TIDMEBM TIDMEBMB TIDMEBMC TIDMBAP
RNS Number : 3999N
Harewood Structured Investment PCC
16 February 2009
HAREWOOD STRUCTURED INVESTMENT PCC LIMITED (the "Company")
Disclosure on Corporate Governance
In accordance with the requirements of the Regulations of the Budapest Stock
Exchange Ltd. and the Corporate Governance Recommendations prepared by the
Corporate Governance Committee of the Budapest Stock Exchange, the Company
announces its Corporate Governance Report as follows:
Harewood Structured Investment PCC Limited, a closed-ended protected cell
investment company, was incorporated with limited liability on 27 January 2005.
The Company is managed by its Board of directors who have appointed Harewood
Asset Management SAS of Paris, France as the Company's external investment
manager in respect of all cells, the shares in which are listed on the Channel
Islands Stock Exchange. No external investment manager has been appointed in
respect of the shares in BNP Paribas Agribusiness, the shares in which are
listed on the Budapest Stock Exchange. Administrative and secretarial support is
provided by Anson Fund Managers Limited in Guernsey, Channel Islands.
BNP Paribas SA acts as distributor and investment counterparty to each of the
Company's cells.
The Company is controlled by the "One Tier System". The Board of directors (the
"Managing Body") comprises John Le Prevost, Francois-Xavier Foucault, Youri
Siegel and Peter Atkinson, all of whom are non-executive directors. Biographies
of the directors are provided in the Company's annual financial report, a copy
of which can be downloaded from the Company's web-site
www.harewoodsolutions.co.uk/press.aspx. A hard copy of the report is available
from the Secretary, Anson Fund Managers Limited, upon request.
The directors' remuneration is fixed by the Managing Body and is not expected to
exceed GBP30,000 in aggregate for all directors in the financial year ended 31
October 2008. Francois-Xavier Foucault and Youri Siegel have waived their right
to remuneration by the Company in relation to their incumbencies as directors of
the Company.
The Managing Body has put in place a framework for corporate governance which it
believes is suitable for an investment company of its kind.
The Managing Body meets at least four times a year to consider the business and
affairs of the Company for the previous quarter and between those quarterly
meetings the Board meets to consider specific matters of a transactional nature
and there is regular contact with the Secretary. During the year under review
the Managing Body met 14 times. The directors are kept fully informed of
investment and financial controls and other matters that are relevant to the
business of the Company and should be brought to the attention of the directors.
The directors also have access, where necessary in the furtherance of their
duties, to professional advice at the expense of the Company.
The Managing Body has a breadth of experience relevant to the Company, and the
directors believe that any changes to the Managing Body's composition can be
managed without undue disruption. With any new director appointment to the
Managing Body, consideration will be given as to whether an induction process is
appropriate. In accordance with the provisions of the Combined Code on Corporate
Governance appended to the UKLA Listing Rules, the performance of the Managing
Body and each director is reviewed annually by the Managing Body and all
directors are subject by rotation to re-election at the Company's Annual General
Meeting.
An Audit Committee has been established consisting of all four directors. The
Audit Committee examines the effectiveness of the Company's internal control
systems, the annual and half-yearly financial reports, the auditors'
remuneration and terms of engagement, as well as the auditors' independence and
any non-audit services provided by them. The Audit Committee receives
information from the Secretary's compliance department and the external
auditors.
The Managing Body is responsible for the Company's system of internal control
and for reviewing its effectiveness. The Managing Body confirms that there is an
ongoing process for identifying, evaluating and managing the significant risks
faced by the Company. This process has been in place since the first formal
meeting of the Managing Body and is reviewed by the Managing Body regularly, at
least twice in each financial year.
The internal control systems are designed to meet the Company's particular needs
and the risks to which it is exposed. Accordingly, the internal control systems
are designed to manage rather than eliminate the risk of failure to achieve
business objectives and by their nature can only provide reasonable and not
absolute assurance against loss.
As a Guernsey-incorporated company listed on the Channel Islands Stock Exchange,
the Company and its Managing Body are required to comply with the Model Code for
securities transactions by directors of listed companies. The Model Code
restricts the freedom of directors and certain employees of listed companies to
deal in their company's securities. Its purpose is to ensure that directors,
certain employees and persons connected with them do not abuse, and do not place
themselves under suspicion of abusing, price-sensitive information that they may
have or be thought to have. They are prohibited from insider dealing. It is a
criminal offence for an individual who has information as an insider to deal on
a regulated market, or through or as a professional intermediary, in securities
whose price would be significantly affected if the inside information were made
public. It is also an offence to encourage insider dealing and to disclose
inside information with a view to others profiting from it.
Corporate Governance Declaration on Compliance with the Corporate Governance
Recommendations
As part of the Corporate Governance Report, by completing the following tables,
the company declares to what extent it applied in its own practice of corporate
governance the recommendations and suggestions formulated in the different
points of the Corporate Governance Recommendations published by the Budapest
Stock Exchange Ltd.
By reviewing the tables, market participants may receive information on the
extent to which the corporate governance practice of different companies meets
certain requirements included in the CGR, and may easily compare the practices
of the different companies.
Level of compliance with the Recommendations
The company should indicate whether it applies the relevant recommendation or
not, and in the case of a negative answer, it should provide the reasons for not
applying the given recommendation.
R 1.1.1 The Managing Body should ensure that shareholders receive access to
information in time to enable them to exercise their rights.
Yes (Complies)
R 1.1.2 In its equity structure, the company should apply the 'one share -
one vote' principle.
Yes (Complies), subject to the following provisions:
The holders of the Preference Shares shall not be entitled to receive notice of
or to attend or vote at any general meeting of the Company. However, Cell or
class Meetings may be held where the sanction by Special Resolution of those
Shareholders is required under the Articles for the purpose of a variation or
amendment to the rights attached to the Preference Shares in that class or Cell.
