Newfound Bay Limited is a long-term focused investor with a strategic emphasis on sustainable value creation. As a responsible investment and holding company, we uphold the highest transparency standards and comply with international regulatory requirements.

Newfound Bay Limited is a subsidiary of Bank of America Corporation, a globally leading financial institution, which is regulated by international financial authorities, including the U.S. Securities and Exchange Commission (SEC) and the Financial Conduct Authority (FCA) in the United Kingdom. As part of this network, Newfound Bay Limited ensures that all business processes and investment activities are conducted in compliance with relevant regulatory requirements and international best practices. Merrill Lynch Corporate Services Limited acts as the operational director of Newfound Bay Limited.

Within this network, we ensure that our investment processes adhere to the highest compliance and disclosure standards. Our transparency policies cover the following areas:

•    Disclosure obligations for portfolio companies exceeding specific thresholds
•    Disclosure obligations for investment firms managing such companies;
•    Industry-specific initiatives for the collection and publication of relevant market data.

Newfound Bay Limited manages investments in various companies; however, our portfolio does not fall under mandatory disclosure requirements as per the criteria mentioned above. Nevertheless, we voluntarily maintain high transparency and disclosure in the following areas:

•    Company Profile: Description of Newfound Bay Limited, including our strategy, investment philosophy, and long-term investments.
•    Management Team: Introduction to the executive team, with relevant qualifications and experience.
•    Portfolio: Overview of our key investments and their strategic significance.
•    Investment Structure: Explanation of our capital strategy and institutional networks.

In addition, we confirm:

•    Conflict of Interest Management: Appropriate mechanisms are in place to avoid and address conflicts of interest.
•    Investor Reporting: We adhere to established reporting practices and international standards.
•    Valuation Principles: Our valuations are conducted in accordance with recognized valuation guidelines.
•    Compliance with Regulatory Requirements: We support initiatives for data collection and enhancing transparency in the financial industry.