Kurt Salmon - Securities Reference Data Management: A Trend towards Outsourcing? White Paper -...

Kurt Salmon White Paper Securities Reference Data

Management: A Trend towards Outsourcing?White Paper

September 2013

24, rue Salomon de Rothschild - 92288 Suresnes - FRANCETél. : +33 (0)1 57 32 87 00 / Fax : +33 (0)1 57 32 87 87Web : www.carrenoir.com

INEUM Kurt SalmonINE_06_0409_Logo_CMYK14/12/2010

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WHITEPAPER | SEPTEMBER 2013

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About Us

Kurt Salmon is a global management consultan-cy of more than 1,400 consultants in 13 countries across four continents. Our clients are industry leaders who benefit from our deep industry and functional expertise. As a trusted advisor, Kurt Salmon partners with clients to design, and then drive strategies and solutions that make last-ing and meaningful impacts. We are committed to delivering measurable results for our clients through execution excellence. Kurt Salmon is part of Management Consulting Group Plc, listed on the London Stock Exchange.




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CONTENTS

RESEARCH BACKGROUND................................................................................................................................................................. 5

EXECUTIVE SUMMARY ......................................................................................................................................................................... 6

GENERAL INDUSTRY CONTEXT ...................................................................................................................................................... 7

DEFINITION OF SECURITIES REFERENCE DATA .................................................................................................................... 8

THE ALTERNATIVE APPROACHES FOR SECURITIES REFERENCE DATA MANAGEMENT .............................................................................................................................................. 10

DIVERGENT VIEWS REGARDING THE OPERATING MODELS .........................................................................................12

THE OUTSOURCING OPERATING MODEL: A STEP BY STEP APPROACH ................................................................14

THE CHANGING OPERATING MODELS: AN EVOLUTIONARY PROCESS ..................................................................16

CAN SECURITIES REFERENCE DATA MANAGEMENT BE OUTSOURCED? ..............................................................18

POSITIONING OF REFERENCE DATA MANAGEMENT SERVICES REGARDING OUTSOURCING ................ 20

ACKNOWLEDGEMENTS ......................................................................................................................................................................22



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RESEARCH BACKGROUND

This white paper is part of series of researches on the evolution of securities operating models. Last year Kurt Salmon published the first part of the research, which studied the evolution of the securities operating platforms in general.

Next year a study on corporate actions handling will be published.

This year the study focuses on the evolution of securities reference data management operating models. In this context, special attention has been given to centralization of the data manage-ment processes and to the role of outsourcing.

In light of the ever-evolving securities industry, this research has been launched in order to advise financial services companies in the selection of the most adequate operating models and tech-nical solutions and to guide future outsourcers in the set-up and implementation of their new solution.

In this white paper, we distinguish on the one hand, custodians - who can be local, multi-country or global - and on the other hand, retail, universal and private banks and asset managers - who provide securities services to their own clients, but can be, at the same time, the (target) clients of custodians.




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EXECUTIVE SUMMARY

In the past 20 years, I have been involved in numerous securities reference data management projects. The main objectives of these projects were almost always the same: increase data qual-ity and reduce cost by simplifying the operating model and automating the process. Creating a centralized securities master file was considered to be one of the best practices, but has not always been achieved.

Faced with many new challenges in terms of reference data, such as the increasing number of new regulations, endless product innovation and increased competition, trying to achieve a centralized reference data management will become more important. Hence, we can expect a slow but sure evolution towards centralization of securities reference data management. For some companies, the business case is positive today, for others this might not be the case, but it will be in years to come, when systems become outdated and the replacement of legacy systems can no longer be postponed, when the cost of adapting to changing data flows, the implementa-tion costs of new regulations, the increasing operational risk and changes in the available pool of resources, will make the business case for centralizing the process positive.

Centralization is only part of the evolutionary change the securities operating models are going through. The trend towards outsourcing is another important aspect.

Finally, the best practice for achieving your securities reference data management project is not to go for a revolution, but to evolve to the final model in a step by step approach.

Herwig Temmerman

Securities Services, Practice Leader



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Securities reference data management is evolving from a necessary and often ignored cost to support operations to a central and vital role within the organization.

Financial institutions have to face many new challenges in terms of Reference Data Manage-ment:

• With an endlessly creative market and ceaseless new instruments to manage, financial institutions must be able to inte-grate and standardize securities refer-ence data.

