Elliott Investment Management L.P.

Allegations: THIS DRP DESCRIBES CIVIL LITIGATION RELATED TO ELLIOTT'S (AS HEREINAFTER DEFINED) DECISION NOT TO TENDER ITS SHARES OF NORBERT DENTRESSANGLE SA ("ND") IN A TENDER OFFER CONDUCTED BY XPO LOGISTICS, INC. AND XPO LOGISTICS FRANCE (COLLECTIVELY, "XPO"). XPO HAS ALLEGED THAT ELLIOTT CAPITAL ADVISORS, L.P. AND CERTAIN FUNDS MANAGED BY ELLIOTT MANAGEMENT CORPORATION (TOGETHER WITH THEIR AFFILIATES, "ELLIOTT") ARE IN VIOLATION OF FRENCH LAW SURROUNDING TENDER OFFERS AND THAT XPO WOULD SUFFER SIGNIFICANT DAMAGE AS A RESULT. ELLIOTT HELD APPROXIMATELY 7.6% OF THE OUTSTANDING SHARES OF ND. ELLIOTT HAS ALLEGED THAT XPO LIKELY HAD TAKEN OR HAD IMMINENT PLANS TO TAKE ACTION THAT WAS MANIFESTLY CONTRARY TO THE CORPORATE INTERESTS OF ND AND THE MINORITY SHAREHOLDERS OF ND IN ORDER TO PURSUE THE PROPOSED MERGER AND THEREBY IGNORE THAT XPO DOES NOT OWN 100% OF ND'S SHARES. Status: Final Summary: ON JULY 8, 2015, THE PARIS COMMERCIAL COURT ISSUED AN EX PARTE ORDER IN RESPONSE TO A CIVIL COMPLAINT FILED BY XPO THAT, AMONG OTHER THINGS, TEMPORARILY BARRED ELLIOTT FROM TRANSFERRING ITS EQUITY INTEREST IN ND TO ANY THIRD PARTY OTHER THAN XPO, UNTIL THE COURT ISSUED A FURTHER ORDER AT OR FOLLOWING A HEARING ON JULY 23, 2015. ON JULY 16, 2015, THE PARIS COMMERCIAL COURT ISSUED AN EX PARTE ORDER AT THE REQUEST OF ELLIOTT THAT, AMONG OTHER THINGS, TEMPORARILY BARRED XPO FROM CARRYING OUT ANY OF ITS CONTEMPLATED TRANSACTIONS WITH ND, INCLUDING PURSUING THE PROPOSED MERGER WITH ND, UNTIL THE COURT ISSUED A FURTHER ORDER AT OR FOLLOWING THE JULY 23 HEARING. ON JULY 29, 2015, THE PARIS COMMERCIAL COURT LIFTED THE RESTRICTIONS CONTAINED IN BOTH EX PARTE ORDERS, AND ADDED ND TO AND REMOVED THE LIVERPOOL LIMITED PARTNERSHIP FROM THE PROCEEDINGS, AND DENIED CERTAIN OTHER RELIEF REQUESTED BY THE PARTIES. ON MAY 2, 2016, ELLIOTT FILED AN ACTION "UT SINGULI," IN THE NATURE OF A DERIVATIVE ACTION, ON BEHALF OF ND (RENAMED "XPO LOGISTICS EUROPE") AGAINST CERTAIN PRESENT AND FORMER EXECUTIVES AND/OR DIRECTORS OF ND. ON NOVEMBER 28, 2019, ELLIOTT SETTLED THESE PROCEEDINGS AND OBTAINED A FULL AND COMPLETE RELEASE. THE MATTER IS NOW CONCLUDED.

