosing Market Participants

On occasion Elliott Advisors (UK) Limited (“EAUK") / Elliott Advisors (London) LLC (“EALL") will be the recipient of a market sounding. A market sounding is an interaction between an issuer or a seller of financial instruments (or in certain circumstances, someone acting on their behalf) (together, the “Disclosing Market Participant" or “DMP") and one or more potential investors (the “Market Sounding Recipient" or “MSR"), prior to the announcement of a transaction in order to gauge the interest of MSRs in the possible transaction. The disclosure of inside information by a bidder prior to a takeover is also a market sounding.

In accordance with the rules and guidance prescribed by the EU Market Abuse Regulation, EAUK and EALL (as potential MSRs) have designated the following persons as contact points to receive market soundings:

  • Christopher Leonard, Assistant GC, Senior European and Compliance Counsel
  • Nicholas Barrett, Compliance Officer

The above parties can be reached at 020 3009 1818.


Shareholder Rights Directive II – Shareholder Engagement Policy

Shareholder Rights Directive II: Each of Elliott Advisors (UK) Limited and EALL, LLC (the “Firm”) is in the process of determining whether it is appropriate for it to develop a shareholder engagement policy and, if so, the form and scope of such a policy.