• Upcoming regulations and always more and more restrictive compliance rules require reliable and real-time availability, as well as high quality data at all time.

• Competition within the securities indus-try reinforces the need to create addi-tional economies of scale within a service that involves labor-intensive processes and highly qualified resources.

• Growing trading volumes as well as demanding clients regarding data qual-ity and transparency, forces financial institutions to better manage their risks (operational, reputation,...) while reduc-ing operating costs at the same time.

• In an automated world where STP is the golden rule, organizations cannot afford inconsistencies, incomplete or inaccurate reference data that will generate internal failure.

In the last two to three years, we have noticed new trends in terms of reference data manage-ment. They have impacted the way financial institutions want or would like to handle their securities referential:

• There are more and more departments using securities reference data, where in the past their usage was limited to specialists. As a consequence, reference data must be shared by several business units and databas-es must be interfaced with even more (legacy) systems.

• With a broad range of data feeds availa-ble on the market and an obligation to provide high quality data, organisations try to perform some cleansing, scrubbing to finally get a “Golden Copy”, but all these implemented rules also have an underlying cost.

• Cloud or Big Data has become THE hot topic and as part of the data management analysis, the securities reference databases are also included in the overall company strat-egy.

GENERAL INDUSTRY CONTEXT




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DEFINITION OF SECURITIES REFERENCE DATA

Today we commonly use the terms “Reference Data”, “Securities Referential” or “Securities Data base” management to reflect the willingness to properly handle the static and the dynamic data linked to financial instruments.

In this study the terms “Reference Data”, “Securities Referential” or “Securities Database” management refer to the collection, verification, cleansing and validation of data on securities required for the processing of securities transactions and management of securities positions. This includes:

|Kurt Salmon – Private and confidential, not for distribution Page 2

Picuture 1 (Autre version):

Static Data Dynamic Data

ISIN Codes, Sedols, Cusips, Tickers …

Name, Interest rate, Issue date, Currency … Ratings, economic sector data, alpha, beta

…

End of Day, Delayed, Real-Time, FX Rates …

Tax and risk data linked to the financial instrument

Counterparties for securities transactions …

Securities Identifiers

Financial Instruments Definition

Pricing Data

Tax & Risk Data

Participant Data

Corporate Data

It is important to note that corporate action data is not included.



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THE CASINO WINNING ROULETTE

Securities reference data management best practices

Casino reference data management:

• Reference data is used everywhere (front, middle and back), decentralized (multiple systems and processes) and rely on manual operations to scrub, update and maintain data

• Internal systems are typically developed/implemented per product line or business silo, each containing their relevant instrument, client and other reference data

• Data is inconsistent, incomplete or inaccurate

• Lack of reference data standards

• Multiple legacy systems and diff erent technologies make central data dissemination diffi cult to achieve

• Multiple data vendors are used by diff erent departments within the organization

• As a consequence risk of errors are signifi cant

Implement the winning roulette in 5 steps in order to better manage your risk of losing and in order to achieve economies of scale:

• Standardization of security information, i.e. one security master fi le

• Standardization of data elements, e.g. single set of prices held centrally for a security

• Uniform approach to money market issuance

• Automatic code allocation service to appro-priate instruments eligible on a single plat-form

• Automatic opening of new instruments

• Centralized processing




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Individual Securities Referential

BU / DEP 1

Each Department or Business Unit has its own securities reference database and some Departments or Business Units use more than one

securities referential

A Market Utility feeding part of a common securities referential for all the

Departments or Business Units of an entity

Collective solution / joint venture

Some securities referentials are shared by different Business Units

or Departments, but not all

Business Process Outsourcing: an external securities referential for all the Departments or Business

Units of an entity

One securities referential for all Departments or Business Units

Against the trend

Challenging

BU / DEP 2

BU / DEP 1

One consolidated securities referential for two or more Institutions (Institutions A and B) and

used by their respective Business Units/Departments

1 2

3 4

5

6

BU / DEP 1

BU / DEP 2

BU / DEP n

BU / DEP 1

BU / DEP 2

BU / DEP n

BU / DEP 1-A

BU / DEP 2-A

BU / DEP 1-B

BU / DEP 2-B

BU / DEP 1

BU / DEP 2

BU / DEP n

BU / DEP 3

BU / DEP 2

BU / DEP 1

REF 1 REF BPO

REF 1

REF 2 Market Utility

REF A+B

REF 1 REF 2 REF 1

REF 2

REF 1

  Picture 2

THE ALTERNATIVE APPROACHES FOR SECURITIES REFERENCE DATA MANAGEMENT

Different operating models are in usage today. We have identified 6 operating models:



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Current Model Description Future Model

1 The Individual Securities Referential

• In this model each Department or Business Unit has its own securities reference database and some Departments or Business Units use more than one securities referential

• Model 1 is against the trend and inefficient: costs can be reduced, data quality increased and operational risk diminished

• Kurt Salmon recommendation: companies who have not yet done so should analyze possibilities to move to a more pragmatic model, ideally a centralized model. The possibility to externalize the process should be considered as well.