A Shareholder in a class or Cell present in person or represented in accordance
with the Articles at such a meeting shall on a poll have one vote in respect of
each relevant Preference Share registered in the name of such Shareholder. The
quorum for any cell or Class Meeting shall be the person or persons holding or
representing a clear majority (by amount paid up) of the issued Preference
Shares of that cell or Class or if at any adjourned meeting such a quorum is not
present, those Shareholders of the relevant Cell or class who are present in
person thereat shall be a quorum. Only Shareholders whose names appear on the
Register on the date of the meeting (or their authorised representatives or
proxies) are entitled to attend and vote at a meeting of the Company.
R 1.2.8 The company should not issue requirements for participation with the
intention of preventing the participation of particular shareholders.
No (Please explain)
The holders of the Preference Shares shall not be entitled to receive notice of
or to attend or vote at any general meeting of the Company. However, Cell or
class Meetings may be held where the sanction by Special Resolution of those
Shareholders is required under the Articles for the purpose of a variation or
amendment to the rights attached to the Preference Shares in that class or Cell.
R 1.2.9The description of the items on the agenda and the related proposals
should be clearly drafted and unambiguous, leaving no room for different
interpretations. It is recommended that the Managing Body does not include in
the agenda the discussion of issues that are not clearly definable. In addition
to the draft proposal of the Managing Body, proposals prepared for the items on
the agenda should include an explanation of the impact of the decision and the
opinion of the Supervisory Board.
Yes (Complies)
R 1.2.10 If comments or additional suggestions by shareholders are received
regarding proposals published in connection with the items included on the
agenda prior to the general meeting, the company should publish them in a
similar manner to the proposals within two days of receipt (but two days prior
to the general meeting at the latest), thus ensuring that shareholders and
market participants have the opportunity of becoming acquainted with them.
No (Please explain)
No such comments or supplements were submitted. In the event that
supplemental resolutions were proposed, notice of the proposed resolutions will
be given to all shareholders entitled to attend and vote t the meeting in
accordance with The Companies (Guernsey) Law, 2008 and the Company's Articles of
Association.
R 1.3.8 It is the responsibility of the Managing Body to ensure that written
comments on the agenda items of the general meeting are published two working
days prior to the general meeting. In the event that shareholders have not had
the opportunity before the day of the general meeting to become informed about
comments or modifying proposals related to any given issue on the agenda, it is
recommended that the Managing Body makes them available to shareholders at least
two hours before the start of the general meeting at the venue of the general
meeting, but at the time of registration at the latest.
No (Please explain)
No such comments were made.
Written comments made on the items on the agenda were published two working days
prior to the general meeting.
No (Please explain)
No such comments were made.
R 1.3.10 In the case of general meeting resolutions relating to the election and
dismissal of executive officers or members of the Supervisory Board, the
Chairman of the general meeting should not hold a combined vote. It is
recommended that an individual decision in the case of each candidate is made.
In the case of executive officers and members of the Supervisory Board who are
nominated with shareholder support, the name of the supporting shareholder
should also be disclosed on presenting the candidate.
No (Please explain)
The Company has no executives, so there are no such instances of election or
dismissal.
R 2.1.1The responsibilities of the Managing Body cover the following main areas:
a.) Participation in defining strategic guidelines and developing the
relevant strategy, supervision of business and financial plans, the execution of
major capital expenditure, acquisitions and divestitures;
b.) After discussion with the Supervisory Board, setting corporate objectives
and continuous monitoring of company performance, informing the Supervisory
Board about the achievement of these objectives;
c.) Ensuring the integrity of financial and accounting reports;
d.) Defining principles of remuneration for executives, monitoring executive
performance, initiating corrective measures if necessary;
e.) Managing cases of conflict of interest, approving the Code of Corporate
Ethics;
f.) Defining risk management guidelines to ensure that risk factors are
identified, and that internal control mechanisms, as well as appropriate
regulatory and monitoring systems, are in place to handle them, as well as
compliance with legal requirements;
g.) Defining the mechanism regarding the nomination of the members of the
Managing Body;
h.) Recommendations for the remuneration of members;
i.) Determining the basic principles and rules of succession;
j.) Defining guidelines for transparency of corporate operations and for
disclosure of information on the company, as well as monitoring compliance with
those guidelines;
k.) Continuous overseeing of the efficiency and effectiveness of corporate
governance;
l.) Ensuring adequate and timely communication with shareholders.
Yes (Complies)
R 2.3.1In order to perform their duties, the Managing Body and the Supervisory
Board should meet regularly at designated times outlined in their respective
work schedules. In addition, in the case of any extraordinary event or matter,
they should ensure that these are discussed in good time and that the
appropriate decisions are made. The boards should set out the dates and the
foreseeable agendas of the meetings in an annual or semi-annual order (work
schedule). In their rules of procedure the boards should allow for unscheduled
and/or emergency meetings, including decision-making by electronic means.
Yes (Complies)
The Supervisory Board held meetings regularly, at times designated in advance.
No (Please explain)
There is no Supervisory Board, as the Company is controlled by the One-Tier
System.
The rules of procedure of the Managing Body provide for unscheduled meetings and
decision-making through electronic communications channels.
Yes (Complies)
The rules of procedure of the Supervisory Board provide for unscheduled meetings
and decision-making through electronic communications channels.
No (Please explain)
There is no Supervisory Board, as the Company is controlled by the One-Tier
System.
R 2.5.1 To ensure the independence of the Management Board, it is recommended
that a sufficient number of independent members be elected, who have no
significant relationship with the company, its executive management or key
shareholders. (2005/162/EC 4.)
Yes (Complies)
R 2.5.4At regular intervals, the Managing Body should request confirmation of
independence from those of its members who are considered independent. It is
recommended that members confirm their independence in connection with the
preparation of the annual report on corporate governance. (2005/162/EC 13.3.2.)
Yes (Complies)
R 2.5.5 At regular intervals (in connection with the preparation of the annual
report on corporate governance), the Supervisory Board should request
confirmation of independence from those of its members who are considered
independent. (2005/162/EC 13.3.2.)
