Jupiter Asset Management Limited

Allegations: THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY ("BAFIN") ALLEGED THAT JUPITER ASSET MANAGEMENT LIMITED ("JAM UK") DID NOT HAVE SUFFICIENT PROCEDURES IN PLACE TO ENSURE COMPLIANCE WITH GERMAN LAW REGARDING NOTIFICATION OF BAFIN OF SIGNIFICANT SHAREHOLDERS IN GERMAN SECURITIES Status: Final Sanction Detail: NONE Summary: THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY ("BAFIN") ALLEGED THAT JAM UK DID NOT HAVE SUFFICIENT PROCEDURES IN PLACE TO ENSURE COMPLIANCE WITH GERMAN LAW REGARDING NOTIFICATION OF BAFIN OF SIGNIFICANT SHAREHOLDERS IN GERMAN SECURITIES. JAM UK PAID THE ADMINISTRATIVE FINE ON MAY 6TH 2016.

Allegations: PURSUANT TO REGULATION (EU) NO. 236/2012 ON SHORT SELLING (THE "REGULATION"), MERIAN GLOBAL INVESTORS (UK) LIMITED ("MGI") IS REQUIRED TO FILE NET SHORT POSITION REPORTS (THE "REPORTS") WITH THE DANISH FINANCIAL SUPERVISORY AUTHORITY ("DANISH FSA") WHEN CERTAIN PRESCRIBED THRESHOLDS ARE CROSSED. IN NOVEMBER 2017, MGI'S COMPLIANCE FUNCTION IDENTIFIED AN ERROR IN THE MONITORING OF SUCH THRESHOLDS. MGI IMMEDIATELY COMMENCED AN IN-DEPTH ANALYSIS OF ALL DISCLOSURE REQUIREMENTS IN ORDER TO ESTABLISH THE UNDERLYING CAUSE AND TO DETERMINE THE EXTENT OF THE ISSUE. ON JANUARY 25 2018, MGI NOTIFIED THE DANISH FSA OF ITS INADVERTENT FAILURE TO FILE THE REPORTS DURING THE PERIOD BETWEEN SEPTEMBER 2015 AND JANUARY 2018. MGI FILED THE DELINQUENT REPORTS AND PUT APPROPRIATE CONTROLS IN PLACE TO MITIGATE THE RISK OF THE ERROR REOCCURRING. THE DANISH FSA SUBSEQUENTLY FOUND THAT MGI BREACHED THE REGULATION BY FAILING TO FILE SUCH REPORTS. Status: Final Sanction Detail: SEE DETAILS IN NUMBER 13 BELOW Summary: ON MAY 8 2018, THE DANISH FSA DETERMINED THAT MERIAN GLOBAL INVESTORS (UK) ("MGI"), NOW KNOWN AS JUPITER INVESTMENT MANAGEMENT LIMITED, BREACHED THE REGULATION AND ISSUED A REPRIMAND. ON MAY 24 2018, THE DANISH FSA PUBLISHED INFORMATION REGARDING THE REPRIMAND ON ITS WEB PAGE.