Model 2, ideally 3 or maybe 5

2 “Pragmatic” Centralized Securi-ties Referential

• In this model some securities referentials are shared by different Business Units or Departments, but not all of them.

• Model 2 is a pragmatic model, i.e. the processes are not efficient but there is no business case to move to a more centralized model and/or outsourcing the proc-ess. Efficiency can be improved: costs can be reduced, data quality increased and operational risk diminished

• Kurt Salmon recommendation: Is your business case up to date? Have all elements been taken into account, i.e.

• Cost of maintenance of existing systems

• Cost of adapting systems to changing data flows

• Cost of implementation of new regulations

• Operational risk

• Staff and “know how” evolution

The possibility to externalize the process should be considered as well.

Model 3 or maybe 5

3 Centralized Securi-ties Referential

• In this model one securities referential is used by all Departments or Business Units

• Model 3 is a best of breed operating model

• Kurt Salmon recommendation: analyze if further efficiency gains can be achieved, e.g.

• Monitoring of data vendor feeds usage

• Cost/benefit analysis of scrubbing process

• …

• The possibility to externalize the process or to offer insourcing services should be considered as well.

Maybe model 5 or provision of insourcing services

4 Collective Solution / Joint Venture

• In this model one consolidated securities referential is used by the Business Units/Departments of two or more Institutions (Institutions A and B)

• Model 4 is a challenging operating model, used in France for example, but currently non-existent in the Benelux area, although some universal banks might move or want to consider moving in that direction

• Kurt Salmon recommendations:

• Only consider moving to this model if you have already strongly centralized your securities reference data management

• Consider maximizing membership in order to achieve economies of scale

Additional Participants

5 Outsourcing of the securities referential

• In this model an external partner provides securities reference data services to all Departments or Business Units of an entity

• This will probably be the most common model in the future

• Different types of outsourcing models exist and are further explained on page 14.

Cross-border expansion

6 Securities referen-tials relying partially on an industry wide initiative

• In this model a Market Utility is feeding part of a common securities referential for all the Departments or Business Units of an entity

• This is a model that could emerge, in particular on an European level

• Kurt Salmon recommendation:

• No action to be taken by data users

• Data or service providers might consider doing an opportunities analysis

Globaliza-tion




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DIVERGENT VIEWS REGARDING THE OPERATING MODELS

Pragmatic approaches and integration software

Most actors currently adopt a model that is often a combination of an individual securities refer-ential and a pragmatic centralized model.

For some of the interviewed companies replacing the legacy securities master file is not consid-ered to be an option. The main reason being that the “old” database is still running fine at a totally depreciated cost and is so well integrated with the technical architecture of the company that replacing this might be opening Pandora’s Box.

In order to improve the process some actors opt for the selection and implementation of integra-tion software. Such a solution is used to map the vendor data that is subsequently loaded into the legacy securities master file.

The main driver for the adoption of such a « middleware » solution is to increase efficiency and decrease cost of having to map the continuously changing data feeds.

Some of the interviewed companies consider this to only be a “half” solution. It does not solve the issue of modernizing, centralizing and, potentially, outsourcing the process.

Centralization of securities referentials

All interviewed companies agree that the data vendor procurement process should be central-ized, but only two thirds of them agree to the possibility of the creation of a centralized securi-ties reference database. Some of the interviewed companies specifically believe different data-bases are required for front office and back office processing.

Sometimes centralization may not be possible due to the fact that used reference data is too integrated with the processes of clients on a specific market.

Various interviewed companies mentioned that the degree of centralization that can be achieved depends on the size of the company and the related economies of scale that can be realized. It also depends on the cost of the operational model currently used, which can have a positive or negative impact on the business case of a centralization project.



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Joint ventures

In the Benelux market, no securities reference data management joint ventures could be iden-tified. However, on the French market, this type of joint ventures does exist, although they are often part of a transaction processing hub solution.

