20 May 2020 This publication provides a high level summary of the targeted measures taken in the and selected European jurisdictions, designed to support businesses and provide relief from the impact of COVID-19. This information has been put together with the assistance of Wolf Theiss for Austria, Stibbe for Benelux, Kromann Reumert for Denmark, Arthur Cox for Ireland, Gide Loyrette Nouel for France, Noerr for Germany, Gianni Origoni, Grippo, Capelli & Partners for Italy, BAHR for Norway, Cuatrecasas for Portugal and Spain, Roschier for Finland and Sweden, Bär & Karrer AG for Switzerland. We would hereby like to thank them very much for their assistance. Ropes & Gray is maintaining a Coronavirus resource centre at www.ropesgray.com/en/coronavirus which contains information in relation to multiple geographies and practices with our UK related resources here.

JURISDICTION PAGE EU LEVEL ...... 2 UNITED KINGDOM ...... 8 IRELAND ...... 14 BENELUX REGION ...... 20 FRANCE ...... 35 GERMANY ...... 38 NORDIC REGION ...... 45 SOUTHERN EUROPEAN REGION ...... 67 AUSTRIA ...... 78 SWITZERLAND ...... 86

EU LEVEL Provider Banks Scheme and high level summary Other comments and related links European Yes Temporary capital and liquidity buffers and operational relief in reaction to Banks are expected to Central Bank coronavirus use the measures to (“ECB”) support the economy, and The ECB has activated a number of measures to ensure that its directly have been asked not to supervised banks can fulfil their role in funding corporates and households to pay for the alleviate the impact of COVID-19. financial years 2019-2020 The ECB will allow banks to operate temporarily below the level of capital or buy back shares during defined by the Pillar 2 Guidance (“P2G”), the capital conservation buffer (“CCB”), the COVID-19 pandemic, the countercyclical capital buffer (“CCyB”) (the latter being set by the national at least until 1 October macroprudential authorities) and the liquidity coverage ratio (“LCR”). 2020. Banks can fully use capital and liquidity buffers. https://ec.europa.eu/info/li ve-work-travel- The new Capital Requirements Directive V (“CRDV”), which was initially eu/health/coronavirus- scheduled to come into effect in January 2021, has been accelerated. Banks will response_en benefit from relief in the composition of capital for Pillar 2 Requirements (“P2R”) and will be able to fulfil the P2R with a minimum 56.25% Common Equity Tier 1 https://www.ecb.europa.e (“CET1”, highest quality of own funds, mainly composed of shares and retained u/press/pr/date/2020/html/ earnings from previous years) as a general principle. The remaining P2R can be ecb.pr200312~45417d86 filled with Additional Tier 1 and Tier 2 instruments (can be equity or liability 43.en.html instruments of lower quality). https://www.bankingsuper According to the ECB, capital relief amounts to €120 billion and could be used to vision.europa.eu/press/pr/ absorb losses or potentially up to €1.8 trillion of lending. date/2020/html/ssm.pr200 320~4cdbbcf466.en.html ECB Yes ECB gives banks further flexibility in treatment of loans backed by public https://www.bankingsuper support measures vision.europa.eu/press/pr/ date/2020/html/ssm.pr200 ECB has introduced supervisory flexibility regarding the treatment of non- 320~4cdbbcf466.en.html performing loans (“NPLs”), in particular to allow banks to fully benefit from guarantees and moratoriums put in place by public authorities to tackle distress resulting from COVID-19, in an effort to support solutions for temporarily distressed debtors. Supervisors will flexibility regarding the classification of debtors as “unlikely to pay” when banks call on public guarantees granted in the context of COVID-19 and regarding loans under Covid-19 related public moratoriums.