Allegations: PURSUANT TO REGULATION (EU) NO. 236/2012 ON SHORT SELLING (THE "REGULATION"), MERIAN GLOBAL INVESTORS (UK) LIMITED ("MGI") IS REQUIRED TO FILE NET SHORT POSITION REPORTS (THE "REPORTS") WITH THE COMISION NACIONAL DEL MERCADO DE VALORES IN SPAIN ("CNMV") WHEN CERTAIN PRESCRIBED THRESHOLDS ARE CROSSED. IN NOVEMBER 2017, MGI'S COMPLIANCE FUNCTION IDENTIFIED AN ERROR IN THE MONITORING OF SUCH THRESHOLDS. MGI IMMEDIATELY COMMENCED AN IN-DEPTH ANALYSIS OF ALL DISCLOSURE REQUIREMENTS IN ORDER TO ESTABLISH THE UNDERLYING CAUSE AND TO DETERMINE THE EXTENT OF THE ISSUE. ON JANUARY 10 2018, MGI NOTIFIED THE CNMV OF ITS INADVERTENT FAILURE TO FILE THE REPORTS DURING THE PERIOD BETWEEN JULY 2014 AND DECEMBER 2017. MGI FILED THE DELINQUENT REPORTS AND PUT APPROPRIATE CONTROLS IN PLACE TO MITIGATE THE RISK OF THE ERROR REOCCURRING. CNMV SUBSEQUENTLY FOUND THAT MGI BREACHED THE REGULATION BY FAILING TO FILE SUCH REPORTS. Status: Final Sanction Detail: SEE DETAILS IN NUMBER 13 BELOW Summary: ON APRIL 12 2018, CNMV ISSUED AN ADMINISTRATIVE SANCTION THAT DETERMINED THAT MERIAN GLOBAL INVESTORS (UK) ("MGI"), NOW KNOWN AS JUPITER INVESTMENT MANAGEMENT LIMITED, BREACHED THE REGULATION AND IMPOSED A FINE OF EUR 200,000 (APPROXIMATELY USD 225,000). BECAUSE MGI COMPLIED WITH CERTAIN TERMS AND CONDITIONS OF THE SANCTION, MGI WAS ELIGIBLE FOR A 40% REDUCTION OF THE FINE (EUR 80,000). MGI PAID THE REDUCED FINE IN THE AMOUNT OF EUR 120,000 (APPROXIMATELY USD 135,000) EFFECTIVE JUNE 8 2018.

Allegations: PURSUANT TO REGULATION (EU) NO. 236/2012 ON SHORT SELLING (THE "REGULATION"), JUPITER INVESTMENT MANAGEMENT LIMITED ("JIML") IS REQUIRED TO FILE NET SHORT POSITION REPORTS (THE "REPORTS") WITH FINANSINSPEKTIONEN (THE SWEDISH FINANCIAL SUPERVISORY AUTHORITY) ("SWEDISH FSA") WHEN CERTAIN PRESCRIBED THRESHOLDS ARE CROSSED. IN NOVEMBER 2017, THE COMPLIANCE FUNCTION OF MERIAN GLOBAL INVESTORS (UK) LIMITED ("MGI"), NOW KNOWN AS JIML, IDENTIFIED AN ERROR IN THE MONITORING OF SUCH THRESHOLDS. MGI IMMEDIATELY COMMENCED AN IN-DEPTH ANALYSIS OF ALL DISCLOSURE REQUIREMENTS IN ORDER TO ESTABLISH THE UNDERLYING CAUSE AND TO DETERMINE THE EXTENT OF THE ISSUE. ON JANUARY 18 2018, MGI NOTIFIED THE SWEDISH FSA OF ITS INADVERTENT FAILURE TO FILE THE REPORTS DURING THE PERIOD BETWEEN APRIL 2016 AND JANUARY 2018. MGI FILED THE DELINQUENT REPORTS AND PUT APPROPRIATE CONTROLS IN PLACE TO MITIGATE THE RISK OF THE ERROR REOCCURRING. THE SWEDISH FSA SUBSEQUENTLY FOUND THAT MGI BREACHED THE REGULATION BY FAILING TO FILE SUCH REPORTS. Status: Final Sanction Detail: SEE DETAILS IN NUMBER 13 BELOW Summary: "ON JUNE 24, 2021, THE SWEDISH FSA DETERMINED THAT MGI BREACHED THE REGULATION AND ISSUED A PENALTY FEE OF SEK 700,000 (APPROXIMATELY $80,436). JUPITER INVESTMENT MANAGEMENT LIMITED PAID THE PENALTY FEE TO FINANSINSPEKTIONEN ON AUGUST 18 2021."