The interviewed retail, private and universal banks do not exclude the possibility of more of these joint ventures emerging in the future.

For custodians, securities reference data management is part of their core business. Joint ventures among competitors are considered to be highly unlikely.

Outsourcing

None of the interviewed companies believe that outsourcing could not be an efficient model. The majority even believes it is the model of the future.

However, some retail, private and universal banks do not think that the model would be the best model for their own operations. The main reason for this is that they have invested in the optimi-zation of processes in the last decade and that consequently, there is currently no business case to further invest in this domain.

Custodians - who can be local, multi-country or global - will not outsource the securities refer-ence data management process given it is a key part of their business. However, global custo-dians have often set up offshore centers to manage part of the data. Cost containment is one of the reasons why this has been done, but another, as important factor is assuring, as much as possible, a 24/24 service, preferably by setting up a follow the sun model.

Custodians could consider further developing their in-sourcing capabilities in the securities refer-ence data management area. However, for the interviewed companies this does not seem to be a top priority. In particular, the issue of responsibility in case of errors and contractual issues with data vendors are mentioned as the main reasons why the offering of this type of services is not so obvious.

Market utilities

Very few actors believe in the feasibility and the benefit of a market utility, in particular on a national level. On an international level it is recognized that this could bring important benefits, but it is still a far-fetched idea, although, if T2S becomes a success, one day this could become a reality on a European level. The market utility would, however, only partially respond to the data needs. Enterprise specific needs would still have to be handled individually.




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THE OUTSOURCING OPERATING MODEL: A STEP BY STEP APPROACH

Companies are often reluctant to outsource the management of reference data. Indeed, the process is not without risk. This is probably why in our market analysis we observed that exter-nalization is often an evolving process. Only when a first step of externalization has been success-ful and a certain level of confidence has been achieved, a next step in the process is being imple-mented. Four main steps can be distinguished:


External aggregation | ASP External aggregation & Control BPO | Business Process Outsourcing

BU / DEP 1

BU / DEP 2

BU / DEP n

BU / DEP 1

BU / DEP 2

BU / DEP n

BU / DEP 1

BU / DEP 2

BU / DEP n

BU / DEP 1

BU / DEP 2

BU / DEP n In

tern

al P

roce

ss

|

Ext

erna

l Par

tner

Picture 3

Data vendor 1

Data vendor 3

Data Vendor 2

REF 1

External SMF

Data vendor 1

Data vendor 3

Data Vendor 2

REF 1

External SMF

Data vendor 1

Data vendor 3

Data Vendor 2

REF 1

External SMF

Data vendor 1

Data vendor 3

Data Vendor 2

External SMF

Control Control

Control Control



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Step 1: External aggregation

In this first step only the aggregation of data from different sources is externalized. The outsourc-ing party still wants to control internally the collected and, sometimes, cleansed data. The exter-nal aggregated data is copied in an internal database and controlled before distributed internally to the different business units and departments.

Step 2: External aggregation and control - ASP (Application Service Provider)

In the second step the outsourcing party still wants to control internally the data, but agrees to do this in the application of the external partner.

Step 3: External aggregation and control - BPO (Business Process Outsourcing)

The next step is the delegation of control of the data to the insourcing party by the outsourcing partner. The operational process is now completely externalized. However, the aggregated and controlled data is still being copied in a central database at the outsourcing party before being distributed internally. This way it remains possible to return to the previous operating model if things would go wrong.

Step 4: Business Process Outsourcing

In this step the outsourcing party decommissions its internal database and distribution network and agrees that the external partner sends the data directly to the different business units and departments.




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THE CHANGING OPERATING MODELS:AN EVOLUTIONARY PROCESS

There is an evolution of operating models towards more centralization and externalization. In general this is a slow process, because in most cases the process goes through diff erent stages.

The « spaghetti » network (model 1) is optimized and evolves towards a «pragmatic » centraliza-tion model (model 2).

If not immediately, in the medium to long term, the busi-ness case for more centralization will become positive because legacy systems have to be replaced sooner or later and the cost of adapting ineffi cient processes to ever faster changing markets and regulations continues to increase until complexity reaches a tipping point and becomes counterproductive.

After centralization of the process, creating a joint venture with other players on the market (model 4) could be an option.

The more likely evolution is, however, towards an externalization of the processes (model 5).