Allegations: CERTAIN PRIVATE INVESTMENT FUND ENTITIES REFERENCED ABOVE IN PART I.A OF THIS DRP (EACH SUCH FUND, AN "ELLIOTT FUND") EACH SEPARATELY RECEIVED A LETTER FROM THE HELLENIC CAPITAL MARKET COMMISSION (THE "HCMC") REGARDING SHORT-SALE ORDERS FOR A SECURITY PLACED ON MAY 6, 2014. HCMC HAS ALLEGED THAT, IN ITS VIEW, EACH ELLIOTT FUND VIOLATED AN EU SHORT-SELLING RULE BY PLACING THE SHORT-SALE ORDER ON THE DAY BEFORE THE SECURITY WAS APPROVED FOR TRADING, WITHOUT ADEQUATELY ENSURING THAT THE SECURITY WOULD BE AVAILABLE FOR SETTLEMENT WHEN DUE. Status: Pending Summary: THE HCMC REQUESTED THE ELLIOTT FUNDS' VIEWS ON THE FOREGOING ALLEGATIONS BEFORE MAKING ANY FINAL DETERMINATION. THE ELLIOTT FUNDS EACH RESPONDED TO THE HCMC AND CONTESTED THE ALLEGATIONS. IN PARTICULAR, THE ELLIOTT FUNDS STATED THAT THEY DID IN FACT ENSURE THAT THE RELEVANT SECURITY WOULD BE AVAILABLE FOR SETTLEMENT WHEN DUE IN ACCORDANCE WITH THE RELEVANT EU SHORT-SELLING RULE. EACH ELLIOTT FUND DID SO BY ENTERING INTO A BINDING AGREEMENT, BEFORE EFFECTING THE SHORT SALE, TO ACQUIRE THE SECURITY TO BE DELIVERED PRIOR TO THE SETTLEMENT DATE. IN FACT, IN ACCORDANCE WITH SUCH AGREEMENT, THE SHARES WERE ACQUIRED PRIOR TO THE SETTLEMENT DATE AND WERE DELIVERED TO THE BUYER ON THE SETTLEMENT DATE. THESE MATTERS REMAIN PENDING BEFORE THE HCMC. ON NOVEMBER 28, 2017, ELLIOTT'S COUNSEL RECEIVED AN EMAIL FROM THE HCMC STATING THAT THE HCMC DECIDED TO IMPOSE A FINE OF EURO 64,500 ON THE LIVERPOOL LIMITED PARTNERSHIP RELATING TO THE ABOVE-REFERENCED ACTIVITY. ON FEBRUARY 21, 2018, ELLIOTT'S COUNSEL RECEIVED A SUBSTANTIALLY IDENTICAL EMAIL FROM THE HCMC IMPOSING A FINE OF EURO 116,500 ON ELLIOTT INTERNATIONAL, L.P. THESE DECISIONS ARE NOT CONSIDERED FINAL AND ARE SUBJECT TO APPEAL.

Allegations: ON APRIL 23, 2014, THE ELLIOTT FUNDS ENGAGED IN TRANSACTIONS IN NATURAL GAS FUTURES WHICH RESULTED IN THE ELLIOTT FUNDS HOLDING A FUTURES EQUIVALENT POSITION IN EXCESS OF THE SPOT MONTH POSITION LIMIT UNDER NEW YORK MERCANTILE EXCHANGE RULE 562. Status: Final Sanction Detail: ELLIOTT MANAGEMENT CORPORATION ("EMC") PAID A FINE IN THE AMOUNT OF $30,000 PROMPTLY FOLLOWING SETTLEMENT OF THIS ACTION. Summary: ON APRIL 23, 2014, THE ELLIOTT FUNDS ENGAGED IN TRANSACTIONS IN NATURAL GAS FUTURES WHICH RESULTED IN THE ELLIOTT FUNDS HOLDING A FUTURES EQUIVALENT POSITION IN EXCESS OF THE SPOT MONTH POSITION LIMIT UNDER NEW YORK MERCANTILE EXCHANGE RULE 562. ON OCTOBER 28, 2014, A PANEL OF THE NYMEX BUSINESS CONDUCT COMMITTEE ACCEPTED EMC'S OFFER OF SETTLEMENT PURSUANT TO WHICH EMC AGREED TO PAY A FINE IN THE AMOUNT OF $30,000 WHILE NEITHER ADMITTING OR DENYING ANY RULE VIOLATION. EMC PAID THIS AMOUNT PROMPTLY FOLLOWING SETTLEMENT OF THIS ACTION. THE ELLIOTT FUNDS WERE NOT ASSESSED ANY FINE.

