AVI Global

AVI Global has held up strongly throughout the uncertainty of 2020, outperforming the benchmark and taking advantage of depressed valuations…

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This is a non-independent marketing communication commissioned by AVI Global. The report has not been prepared in accordance with legal requirements designed to promote the independence of investment research and is not subject to any prohibition on the dealing ahead of the dissemination of investment research.

AVI Global

Summary

AVI Global Trust (AGT – previously British Empire Trust) seeks to generate capital growth for investors through investment in a reasonably concentrated portfolio of listed companies whose shares trade at a discount to the managers’ estimate of fair value.

AGT’s investment strategy under current lead manager Joe Bauernfreund, who took over in 2015, has moved to increase portfolio concentration and place a greater emphasis on identifying a catalyst for value realisation. AGT looks to exploit market inefficiencies whereby the managers can invest in high-growth and/or quality underlying companies at a discount by accessing them through a holding company structure.

As we discuss under the Portfolio section, holdings can be categorised as: 1) closed-ended funds, 2) family-backed holding companies, or 3) asset-backed special situations (which currently consist primarily of Japanese cash-rich operating companies). The exposure to Japan has been gradually increasing in recent years, as Asset Value Investors (AVI) believes there is a substantial investment opportunity in this area, so much so that the firm launched a separate investment vehicle to focus solely on it.

Presently, the look-through weighted double discount to NAV of the underlying holdings stands at c. 42% (as at 31/10/2020), as highlighted under the Performance and Discount sections. This is wide by historical standards, and we note that previous instances where the double discount has reached this level have tended to lead to subsequent periods of outperformance.

Gearing has been tactically utilised in recent months, and the team tell us the recent market volatility has continued to create new opportunities in high-quality assets.

Kepler View

In the wake of the COVID-19 pandemic and associated economic shutdown, global equity markets seemingly remain bifurcated between perceived ‘old’ and ‘new’ economy stocks. The former are presumed to be at the mercy of a potential global economic recovery in order to stave off insolvency, and the latter are assumed to win in any continuation of current circumstances. Elements of truth exist in both, but in such capricious circumstances considerations of which companies are which often seem transitory.

In our view AGT seems well placed to straddle both considerations. The underlying companies have exposure to many of the well-known and acknowledged secular growth stories. Yet the method AVI employs to access them (usually through holding companies) gives the managers the opportunity to find valuation opportunities where a temperamental market has significantly discounted look-through valuations.

This latter element in particular can be seen in the double discount which, despite tightening in recent months, remains at a level which has typically led to notable outperformance. AGT’s portfolio therefore looks to us nicely balanced between two forces. Operationally, it is exposed on a look-through basis to secular growth trends which would benefit from a continuation of current conditions. Yet a change to a more reflationary/recovery environment should, we believe, see AGT benefit from a narrowing of the double discount (as discussed under Performance). This balance probably prevents full upside capture in any one scenario, but should offer a structurally sound long-term proposition with demonstrable flexibility.

Bull beAR
Double discount remains wide by historic standards
Illiquid nature of many closed-ended holdings makes discounts vulnerable to market reversals
Discounted access to high-growth opportunities
Gearing can exacerbate downside (as well as amplify upside)
Exposure to an array of otherwise hard-to-access, high-quality opportunities High level of KID RIY

Portfolio

AVI Global Trust (AGT) – previously British Empire Trust (BTEM) – invests in listed equities around the globe, focusing on under-researched and overlooked companies. Under the sole lead management of Joe Bauernfreund since October 2015, AGT has been operating for c. 130 years.

Joe and the team look to build a concentrated portfolio of companies, having in recent years cut the number of holdings (if certain baskets of stocks are considered as thematic plays, as they are intended to be by the manager when they have a common driver of returns; the decision to hold a basket is in recognition of this and with a view to managing liquidity).

The management team look to identify companies that are overlooked and/or under-researched, with low or no broker coverage, and thus more likely to display pricing inefficiencies. The team note that recent market volatility, and often seeming market irrationality, is presenting them with a surfeit of ideas at the present time.