-2- EU LEVEL Provider Banks Scheme and high level summary Other comments and related links NPLs under public guarantees will benefit from preferential prudential treatment in terms of supervisory expectations about loss provisioning. ECB recommends that all banks avoid pro-cyclical assumptions in their models to determine provisions for NPLs and that those banks opt for the IFRS 9 transitional rules. ECB Yes Longer-term refinancing operations (“LTROs”) https://www.ecb.europa.e u/press/pr/date/2020/html/ ECB will provide additional LTROs to provide immediate liquidity support to ecb.mp200312~8d3aec3ff banks. 2.en.html The operations will be conducted as fixed rate tender procedures with full For detail on the latest allotment. The rate will be fixed at the average of the deposit facility rate over the update: life of the respective operation. Interest will be paid when the respective operation matures. All operations will mature on 24 June 2020. https://www.ecb.europa.e u/press/pr/date/2020/html/ The LTROs will provide liquidity at favourable terms to bridge the period until the ecb.mp200430~1eaa1282 TLTRO III (below) operation in June 2020. 65.en.html (“ ”) Third series of targeted longer-term refinancing operations TLTRO III For the original decision More favourable terms on TLTRO III’s (originally launched in March 2019) will be on TLTRO III: applied for banks, for operations outstanding during the period from June 2020 https://www.ecb.europa.e to June 2021, in an effort to support bank lending to those affected most by the u/ecb/legal/pdf/en_ecb_2 spread of COVID-19, in particular SMEs. 019_21_f_sign.pdf Interest rates on the TLTRO III operations during this period will be 50 basis For detail on PELTROs: points below the average rate applied in the Eurosystem’s main refinancing operations. https://www.ecb.europa.e u/press/pr/date/2020/html/ Counterparties whose eligible net lending reaches the lending performance ecb.pr200430_1~477f400 threshold, the interest rate over the period from June 2020 to June 2021 will be e39.en.html 50 basis points below the average deposit facility rate prevailing over the same period. The maximum total amount that counterparties are entitled to borrow in TLTRO III operations has been raised to 50% of their stock of eligible loans to non-

financial corporations and households as at 28 February 2019.

TLTROs-III will each have a of 2 years.

-3- EU LEVEL Provider Banks Scheme and high level summary Other comments and related links New series of non-targeted pandemic emergency longer-term refinancing operations (“PELTROs”) The PELTROs consist of seven additional refinancing operations commencing in May 2020 and maturing in a staggered sequence between July and September 2021 in line with the duration of the collateral easing measures. These operations will provide liquidity support to the area financial system and contribute to preserving the smooth functioning of money markets by providing an effective backstop after the expiry of LTROs that have been conducted since March 2020, and will allow counterparties to benefit from collateral easing measures in place until the end of September 2021. The operations will be carried out as fixed rate tender procedures with full allotment, with an interest rate that is 25 basis points below the average rate on the main refinancing operations prevailing over the life of each PELTRO. The operations provide longer-term funding for counterparties with decreasing tenors, starting with a term of 16 months in the first operation and ending with a term of 8 months in the last operation. ECB Yes Asset purchase programme (“APP”) For detail on the existing APP: In combination with the existing APP (part of a package of monetary policy measures initiated in mid-2014 for the purchase of securities), additional net https://www.ecb.europa.e APPs of €120 billion will be added until the end of the year. u/mopo/implement/omt/ht ml/index.en.html#cbpp3 The existing APP includes: For detail on the latest i) Corporate sector purchase programme (“CSPP”): 6 national central update: banks have been and will continue to purchase investment-grade (credit quality step 3 (BBB- or equivalent) minimum) https://www.ecb.europa.e and euro-denominated bonds with 6 months – 30 years maturity issued u/press/pr/date/2020/html/ by non-bank corporates incorporated in the Eurozone (the issuer’s ecb.mp200430~1eaa1282 parent need not also be incorporated in the Eurozone). 65.en.html ii) Public sector purchase programme (“PSPP”): purchase of central and For detail on eligibility of local government bonds. ABS: iii) Asset-backed securities purchase programme (“ABSPP”): an ABS https://www.ecb.europa.e must be (i) eligible as collateral for the Eurosystem and (ii) pass due u/mopo/implement/omt/ht