Allegations: PURSUANT TO REGULATION (EU) NO. 236/2012 ON SHORT SELLING (THE "REGULATION"), JUPITER INVESTMENT MANAGEMENT LIMITED ("JIML") IS REQUIRED TO FILE NET SHORT POSITION REPORTS (THE "REPORTS") WITH THE AUTORITEIT FINANCIELE MARKTEN (THE DUTCH FINANCIAL SUPERVISORY AUTHORITY) WHEN CERTAIN PRESCRIBED THRESHOLDS ARE CROSSED. IN NOVEMBER 2017, THE COMPLIANCE FUNCTION OF MERIAN GLOBAL INVESTORS (UK) LIMITED ("MGI"), NOW KNOWN AS JIML, IDENTIFIED AN ERROR IN THE MONITORING OF SUCH THRESHOLDS. MGI IMMEDIATELY COMMENCED AN IN-DEPTH ANALYSIS OF ALL DISCLOSURE REQUIREMENTS IN ORDER TO ESTABLISH THE UNDERLYING CAUSE AND TO DETERMINE THE EXTENT OF THE ISSUE. ON JANUARY 18 2018, MGI NOTIFIED THE AUTORITEIT FINANCIELE MARKTEN OF ITS INADVERTENT FAILURE TO FILE THE REPORTS DURING THE PERIOD BETWEEN APRIL 2016 AND JANUARY 2018. MGI FILED THE DELINQUENT REPORTS AND PUT APPROPRIATE CONTROLS IN PLACE TO MITIGATE THE RISK OF THE ERROR REOCCURRING. THE AUTORITEIT FINANCIELE MARKTEN SUBSEQUENTLY FOUND THAT MGI BREACHED THE REGULATION BY FAILING TO FILE SUCH REPORTS. Status: Final Sanction Detail: SEE DETAILS IN NUMBER 13 BELOW Summary: ON JUNE 24, 2021, THE AUTORITEIT FINANCIELE MARKTEN DETERMINED THAT MGI BREACHED THE REGULATION AND ISSUED A PENALTY FEE OF EUR 250,000. JUPITER INVESTMENT MANAGEMENT LIMITED PAID THE PENALTY FEE TO AUTORITEIT FINANCIELE MARKTEN ON DECEMBER 10 2021.

Allegations: PURSUANT TO REGULATION (EU) NO. 236/2012 ON SHORT SELLING (THE "REGULATION"), MERIAN GLOBAL INVESTORS (UK) LIMITED ("MGI") IS REQUIRED TO FILE NET SHORT POSITION REPORTS (THE "REPORTS") WITH THE COMMISSIONE NAZIONALE PER LE SOCIETA E LA BORSA ("CONSOB") WHEN CERTAIN PRESCRIBED THRESHOLDS ARE CROSSED. IN NOVEMBER 2017, MGI'S COMPLIANCE FUNCTION IDENTIFIED AN ERROR IN THE MONITORING OF SUCH THRESHOLDS. MGI IMMEDIATELY COMMENCED AN IN-DEPTH ANALYSIS OF ALL DISCLOSURE REQUIREMENTS IN ORDER TO ESTABLISH THE UNDERLYING CAUSE AND TO DETERMINE THE EXTENT OF THE ISSUE. ON JANUARY 10 2018, MGI NOTIFIED THE CONSOB OF ITS INADVERTENT FAILURE TO FILE THE REPORTS DURING THE PERIOD BETWEEN JULY 2014 AND JANUARY 2018. MGI FILED THE DELINQUENT REPORTS AND PUT APPROPRIATE CONTROLS IN PLACE TO MITIGATE THE RISK OF THE ERROR REOCCURRING. CONSOB SUBSEQUENTLY FOUND THAT MGI BREACHED THE REGULATION BY FAILING TO FILE SUCH REPORTS. IN MAKING ITS DETERMINATION, CONSOB NOTED THAT THE BREACH DID NOT MISLEAD INVESTORS OR GENERATE ANY PROFIT FOR MGI. ADDITIONALLY, MGI ADOPTED A COLLABORATIVE APPROACH WITH CONSOB AND DID NOT HAVE ANY PREVIOUS VIOLATIONS SANCTIONED BY CONSOB CONCERNING FINANCIAL MATTERS. Status: Final Sanction Detail: SEE DETAILS IN NUMBER 13 BELOW Summary: ON DECEMBER 13 2018, CONSOB ISSUED AN ADMISNTRATIVE SANCTION THAT DETERMINED THAT MGI BREACHED THE REGULATION AND IMPOSED A FINE OF EUR 160,000 (APPROXIMATELY USD 180,000). MGI PAID THE FINE IN FULL EFFECTIVE FEBRUARY 4 2019.