In recent years the managers have also looked to increase concentration into higher-conviction positions, whilst simultaneously transitioning the investment style slightly from an absolute focus on valuation opportunities to discounted opportunities in companies which typically exhibit strong quality and growth characteristics and where there is a tangible catalyst which can drive value realisation. This includes re-evaluating holdings where perceived catalysts have failed to spark the anticipated narrowing of the discount to fair value, such as the sizeable holding in Third Point Investors (TPOU) where AVI’s engagement has led to several corporate governance and capital allocation ‘wins’, including a sizeable share buyback programme that has thus far not translated into a sustainably tighter discount. However, in cognisance of value considerations, the team will look to remain patient in such scenarios if they believe the investment thesis remains sound. Such is the case with TPOU, where they note that the board remains supportive of addressing the discount issue and is undertaking a strategic review in Q4 2020 to seek to resolve this.

In the wake of the COVID-19 pandemic and associated economic contraction the team opted to tilt the portfolio further towards their more growthy and quality-oriented ideas, which has had a highly positive impact on performance thus far (as discussed under Performance). Conversely, the team have exited other ideas where the potential for value realisation is less tangible in the current environment.

We can see the move towards increased concentration and higher-conviction positions when we compare the largest holdings currently with those from five years ago, though it should be noted that ‘Japanese Special Situations’ is a thematic basket of holdings in a variety of companies (as discussed below).

AGT: Top ten holdings

As at 30/09/2015

As at 31/10/2020


Holding

% of NAV

Holding

% of NAV

Discount/Premium (%)

Investor AB ‘A’

5.8

Japanese Special Situations

17.4

-39.0

Sofina

4.8

Pershing Square Holdings

7.9

-27.6

NB Private Equity

4.5

Oakley Capital Investments

7.1

-26.0

HarbourVest Global Private Equity

4.3

SoftBank Group

6.9

-53.1

Kinnevik ‘AB-B’

4.0

Sony

5.5

-35.8

Jardine Matheson

3.9

Fondul Proprietatea

5.0

-17.6

AP Alternative Assets

3.3

Third Point Offshore Investors

4.8

4.8

Mitsui Fudosan

3.3

Kinnevik AB-B

4.3

-21.7

DWS Vietnam

3.2

KKR

4.0

-25.3

Wendel

3.2

EXOR

3.7

-40.9

Total:

40.3

Total:

66.6



Source: Asset Value Investors

Holdings within AGT presently fall within one of three categories: 1) closed-ended investment funds, 2) family-backed holding companies, or 3) asset-backed special situations. The vast majority of the asset-backed special situations category consists of cash-/asset-rich Japanese operating companies, but also contains within it a small basket of UK property names which were established recently as a COVID-19 recovery play. Joe and the team observe that UK commercial property assets are currently pricing in extreme negative scenarios and are attracting private equity interest. When positive news broke recently regarding a COVID vaccine, this basket punched well above its small weight with some very material share price moves across these holdings.

AGT: Thematic allocation over time

Source: Asset Value Investors

As noted above, the team are currently identifying an abundance of attractive opportunities. This includes thematic ideas which may not appear to be traditional ‘value’ at this time, such as moves to start building thematic exposure to music royalties through Hipgnosis Songs Fund (SONG) and, most recently, Round Hill Music Royalty Fund. Having observed from tangential research into related companies (Sony, owned and in AGT’s portfolio; and Vivendi, not currently owned) the growth in revenues available from streaming services, the team have started to build a position. The ostensibly high multiples paid by many of the vehicles for accessing this asset class for royalty streams are, in the AGT team’s view, a cipher. Decay rates may be variable on an individual basis, but purchase prices for catalogues reflect this and growth rates look fairly structural and should support distributions. Joe and the team expect this asset class to attract increasing attention from institutional investors, such as pension funds which need relatively predictable ultra-long-duration income streams to match against liabilities. In this context, current multiples being paid (an implied 5.5% earnings yield on SONG’s most recent catalogue purchase) do not look demanding in Joe and the team’s view.

Asset Value Investors (AVI) continually runs live models on a universe of between 350 and 400 companies, looking to identify what the firm believes to be a fair value estimate of the net asset value (NAV) of each company, and to identify which companies within the firm’s universe are presently trading at a significant discount to AVI’s estimate of NAV.

Although this gives an ostensible value skew to many of their holdings, Joe and the team note that many of the underlying companies are themselves exposed to high-quality assets and have displayed strong NAV growth (or else have a compelling strategy in place to drive NAV growth). Holdings such as VNV Holdings, a Swedish investment company with c. 33% of NAV invested in Babylon Digital (a digital and remote healthcare service), have seen the current crisis serve as a catalyst to accelerate growth in the demand for the services of their underlying holdings.

