Short Selling Disclosure

[1] This form relates to the disclosure of short positions in compliance with chapter 2 of the FSA's Financial Stability and Market Confidence sourcebook (FINMAR) . The form, or the information contained within it, should be disclosed via an RIS using the short code SSD.

[2] Specify the holder of the net short position. The naming of nominees or vehicle companies is insufficient. In the case of a discretionary investment manager managing assets on behalf of a client, the disclosure obligation applies at the level of both the entity to which FINMAR 2.2.1 R or 2.2.3 R applies and at the level of the discretionary investment manager. The discretionary investment manager may make a net short position disclosure on behalf of its client. In respect of itself, the discretionary investment manager is required to disclose its aggregate net short position across all of the funds it manages. Non-discretionary investment managers may also make disclosure of a net short position on behalf of their clients.

Where a disclosure by a discretionary investment manager is the same as that being made for its client/fund/sub-fund, it is permitted to make a single disclosure provided that the disclosure makes it clear that it applies to both parties.

[3] Figure to be expressed as a percentage of issued capital. Disclosable short position is defined in the Glossary of Definitions in the FSA Handbook. Positions must be disclosed on a net basis of all holdings. All financial instruments that represent a direct or indirect economic interest in the shares of the issuer must be included within such holdings.