As seen in previous chapter, the externalization itself often goes through diff erent stages from aggregation of data only up to complete business process outsourcing.

Following chart shows the relative positioning of the diff erent companies interviewed in this “evolutionary” process. Some companies have plans to change their operating model. Others are “satisfi ed” with their current model and have no plans to change it at this stage.|Kurt Salmon – Private and confidential, not for distribution Page 8

The changing operating models: an evolutionary process

1 2

3 4

5

6

BPO



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Picture 5

Individual Pragmatic Centralised External aggregation External aggregation & control

Business Process Outsourcing

Companies interviewed and with no intention to change their current model

Companies interviewed that intend to change their model

: Number of companies

: Plan to evolve model towards

11

11

1 1 1

3

32 3




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CAN SECURITIES REFERENCE DATA MANAGEMENT BE OUTSOURCED?

In « Business Process Outsourcing, the Competitive Advantage », Rick L. Click and Thomas N. Duening present an outsourcing decision model. The model has three dimensions: productivity, cost and mission criticality. The following illustration summarizes the outsourcing decision matrix suggested:

(Source: Rick L. Click and Thomas N. Duening, Business Process Outsourcing. The competitive advantage. John Wiley & Sons Inc., 2005, pp. 60-64)


7. How to define what is important for your business model and what can be outsourced _PICTURE 6

In « Business Process Outsourcing, the Competitive Advantage », Rick L. Click and Thomas N. Duening, present an outsourcing decision model. The model has three dimensions: productivity, cost and mission criticality

Cost

Productivity

HIGH

LOW

LOW HIGH

3 7

High Cost / Low Productivity

High Cost / High Productivity

Low Cost / Low Productivity

Low Cost / High Productivity

Outsourcing Decision Matrix

Mission Criticality

Mission Criticality

Mission Criticality

Mission Criticality

Lo

Lo

Lo

Lo

Hi

Hi

Hi

Hi

  Type 1: Processes that are high on each on the three dimensions are difficult to outsource. These functions are usually at the highest levels of the organizations

  Type 2: Prime candidate for outsourcing, if productivity levels are maintained throughout the transition process and afterward

  Type 3: Unattractive candidate, unless partners who can provide competitive advantages over the internal unit are identified

  Type 4: Low cost processes with high productivity are difficult to outsource, event if not mission critical. Only candidate for outsourcing if productivity can be maintained or increased and cost can be further decreased, for example, by moving the process to low cost centers offshore

  Type 5: Good candidate for outsourcing, even tough high mission criticality makes the outsourcing decision more difficult. There are techniques for limiting a firm’s risk exposure to outsourcing mission-critical functions: e.g. choice of vendor is important, as is potential for backup and recovery.

  Type 6: The most likely to be outsourced (high cost, low productivity, low mission criticality).

  Type 7: Not worth considering for outsourcing unless the company can identify a provider with strategically dominant services

  Type 8: Low cost processes that are low in productivity and mission criticality, are a good first candidate for outsourcing permitting the organization to become acquainted with the process of externalization

Kurt Salmon recommends the streamlineing of processes during the outsourcing project

5

6 2

4

= Potential outsourcing candidates

1

8



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• Type 1: Processes that are high on each of the three dimensions are difficult to outsource.

• Type 2: Prime candidate for outsourcing, if productivity levels are maintained throughout the transition process and afterwards.

• Type 3: Unattractive candidate, unless partners who can provide competitive advantages over the internal unit are identified.

• Type 4: Low cost processes with high productivity are difficult to outsource, even if not mission critical. Only candidate for outsourcing if productivity can be maintained or increased and cost can be further decreased by, for example, moving the process to low cost centres offshore.

• Type 5: Good candidate for outsourcing, even though the high mission criticality makes the outsourcing decision more difficult. There are techniques for limiting a firm’s risk exposure to outsourcing mission-critical functions: e.g. choice of vendor is important, as does the potential for backup and recovery.

• Type 6: The most likely to be outsourced (high cost, low productivity, and low mission criti-cality).

• Type 7: Not worth considering for outsourcing unless the company can identify a provider with strategically dominant services.

• Type 8: Low cost processes that are low in productivity and mission criticality are a good first candidate for outsourcing permitting the organization to become acquainted with the process of externalization.

On the following page, we summarize where the different companies interviewed are positioned regarding securities reference data management in the outsourcing decision matrix, making a distinction between universal, retail and private banks and global custodians.