Indeed, many holdings offer discounted opportunities to access widely understood growth opportunities vicariously. This can be seen in holdings such as Christian Dior (a new addition in March 2020), which as a mono-holding company offers access to the widely appreciated growth story in LVMH at a discount to simply buying LVMH shares. The team anticipate upside over and above LVMH’s share price performance from an eventual collapse of the Christian Dior holdings structure.

The converse can also hold true when the relative opportunity is in the underlying company, rather than in the holding company. The team have recently trimmed long-term holding Kinnevik after it moved to a premium to their estimation of NAV. Approximately 40% of Kinnevik’s NAV derives from a position in Zalando, an online fashion retailer which has seen strong sales growth throughout 2020. With the team wishing to remain exposed to this stock, Joe and the team opted to recycle some of the proceeds of the reduction in the Kinnevik position directly into Zalando.

Similarly, a relatively new holding in Prosus offers vicarious exposure to Tencent, as well as a further book of early-stage technology investments and a €4bn net cash pile. Joe and the team note that Prosus trades on a c. 34% discount to a sum-of-its-parts valuation, offering potential upside from discount narrowing as well as from potential NAV gains from the underlying holdings. Having been spun out of Naspers, a South African company, they believe that a European listing can help to achieve this discount narrowing. AGT also owns a holding in Naspers itself, which trades on an even deeper look-through discount (54%) to the value of its underlying holding in Tencent.

The Prosus/Naspers positions offer AGT exposure to a rapid growth story in the Chinese market, but with a valuation buffer relative to direct exposure with additional upside from anticipated discount-narrowing events at the corporate level of Prosus/Naspers. Similarly, SoftBank offers indirect exposure to Alibaba, but at a discount of c. 50% to the underlying securities for the level of exposure incurred. Given the significant regulatory and geopolitical risks we would consider to be attached to the Chinese market generally, being able to hold this valuation margin of safety whilst staying exposed to the ostensible growth story is in our view reassuring and preferable to direct exposure. The team are keeping a close eye on recent regulatory developments affecting Chinese internet companies, but believe at this early stage that while Alibaba is likely to be negatively affected to some extent, Tencent has been unfairly swept up in the associated sell-off.

In recent years the team have increasingly sought to engage with company managements and boards to help catalyse moves towards fair value in the share price. Joe and the team encourage boards to implement policies which can prove beneficial to shareholders, such as corporate governance reform and/or instigating returns of excess capital to shareholders. This is particularly tangible within the Japanese Special Situations basket, a thematic basket of holdings in cash-rich Japanese operating companies. As well as the basket of Japanese stocks specifically meeting this definition, AGT holds further exposure to similar themes in other Japanese stocks such as Sony. We note that Japan is the second-largest geographic exposure within the portfolio at this time.

AGT: Geographic region risk allocations

Source: Asset Value Investors

Relative to global indices, the weighting to Japan is significant. AGT’s companies here hold significant levels of net cash and investment securities on their balance sheets, and Joe and the team believe the ongoing push for corporate governance reform in Japan can continue to drive the return of some of these assets to shareholders. Yet they note that in many cases it remains insufficient to passively wait for value realisation to occur, and instead are looking to continually engage with corporate management teams to try to drive improved policies around shareholder returns. So deep is the opportunity set in this area in the team’s view that AVI launched a separate vehicle AVI Japan Opportunity Trust (AJOT) – to specifically access this trend.

Whilst AGT and AJOT are separate strategies, the investment thesis in the Japanese Special Situations basket is the same and there is significant crossover in the holdings within each. As we detailed in our recent AJOT research note, Joe notes that Japanese corporate management teams remain constructive on engaging with shareholders despite the challenges many companies have faced from the COVID-19 pandemic and associated economic contraction. Such is the quantum of cash and securities on many corporate balance sheets that these companies can maintain very significant cash buffers against similar potential future ruptures whilst still returning substantial sums to shareholders. Such was the case with Fujitec, a holding in both AGT and AJOT, where AVI and other shareholders have conducted a public campaign to improve corporate governance but also to improve operational efficiency. We have detailed this campaign and its success further in our AJOT research note.