Allegations: ON MAY 8 AND MAY 9, 2014, THE ELLIOTT FUNDS ENGAGED IN TRANSACTIONS IN SOYBEAN MEAL FUTURES CONTRACTS THAT RESULTED IN THE ELLIOTT FUNDS HOLDING A FUTURES EQUIVALENT POSITION IN EXCESS OF THE STANDARD ALL MONTHS LIMIT UNDER CHICAGO BOARD OF TRADE RULE 562. Status: Final Sanction Detail: ELLIOTT MANAGEMENT CORPORATION ("EMC") PAID A FINE IN THE AMOUNT OF $20,000 AND PAID $125,082.24 REPRESENTING DISGORGEMENT OF PROFITS PROMPTLY FOLLOWING SETTLEMENT OF THIS ACTION. Summary: ON MAY 8 AND MAY 9, 2014, THE ELLIOTT FUNDS ENGAGED IN TRANSACTIONS IN SOYBEAN MEAL FUTURES CONTRACTS THAT RESULTED IN THE ELLIOTT FUNDS HOLDING A FUTURES EQUIVALENT POSITION IN EXCESS OF THE STANDARD ALL MONTHS LIMIT UNDER CHICAGO BOARD OF TRADE RULE 562. ON OCTOBER 28, 2014, A PANEL OF THE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE ACCEPTED EMC'S OFFER OF SETTLEMENT PURSUANT TO WHICH EMC AGREED TO PAY A FINE IN THE AMOUNT OF $20,000 AND PAY $125,082.24 REPRESENTING DISGORGEMENT OF PROFITS WHILE NEITHER ADMITTING OR DENYING ANY RULE VIOLATION. EMC PAID THESE AMOUNTS PROMPTLY FOLLOWING SETTLEMENT OF THIS ACTION. THE ELLIOTT FUNDS WERE NOT ASSESSED ANY FINE AND DID NOT MAKE ANY DISGORGEMENT.

Allegations: ON DECEMBER 23, 2019, ELLIOTT CAPITAL ADVISORS, L.P. ("ECALP") RECEIVED, AND SUBSEQUENTLY ON DECEMBER 31, 2019, ELLIOTT ADVISORS (UK) LIMITED ("EAUK") RECEIVED, A COPY OF AN AUTORITÉ DES MARCHÉS FINANCIERS (THE "AMF") INVESTIGATIVE REPORT (THE "REPORT") TO THE SANCTIONS COMMISSION OF THE AMF IN FRANCE. (ECALP AND EAUK ARE TOGETHER REFERRED TO BELOW AS "ELLIOTT".) THE REPORT REFLECTS NON-BINDING RECOMMENDATIONS AS TO CERTAIN ALLEGATIONS SET FORTH BY THE AMF AS A RESULT OF THEIR INVESTIGATION INTO ELLIOTT'S ACTIVITY CONCERNING A TENDER OFFER CONDUCTED BY XPO LOGISTICS, INC. AND XPO LOGISTICS FRANCE (COLLECTIVELY "XPO") FOR THE SHARES OF NORBERT DENTRESSANGLE SA ("NDSA") IN 2015. THE RECOMMENDATIONS SET FORTH IN THE REPORT ARE THAT (I) ALTHOUGH ELLIOTT'S PUBLIC DISCLOSURE OF ITS POSITION IN NDSA WAS NOT MISLEADING OR MANIPULATIVE, IT INACCURATELY DESCRIBED ITS DERIVATIVE HOLDINGS AS "CONTRACTS FOR DIFFERENCE" RATHER THAN AS "EQUITY SWAPS"; (II) ELLIOTT DID NOT DECLARE ITS INTENTION TO NOT TENDER ITS HOLDINGS IN NDSA INTO XPO'S TENDER OFFER IN A TIMELY MANNER; AND (III) DESPITE RESPONDING TO EACH OF THE AMF'S REQUESTS FOR INFORMATION IN A TIMELY MANNER, AND DESPITE ELLIOTT HAVING VOLUNTARILY AGREED TO