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  • 1. Citywire MontreuxStephen Zinser – Chief Executive Officer / Chief Investment OfficerNicholas Cranston – Marketing DirectorJoao De Vasconcellos – Marketing DirectorAlfonso De Maqua – Marketing Director11th – 13th May 2011
  • 2. European Credit Management LtdCompany Overview
  • 3. European Credit ManagementECM credit funds offer diversified exposure to European credit on a duration neutral basisECM has expertise across full range of sectors within the European credit universe:  Investment Grade Corporates Senior Secured Loans  Bank Capital € 1,565m Asset Backed € 2,345m  ABS High Yield € 863m  Senior Secured Loans European Emering Markets Bank Capital  High Yield € 445m € 1,108m  European Emerging Markets Corporate Bonds  Distressed Debt / Special Situations € 3,091m Source: ECM. 4th May 2011 AUTHORISED AND REGULATED BY THE FSA 3
  • 4. Credit Market OverviewSetting the scene
  • 5. ECM 2011 view – constructive on credit markets and abilityto generate outsized excess returns ECM remains vigilant with respect to macro, sovereign and equity market “tail risks” and is well positioned for renewed volatility U.S. / global macro-economy showing reasonable growth momentum Credit technicals positive outside the European periphery Corporate earnings expected to be supportive Central bank policies still supportive of credit markets although ECB adopting a more hawkish stance and Fed’s QE2 measures expire in June Ongoing risks associated with banking sector, government and individual de-leveraging Interest rate and FX markets vulnerable to rising inflation and macro imbalances – ECM programmes hedged Significant Q1 news flow including enlargement of EFSF facility, burden sharing legislation and BIS III clarifications AUTHORISED AND REGULATED BY THE FSA 5
  • 6. Q2 2011 ECM credit strategy –Retain near term cautious stance  Favour Lower Tier 2 on a selective basis avoiding peripherals. BIS III announcements are positive but we have reduced subordinated financials into strong market rally from Q3 2010 onwards  Hold/Add valuation stressed but ‘money good’ portfolio exposures - including selective ABS  Investment Grade Corporates: Bonds to remain a relative safe haven – fundamentals robust  Sub Investment Grade: Opportunistic. Favour Senior Leveraged Loans and better quality High Yield  Maintain de minimis leveraged exposure (where permitted) to market with significant financial flexibility to exploit market corrections  Credit markets should prove relatively resilient to equity / macro volatility AUTHORISED AND REGULATED BY THE FSA 6
  • 7. European Credit Fund SICAV: ELBE Sub-FundFund Current Status & Performance Review
  • 8. European Credit Fund SICAV: ELBE Sub-Fund Elbe targets a net return of benchmark plus an excess return of 200-300 bps per annum over Euribor in the medium to long term But because current spreads significantly overcompensate for credit quality deterioration and defaults, net annual excess returns in the short to medium term are targeted in the 6-8% pa range Elbe provides broad diversification:  Contains credit securities issued by 292 different European obligors  AUM of €558 million  Bond fund rating of BBB-/V3 from Fitch Significant outperformance in 2010 with total excess return of 10.65% Average portfolio credit rating of BBB+ with attractive carry and no direct long peripheral sovereign risk The fund is regulated by the CSSF (Lux) and is UCITS III compliant Source: ECM March month end 2011 AUTHORISED AND REGULATED BY THE FSA 8
  • 9. Performance vs. market excess returns Average 2009 2010 2011 YTD Fund rating Excess return Excess return Excess Return Elbe BBB+ 31.63% 10.65% 4.61% Interlaken A 28.51% 10.13% 3.76% 2010 2011 YTD Average 2009 rating Excess swap Excess Swap Excess swap return return Return ER 00 Broad EMU Corp A2 10.38% 0.674% 1.07% EMU Corporates Non- A3 12.0% 0.749% 0.557% Financial IndexEMU Corporates BBB Index BBB2 22.3% 1.768% 2.125% (Including Financials)Euro Sub-Debt Lower Tier 2 A2 12.45% - 1.071% 2.542% Source: ECM 31st March 2011 Source: ML indices as at 31st March 2011 AUTHORISED AND REGULATED BY THE FSA 9