As we have detailed under Performance, the ‘double discount’ of AGT on a look-through basis remains wide at c. 42% (as at 31/10/2020). The double discount accounts for the discount of the underlying holdings, using market prices for listed holdings and peer group multiples (amongst other valuation techniques) for the underlying unlisted holdings.


Gearing

AGT currently has net gearing totalling c. 8% in place (as at 01/11/2020, Source: AVI). This includes long-term debt in sterling and the euro, and a revolving credit facility ostensibly in yen. The latter facility was expanded in March 2020, having been originally entered into in April 2019. This expanded the borrowing facility from a previous limit of ¥4bn to ¥9bn (c. £66.3m as at 05/11/2020), up to 50% of which may be drawn in GBP, USD or EUR. This facility was expanded in recognition of the additional flexibility it would afford the management team in the volatile market environment, with significant optionality deemed to be available in certain share prices which in the managers’ view had been indiscriminately marked down in the liquidity squeeze of Q1 2020.

Long-term sterling and euro debt is held through long-term loan notes (2036 and 2037 maturities). A total of c. £30m and c. €50m in loan notes were issued, with their value at issuance equating to approximately 7.3% of current net assets (based on current FX rates). We estimate the weighted average interest cost of these at this time to be c. 3.5% (using GBPEUR FX rates as at 05/11/2020).

Deployment of gearing remains on a flexible and variable basis, and gearing levels are likely to primarily reflect the depth of opportunities and potential upside the managers have identified on a bottom-up basis. It was largely on this basis that the managers opted to reduce gearing levels in early 2020, before subsequently looking to not only increase the gearing ratio but expand the capacity to gear (as detailed above). This has largely proven beneficial to returns. Subsequently, the managers have opted to reduce gearing again in the run-up to the US presidential election, anticipating that market volatility would be likely to give rise to buying opportunities. Gearing has subsequently been raised slightly again, though the team retain significant scope to expand this further.

With most/all gearing non-GBP-denominated, variations in the GBP exchange rate will have a mechanical impact upon the gearing ratio. Declines in GBP relative to the currencies in which debt is denominated (USD, EUR and JPY) will typically increase the relative value of gearing, whilst the converse also holds true.


Returns

Joe took over as sole lead manager of AGT in October 2015. Over the five years to 09/11/2020, AGT has outperformed the MSCI ACWI ex-US benchmark index (represented in this section by the iShares MSCI ACWI ex US ETF, a passive strategy replicating the benchmark) but marginally underperformed the broader Morningstar Global peer group on an NAV basis. Over this period, AGT has delivered NAV and share price returns of c. 80.7% and c. 86.5% respectively, against benchmark returns of c. 57.7%. Over this same period, the broader investment trust peer group returned average NAV returns of c. 81.1%.

It is notable, however, that over this same period the HSBC S&P 500 ETF has returned c. 118.2%. Clearly the low exposure to the US has proven a headwind for AGT. Allied to this, we also note that AGT has in fact been ahead of the peer group on an NAV basis for the majority of the past five years, with the significant outperformance of US equities and the secondary effect on AGT’s relative returns over the previous 12 months skewing cumulative figures.

AGT: Five-year returns vs peers and benchmark

Source: Morningstar

Over the short term AGT has also performed strongly relative to its benchmark. AGT has outperformed its benchmark over the 12 months to 09/11/2020, generating NAV and share price returns of c. 9.5% and c. 6.9% respectively against a benchmark return of c. 2.3%. Returns have been boosted by the strong performance of diverse holdings such as Kinnevik, Pershing Square and KKR. The team’s decision to increase the portfolio’s tilts towards growth and quality factors earlier in 2020 has proven beneficial.

It is notable that AGT largely performed as would be expected by the managers in the volatile markets seen thus far in 2020, having declined more rapidly than the benchmark in the drawdown of Q1 2020 before recovering more strongly from the market lows in late March. In part this was a reflection of market conditions and the fluctuations in the underlying double discount, but the team note that their internal attribution shows that portfolio activity in Q1 to tilt the portfolio towards growth and quality considerations has also subsequently proven beneficial to returns thus far. AVI estimates that, from the weighted average selling date of positions exited in Q1 2020 to 15/09/2020, active portfolio management and turnover contributed c. 6% to portfolio returns. We can see in the graph below AGT’s cumulative NAV returns over the previous 12 months relative to the peer group and benchmark. As we can see, returns trailed in Q1 2020 as the market sold off, but the low in AGT’s relative performance came shortly after the low in the benchmark, and it has been outperforming since this time.