ANSWER REQUESTS IT WAS NOT COMPELLED TO ANSWER, EAUK IMPEDED THE AMF'S INVESTIGATION BY MAKING A DELAYED PRODUCTION OF DOCUMENTS THAT ELLIOTT, IN THE AMF'S VIEW, SHOULD HAVE UNDERSTOOD WERE BEING SOUGHT BY THE AMF. Status: On Appeal Sanction Detail: THE SANCTIONS COMMISSION OF THE AMF ASSESSED A FINE OF EUR 15 MILLION (APPROXIMATELY $16,500,000) AGAINST EAUK AND EUR 5 MILLION (APPROXIMATELY $5,500,000) AGAINST ECALP. THE PARIS COURT OF APPEALS REDUCED THE FINE AGAINST EAUK BY EUR 1 MILLION (APPROXIMATELY $1,100,000) AND AGAINST ECALP BY EUR 0.5 MILLION (APPROXIMATELY $555,000). Summary: ON APRIL 22, 2020, ELLIOTT RECEIVED A WRITTEN DECISION IN AN ADMINISTRATIVE PROCEEDING FROM THE SANCTIONS COMMISSION OF THE AMF IN FRANCE RELATING TO ELLIOTT'S ACTIVITY CONCERNING A TENDER OFFER CONDUCTED BY XPO FOR THE SHARES OF NDSA IN 2015. IN THE WRITTEN DECISION THE AMF FOUND (I) THAT ELLIOTT INACCURATELY DESCRIBED THEIR DERIVATIVE HOLDINGS AS "CONTRACTS FOR DIFFERENCE" RATHER THAN AS "EQUITY SWAPS" IN THEIR PUBLIC DISCLOSURE OF THEIR POSITION IN NDSA; (II) THAT ELLIOTT DID NOT DECLARE THEIR INTENTION TO NOT TENDER THEIR HOLDINGS IN NDSA INTO XPO'S TENDER OFFER IN A TIMELY MANNER; AND (III) THAT EAUK IMPEDED THE AMF'S INVESTIGATION BY MAKING A DELAYED PRODUCTION OF DOCUMENTS THAT ELLIOTT, IN THE AMF'S VIEW, SHOULD HAVE UNDERSTOOD WERE BEING SOUGHT BY THE AMF. ALTHOUGH THE SANCTIONS COMMISSION ACCEPTED THAT ELLIOTT'S DECLARATIONS RELATING TO XPO'S TENDER OFFER DID NOT IN FACT MISLEAD OR CAUSE MARKET PARTICIPANTS TO MODIFY THEIR STRATEGIES CONCERNING THE TENDER OFFER, AND FOUND NO INTENT BY EAUK TO IMPEDE THE AMF'S INVESTIGATION THROUGH THE DELAYED PRODUCTION OF MATERIALS, IT NEVERTHELESS IMPOSED A FINE OF EUR 15 MILLION AGAINST EAUK AND A FINE OF EUR 5 MILLION AGAINST ECALP. ELLIOTT STRONGLY DISAGREES WITH THE FINDINGS AGAINST ELLIOTT IN THIS ADMINISTRATIVE PROCEEDING, CONSIDERS THEM WHOLLY WITHOUT FOUNDATION, VIGOROUSLY OPPOSES ANY SUGGESTION OF WRONGDOING, AND APPEALED THE MATTER TO THE PARIS COURT OF APPEALS. ON MARCH 24, 2022 THE PARIS COURT OF APPEALS DETERMINED THAT ELLIOTT WAS NOT IN FACT REQUIRED IN ITS DECLARATIONS OF INTENT TO DISTINGUISH THE TYPE OF ITS DERIVATIVE HOLDINGS AND REDUCED THE FINE AGAINST EAUK BY EUR 1 MILLION AND AGAINST ECA BY EUR 0.5 MILLION. HOWEVER, THE COURT OF APPEALS UPHELD THE AMF'S FINDINGS THAT: (I) ELLIOTT WAS NEVERTHELESS REQUIRED TO DISTINGUISH THE TYPE OF ITS DERIVATIVE