No (Please explain)
There is no Supervisory Board, as the Company is controlled by the One-Tier
System.
R 2.5.7On the company's website, the company should publish its guidelines on
the independence of the Managing Body, and the Supervisory Board, and the
applied criteria for independence.
No (Please explain)
The Company discloses in its annual financial reports all matters relating
to the independence of the Managing Body.
R 2.6.1 Members of the Managing Body should inform the Managing Body and (if
there is one operating) the Supervisory Board (in case of a unitary board
structure the Audit Committee) if he (or any other person in a close
relationship to him) has a significant, personal interest in a transaction of
the company (or of any of the company's subsidiaries).
Yes (Complies) (No such transactions)
R 2.6.2 Transactions and commissions between members of the Board and executive
management (or persons in a close relationship to them) and the company (or the
company's subsidiaries) should be conducted according to the general rules of
practice of the company, but, with stricter transparency rules in place. In the
case of a transaction outside the normal course of the company's business, the
transaction and its terms should be approved by the Supervisory Board or, in the
case of a unitary board structure, the Audit Committee.
Yes (Complies) (No such transactions)
Transactions which according to 2.6.2, fell outside the normal course of the
company's business, and their terms and conditions were approved by the
Supervisory Board (Audit Committee).
Yes (Complies) (No such transactions)
R 2.6.3 Board members should inform the Supervisory Board (or in the case of a
unitary board structure, the Audit Committee), and, if the company has one, the
Nomination Committee, if they receive an offer of Board membership or an offer
of an executive management position in a company which is not part of the
company group. On the basis of the information received from Board members, the
company should inform market participants.
Yes (Complies)
R 2.6.4 In order to prevent insider trading, the Managing Body should set up
guidelines on information flow within the company, the handling of insider
information, and insiders trading in securities and ensure that these guidelines
are complied with. It is the responsibility of the Managing Body to ensure that
the records concerning persons with access to insider information are kept in
accordance with the provisions of the law.
Yes (Complies)
The Managing Body established its guidelines regarding insiders' trading in
securities and monitored compliance with those guidelines.
No (Please explain)
As a Guernsey-incorporated company listed on the Channel Islands Stock
Exchange, the Company and its Managing Body are required to comply with the
Model Code for securities transactions by directors of listed companies, so it
is not considered necessary to establish separate guidelines on trading in the
Company's securities.
R 2.7.1 The Managing Body, as well as a committee set up from among the members
of the Managing Body should establish guidelines and rules ("Remuneration
Guidelines") concerning the performance and remuneration of the Managing Body,
the Supervisory Board and the executive management. The remuneration guidelines
formulated by the Managing Body should be assessed by the Supervisory Board, and
the rules of remuneration (and any major changes therein) for the Managing Body
and the Supervisory Board should be approved by the general meeting, as a
separate item on the agenda. (2004/913/EC 4.1.)
No (Please explain)
There is no Supervisory Board and there are no executive management. All
decisions relating to remuneration of the Managing Body are made by the Managing
Body having considered the best interests of the Company and its shareholders.
The Supervisory Board formed an opinion on the remuneration guidelines.
No (Please explain)
There is no Supervisory Board, as the Company is controlled by the One-Tier
System.
The guidelines regarding the remuneration for the Managing Body and the
Supervisory Board and the changes in those guidelines were approved by the
general meeting, as a separate item on the agenda.
No (Please explain)
There is no Supervisory Board and there are no executive management. As all
expenses of the Company are borne by a third party, it is not considered
necessary or appropriate for the Company's shareholders to approve guidelines
for the remuneration of the Managing Body.
R 2.7.2 The Managing Body and the Supervisory Board should evaluate the
performance of the Board(s) annually. (2005/162/EC 8.)
Yes (Complies)
The Supervisory Board prepared an evaluation of the work it carried out in the
given business year.
No (Please explain)
There is no Supervisory Board, as the Company is controlled by the One-Tier
System.
R2.7.3The responsibilities of the Managing Body should include control over the
performance and establishment of the remuneration (including incentive payments,
share options, special contracts, agreements and other allowances) of the
executive management. It is recommended that this duty is performed on the basis
of the Remuneration Committee's proposal (See 3.4). In order to avoid conflict
of interest, it is recommended that the system of option and share allotments,
the terms of individual loans granted by the company, and the framework for
other benefits applied by the company (and significant changes in them), if they
do not represent normal practice, should be approved by the general meeting as a
separate agenda item (2004/913/EC 6.1.). The Managing Body should pass a
resolution to determine the persons whose remuneration falls under the review of
the Board.
No (Please explain)
There is no executive management.
The frameworks of benefits due to members of the executive management that do
not represent normal practice, and the changes in those benefits were approved
by the general meeting as a separate agenda item.
No (Please explain)
There is no executive management.
R 2.7.4In the case of share-based remuneration schemes, the structure should be
approved by the general meeting, as well as the amount of actual remuneration in
the case of Managing Body and Supervisory Board members. In the case of the
members of the executive management, the level of actual remuneration is not the
responsibility of the general meeting.
Before voting, shareholders should be provided with detailed information on
the share-based remuneration schemes (and any amendments to them), how the
company provides the necessary shares and what cost this entails. (2004/913/EC
7.1.-7.2.)
No (Please explain)
There are no share incentive schemes.
Prior to the decision by the general meeting on share-incentive schemes,
shareholders received detailed information (at least according to those
contained in 2.7.4).
No (Please explain)
There are no share incentive schemes.
R 2.7.7 On the remuneration principles and the actual remuneration of the
members of the Managing Body, the Supervisory Board and the executive management
the company should provide information ("Remuneration Statement - 0) for
shareholders which should be submitted to the general meeting. The Remuneration
Statement should contain the remuneration of each member of the Managing Body,
the Supervisory Board and the executive management..
No (Please explain)
As all expenses of the Company are borne by a third party, it is not
considered necessary or appropriate for the Company's shareholders to approve
receive a separate remuneration statement. All expenses incurred by the Company
are fully disclosed in the annual financial report sent to all shareholders.