  • 10. Elbe Asset Class and peripheral Europe allocation shifts Allocation % of DENAV Asset Class 31-Dec-09 31-Mar-2011 Shift Asset Backed 17.3% 21.0% 3.7% Bank Capital 37.7% 16.1% -21.6% Corporate Bonds (Inv. Grade) 70.7% 47.0% -23.7% High Yield 12.0% 8.0% -4.0% Leveraged Loans 2.5% 2.9% 0.4% Emerging Markets 7.9% 8.2% 0.3% Sovereign 0.0% 0.0% 0.0% Total 147.9% 103.2% -44.7% Country Risk 31-Dec-09 31-Mar-2011 Shift Greece 1.3% 0.0% -1.3% Ireland 2.3% 0.8% -1.5% Italy 14.2% 6.9% -7.3% Portugal 1.8% 1.0% -0.8% Spain 9.2% 3.2% -6.0% Total Peripheral Europe 28.8% 11.9% -16.9% Source: ECM. Data as of 31st March 2011. AUTHORISED AND REGULATED BY THE FSA 10
  • 11. ELB – Attribution Analysis ELB YTD Net Increment to Euribor Breakdown 1,500 1,065 1,000 726 670 461 500 117 195 146 112 0 (500) (447) (1,000) Q1 10 Q2 10 Q3 10 Q4 10 2010 Total Jan-11 Feb-11 Mar-11 Q1 11 Emerging Markets (Non-Inv. Grade) 9 (4) 6 2 13 1 1 1 3 Total Leveraged Loans 10 (1) 4 9 24 9 4 2 14 High Yield 34 (40) 65 29 89 26 14 (6) 28 Asset Backed (High Yield) 22 11 18 26 81 7 11 12 31 Emerging Markets (Inv. Grade) 29 (28) 20 18 39 (0) (1) 10 10 Non-Financial Corporates (Inv. Grade) 23 (102) 67 37 22 38 24 10 71 Financials (Inv. Grade) 86 (166) 122 (16) 17 47 18 7 75 Bank Capital 270 (279) 255 (85) 140 42 42 21 108 WBS (Inv. Grade) 9 14 26 (1) 50 0 (2) 10 9 Asset Backed (Inv. Grade) 234 148 88 97 590 27 35 45 112 Source: ECM. Fund Snapshots. Data as of 31st March 2011. AUTHORISED AND REGULATED BY THE FSA 11
  • 12. ELB – Current Status Net Credit Net Net Net Duration Net Credit SpreadSectorLevel1 SectorLevel2 (%TP) (% DENAV) Net Duration Contrib. Spread Contrib. Avg PriceAsset Backed (Inv. Grade) Asset Backed (Inv. Grade) 17.4% 18.0% 2.6 0.5 917 165 76WBS (Inv. Grade) WBS (Inv. Grade) 1.6% 1.6% 4.0 0.1 1,297 21 84Financials (Inv. Grade) Insurance 5.8% 6.0% 4.6 0.3 380 23 95 Senior Banks 6.4% 6.6% 5.9 0.4 156 10 101 iTraxx Senior Financial (0.5%) (0.5%) 4.2 0.0 152 -1 98 Covered Bonds 0.9% 0.9% 9.8 0.1 101 1 102Bank Capital Lower Tier 2 & Tier 3 9.7% 10.0% 3.4 0.3 411 41 97 Upper Tier 2 1.9% 1.9% 2.8 0.1 481 9 95 Tier 1 3.5% 3.6% 2.7 0.1 839 30 92Non-Financial Corporates (Inv. Grade) Industrials (Inv. Grade) 23.0% 23.8% 5.7 1.3 142 34 103 Telecommunications (Inv. Grade) 3.6% 3.7% 5.8 0.2 144 5 105 Utilities (Inv. Grade) 6.3% 6.5% 6.7 0.4 180 12 100Emerging Markets (Inv. Grade) Emerging Markets (Inv. Grade) 7.0% 7.2% 4.7 0.3 221 16 105Asset Backed (High Yield) Asset Backed (High Yield) 1.4% 1.5% 2.0 0.0 2,701 39 41Bank Capital (High Yield) Lower Tier 2 & Tier 3 0.0% 0.0% 2.2 0.0 1,879 1 18 Upper Tier 2 0.3% 0.3% 3.4 0.0 1,439 4 47 Tier 1 0.3% 0.3% 5.0 0.0 1,727 5 62High Yield Senior Secured (High Yield) 2.1% 2.1% 2.7 0.1 532 11 101 Unsecured (High Yield) 6.5% 6.7% 3.7 0.3 322 22 104 iTraxx Crossover (0.8%) (0.9%) 3.9 0.0 387 -3 104Total Leveraged Loans Structured Notes 2.8% 2.9% 2.9 0.1 0 0 135Emerging Markets (Non-Inv. Grade) Emerging Markets (Non-Inv. Grade) 0.9% 1.0% 1.5 0.0 341 3 106Grand Total 100.0% 103.2% 4.4 4.5 435 449 93 Def initions: (i) Net (% TP) = Euro-equiv alent exposure div ided by total Euro-equiv alent exposure (ii) Net (% DENAV) = Euro-equiv alent exposure div ided by total DENAV = Net (% TP) * Lev erage (iii) Long / Short (% DENAV) = Long (short) Euro-equiv alent exposure div ided by total DENAV (iv ) Net Duration = Weighted av erage (unlev eraged) duration f or each asset class (weighted by Euro market v alue). (v ) Net Duration Contribution = Net Duration * Net (% DENAV) = contribution of each asset class to the f und’s total, lev eraged duration. (v i) Net Credit Spread = Weighted av erage credit spread (unlev eraged) f or each asset class (Euro-equiv alent market v alue weighting) (v ii) Net Credit Spread Contribution = Net Credit Spread * Net (% DENAV) = contribution of each asset class to the total, lev eraged credit spread. (v iii) Av erage Price = Weighted av erage asset price f or each asset class (Euro-equiv alent market v alue weights) Source: ECM. Fund Snapshots. Data as of 31st March 2011. AUTHORISED AND REGULATED BY THE FSA 12