-4- EU LEVEL Provider Banks Scheme and high level summary Other comments and related links diligence analysis to qualify for purchase under ABSPP. See link for ml/abs_guiding_principles detail. .en.html iv) Third covered purchase programme (“CBPP3”): purchase of euro area credit institutions covered bonds denominated in meeting

certain credit assessments of credit quality step 3. ECB Yes Pandemic Emergency Purchase Programme (“PEPP”) https://www.ecb.europa.e u/mopo/implement/pepp/h PEPP is a temporary asset purchase programme of private and public sector tml/index.en.html securities of up to €750 billion.

Eligibility: https://www.ecb.europa.e All asset categories eligible under the existing APP are also eligible under the u/press/pr/date/2020/html/ new PEPP. ecb.pr200318_1~3949d6f Non-financial commercial paper is now also eligible for purchases both under the 266.en.html PEPP and the corporate sector purchase programme. Termination of PEPP: Not before end of 2020, and otherwise once Covid-19 crisis phase is over. European Yes Common European response initiative https://ec.europa.eu/info/li Commission and ve-work-travel- Including: European eu/health/coronavirus- Investment Bank i) EIB to invest up to €20 billion in SMEs (using own capital and EU response_en (“EIB”) budget). ii) European Commission to make available €1 billion in an EU budget guarantee to EIF, to incentivize banks to provide liquidity to SMEs and midcaps, mobilising €8 billion in all to help at least 100,000 companies. iii) Coronavirus Response Investment Initiative for investment of €37 billion to support public investment for hospitals, SMEs, labor markets, and stressed regions. iv) Extension of the scope of the EU Solidarity Fund to include a public health crisis within its scope, with a view of mobilizing it if needed for the hardest-hit EU member states (up to €800 million is available in 2020).

-5- EU LEVEL Provider Banks Scheme and high level summary Other comments and related links v) Credit holidays to existing debtors that are negatively affected. The European Commission also activated the general escape clause in the EU fiscal rules, which suspends the fiscal adjustment requirements for countries not at their medium-term objective and allowing countries to run deficits in excess of 3 percent of GDP. European Banking package For details on the banking Commission package: On 28 April 2020, the European Commission adopted a banking package comprised of: https://ec.europa.eu/com mission/presscorner/detail i) Exceptional temporary amendments to the Capital Requirements /en/ip_20_740 Regulation (“CRR”) (EU) No. 575/2013 https://ec.europa.eu/com Including: mission/presscorner/detail a. an extension of 2 years has been granted for the current /en/qanda_20_757 transitional arrangements for mitigating the impact of IFRS 9 For detail on the proposed provisions on regulatory capital – only provisions incurred as of amendments to the 1 Jan 2020 are eligible; Capital Requirements b. more favourable treatment of NPLs guaranteed by the public Regulation (EU) No. sector in the context of measures to mitigate the impact of the 575/2013: coronavirus crisis, with respect to minimum loss coverage https://ec.europa.eu/finan requirements on banks to set aside funds to cover the risk of ce/docs/law/200428- NPLs; banking-package- c. postponement of the date of application of the leverage ratio proposal_en.pdf buffer requirement on global systemically important institutions

to 1 Jan 2023; d. modification of the capital requirement based off of a leverage ratio (of the bank’s capital and its exposures) – discretion to temporarily exclude central bank reserves from a bank's leverage ratio calculation in exceptional circumstances, which is usually offset via a mechanism that increases a credit institutions' individual leverage ratio requirement in a proportionate manner – such offset mechanism is to be modified; and