The Remuneration Statement includes information about the remuneration of
individual members of the Managing Body, the Supervisory Board, and the
executive management.
No (Please explain)
For the reasons stated above, no separate reumuneration statement is
prepared.
R 2.8.1The Managing Body or a committee operated by it should have
responsibility for overseeing and controlling the complete risk management of
the company and should, at regular intervals, be obliged to look into the
effectiveness of risk management procedures. A report on risk management control
should be submitted to the annual general meeting in the report on corporate
governance. In order to ensure the successful operation of the company, it is
the duty of the Managing Body to take measures necessary to identify major risk
areas.
Yes (Complies)
The Managing Body requests information on the efficiency of risk management
procedures at regular intervals.
Yes (Complies)
The Managing Body took the necessary steps to identify the major risk areas.
Yes (Complies)
R 2.8.3 It is the duty and responsibility of the Managing Body to formulate
principles regarding the system of internal controls and to ensure the
development of a reliable system of internal controls by the executive
management which ensures the management of risks affecting the operation of the
company and the achievement of the company's performance and profit targets.
Yes (Complies)
The system of internal controls established by the executive management
guarantees the management of risks affecting the activities of the company, and
the achievement of the company's performance and profit targets.
No (Please explain)
There is no executive management. The Managing Body regularly reviews and
agrees policies for managing the risks relevant to the Company. As a
closed-ended investment company with fixed investment portfolios, the Company
has no performance and profit targets.
R 2.8.4When establishing the guidelines on the system of internal controls, the
Managing Body should take into consideration:
a.)what kind of risks and what degree of risk the company is exposed to during
its operation;
b.)what kind of risks and what degree of risk the company considers acceptable;
c.)what kind of risks the company considers important;
d.)what measures the company can apply to reduce the risks in the operations of
the company;
what the proportion is between the quantity and quality of the company's risk
management and internal control resources and the efficiency expected in these
areas.
Yes (Complies)
R 2.8.5 It is the executive management's task and responsibility to establish
and maintain a system of internal controls.
No (Please explain)
There is no executive management. An Audit Committee has been established
consisting of all four directors. The Audit Committee examines the effectiveness
of the Company's internal control systems.
R 2.8.6 As an integral part of the system of internal controls, it is
recommended that the company sets up an independent internal audit function
("Internal Audit") which reports directly to the Audit Committee. At least once
annually, it should prepare a report on the operation of risk management,
internal control mechanisms and governance functions. In its report on the
operation of internal controls, the Internal Audit should provide information on
deficiencies that may have a significant effect on the performance of the
company.
No (Please explain)
The Company does not have an internal audit department. All the Company's
management and administration functions are delegated to independent third
parties and it is therefore felt there is no need for the Company to have an
internal audit facility. However, this matter is reviewed periodically.
The Internal Audit reported at least once to the Audit Committee on the
operation of risk management, internal control mechanisms and corporate
governance functions.
No (Please explain)
The Company does not have an internal audit department for the reasons set
out above.
R 2.8.7 On the basis of authorisation by the Managing Body or the Supervisory
Board, the Audit Committee should assign to the Internal Audit the execution of
the monitoring activity specified in the internal audit strategy, the annual
plan, and the internal audit charter and manual. Within this framework, it
should provide unlimited access to all necessary information, documents, data
and persons involved in the activity or process under review. To maintain his
independence, the head of the Internal Audit should report directly to the
Managing Body or the Supervisory Board (in the case of a unitary board
structure, to the Audit Committee).
No (Please explain)
The Company does not have an internal audit department for the reasons set
out above.
As an organisation, the Internal Audit function is independent from the
executive management.
No (Please explain)
The Company does not have an internal audit department for the reasons set
out above, nor is there any executive management.
R 2.8.8 On the basis of the anticipated financial, operational, regulatory and
other risks of the company, and with the involvement of the executive
management, the head of the Internal Audit prepares an internal control
schedule, which, on the recommendation of the Audit Committee, is approved by
the Managing Body or the Supervisory Board.
No (Please explain)
The Company does not have an internal audit department for the reasons set
out above.
R 2.8.9 The Managing Body should regularly review the reports on the operation
of internal controls (prepared by the executive management or the Internal
Audit), on the basis of which - as part of the report on corporate governance -
it prepares an annual evaluation for shareholders. The Managing Body should
establish procedures regulating the processing and acceptance of reports and the
preparation of its annual report on the operation of the system of internal
controls.
Yes (Complies)
The Managing Body developed its procedures regarding the receipt,
processing of reports on the operation of internal controls, and the preparation
of its own report.
Yes (Complies)
R 2.8.11 If the Managing Body detects an important deficiency or flaw in the
system of internal controls, it should attempt to eliminate the deficiency. The
Managing Body should identify the cause of the flaw or deficiency, and the
situation which brought about the problem; it should review and re-evaluate the
executive management or the Internal Audit's (planning, operational and
continuous monitoring) activity regarding the systems of internal controls.
Yes (Complies)
R 2.9.2In the event that the company or its management give an assignment to the
company's auditor to provide other professional services, the Managing Body, the
Supervisory Board and the Audit Committee should be notified in all cases when
the fee for the services, the type of the service or any other circumstance may
result in significant additional expenses for the shareholders or may cause a
conflict of interest, or affect normal business practices significantly in any
other way.
No (Please explain)
Complies in all respects except that there is no Supervisory Board, as the
Company is controlled by the One-Tier System.
R 2.9.3If the auditor or an external advisor is assigned to audit an event that
has significant bearing on the company's operations, the Managing Body should
inform the Supervisory Board (Audit Committee) and shareholders about the event
and the type of assignment given to such external auditor. The Managing Body
should pre-determine in its resolutions what circumstances constitute
'significant bearing'.
No (Please explain)
There is no Supervisory Board, as the Company is controlled by the One-Tier
System.
The Managing Body pre-determined in a resolution what circumstances
constitute "significant bearing".