HOLDINGS IN ITS OTHER FILINGS; (II) ELLIOTT DID NOT DECLARE ITS INTENTION TO NOT TENDER ITS HOLDINGS IN NDSA INTO XPO'S TENDER OFFER IN A TIMELY MANNER; AND (III) EAUK IMPEDED THE AMF'S INVESTIGATION BY MAKING A DELAYED PRODUCTION OF DOCUMENTS THAT ELLIOTT, IN THE AMF'S VIEW, SHOULD HAVE UNDERSTOOD WERE BEING SOUGHT BY THE AMF. ELLIOTT DISAGREED WITH THE DECISION OF THE PARIS COURT OF APPEALS AND APPEALED THE DECISION TO THE FRENCH SUPREME COURT, THE COUR DE CASSATION. ON APRIL 4, 2024 THE COUR DE CASSATION AFFIRMED THE DECISION OF THE PARIS COURT OF APPEALS. ELLIOTT DISAGREES WITH THE DECISION OF THE COUR DE CASSATION. ON AUGUST 2, 2024, ELLIOTT SUBMITTED AN APPLICATION TO THE EUROPEAN COURT OF HUMAN RIGHTS TO HEAR AN APPEAL. NONE OF THE COSTS ASSOCIATED WITH THIS MATTER (INCLUDING THE PENALTY ASSESSED BY THE SANCTIONS COMMISSION AND THE COST OF THE APPEAL) HAVE BEEN OR WILL BE BORNE BY THE ELLIOTT FUNDS, AND ELLIOTT CONTINUES TO BELIEVE THAT THIS MATTER WILL NOT HAVE AN ADVERSE IMPACT ON THE FUNDS.

Allegations: ON DECEMBER 28, 2012, ELLIOTT ADVISORS (UK) LIMITED ("EAUK") RECEIVED A LETTER OF GRIEVANCE FROM THE FRENCH FINANCIAL MARKET REGULATOR, THE AUTORITÉ DES MARCHÉS FINANCIERS (THE "AMF"), STATING THAT EAUK MAY HAVE PURCHASED THE STOCK OF AUTOROUTES PARIS RHIN-RHÔNE ("APRR") BASED ON MATERIAL NONPUBLIC INFORMATION RELATING TO A POTENTIAL SALE OF ELLIOTT'S APRR STAKE TO EIFFARIE, APRR'S MAJORITY OWNER. THE AMF ALSO STATED THAT ELLIOTT'S APRR PURCHASES DURING THE RELEVANT PERIOD MAY HAVE CAUSED THE APRR STOCK PRICE TO BE ARTIFICIALLY INFLATED. ON JANUARY 31, 2013, ELLIOTT MANAGEMENT CORPORATION ("EMC") RECEIVED A SUBSTANTIALLY IDENTICAL LETTER OF GRIEVANCE FROM THE AMF. THE LETTER TO EMC DID NOT ASSERT ANY NEW STATEMENTS OR SET FORTH ANY NEW FACTS. Status: Final Sanction Detail: THE SANCTIONS COMMISSION OF THE AMF ASSESSED A PENALTY OF 8 MILLION EUROS AGAINST EMC (APPROXIMATELY $11 MILLION) AND 8 MILLION EUROS AGAINST EAUK. Summary: ON MAY 5, 2014, EAUK AND EMC RECEIVED A WRITTEN DECISION IN AN ADMINISTRATIVE PROCEEDING FROM THE SANCTIONS COMMISSION OF THE AMF IN FRANCE. THE WRITTEN DECISION (THE "AMF DECISION") RELATED TO ALLEGATIONS BY THE AMF THAT ELLIOTT PURCHASED STOCK OF APRR BASED ON MATERIAL NONPUBLIC INFORMATION AND THAT ELLIOTT MANIPULATED THE STOCK OF APRR. IN THE AMF DECISION, THE SANCTIONS COMMISSION FOUND THAT ELLIOTT USED MATERIAL NONPUBLIC INFORMATION IN THE PURCHASE OF