-6- EU LEVEL Provider Banks Scheme and high level summary Other comments and related links e. advancement of the date of application of certain agreed measures that incentivise banks to finance employees, SMEs and infrastructure projects. These amendments will now be considered by the European Parliament and the European Council. ii) Interpretative Communication The European Commission clarified how banks can apply certain rules in the EU’s prudential and accounting framework more flexibly to encourage banks to further support companies and citizens through the pandemic. The areas of flexibility include: a. Expected Credit Loss (“ECL”) approach under IFRS 9 - the temporary inability of households or businesses to pay back their loans because of the Coronavirus pandemic should not mean that banks have to automatically significantly increase their so-called ECL provisions. b. Assessment of a “Significant Increase in ” (“SICR”) - to be based on the remaining lifetime of a loan and not just on the sudden increase in the probability of default caused by the Coronavirus pandemic, and loans should not be automatically classified as SICR because they have become subject to moratoria. c. Non-Performing Loans (“NPLs”) – prudential rules on classification of NPLs and minimum loss coverage requirements should not prevent use of measures such as Government guarantees and moratoria. It will monitor implementation of the Interpretive Communication in close cooperation with the ECB-SSM and national competent authorities.

-7- UNITED KINGDOM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Bank of Yes No No Covid Corporate Financing Facility (CCFF) Not eligible: England and Unsecured commercial paper to be bought by the Covid Regulated financial sector HM Treasury Corporate Financing Facility Limited (the “Fund”) entities. operated by the Bank of England. Leveraged investment Eligibility: vehicles. i) Investment grade issuer credit rating (short or https://www.bankofenglan long term) as at 1 March 2020 (if split rating, all d.co.uk/news/2020/march/ must be investment grade). the-covid-corporate- financing-facility ii) If the issuer did not have an existing credit rating from the major credit ratings agencies, internally https://www.businesssupp viewed by its banks as equivalent to investment ort.gov.uk/covid-19- grade as at 1 March 2020. corporate-financing- facility/ Companies must make a material contribution to the UK economy. https://www.icmagroup.or g/Regulatory-Policy-and- : Other criteria Market-Practice/covid-19- In sterling. market-updates/ With maturity of one week to 12 months. https://www.bankofenglan d.co.uk/markets/market- To be issued into Euroclear and/or Clearstream. notices/2020/joint-hmt- The Bank will accept International Capital Market and-boe-ccff- Association (“ICMA”) market standard documentation. consolidated-market- notice-may-2020 No non-standard features (e.g. extendibility, subordination). Requests for early repayment before 30 June 2020 will not be subject to the usual additional fee. Restrictions: businesses that wish to draw from the CCFF for a term extending beyond 19 May 2021 will be expected to commit to restraint on the payment of dividends and other capital distributions and on senior pay

-8- UNITED KINGDOM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap while their commercial paper is outstanding. A letter of commitment will be required if: • an increase in an issuer’s CCFF limit, over and above that suggested by the issuer’s investment rating, is requested and approved; and/or • a CCFF transaction is entered which involves CP maturing on or after 19 May 2021. Pricing: The Fund will purchase securities at a spread above a reference rate, based on the current sterling overnight index (OIS) curve. Rating – Spread to OIS A1/P1 - 20 bps A2/P2 - 40 bps A3/P3 - 60 bps Offers to sell commercial paper to the Fund must be received and accepted by 31 December 2020. The Fund’s purchases of commercial paper will normally settle on a T+2 basis. From Thursday 4 June 2020, the Bank will publish the names of those businesses benefiting from, and the amount of CP each business has outstanding under, the CCFF.

-9- British Yes No Yes Coronavirus Large Business Interruption Loan Not eligible: Business Scheme (CLBILS) Banks and building Bank Government-owned British Business Bank guarantee to societies, insurers and Applications commercial banks for credit facilities of up to £25 million reinsurers (but not via for businesses with turnover of more than £45 million, and brokers), commercial up to £50 million (to be increased to £200 million with public-sector lenders effect from 26 May 2020) for businesses with turnover of organisations, including more than £250 million. state-funded schools. Eligibility: Companies that have participated in the CCFF i) UK based business activity; scheme cannot borrow ii) businesses with annual turnover of more than under CLBILS. £45 million – there is no cap on the size of the https://www.british- business; business- iii) have a borrowing proposal which the lender: bank.co.uk/ourpartners/co ronavirus-business- a) would consider viable, were it not for the interruption-loan- COVID-19 pandemic; schemes/clbils/ b) believes will enable the business to trade out https://www.gov.uk/gover of any short-to-medium term difficulty; nment/news/larger- iv) self-certify that it has been adversely impacted businesses-to-benefit- by the coronavirus; and from-loans-of-up-to-200- million v) not participated in the Bank of England’s CCFF. https://www.gov.uk/gover Annual turnover is measured on a consolidated group 1 nment/news/larger- undertaking basis. businesses-to-benefit- Coverage: from-loans-of-up-to-200- million Government guarantee for up to 80% of the outstanding facility balance provided to accredited lenders, on individual loans for businesses.

