Senvest Management, Llc

Allegations: IT WAS ALLEGED THAT THE ADVISER VIOLATED AND CAUSED VIOLATIONS OF SECTIONS 13(D) AND 16(A) OF THE EXCHANGE ACT OF 1934 AND RULES 13D-1, 13D-2 AND 16-A3 PROMULGATED THEREUNDER. Status: Final Sanction Detail: THE ADVISER PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $68,000. Summary: WITHOUT ADMITTING OR DENYING ANY WRONGDOING, THE ADVISER AGREED TO THE TERMS OF THE SETTLEMENT WITH THE SEC ON SEPTEMBER 10, 2014, THAT INCLUDES THE SANCTIONS DESCRIBED IN QUESTION 12 ABOVE.

Allegations: THE SEC FOUND THAT SENVEST MANAGEMENT, LLC ("SENVEST") VIOLATED: (1) SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) BY FAILING TO ADEQUATELY PRESERVE CERTAIN OFF-CHANNEL COMMUNICATIONS RELATED TO ITS BUSINESS; (2) SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 BY FAILING TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATION OF THE ADVISERS ACT AND THE RULES THEREUNDER; (3) SECTION 204A OF THE ADVISERS ACT AND RULE 204A-1 BY FAILING TO ESTABLISH, MAINTAIN, AND ENFORCE A WRITTEN CODE OF ETHICS THAT MEETS THE MINIMUM STANDARDS SET FORTH IN RULE 204A-1; AND (4) SECTION 203(E)(6) OF THE ADVISERS ACY BY FAILING TO REASONABLY SUPERVISE CERTAIN EMPLOYEES. Status: Final Sanction Detail: IN CONNECTION WITH THE ENTRY OF THE ORDER, SENVEST HAS AGREED TO (1) A CENSURE, (2) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATIONS OF SECTIONS 204, 204A, AND 206(4) OF THE ADVISERS ACT, (3) PAY A $6.5 MILLION CIVIL MONEY PENALTY AND (4) PERFORM UNDERTAKINGS DESCRIBED IN RESPONSE TO QUESTION 13 OF THIS DISCLOSURE REPORTING PAGE. Summary: ON APRIL 3,2024 , THE SEC ISSUED A SETTLED ADMINISTRATIVE ORDER (THE "ORDER") FINDING VIOLATIONS DESCRIBED ABOVE UNDER ITEM 7 OF THIS DRP. SENVEST PAID THE CIVIL MONEY PENALTY ON APRIL 3, 2024. IN ADDITION TO THE OTHER SANCTIONS DETAILED IN ITEM 12 OF THIS DRP, PURSUANT TO THE ORDER, SENVEST HAS UNDERTAKEN TO RETAIN A COMPLIANCE CONSULTANT TO REVIEW CERTAIN ASPECTS OF SENVEST'S COMPLIANCE PROGRAM RELATED TO THE USE OF UNAUTHORIZED COMMUNICATION METHODS FOR BUSINESS COMMUNICATIONS, INCLUDING RELATED POLICIES, PROCEDURES, TRAININGS, SURVEILLANCE PROGRAM, TECHNOLOGICAL SOLUTIONS, AND OTHER PREVENTATIVE MEASURES. SENVEST HAS UNDERTAKEN TO IMPLEMENT SUCH CONSULTANT'S RECOMMENDATIONS, SUBJECT TO THE TERMS OF THE ORDER, AND AGREED TO A FOLLOW-ON REVIEW.