  • 13. The Investment Case for Elbe in 2011 Elbe is an investment grade fund which has an expected return profile similar to or greater than high yield Elbe is fully hedged against Interest Rates & FX Declining credit asset class correlations bringing back the benefits of diversification Portfolio has been actively positioned focusing on those asset classes/credits with best risk adjusted returns in what is likely to be a low growth environment with significant macro, sovereign and equity market “tail risks” No direct long peripheral sovereign risk Although currently the fund is unleveraged, it has the ability to use modest leverage to facilitate market timing and boost returns AUTHORISED AND REGULATED BY THE FSA 13
  • 14. European Corporate Fund (“ECF”)A Sub Fund Of The European Credit Fund SICAV II
  • 15. European Corporate Fund (“ECF”) ECF targets a net return of benchmark plus an excess return of 175 – 225 bps per annum over Euribor in the medium to long term Average portfolio credit rating of A- with attractive carry and no direct long peripheral sovereign risk Unleveraged investment grade diversified credit risk Predominantly investing in European corporates Up to 100% of assets can be invested in non financial corporates. Exposure to banks is limited to 45%. A sub limit set at 15% exists for exposure to lower tier II debt. The fund is regulated by the CSSF (Lux) and is UCITS III compliant Source: ECM March month end 2011 AUTHORISED AND REGULATED BY THE FSA 15
  • 16. European Corporate Fund Portfolio comprises 76 investment Portfolio by Industry grade European credits 5% Automotive & Automotive Parts 20% Banks 3% Beverages 9% Insurance Allocation at the issuer level is 6% Telecommunications 4% Tobacco based on credit strength, liquidity, 16% Utilities 36% Other relative value and yield considerations, all which are part of the rigorous investment process Portfolio by Industry – Breakdown of Others that is ECM’s core strength. 7% Air Transport Portfolio Data Summary 6% Building Materials 5% Building, Development & Real Estate Credit Obligors 76 8% Cable & Satellite Television Exposure by Currency (pre hedging) 5% Communications Technology 6% Conglomerates EUR 67.7% 5% Containers & Packaging 7% Corporates GBP 15.4% 8% Energy, Oil & Gas USD 17.0% 6% Food & Drug Retailers 3% Leisure Goods, Recreation, Entertainment Current Carry over Euribor 4% Mining, Metals & Minerals 7% Other (non-Bank) Financial 1.4% Source: ECM. 31st March 2011 AUTHORISED AND REGULATED BY THE FSA 16
  • 17. European Corporate FundCredit risk Portfolio by Credit Rating Investment grade diversified credit 4% AAA 1% AA+portfolio composed mainly of corporate 1% AAbonds. 10% AA- 12% A+ 17% A Each bond purchased for the portfolio 14% A- 12% BBB+must be rated BBB- or above by one of 14% BBB 15% BBB-Moody’s, Standard & Poor’s or Fitch. Portfolio by Country Main holdings by Obligor 7% Denmark 1 VIRGIN MEDIA 2.6% 16% France 2 ABN AMRO 2.4% 8% Germany 3 STANDARD CHARTERED 2.3% 7% Global Companies 4 BP 2.2% 3% Luxembourg 5 AVIVA PLC 2.2% 8% Netherlands 6 MORGAN STANLEY 2.2% 8% Switzerland 7 IMPERIAL TOBACCO 2.2% 31% United Kingdom 8 VEOLIA 2.1% 11% Other 9 CASINO GUICHARD 2.1% 10 EDF 2.1% Source: ECM 31st March 2011 AUTHORISED AND REGULATED BY THE FSA 17
  • 18. ECF Asset Class and peripheral Europe allocation shifts Allocation % of DENAV Asset Class 31-Mar-10 31-Mar-2011 Shift Bank Capital 11.4% 9.6% -1.8% Corporate Bonds (Inv. Grade) 87.3% 78.7% -8.6% Sovereign 0.0% -0.5% -0.5% Total 98.7% 87.8% -10.9% Country Risk 31-Mar-10 31-Mar-2011 Shift Greece 0.0% 0.0% 0.0% Ireland 0.5% 0.0% -0.5% Italy 6.7% 2.7% -4.0% Portugal 0.9% 0.0% -0.9% Spain 6.2% 2.0% -4.2% Total Peripheral Europe 14.3% 4.7% -9.6% Source: ECM. Data as of 31st March 2011. AUTHORISED AND REGULATED BY THE FSA 18