No (Please explain)
No such assignments are ordinarily given to the external auditor. Where such
assignment was to be given, it would be the subject of a separate Letter of
Engagement, which Letter of Engagement would be considered by the Managing Body
in consultation with its advisors before being executed.
R 3.1.6On its website, the company should publish the tasks delegated to the
committee, the goals of the committee, its rules of procedure, composition (with
members' names, short professional biography and date of nomination).
No (Please explain)
The Company has an Audit Committee. The duties of the Audit Committee are
disclosed to shareholders in the Company's annual financial report.
R 3.2.1 In addition to tasks specified by law, the Audit Committee should
monitor the efficiency of risk management, the operation of the internal control
system, and the Internal Audit activities.
No (Please explain)
As stated above, the Company has no internal audit function. The Audit
Committee examines the effectiveness of the Company's internal control systems,
the annual and interim reports and financial statements, the auditors'
remuneration and engagement, as well as the auditors' independence and any
non-audit services provided by them. The Audit Committee receives information
from the Secretary's compliance department and the external auditors.
R 3.2.3 In order to be able to perform its duties, the Audit Committee should
receive accurate and detailed information about the work schedule of the
Internal Audit and the company's auditor, and should receive the auditor's
report on problems discovered during the audit.
No (Please explain)
The Company complies with this recommendation except for the absence of an
internal auditor.
R 3.2.4 Before nominating a new auditor, the Audit Committee should request a
written statement from the candidate in which the auditor discloses any
connection between himself (or a close relative) and a member of the Managing
Body of the company (and the company's subsidiary), or a member of the
Supervisory Board or the executive management.
Yes (Complies)
R 3.3.1 The general meeting (or on the basis of authorisation by the general
meeting, the Managing Body) should set up a Nomination Committee from the
members of the Managing Body, which assists in selecting members for the
Managing Body, the Supervisory Board, and the Chief Executive Officer.
No (Please explain)
The members of the Managing Body consider new appointments although there is no
separate nomination committee. The Managing Body or other appropriate persons
give new appointees to the Managing Body a preliminary briefing on the workings
of the Company. When appointing a new director, the Managing Body takes care to
ensure that there is a balance of skills and experience appropriate to the
requirements of the Company and that new directors will have enough time
available to devote to the affairs of the Company.
R 3.3.2 The Nomination Committee should ensure the preparation of personnel
changes with the aim that the replacement of a Managing Body member leaving due
to retirement, resignation or any other reason, or the succession of members of
the executive management is carried out smoothly, with the company's work
continuing uninterrupted. The Nomination Committee examines the practice of the
Managing Body for selecting and appointing members of the executive management,
assesses the performance of members of the Managing Body, the Supervisory Board,
and the executive management (and the suitability of candidates). The Nomination
Committee examines all suggestions relating to the nomination of Board members
which are submitted by the shareholders or the Managing Body.
No (Please explain)
As disclosed above, there is no separate Nomination Committee.
The Nomination Committee reviewed the procedures regarding the election and
appointment of members of the executive management.
No (Please explain)
As disclosed above, there is no separate Nomination Committee.
The Nomination Committee evaluated the activity of board and executive
management members.
No (Please explain)
As disclosed above, there is no separate Nomination Committee.
The Nomination Committee examined all the proposals regarding the nomination of
board members which were submitted by shareholders or the Managing Body.
No (Please explain)
As disclosed above, there is no separate Nomination Committee.
R 3.4.1The general meeting (or on the basis of authorisation by the general
meeting, the Managing Body) should set up a Remuneration Committee from the
members of the Managing Body, which assists in outlining the principles of the
remuneration of the members of the Managing Body, the Supervisory Board and the
executive management.
No (Please explain)
There is no Remuneration Committee. All decisions relating to remuneration
of the Managing Body are made by the Managing Body having considered the best
interests of the Company and its shareholders.
R 3.4.2The Remuneration Committee should make a proposal for the system of
remuneration of the Managing Body, the Supervisory Board and the executive
management (individual level and structure of fees), and carry out a review,
ensuring adequate structure and transparency. (2005/162/EC App. I. 3.2.) No
member of the Managing Body may participate in formulating a suggestion on his
own remuneration.
No (Please explain)
There is no Remuneration Committee nor executive management.
R 3.4.3 The Remuneration Committee should prepare proposal packages for the
Managing Body, to be discussed and approved, in the case of the executive
management, by the Managing Body, in the case of the Managing Body, by the
general meeting. It is the task of the Committee to exercise control over the
system of share options, cost reimbursements and allowances (agreements on
pensions, severance pay) contained in the remuneration of the Board members and
the members of the executive management. (2005/162/EC App. I. 3.2.)
No (Please explain)
There is no executive management.
The remuneration of the Managing Body was approved by the general meeting
based on the recommendation of the Remuneration Committee.
No (Please explain)
There is no Remuneration Committee. As all expenses incurred by the Company
are borne by a third party, it is not considered necessary for shareholders to
be consulted on the remuneration of the Managing Body.
The Remuneration Committee also monitored the share option, cost
reimbursement and other benefits in the remuneration system.
No (Please explain)
There are no share options and other benefits in the remuneration system.
R 3.4.4In addition to remuneration guidelines and proposals on the remuneration
of given individuals, the Remuneration Committee should also deal with the terms
of agreements concluded with members of the executive management, and ascertain
whether the company has fulfilled its publication obligations regarding issues
of remuneration. (2005/162/EC App. I. 3.2.)
No (Please explain)
There is no Remuneration Committee.
The Remuneration Committee reviewed the terms and conditions of contracts
concluded with the members of the executive management.
No (Please explain)
There is no Remuneration Committee nor executive management.
The Remuneration Committee ascertained whether the company fulfilled its
disclosure obligations regarding remuneration issues.
No (Please explain)
There is no Remuneration Committee.
R 3.4.7 The majority of the members of the Remuneration Committee should be
independent. (2005/162/EC App. I. 3.1.2.)
No (Please explain)
There is no Remuneration Committee.