APRR SHARES BETWEEN MAY 28, 2010 AND JUNE 11, 2010 BUT HELD THAT ELLIOTT DID NOT COMMIT MARKET MANIPULATION OR ARTIFICIALLY INFLATE THE PRICE OF APRR SHARES. THE SANCTIONS COMMISSION ASSESSED A PENALTY OF 8 MILLION EUROS AGAINST EMC AND 8 MILLION EUROS AGAINST EAUK. ELLIOTT DISAGREES WITH THE FINDINGS AGAINST EMC AND EAUK IN THIS ADMINISTRATIVE PROCEEDING. IT REMAINS ELLIOTT'S POSITION THAT ITS TRADING IN APRR'S SECURITIES WAS LAWFUL AT ALL TIMES. ELLIOTT'S PURCHASES OF APRR STOCK WERE MADE AS PART OF A LONGSTANDING TRADING STRATEGY DATING BACK TO 2005. ELLIOTT PURCHASED APRR STOCK ON OVER 300 TRADING DAYS BETWEEN DECEMBER 2005 AND JUNE 2010. ELLIOTT HAS LONGSTANDING POLICIES AND PROCEDURES IN PLACE TO PREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION. CONSISTENT WITH THOSE PROCEDURES, ELLIOTT HAD A CHINESE WALL IN PLACE WITH RESPECT TO APRR DURING THE PERIOD IN QUESTION, AND NO MATERIAL NONPUBLIC INFORMATION WAS TRANSMITTED TO THE PERSONNEL WHO DIRECTED THE PURCHASES OF APRR STOCK. DESPITE AN INVESTIGATION WHICH INCLUDED EXTENSIVE REVIEWS OF EMAILS, AUDIOTAPED TRADING LINES AND INTERVIEWS WITH WITNESSES, THE AMF OFFERED NO EVIDENCE THAT ELLIOTT'S CHINESE WALL WAS BREACHED, BUT INSTEAD SIMPLY CONCLUDED THAT THE CIRCUMSTANCES SUPPORTED THEIR INFERENCE THAT THE CHINESE WALL WAS BREACHED. EMC AND EAUK APPEALED THE AMF DECISION TO THE PARIS COURT OF APPEALS. ON JANUARY 14, 2016, THE PARIS COURT OF APPEALS AFFIRMED THE AMF DECISION. ELLIOTT DISAGREES WITH THE DECISION OF THE PARIS COURT OF APPEALS AND EMC AND EAUK APPEALED THE DECISION TO THE FRENCH SUPREME COURT, THE COUR DE CASSATION. ON MARCH 27, 2019, THE COUR DE CASSATION AFFIRMED THE AMF DECISION. ELLIOTT DISAGREES WITH THE DECISION OF THE COUR DE CASSATION. ON FEBRUARY 6, 2020, THE EUROPEAN COURT OF HUMAN RIGHTS DECLINED TO HEAR THE APPLICATION OF EMC AND EAUK. EMC AND EAUK SUBSEQUENTLY SUBMITTED AN APPLICATION TO THE EUROPEAN COMMISSION REGARDING, AMONG OTHER THINGS, THE INCORRECT APPLICATION OF EU LAW, WITH A VIEW TO APPEALING THE DECISION OF THE FRENCH COURTS. ON JUNE 21, 2021, ELLIOTT WAS NOTIFIED THAT THE EUROPEAN COMMISSION HAD REJECTED THE APPLICATION. NONE OF THE COSTS ASSOCIATED WITH THIS MATTER (INCLUDING THE PENALTY ASSESSED BY THE SANCTIONS COMMISSION AND THE COST OF THE APPEAL) HAVE BEEN OR WILL BE BORNE BY THE ELLIOTT FUNDS, AND ELLIOTT CONTINUES TO BELIEVE THAT THIS MATTER DID NOT HAVE AN ADVERSE IMPACT ON THE FUNDS.