  • 19. Daily liquidity / daily valuation - available on Bloomberg(EUCORIC LX <EQUITY> GO) Source: Bloomberg. As at 4th May 2011 AUTHORISED AND REGULATED BY THE FSA 19
  • 20. The investment case for ECF in 2011:  Exposure to inherent value in credit spreads in a regulated fund format with daily liquidity and valuations  The fund is designed to provide safe, liquid and duration neutral credit exposure  Safe:  Exposure only to Investment Grade Non Financial Corporate and Financial credit risk. No HY, EM, ABS or Leveraged Loans risk. No perpetual financials  No leverage  Liquid:  Daily valuation and liquidity  Duration Neutral:  All material interest rate risk and FX Risk is hedged AUTHORISED AND REGULATED BY THE FSA 20
  • 21. Appendix
  • 22. ECM UCITS III – ECF/ ECF II European Credit Fund SICAV European Credit Fund SICAV IIUmbrella Fund European Credit Fund SICAV European Credit Fund SICAV IINumber of sub funds 4 1Sub Fund Elbe, Danube, Interlaken + 1 Segregated Account European Corporate FundStatus UCITS III UCITS IIIClassification Sophisticated non-sophisticatedBase Currency EUR EURTypes of share classes Institutional and Non Institutional Institutional, Distributor and RetailHedging Hedged ( Non –Eur investors hedged) Hedged ( Non –Eur investors hedged)Dealing Bi -Monthly DailyOfficial Valuations Bi-Monthly DailyType of Valuation One NAV produced per series One NAV produced per share classSwing Pricing applied No YesNAV Issued at mid swing factor depending on net flowsNotice Period T-3 T-1Dividend Frequency Semi-annual ( Distributing and Non -Distributing) Annual ( Distributing and Non -Distributing) Base dividend (Euribor/ Libor or equivalent) + Based on proportionate entitlement of net income of the sub-Dividend type performance fundLeverage Capacity to moderately use leverage UnleveragedShare Class/SeriesConcept Shares issued at a series level Shares issued at a share class levelMinimum intial investment €125 Different per share classPerformance Fee Different per sub fund NoneManagement Fee Fixed per Sub Fund Different per share classDistribution fee N/A Different per share class AUTHORISED AND REGULATED BY THE FSA 22
  • 23. Investment Process & Professionals
  • 24. ECM investment process TO P DOWN ‘DRIVERS’ CREDIT MACRO- STATE OF EQUITY FUNDAMENTALS MARKET ECONOMIC BANKING MARKET AND RELATIVE TECHNICALS FUNDAMENTALS SYSTEM VOLATILITY VALUE Cr edit a nd in ve st m en t st r at e gyKey Variables: Asset Class Allocation, Credit Duration, Leverage, Industry, Rating, Liquidity, Country Risk INVE STMENT DECIS IONS BOTTOM UP SELECTION One on One Swap hedging allows Industry and meetings value to be sought Determine relative attractiveness of Credit investments: country specific with senior across international sectors and individual names Bonds, Loans, CDS expertise management of bond markets within a given sector issuers F U N DAM E N TAL R E SEAR C H AUTHORISED AND REGULATED BY THE FSA 24
  • 25. Integrated investment process Monthly Credit Strategy Review Peer Review Lead PMs, Lev Loans PMs review absolute & relative Top down credit strategy including overall market outlook , performance, implementation of credit strategy & sector asset class allocation, assessment of external risk factors allocation, exchange trade ideas Portfolio Review Sector Allocation Review Lead PMs, CIO, Head of Credit Research and Head of HY Asset Class teams recommend to Lead PMs, CSG sub- Research review treasury & risk themes, cross portfolio asset class sector allocations, top picks & pans issues Weekly (Monday) Ad-Hoc Informal meetings, buy/sell discussions, Investment Committee one-on-one meetings with issuers (attended by all Investment Professionals) Top down review of market Daily Economy & strategy Funding & risk management Research & PMs review of day’s events, preparation for key events expected for nextPortfolio positioning following Peer Reviews, Credit day Strategy Bi-weekly Asset Class Sub Committees Review thematic issues affecting asset classes, detailed picks and pans updates Corporate High Yield ABS Financials Leveraged Loans EM AUTHORISED AND REGULATED BY THE FSA 25