Cost has been measured by the number of persons required to manage the data. Cost does not include vendor cost, because whatever scenario, vendor cost remains constant, although some-times discounts can be obtained when contracts are negotiated on group level. System costs have not been taken into account.

Productivity is measured by the number of financial instruments managed per person.




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POSITIONING OF REFERENCE DATA MANAGEMENT SERVICES REGARDING OUTSOURCING

Securities reference data management is considered to be highly critical for the business of custodians. The required investments are made to achieve low cost and high productivity. Conse-quently, outsourcing is not recommended.

For retail, private and universal banks not active in the asset servicing business, outsourcing the securities reference data management process should be considered (6 of the interviewed companies). Some institutions have investigated significantly in the centralization of their securi-ties reference data management (4 of the interviewed companies). For these companies there is currently probably no positive business case to outsource these processes. They could even consider to provide securities reference data management insourcing services.


Positioning of securities reference data management picture 7

Cost

Productivity

HIGH

LOW

LOW HIGH

3 7

High Cost / Low Productivity

High Cost / High Productivity

Low Cost / Low Productivity

Low Cost / High Productivity

Outsourcing Decision Matrix

Mission Criticality

Mission Criticality

Mission Criticality

Mission Criticality

Lo

Lo

Lo

Lo

Hi

Hi

Hi

Hi

5

6 2

4

= Potential outsourcing candidates

1

8

n = Number of actors

Universal/Retail/Private banks

Multi market global custodians

4 3

6



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Following relationship between productivity and the non-outsourced operating model used (models 1, 2 & 3) could be identified:

Centralized securities reference data management permits to achieve a significant higher produc-tivity.|Kurt Salmon – Private and confidential, not for distribution Page 13

Productivity

Model Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

4

2

1

1 1

Universal/Retail/Private banks n = Number of actors

High Productivity

Low Productivity




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Acknowledgements

A very special Thank You goes to all of the financial institutions and service providers who contributed to our research and for their partici-pation in this survey. For reasons of confidential-ity, it was preferred not to mention the names of the financial institutions interviewed.



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Disclaimer

This study carried out by Kurt Salmon contains general information provided «as is».

In this study, Kurt Salmon provides various information, data and other resources (the «content») for general information purposes.

Kurt Salmon can modify or update the information and the reference to its source at any time and particularly undertakes to correct

any error or omission which might be detected (directly or by a third party). Kurt Salmon has done everything possible to guarantee

that the content of this study and its potential revisions are up to date and accurate although provided «as is». Kurt Salmon in no way

guarantees and waives all liability, on its part, that of its officers, consultants, employees, agents or representatives:

• With regard to the information sources mentioned in this study;

• With regard to its usefulness or relevance in respect of any purpose or use whatsoever;

• With regard to the results which the user obtains by using the content. Any dispute related to this study or its content shall be

governed by French law and competence shall be given to the Courts of Nanterre. links with brands and/or companies cited

Reference to the brands/companies cited has been made to facilitate the reading of this study. Kurt Salmon does not endorse the

companies, the brands, nor their websites or the entities which run them. Furthermore, Kurt Salmon does not confirm anything and

waives all liability related to the said websites:

• As to their content;

• As to any action, error or omission of the persons or entities running them.

Copyright ©2013, Kurt Salmon.

Kurt Salmon is the owner of the copy right for the content , the documents and information found in this study, unless stipulated

otherwise in the said study. Kurt Salmon authorises any person using this study, without paying any fee or requesting any other

permission, to reproduce and distribute the information, the content elements and the documents found in this study, only for

personal notfor-profit purposes and under the following conditions:

• It must be clearly stated that Kurt Salmon is the source of the study reproduced;

• This preamble must be included in all reproductions and copies.

Any reproduction for any other purpose whatsoever and by any means and in any form whatsoever, is prohibited without obtaining

the formal written consent of Kurt Salmon. Kurt Salmon prohibits the modification of the information of the Document reproduced

or copied from this study.

www.kurtsalmon.com

Our Offi cesAtlanta – Minneapolis – New York – San Francisco – Bruxelles – Casablanca – Düsseldorf – Genève – Luxem-bourg – Londres – Lyon – Manchester – Marseille – Nantes – Paris – Rome – Hong Kong – Shanghai – Tokyo

ContactsHerwig Temmerman, Securities Services, Practice Leader

Phone: +352 621 321 440

[email protected]

Eric Crabie, Managing Partner

Phone: +352 26 37 74 1

[email protected]

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