Allegations: ON DECEMBER 9, 2016, THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ISSUED A "SHOW CAUSE NOTICE" (THE "NOTICE") UNDER SECTIONS 11, 11B AND 11(4) OF THE SEBI ACT, 1992, AND REGULATIONS 3(B), (C), (D) AND 4(1) OF THE SEBI (PROHIBITION OF FRAUDULENT AND UNFAIR PRACTICE RELATING TO SECURITIES MARKET) REGULATIONS, 2003, ADDRESSED TO ELLIOTT ADVISORS (HK) LIMITED ("EAHK"), ELLIOTT MANAGEMENT CORPORATION, ELLIOTT ASSOCIATES, L.P., ELLIOTT INTERNATIONAL, L.P., THE LIVERPOOL LIMITED PARTNERSHIP, MANSFIELD (MAURITIUS) LIMITED, SUFFOLK (MAURITIUS) LIMITED (TOGETHER "ELLIOTT") AND ASTRAZENECA PHARMACEUTICALS AB SWEDEN ("AZ SWEDEN"). THE NOTICE WAS ISSUED PURSUANT TO SEBI'S INVESTIGATION INTO MATTERS CONCERNING A SALE BY AZ SWEDEN OF SHARES IN ASTRAZENECA PHARMA INDIA LIMITED ("AZ INDIA") IN A PUBLIC OFFER FOR SALE PROCESS (THE "OFS") CONDUCTED IN MAY 2013, AND PERCEIVED CONNECTIONS WITH THE SUBSEQUENT INTENDED PRIVATIZATION AND DELISTING OF AZ INDIA THAT WAS ANNOUNCED ON MARCH 3, 2014 BUT WAS NOT EXECUTED. THE NOTICE SET FORTH CERTAIN ALLEGATIONS, INCLUDING THAT (I) ELLIOTT AND AZ SWEDEN EMPLOYED MANIPULATIVE AND DECEPTIVE DEVICES BY CONDUCTING FRAUDULENT NEGOTIATIONS TO INFLUENCE THE DELISTING PRICE OF AZ INDIA; AND (II) MATERIAL INFORMATION CONCERNING SUCH NEGOTIATIONS, THE SIZE OF ELLIOTT'S OVERALL EXPOSURE TO AZ INDIA, AND ITS ABILITY TO INFLUENCE THE INTENDED DELISTING PROCESS WAS CONCEALED FROM RETAIL INVESTORS. Status: Final Sanction Detail: SEE ITEM 13 BELOW. Summary: ON JUNE 5, 2020, ELLIOTT AND AZ SWEDEN RECEIVED A WRITTEN ORDER IN AN ADMINISTRATIVE PROCEEDING CONDUCTED UNDER SECTIONS 11(1), 11(4) AND 11(B) OF THE SEBI ACT 1992 BY SEBI. THE ORDER RELATES TO ALLEGATIONS BY SEBI THAT ELLIOTT AND AZ SWEDEN EMPLOYED MANIPULATIVE AND DECEPTIVE DEVICES BY CONDUCTING FRAUDULENT NEGOTIATIONS TO INFLUENCE THE DELISTING PRICE OF SHARES IN AZ INDIA. THE DELISTING OF AZ INDIA WAS PROPOSED BY AZ SWEDEN IN EARLY 2014 BUT DID NOT TAKE PLACE. AS NOTED ABOVE, THE SEBI ORDER CAN BE INTERPRETED