R 3.5.1When setting up the committees, the Managing Body may decide that the
duties of the Nomination Committee and the Remuneration Committee will be
executed by one (merged board) committee. In this case, an explanation should be
given as to the causes of the decision, and it should be indicated how,
according to the Managing Body, the committees, with a reduced number of
members, will be able to achieve the general goals of two (remuneration and
nomination) committees. (2005/162/EC 7.1.)
No (Please explain)
The Company has no Remuneration Committee nor Nomination Committee.
R 3.5.2In the case of a small number of members, the Managing Body may carry out
the duties of the Nomination and Remuneration Committees, if it meets the
requirements regarding the composition of the given committee and provides
adequate information on this. (2005/162/EC 7.2.)
Yes (Complies)
R 4.1.1In its disclosure guidelines, the Managing Body - if it considers it
necessary - may adopt guidelines and procedures which ensure that all relevant
information on the operations of the company and circumstances influencing its
share price are disclosed accurately, in time and in full, and that it is
available to market participants at the same time. It is the responsibility of
the Managing Body to provide adequate information to shareholders and other
stakeholders about the company's key issues, strategic goals, and about how the
company manages risks and handles issues of conflict of interest.
Yes (Complies)
R 4.1.2When providing information, the company should ensure that all
shareholders and market participants are treated equally. The company should not
give preference to any group of market participants over others (it is
especially important to keep this in mind during press discussions, analysts
meetings and conferences).
Yes (Complies)
R 4.1.3 The company's disclosure guidelines (basic principles and procedures
relating to disclosures) should ensure that information intended for disclosure
is published as soon as possible, and for that reason, the company's disclosure
principles should cover the procedures for electronic, on-line disclosure. The
company should attempt to ensure that disclosed information is available to all
shareholders at reasonable cost and at the same time. The company should develop
its website by taking into consideration disclosure principles and the
notification of investors.
Yes (Complies)
The company develops its website taking into consideration disclosure
guidelines and the provision of information to investors.
Yes (Complies)
R 4.1.4 The Managing Body should determine methods by which it measures the
significance of company events and new businesses in order to continuously
inform the shareholders. The Managing Body should assess the efficiency of
disclosure procedures.
Yes (Complies)
R 4.1.5 Prior to a given business year, the company should publish on its
website a corporate events calendar, which informs market participants of the
timing of the publication of the company's most important announcements
(financial reports) and the expected dates of the anticipated major events
(planned dates of general meetings, investors' meetings, road shows).
No (Please explain)
The company has no corporate events calendar. All corporate events are
notified to all shareholders via a Regulatory Information Service and to all
exchanges on which the Company's preference shares are listed.
R 4.1.6 The public should be informed of the company's corporate strategy, its
main business activities, business ethics, and its guidelines regarding other
stakeholders. The company's strategic goals should appear in the annual report,
as well as on the company's website. (2005/162/EC 9.2.)
Yes (Complies)
R 4.1.8 In the annual report, the Managing Body should disclose the character
and size of any other assignments given by the company or its subsidiaries to
the auditing firm in charge of auditing the financial statements.
Yes (Complies)
R 4.1.9In its annual report and on its website, the company should disclose
information on the professional career of the members of the Managing Body, the
Supervisory Board and the executive management.
Yes (Complies)
Complies, except that there is no Supervisory Board nor executive
management.
R 4.1.10 The company should publish information about the internal structure and
operations of both the Managing Body and the Supervisory Board, and the criteria
considered when evaluating the work of the Managing Body and the executive
management, as well as of the individual members. The information should also
include whether evaluation carried out in the relevant period has resulted in
any changes. (2005/162/EC 9.1.)
Yes (Complies)
Complies, except that there is no Supervisory Board nor executive
management.
R 4.1.11 It is recommended that, after considering all the factors influencing
the company's operations, in a manner acceptable to the company, the company
should provide information to the public in a "Remuneration Statement" in its
annual report and on its website on the remuneration guidelines applied by the
company, in which it informs its owners about the remuneration provided for
members of the Managing Body, the Supervisory Board and the executive
management. (2004/913/EC 3.1.)
It is recommended that the Remuneration Statement should explain the
guidelines relating to the members of the Managing Body, the Supervisory Board
and the executive management, according to which their performance is evaluated
and their remuneration is established. The disclosure should contain the amount
of aggregate remuneration of the Managing Body and the Supervisory Board,
detailing the fixed and variable components, any other benefits, and an outline
of the guidelines for the remuneration system, as well as major changes as
compared to the previous financial year. (2004/913/EC 3.2.)
In addition to information about the given business year, it is recommended that
the Remuneration Statement covers the remuneration framework for members of the
Managing Body, the Supervisory Board and the executive management for the
following year (or preferably years) with information on major changes in
remuneration.
The Remuneration Statement should contain the following information on the
guidelines for the remuneration of members of the Managing Body, the Supervisory
Board and the executive management:
-the proportion of variable (connected to a variable factor) and non-variable
components in the remuneration (2004/913/EC 3.3. a) );
-performance criteria forming the basis of entitlement regarding a share option,
share allotment or other variable remuneration element; (2004/913/EC 3.3. b) );
-link between remuneration and performance criteria (2004/913/EC 3.3. c) );
-main features of annual bonuses or any non-cash benefits, and the entitlement
thereto(2004/913/EC 3.3. d) );
-the description of the main features of any supplementary pension and early
retirement scheme (2004/913/EC 3.3. e) );
-a short description of the preparatory and decision-making process for the
determination of the principles of remuneration, the mandate and composition of
the Remuneration Committee, the names of external advisors; the description of
decision-making authorities (committees, general meeting) (2004/913/EC 3.5.)
-
and also cover the following elements:
-contract terms and conditions of executive members of the Managing Body (with
special regard to contract terms, notice period) (2004/913/EC 3.4.)