AGT: 12-month NAV returns relative to peers and benchmark

Source: Morningstar

In our view, it is not unexpected that AGT should underperform in a sharp bear market where liquidity pressures can cause discounts to widen on relatively slim selling volumes in the absence of buying pressure. This was witnessed in Q1 2020, and caused the ‘double discount’ on AGT to move out to a highly elevated level. Whilst the current ‘double discount’ of c. 42% has reverted somewhat as confidence has returned to the market in recent months, it still remains wide by historic standards.

AGT: Double discount

Source: Asset Value Investors

We have previously highlighted that there has historically tended to be an opportunity in both absolute and relative subsequent 12-month returns achieved when the ‘double discount’ exceeds the long-term average level, and in particular when it exceeds a level of c. 40% (approximately one standard deviation below the mean level). The double discount, at c. 42%, is at a level which has historically been associated with strong subsequent relative and absolute returns.

At the same time, a more pronounced structural trend downwards in global inflation expectations could mean that whilst many of AGT’s underlying holdings are likely to prove beneficiaries of such secular trends, value realisation via the double discount might be considered more challenging as increasingly low discount rates are applied to future cash flows to the disadvantage of present value. We can see in the graph below a close correlation between moves in the AGT double discount and US 5Yr5Yr forward inflation expectation rates. Were we to see a sustained reflationary impulse in the global economy, in our view shareholders could well enjoy a sustained tailwind from a trend of a narrowing in the double discount.

AGT: Double discount vs US 5Yr5Yr rates

Source: St. Louis Federal Reserve, Asset Value Investors, as at 31/10/2020

Dividend

AGT currently yields c. 2.2% (as at 09/11/2020). The investment objective is to target capital growth, with income a secondary consideration in general. Despite this, there is a track record within AGT of gradually increasing dividends over the longer term, with ordinary dividends having been maintained or increased every financial year since financial year (FY) 2009.

AGT has paid out a substantially raised interim dividend for FY 2020. The board has announced it will pay a final dividend of 10.5p per share, which would result in the total dividends for FY 2020 being the same as those paid in FY 2019. The board noted that it was supported by AGT’s revenue reserves in seeking to maintain the dividend, given the challenging operating environment for income generation given the macroeconomic backdrop. We estimate the revenue reserves at present represent c. 1.5x the FY 2020 dividend when we account for the substantial share buybacks that have occurred thus far in the new financial year.

AGT: Ordinary dividends and revenue returns

Source: Asset Value Investors

In 2017, it was agreed that going forward capital profits generated by AGT could be distributed as dividends. As a route to value realisation, AGT may itself be in receipt of increased dividends or special dividends from the underlying holdings. This can result in variable income generation from the underlying investment strategies, though we would note that the largely non-GBP-denominated nature of income streams will also likely result in underlying revenue returns displaying something of an inverse nature to the strength or weakness of GBP (with a weaker pound likely to boost the reported levels of income generated). As can be seen in the chart below, this can result in substantial special dividends being paid in some years.

AGT: Total dividends per share and contribution from special dividends

Source: Asset Value Investors



Management

Joe Bauernfreund has been sole named manager of AGT since October 2015. Joe is CEO and CIO of Asset Value Investors (AVI), and has been with the group since 2002, starting as an analyst working on European holding companies. He became co-manager of AVI Global Trust (then British Empire Trust) in 2013 before becoming sole named manager in October 2015.

Joe is supported by Tom Treanor, head of research and an AVI director since 2017. Tom leads on closed-ended fund research and activism engagement, with significant experience in various roles covering closed-ended fund analysis. They are further supported by a team of dedicated analysts, and have been adding significant analytical resources in recent years.

AGT (and BTEM, as it was previously) has seen low managerial turnover, with only three portfolio managers over the previous c. 35 years. The board remains involved in oversight of the investment strategy, and whilst there is evolution of the investment process, the board has been keen to ensure that any changes are part of a natural progression. There is substantial investment trust experience on the board.

AVI is an international equity boutique founded in 1985, which is majority owned by employees. Part of the strategic transition that AVI and AGT have undertaken in recent years has included partnering with Goodhart Partners, an independent multi-boutique that has helped provide resources to support the growth of AVI.


