Tetragon Partners L.P.

Allegations: NOTIFICATIONS OF NET SHORT POSITIONS IN EUROPEAN LISTED ISSUERS ARE SUBJECT TO REGULATION (EU) NO. 26/2012 OF THE EUROPEAN PARLIAMENT (THE "EU SHORT SELLING REGULATION"). UNDER THE EU SHORT SELLING REGULATION, NET SHORT POSITIONS EQUAL TO 0.20% OF THE ISSUED SHARE CAPITAL AND CHANGES OF EACH 0.10% ABOVE THAT MUST BE DISCLOSED BY 3:30 P.M. ON THE TRADING DAY IMMEDIATELY FOLLOWING THE THRESHOLD CROSSING. IN THIS INSTANCE, THE FIRM DID NOT DISCLOSE A CHANGE IN ITS NET SHORT POSITION IN A SWEDISH ISSUER THAT CROSSED A 0.10% THRESHOLD PRIOR TO 3:30 P.M. ON THE FOLLOWING DAY. THIS CHANGE IN THE FIRM'S POSITION (WHICH CROSSED A SINGLE 0.10% THRESHOLD) RESULTED FROM A CHANGE IN THE ISSUER'S NUMBER OF OUTSTANDING SHARES AND NOT AS A RESULT OF ANY ACTIVE TRADING ON THE PART OF THE FIRM. IMMEDIATELY UPON IDENTIFYING THE LATE FILING, THE FIRM NOTIFIED THE FI. Status: Final Sanction Detail: N/A Summary: THE FI'S PENALTY FEE BECAME FINAL ON 25 JULY 2016. THE FI TYPICALLY APPLIES FEES FOR UNTIMELY SHORT POSITION NOTIFICATIONS EFFECTIVELY ON A "STRICT LIABILITY" BASIS USING PRE-DETERMINED FEE BANDS THAT ARE BASED ON (A) THE SIZE OF THE SHORT POSITION, (B) THE TARDINESS OF THE FILING AND (C) THE LEGAL STATUS OF THE BREACHING PARTY. IN THIS INSTANCE, HOWEVER, THE FI CONSIDERED THERE TO BE SUFFICIENT MITIGATING CIRCUMSTANCES TO APPLY A LESSER FEE BAND. THE FIRM WILL PAY THE ASSESSED FEE. THERE WERE NO OTHER SANCTIONS OR DISCIPLINARY ACTIONS ASSOCIATED WITH THIS MATTER.

Allegations: ON 9 DECEMBER 2021, FINANSTILSYNET (FINANCIAL SUPERVISORY AUTHORITY OF NORWAY) IMPOSED A FINE OF NOK 80,000 UPON TFG ASSET MANAGEMENT UK LLP (F/K/A POLYGON GLOBAL PARTNERS LLP) WITH RESPECT TO A FAILURE BY POLYGON TO DISCLOSE A CHANGE IN ITS NET SHORT POSITION IN A NORWEGIAN ISSUER. THERE WERE NO OTHER SANCTIONS OR DISCIPLINARY ACTIONS ASSOCIATED WITH THIS MATTER. Status: Final Sanction Detail: N/A Summary: ON 9 DECEMBER 2021, FINANSTILSYNET (FINANCIAL SUPERVISORY AUTHORITY OF NORWAY) IMPOSED A FINE OF NOK 80,000 UPON TFG ASSET MANAGEMENT UK LLP (F/K/A POLYGON GLOBAL PARTNERS LLP) WITH RESPECT TO A FAILURE BY POLYGON TO DISCLOSE A CHANGE IN ITS NET SHORT POSITION IN A NORWEGIAN ISSUER. THERE WERE NO OTHER SANCTIONS OR DISCIPLINARY ACTIONS ASSOCIATED WITH THIS MATTER.