-
It is recommended that the Remuneration Statement - in the case of persons
fulfilling functions in the given business year in the Managing Body,
Supervisory Board and executive management - should include the following for
each person separately:
-fees paid, other payments (including attendance fees for a function fulfilled
in the Managing Body, or profit sharing with reasons shown; or additional
remuneration) in absolute amounts (2004/913/EC 5.3. a), c), d) );
-remuneration received from the subsidiaries of the company's Group (financial
benefits and other advantages) (2004/913/EC 5.3. b) );
-in the case of the executive members of the Managing Body, compensation paid in
connection with the termination of their activities (2004/913/EC 5.3. e) );
-loans, deposits and guarantees provided by the company or the company's
subsidiaries (i.e. companies consolidated in the financial accounts);
-the estimated value of non-cash benefits considered as remuneration components
in addition to the above (2004/913/EC 5.3. f) ).
-
The Remuneration Statement should give detailed information on the conditions of
the share incentive scheme to which members of the Managing Body, the
Supervisory Board and the executive management are entitled, as well as on the
cost to the company of maintaining these schemes (provision of securities, other
costs).
As regards shares, share options (or other share incentive schemes):
-in the relevant year, the number of share options or shares offered, and
detailed conditions of application (2004/913/EC 5.4. a) );
-the number of share options exercised and the number of shares affected, giving
the exercise price, the extent of the shareholding which the acquired shares
represent (2004/913/EC 5.4. b) );
-information regarding share options not exercised - exercise price, exercise
date, main conditions for the exercise of the right (2004/913/EC 5.4. c) );
annual changes in the terms of share options (2004/913/EC 5.4. d) and
In the case of supplementary pensions schemes (depending on the type of system)
in the financial year:
-accrued benefits under that scheme (2004/913/EC 5.5. a) );
-contributions paid (or payable) by the company (2004/913/EC 5.5. b) ).
The company is not obliged to disclose information of a commercially
sensitive nature, but it should justify the reasons for not disclosing any
information on remuneration in the Remuneration Statement. (2004/913/EC 3.3.).
No (Please explain)
As all expenses of the Company are borne by a third party, it is not
considered necessary or appropriate for the Company's shareholders to approve
receive a separate remuneration statement. All expenses incurred by the Company
are fully disclosed in the annual financial report sent to all shareholders.
There is no Supervisory Board and there are no executive management.
R 4.1.12 The Managing Body should disclose the risk management guidelines
ensuring that all significant risks of internal and external operational,
financial and legal compliance and other risks are evaluated and managed
adequately by a sound internal mechanism. The disclosure should include the
review of the system of internal controls, adopted risk management policy and
main areas of risk management.
Yes (Complies)
R 4.1.13 In order to provide adequate information to market participants the
company should submit to the general meeting for approval and, simultaneously
with the publication of the annual report, disclose on its website its Corporate
Governance Report. The Managing Body should declare to what extent it actually
adopts corporate governance set out in the present document. The Managing Body
should specify those principles from which the company deviated in the relevant
year and should provide reasons why the relevant recommendations were not
applied.
Yes (Complies)
R 4.1.14 A company should disclose on its website its guidelines on insider
trading in the company's shares. Ownership of the company's securities and
interest in any company share-incentive scheme of the members of the Managing
Body, the Supervisory Board and the executive management should be disclosed in
the annual report and on the company's website.
No (Please explain)
As a Guernsey-incorporated company listed on the Channel Islands Stock
Exchange, the Company and its Managing Body are required to comply with the
Model Code for securities transactions by directors of listed companies, so it
is not considered necessary to establish separate guidelines on trading in the
Company's securities.
The company published in the annual report and on its website ownership in
the company's securities held by the members of the Managing Body, the
Supervisory Board and the executive management, as well as any interests held in
share-incentive schemes.
Yes (Complies)
Complies, except that there is no Supervisory Body nor executive management
and there are no share incentive schemes in place.
R 4.1.15 Without revealing trade secrets, any relationship between members of
the Managing Body or the executive management and a third party which might have
an influence on the operation of the company should be disclosed in the annual
report and on the company's website.
Yes (Complies)
Level of compliance with the Suggestions
The company should indicate whether the relevant suggestion of the CGR is
applied or not (- Yes / No)
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.1.3 | The company has an investor relations department. | Yes |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.1 | The company published on its website the summary document regarding the conducting of | No |
| | the general meeting and the exercise of shareholders' rights to vote (including voting | |
| | via proxy) | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.2 | The company's articles of association are available on the company's website. | No |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.3 | The company disclosed on its website information according to 1.2.3 (on the record | No |
| | date of corporate events). | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.4 | Information and documents according to 1.2.4 regarding general meetings (invitations, | No |
| | proposals, draft resolutions, resolutions, minutes) were published on the company's | |
| | website. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.5 | The general meeting of the company was held in a way that ensured the greatest | Yes |
| | possible shareholder participation. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.6 | Additions to the agenda were published within 5 days of receipt, in the same manner as | No |
| | the publication of the original invitation for the general meeting. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.7 | The voting procedure applied by the company ensured unambiguous, clear and fast | Yes |
| | decision-making by shareholders. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.2.11 | At the shareholders' request, the company also provided information on the general | No |
| | meeting electronically. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.1 | The identity of the chairman of the general meeting was approved by the company's | Yes |
| | general meeting prior to the discussion of the items on the agenda. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.2 | The Managing Body and the Supervisory Board were represented at the general meeting. | Yes |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.3 | The company's articles of association render possible that at the initiation of the | Yes |
| | chairman of the Managing Body or the shareholders of the company, a third party be | |
| | invited to the company's general meeting and be granted the right of participation in | |
| | the discussion of the relevant items on the agenda. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.4 | The company did not prevent shareholders attending the general meeting from exercising | No |
| | their rights to request information, make comments and proposals, and did not set any | |
| | pre-requisites to do so. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.5 | The company published on its website within three days its answers to those questions | No |
| | which it was unable to answer satisfactorily at the general meeting. Where the company | |
| | declined to give an answer it published its reasons for doing so. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.6 | The chairman of the general meeting and the company ensured that in answering the | Yes |
| | questions raised at the general meeting, national laws and regulations of the Stock | |