Discount

AGT currently trades on a discount of c. 9.4% (as at 09/11/2020). As can be seen in the graph below, this is wide relative to the sector as a whole, especially relative to recent history. And yet, as discussed under Performance, this does not account for the underlying discount to fair value on the underlying holdings. When we examine this, we can see a significantly greater ‘double discount’, which as at 31/10/2020 equated to c. 42%.

Significant buybacks were conducted in the previous financial year (ending 30/09/2020), with a net c. 4.8m shares repurchased at a weighted average discount of c. 10.4%. Excluding shares in treasury, we estimate this represents c. 4.4% of shares that were in issuance at the commencement of financial year 2020 (01/10/2019). These discount-supportive buybacks have continued into the current financial year, with a further c. 403,000 shares repurchased at a weighted average discount of c. 10.6% as at 09/11/2020. The directors have authority to buy back up to 14.99% of ordinary shares in issue.

agt: dISCOUNT/Premium

Source: Morningstar

The current ‘double discount’ of c. 42% is wide relative to history. We have noted under Performance that a double discount in excess of 40% has historically represented a period where subsequent relative returns were notably more likely to be strong. However, this has been more likely to be a representation of underlying NAV performance than of headline discount narrowing in AGT itself, as we can see in the table below.

This shows that there is little substantive difference between subsequent 12-month returns from a share price and NAV perspective to the upside when the discount is wider than average. Whilst, as we discuss under Portfolio, the assets held within AGT should not be considered solely as ‘value’ assets, the process of value realisation is still impacted by wider considerations of current versus future value.

Against a backdrop of sharp value underperformance and a downtrend in global inflation expectations, we think it is notable that the relative value opportunity of recent years when the discount is wider than average has been more muted than previously, whilst the downside risks have typically been more acute. However, a change in broader macroeconomic environment could cause a more positive backdrop, as we discuss under Performance.

AGT: Subsequent 12-month NAV and share price returns depending on double discount

Since March 2006

Double discount wider than 40%

Double discount wider than average

Double discount narrower than average

Average (share price absolute)

14.8

9.3

-1.7

Average (NAV absolute)

14.1

9.4

0.4





Past ten years



Average (share price absolute)

14.8

8.3

-7.3

Average (NAV absolute)

14.1

8.1

-5.6

Source: Asset Value Investors


Charges

AVI is paid a management fee of 0.7% of NAV per annum and no performance fee. The OCF is 0.85%, compared to a weighted average of 0.5% for the sector (Source: JPMorgan Cazenove), although this sector figure is skewed by a large outlier to the downside. The KID RIY figure is 3.45%, compared to a 1.04% weighted average for the AIC Global sector, although we would caution that different managers use differing methodologies to calculate this figure. AVI notes that these charges reflect costs of gearing at investee closed-ended funds, and contends it is inappropriate to consider solely the costs of leverage without also taking into account its beneficial impact on returns. Similarly, performance fees on underlying holdings inflate these figures and are reflective of strong returns.

ESG

AGT’s investment process places a premium on governance and sustainability concerns. Increasingly, as we discuss in the Portfolio section, this includes active engagement with the managements of the underlying companies to ensure strong corporate governance is in place and that company managements are cognisant of their responsibilities as shareholders.

AVI tries to understand the social system that holdings operate within, ensuring that the rights of minority stakeholders are properly respected and also finding out how employees and management are incentivised. Similarly, AVI seeks to support policies and/or actions by the companies it holds which aim to support a sustainable environment.

Fund History

Disclaimer

This report has been issued by Kepler Partners LLP.  The analyst who has prepared this report is aware that Kepler Partners LLP has a relationship with the company covered in this report and/or a conflict of interest which may impair the objectivity of the research.

Past performance is not a reliable indicator of future results. The value of investments can fall as well as rise and you may get back less than you invested when you decide to sell your investments. It is strongly recommended that if you are a private investor independent financial advice should be taken before making any investment or financial decision.

Kepler Partners is not authorised to make recommendations to retail clients. This report has been issued by Kepler Partners LLP, is based on factual information only, is solely for information purposes only and any views contained in it must not be construed as investment or tax advice or a recommendation to buy, sell or take any action in relation to any investment.

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