Otus Capital Management Limited

Event Detail: MR. CASONI WAS A LONDON BASED RESEARCH ANALYST AT CITIGROUP. HE WAS FINED £52,500 BY THE FINANCIAL SERVICES AUTHORITY "FSA" FOR A BREACH OF PRINCIPAL 3 "FAILING TO OBSERVE PROPER STANDARDS OF MARKET CONDUCT" IN MARCH 2007. THE FSA REPORT ALSO ADDED THAT IN REACHING THE DECISION, THE FSA TOOK INTO ACCOUNT THAT MR. CASONI DID NOT HAVE ANY INTENTION OF MANIPULATING THE COMPANY'S SHARE PRICE IN MAKING THE DISCLOSURES NOR DID HE OBTAIN ANY FINANCIAL GAIN FROM HIS MISCONDUCT. IN SEPTEMBER 2008, CONSOB INVESTIGATED MR. CASONI AND IN AUG 2009 FOUND MR. CASONI GUILTY OF MARKET MISCONDUCT AND ISSUED A FINANCIAL PENALTY. IN JULY 2011, CRIMINAL PROCEEDINGS RELATING TO THE SAME INCIDENT WERE LAUNCHED AGAINST MR. CASONI BY ITALY'S PUBLIC PROSECUTOR WITH THE CASE PROCESS TO BE IN 3 PHASES. Status: Final Disposition: PRIOR TO JOINING OCM IN MAY 2007, ROBERTO CASONI WAS FINED BY THE FINANCIAL SERVICES AUTHORITY "FSA" FOR A BREACH OF PRINCIPAL 3 - "FAILING TO OBSERVE PROPER STANDARDS OF MARKET CONDUCT" IN THE FIRST EVER CASE CONCERNING THE SELECTIVE RELEASE OF RESEARCH PRIOR TO OFFICIAL PUBLICATION. FURTHERMORE, THE ITALIAN REGULATORY AUTHORITY - CONSOB - CARRIED OUT ITS OWN INVESTIGATION OF THE SAME CASE AND FOUND ROBERTO GUILTY OF MARKET MISCONDUCT IN 2009. AS A DIRECT RESULT OF THIS CONSOB FINDING, CRIMINAL PROCEEDINGS WERE BROUGHT AGAINST ROBERTO AND THIS CASE FINALLY CONCLUDED - AFTER ALMOST 11 YEARS - WHEN ROBERTO'S GUILTY VERDICT WAS UPHELD - IN MARCH 2019. CASE NOW CLOSED Summary: IN MARCH 2007 THE FSA ISSUED A FINAL NOTICE REPORT AGAINST MR. CASONI. THE MISCONDUCT TOOK PLACE IN JANUARY 2006 WHEN MR. CASONI WAS A LONDON BASED RESEARCH ANALYST AT CITIGROUP. THE FSA CONCLUDED THAT MR. CASONI DISSEMINATED INFORMATION TO CERTAIN CLIENTS AHEAD OF PUBLICATION ALLOWING THOSE CLIENTS OPPORTUNITY'S TO PRE-EMPT THE CONCLUSIONS OF THE PUBLISHED RESEARCH AND THEREBY POTENTIALLY INFLUENCING THEIR INVESTMENT DECISIONS AHEAD OF THE MARKET. IN AUGUST 2008 MR. CASONI RECEIVED NOTICE OF THE INVESTIGATION FROM CONSOB REGARDING THE SAME CASE.

Allegations: DISCLOSURE OF NON-PUBLIC INFORMATION. DISSEMINATING RESEARCH TO CLIENTS PRIOR TO PUBLICATION. Status: Final Summary: IN MAY 2007, MR CASONI WAS FINED BY THE FINANCIAL SERVICES AUTHORITY "FSA" FOR A BREACH OF PRINCIPAL 3 "FAILING TO OBSERVE PROPER STANDARDS OF MARKET CONDUCT". IN AUGUST 2008, MR. CASONI RECEIVED NOTICE FROM CONSOB - THE ITALIAN REGULATOR - WHO CARRIED OUT ITS OWN INVESTIGATION INTO THE SAME CASE AND ITALY'S PUBLIC PROSECUTOR LAUNCHED CRIMINAL PROCEEDINGS IN SEPTEMBER 2009.

Allegations: ON THE 21 DECEMBER 2018, OCM RECEIVED NOTIFICATION FROM THE SWEDISH REGULATOR - FINANSINSPEKTIONEN - THAT IT WAS ISSUING THE FIRM WITH A PENALTY NOTICE OF SEK 240,000 (APPROX £20,500) RELATING TO AN ERROR IN A DISCLOSURE NOTIFICATION MADE BY OCM IN THE SWEDISH SECURITY STRAX AFTER WE WENT ABOVE THE 5% LONG DISCLOSURE THRESHOLD. THIS DISCLOSURE WAS MADE ON TIME (NEXT BUSINESS DAY) BUT THE NOTIFICATION SUBMITTED CONTAINED A DATE FIELD ERROR. THIS PENALTY NOTICE WAS APPEALED BY OCM BUT THE APPEAL WAS ULTIMATELY REJECTED BY FÖRVALTNINGSRÄTTEN (THE SWEDISH ADMINISTRATIVE COURT). THIS PENALTY FINE WAS PAID IN SEPTEMBER 2019 AND WAS BORNE BY OCM AND NOT BY ANY OF ITS CLIENT FUNDS OR MANAGED ACCOUNTS. Status: Final Sanction Detail: ISSUING THE FIRM WITH A PENALTY NOTICE OF SEK 240,000 (APPROX £20,500) Summary: ON THE 21 DECEMBER 2018, OCM RECEIVED NOTIFICATION FROM THE SWEDISH REGULATOR - FINANSINSPEKTIONEN - THAT IT WAS ISSUING THE FIRM WITH A PENALTY NOTICE OF SEK 240,000 (PPROX.. £20,500) RELATING TO AN ERROR IN A DISCLOSURE NOTIFICATION MADE BY OCM IN THE SWEDISH SECURITY STRAX AFTER WE WENT ABOVE THE 5% LONG DISCLOSURE THRESHOLD. THIS DISCLOSURE WAS MADE ON TIME (NEXT BUSINESS DAY) BUT THE NOTIFICATION SUBMITTED CONTAINED A DATE FIELD ERROR. THIS PENALTY NOTICE WAS APPEALED BY OCM BUT THE APPEAL WAS ULTIMATELY REJECTED BY FÖRVALTNINGSRÄTTEN (THE SWEDISH ADMINISTRATIVE COURT). THIS PENALTY FINE WAS PAID IN SEPTEMBER 2019 AND WAS BORNE BY OCM AND NOT BY ANY OF ITS CLIENT FUNDS OR MANAGED ACCOUNTS.