| | Exchange pertaining to disclosure were complied with. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.7 | The company published a press release and held a press conference on the decisions | No |
| | passed at the general meeting. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.11 | The company's general meeting decided on the different amendments of the articles of | No |
| | association in separate resolutions. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.3.12 | The minutes of the general meeting containing the resolutions, the presentation of | No |
| | draft resolutions, as well as the most important questions and answers regarding the | |
| | draft resolutions were published by the company within 30 days of the general meeting. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.4.1 | The dividend was paid within 10 days to those shareholders who had provided all the | Yes |
| | necessary information and documentation. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 1.4.2 | The company disclosed its policy regarding anti-takeover devices. | No |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.1.2 | The rules of procedure define the composition of the Managing Body and all procedures | Yes |
| | and protocols for the preparation and holding of meetings, the drafting of resolutions | |
| | and other related matters. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.2.1 | The rules of procedure and the work schedule of the Supervisory Board gives a detailed | No |
| | description of its operation and duties, as well as procedures and processes which the | |
| | Supervisory Board followed. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.3.2 | Board members had access to the proposals of a given meeting at least five days prior | Yes |
| | to the board meeting. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.3.3 | The rules of procedure regulate the regular or occasional participation at board | Yes |
| | meetings of persons who are not members of the boards. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.4.1 | The election of the members of the Managing Body took place in a transparent way, | No |
| | information on candidates was made public at least five days prior to the general | |
| | meeting. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.4.2 | The composition of boards and the number of members complies with the principles | No |
| | specified in 2.4.2. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.4.3 | Newly elected, non-executive board members were able to familiarize themselves with | Yes |
| | the structure and operations of the company, as well as their duties as board members | |
| | through a tailored induction programme. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.5.2 | The separation of the responsibilities of the Chairman of the Managing Body from those | No |
| | of the Chief Executive Officer has been outlined in the basic documents of the | |
| | company. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.5.3 | The company has published a statement about the means it uses to ensure that the | No |
| | Managing Body gives an objective assessment of the executive management's work where | |
| | the functions of Chairman and CEO are combined. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.5.6 | The company's Supervisory Board has no member who held a position in the Managing Body | No |
| | or the executive management of the company in the three years prior to his nomination. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.7.5 | The development of the remuneration system of the Managing Body, the Supervisory Board | Yes |
| | and the executive management serves the strategic interests of the company and thereby | |
| | those of the shareholders. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.7.6 | In the case of members of the Supervisory Board, the company applies a fixed amount of | No |
| | remuneration and does not apply a remuneration component related to the share price. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.8.2 | The Managing Body developed its risk management policy and regulations with the | Yes |
| | cooperation of those executives who are responsible for the design, maintenance and | |
| | control of risk management procedures and their integration into the company's daily | |
| | operations. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.8.10 | When evaluating the system of internal controls, the Managing Body took into | Yes |
| | consideration the aspects mentioned in 2.8.10. | |
| | | |
| | | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.8.12 | The company's auditor assessed and evaluated the company's risk management systems and | Yes |
| | the risk management activity of the executive management, and submitted its report on | |
| | the matter to the Audit Committee. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.9.1 | The rules of procedure of the Managing Body, the Supervisory Board and the committees | Yes |
| | cover the procedure to be followed when employing an external advisor. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.9.4 | The Managing Body may invite the company's auditor to participate in those meetings | Yes |
| | where it debates general meeting agenda items. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 2.9.5 | The company's Internal Audit function co-operated with the auditor in order to help it | No |
| | successfully carry out the audit. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.1.2 | The chairmen of the Audit Committee, Nomination Committee, Remuneration Committee (and | Yes |
| | any other committees operating at the company) regularly inform the Managing Body | |
| | about the meetings of the committee, and the committees prepared at least one report | |
| | for the Managing Body and the Supervisory Board in the given business year. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.1.4 | The company's committees are made up of members who have the capabilities, | Yes |
| | professional expertise and experience required to perform their duties. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.1.5 | The rules of procedure of committees operating at the company include those aspects | Yes |
| | detailed in 3.1.5. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.2.2 | The members of the Audit Committee were fully informed about the accounting, financial | Yes |
| | and operational peculiarities of the company. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.3.3 | The Nomination Committee prepared at least one evaluation for the chairman of the | No |
| | Managing Body on the operation of the Managing Body and the work and suitability of | |
| | the members of the Managing Body. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.3.4 | The majority of the members of the Nomination Committee are independent. | No |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.3.5 | The rules of procedure of the Nomination Committee includes those details contained in | No |
| | 3.3.5. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.4.5 | The Remuneration Committee prepared the Remuneration Statement. | No |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 3.4.6 | The Remuneration Committee exclusively consists of non-executive members of the | No |
| | Managing Body. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 4.1.4 | The disclosure guidelines of the company at least extend to those details contained in | Yes |
| | 4.1.4. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| | The Managing Body informed shareholders in the annual report on the findings of the | No |
| | investigation into the efficiency of disclosure procedures. | |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 4.1.7 | The company's financial reports followed IFRS guidelines. | Yes |
+------------+----------------------------------------------------------------------------------------+-----------+
| S 4.1.16 | The company also prepares and releases its disclosures in English. | Yes |
+------------+----------------------------------------------------------------------------------------+-----------+
For further information contact:
BNP Paribas
Tel: 44 207 595 8442 or E-mail: EQD_CEE@bnpparibas.com
Anson Fund Managers Limited
Secretary
Tel: Guernsey 44 1481 722260
16 February 2009
END OF ANNOUNCEMENT
E&OE - In transmission
This information is provided by RNS
The company news service from the London Stock Exchange
END
STRSFSFMMSUSEFE
Bnp Energy(2) (LSE:EBMB)
Gráfico Histórico do Ativo
De Abr 2024 até Mai 2024
Bnp Energy(2) (LSE:EBMB)
Gráfico Histórico do Ativo
De Mai 2023 até Mai 2024