  • 26. Investment professionals STEVEN STEPHEN BLAKEY ZINSER Chairman CEO/CIO Credit Market Risk Portfolio Credit Portfolio Strategy & Treasury Management Research Management Stephen Zinser Management Ross Pamphilon Leveraged Chief Executive Officer / Head of Investments Loans Chief Investment Officer Alastair Thomas Head of Market Risk Mgt. Derek Hynes Corporates Frances Hutchinson Lead Portfolio Manager Duncan Warwick-Champion Matthew Craston Head of Business and Alex Temple Henrietta Pacquement Lead Analyst IG Corporates Head of Alternative Strategic Planning Senior Market Risk Lead Portfolio Manager Lead Analyst High Yield* Investments Manager Sr. Investment Analyst* Torben Ronberg Jens Vanbrabant Ross Pamphilon David Jones Lead Portfolio Manager Michie Yana Head of Loans Head of Investments Market Risk Manager Sr. Investment Analyst Alex Woolrich Jon Mawby Adam Gibson Lead Portfolio Manager Carter Holloran Portfolio Manager Alastair Thomas Jr. Market Risk Manager Investment Analyst Sam McGairl Andre Mazzella Head of Market Risk Treasury Manager* Investment Analyst* Portfolio Manager Lead Portfolio Manager - HY Mgmt Adam Hicks Amit Staub & Loan Trader Andrew Li Jr. Treasury Manager High Yield Research Analyst Stuart Fuller Spec. Asset Class PM – Fin. Matthew Craston Sam Barker Portfolio Manager Head of Alternative George Flynn Associate Investment Analyst Senior Investment Analyst* Investments Spec. Asset Class PM – Corp.. Daniel Harris James Fielder Investment Strategist* Spec Asset Class PM - Corp. Financials Portfolio Analyst Sahil Khan Satish Pulle Sr. Investment Analyst Portfolio Analyst Investment Analyst* Special Situations Milos Brajovic ABS Senior Portfolio Manager Andrew Lennox Sohail Malik ABS Spec, Lead PM ABS funds Senior Portfolio Manager Jonathan Wyles ABS Spec, PM ABS Funds Maddi Rowlatt ABS Specialist As at March 2011 * Pending hires AUTHORISED AND REGULATED BY THE FSA 26
  • 27. Recent New Hires at ECMAndre Mazzella, CFA – Lead Portfolio Manager, High YieldAndre joined ECM in October 2010 from CQS, where he was a member of the portfolio management team and senior credit analystfocusing mainly on US and European High Yield and Crossover credits. Prior to CQS, Andre was a High Yield Fund Manager atMorley Fund Management overseeing life insurance and retail funds invested in US and European High Yield bonds. Previously hewas a member of the High Yield Group at Abbey National Treasury Services after having begun his career in various finance andresearch positions at Putnam Investments and Bankers Trust. Andre holds an MBA from the Stern School of Business at New YorkUniversity and a B.S. in Business Administration from Montclair State University. He is a CFA charterholder.Duncan Warwick-Champion – Lead Corporate AnalystDuncan has joined the firm from Vanguard where he was a senior credit analyst. Prior to joining Vanguard in 2009, Duncan spentseven years at UBS where he was a highly regarded TMT analyst and Head of the European Research Team. Prior to UBS he spentsix years at Standard & Poors, latterly as Head of the European Telecoms team. He is a graduate of Macquarie University.Satish Pulle – Senior Investment Analyst, FinancialsSatish Pulle joined ECM in mid-November 2010 as the Senior Investment Analyst for financials. Satish joins from Merrill Lynch wherehe traded and analyzed European and US banks and insurers, most recently a Director & Senior Trader for Credit Flow Trading. Priorto joining Merrill Lynch in 2007, Satish spent five years as a credit analyst for European financials and ABS at Schroders Plc inLondon. He started