AS SAYING THAT ELLIOTT AND AZ SWEDEN DID NOT COMPLY WITH REQUIREMENTS UNDER THE SEBI (PROHIBITION OF FRAUDULENT AND UNFAIR PRACTICE RELATING TO SECURITIES MARKET) REGULATIONS, 2003. ELLIOTT AND AZ SWEDEN WERE CENSURED AND DIRECTED TO REFRAIN FROM SIMILAR ACTIONS IN THE FUTURE. NO MONETARY PENALTY WAS IMPOSED. ELLIOTT STRONGLY DISAGREES WITH THE ORDER AND THE FINDINGS, CONSIDERS THEM TO BE WHOLLY WITHOUT FACTUAL AND LEGAL FOUNDATION, AND IT REMAINS ELLIOTT'S POSITION THAT THE ACTIVITIES OF ELLIOTT WERE LAWFUL AT ALL TIMES.

Allegations: ON OCTOBER 25, 2024, ELLIOTT INVESTMENT MANAGEMENT L.P. ("ELLIOTT") BECAME AWARE OF A NOTICE (THE "NOTICE") ISSUED BY BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICGHT ("BAFIN"), ADDRESSED TO MR. PAUL SINGER, THE ULTIMATE CONTROL PERSON OF ELLIOTT, ALLEGING THAT ELLIOTT FAILED TO TIMELY FILE CERTAIN NOTIFICATIONS IN CONNECTION WITH AN INVESTMENT MADE BY CERTAIN OF EIM'S ADVISORY CLIENTS (THE "ELLIOTT FUNDS") IN HELLA GMBH & CO. KGAA, A GERMAN-DOMICILED COMPANY (THE "ISSUER"). ELLIOTT TIMELY FILED SUCH NOTIFICATIONS AND CORRECTLY IDENTIFIED BOTH THE LEGAL AND ULTIMATE BENEFICIAL OWNERS IN SUCH NOTIFICATIONS AT THAT TIME. ELLIOTT SUBSEQUENTLY NOTIFIED BAFIN OF ITS INTENTION TO UPDATE, AND THEN UPDATED, THE NOTIFICATIONS WITH RESPECT TO IDENTIFYING CERTAIN ENTITIES IN THE HOLDING STRUCTURE THROUGH WHICH THE ISSUER WAS HELD BY THE ELLIOTT FUNDS. BAFIN HAS ALLEGED THAT ELLIOTT FAILED TO CORRECTLY IDENTIFY THOSE ENTITIES IN THE HOLDING STRUCTURE IN ITS ORIGINAL NOTIFICATIONS. Status: Pending Summary: ON OCTOBER 25, 2024, ELLIOTT BECAME AWARE OF THE NOTICE FROM BAFIN DATED JULY 30, 2024 STATING THAT BAFIN HAD INITIATED ADMINISTRATIVE OFFENCE PROCEEDINGS AGAINST MR. SINGER, THE ULTIMATE CONTROL PERSON OF ELLIOTT. PURSUANT TO SUCH NOTICE, BAFIN IS PROVIDING AN OPPORTUNITY TO COMMENT ON THE FOREGOING ALLEGATIONS PRIOR TO DECIDING WHETHER TO TAKE ANY ACTION WITH RESPECT TO THIS MATTER. ELLIOTT IS SUBMITTING A WRITTEN RESPONSE TO BAFIN WITH RESPECT TO THESE ALLEGATIONS.