his career at Tata Consultancy Services in India before moving to London in 1996 as an Associate and laterAssociate Director for Barclays Capital’s Infrastructure Investment Banking team. Satish holds a Masters in Finance from the LondonBusiness School, an M.Sc. in International Accounting and Finance from the London School of Economics as well as an MBA with aspecialization in Finance and Operations from the Indian Institute of Management, Calcutta, India, and a Bachelor of Engineering,Mechanical Engineering from Osmania University, Hyderabad, India.Sahil Khan – Portfolio AnalystSahil has joined the firm from Barings Asset Management where he was a Quantitative Analyst responsibile for the update andenhancement of the firm’s tools for scenario forecasting as well as the application of these tools in optimal portfolio construction andrisk management. Sahil holds a MSc in Economics & Finance and an MA (HONS) in Economics, both from Edinburgh University.Sahil also earned a Certificate in Quantitative Finance (CQF) in January 2008. AUTHORISED AND REGULATED BY THE FSA 27
  • 28. Pending new hiresJoinersSally Tankard – Senior Loans Analyst joins in June 2011  Sally has spent the last seven years as Director of Loans at Henderson Global Investors where she has been an integral part of the growth of the loans business  Sally has 18 years credit research experience, buy side and sell side, including loan originations with CSFBRhys Foulkes- Research Analyst joins July 2011  Joins from Threadneedle  Rhys will cover IG/HY: Retail/Consumer/Beverage sectors  Previously Rhys was a research assistant at the Bank of EnglandHenry Craik-White - Research Analyst joins July 2011  Henry will be High Yield focused  Joins from Blue Mountain where he has been covering TMT, Retail & Building  Previous experience came at RBS and CazenoveLeaversNancy Utterback, Senior Credit Analyst, left in Q1 2011 AUTHORISED AND REGULATED BY THE FSA 28
  • 29. EUROPEAN CREDIT MANAGEMENTLIMITED34 Grosvenor Street, London W1K 4QUTel: +44 (0) 20 7529 7400Fax: +44 (0) 20 7529 7411This document is:(1) issued by ECM for information only; it is not investment advice and is confidential and should not be disclosed other than to yourprofessional advisers;(2) directed at persons (“Investment Professionals”) having professional experience in matters relating to investments and anyinvestment or investment activity to which this document relates is available only to and will be engaged in only with such persons.If you are not an Investment Professional you should not read this document or participate in any meeting or other communicationrelating to it.ECM accepts no liability for and gives no warranty or guarantee and makes no representation relating to the performance of anyinvestments referred to in this document or to the accuracy and/or completeness of the information contained in this document. Anyinformation contained in this document relating to any securities or issuer thereof is subject to the offering document relating thereto.This document may be distributed only to persons permitted to receive it under applicable law and may not be distributed or passed toany person in any jurisdiction in which such distribution would violate any applicable law.This document may not be distributed other than: (1) within the USA, to investors that are Qualified Institutional Buyers; and (2) outsidethe USA, to non-US persons in offshore transactions in reliance on Regulation S under the Securities Act.ECM and its affiliates do not provide tax advice. Please note that: (1) any discussion of tax matters contained in this document(including any attachments) cannot be used by you for the purpose of avoiding tax penalties; (2) this document was written to supportthe promotion or marketing of the matters addressed herein; and (3) you should seek advice based on your particular circumstancesfrom an independent tax advisor. AUTHORISED AND REGULATED BY THE FSA 29