Finance is available in the form of term loans, revolving credit facilities (including overdrafts), invoice finance and asset finance.

1 As with CBILS, we expect the turnover test which includes linked enterprises, will specifically excludes PE investors and their other investee/portfolio companies.

-10- In each case the amount borrowed should not be greater than i) double the borrower’s annual wage bill for the most recent year available; ii) 25% of the borrower’s total turnover for the most recent year available; or iii) the borrower’s liquidity needs for the next 12 months (with appropriate justification, can be self-certified by the borrower). A fee will be charged to lenders which make use of the scheme. Loans backed by a guarantee under CLBILS will be offered at commercial rates of interest. The maximum repayment term under the scheme is 3 years. Unlike the CBILS scheme for smaller businesses, the CLBILS scheme does not have business interruption payment to cover interest and fees for the first 12 months. Borrowers are responsible for the payment of all interest and fees. The scheme will be available through a series of accredited lenders, which will be listed on the British Business Bank website. Syndicated lending is possible under the scheme. Guidance from the British Business Bank to lenders states that CLBILS can be used to facilitate new lending, and to a limited extent, to refinance existing debt (refinancing is generally limited to a maximum 20% of a lender’s annual portfolio of CLBILS-supported lending). Lenders who wish to offer larger loans will need to undergo further accreditation checks Restrictions apply to Companies borrowing more than £50 million through CLBILS as follows:

-11- • Dividends: no payments other than those already declared. •Share buyback: no share buybacks permitted. •Executive pay: No payment of any cash bonuses; no pay rises to senior management (including the board) except where they a) were declared before the CLBILS loan was taken out, b) are in keeping with similar payments made in the preceding 12 months, and c) do not have a material negative impact on the borrower’s ability to repay. Scheme launched 20 April 2020. The expanded loans will be available from 26 May 2020. British No Yes No Coronavirus Business Interruption Loan Scheme Not eligible: Business (CBILS) Banks, building societies, Bank Government-owned British Business Bank guarantee to insurance and re- Applications accredited banks for credit facilities up to £5 million. insurance companies, via public sector Eligibility: accredited organisations including lenders i) UK based business activity; state-funded schools, 2 trade unions and other ii) annual turnover of no more than £45 million ; named organisations. iii) have a borrowing proposal which the lender Certain industries may not would consider viable, were it not for the current benefit from government COVID-19 pandemic; and paid interest and fees: iv) self-certify that your business has been fisheries, aquaculture and adversely impacted by coronavirus. agriculture. All viable small businesses affected by COVID-19 can https://www.british- apply for the scheme, and not just those unable to secure business- regular commercial financing. bank.co.uk/ourpartners/co ronavirus-business- Individual lending decisions are at the discretion of the interruption-loan- accredited lenders. schemes/ https://www.british- business-

2 We believe the usual SME criteria does not apply – the only SME test is the £45m turnover test which includes linked enterprises, but specifically excludes PE investors and their other investee/portfolio companies.

-12- Coverage: bank.co.uk/ourpartners/co ronavirus-business- Government guarantee for up to 80% of the outstanding interruption-loan-scheme- facility balance provided to lenders. cbils-2/ For term loans and asset finance: maturity of up to 6 For list of accredited years. lenders: For overdraft and invoice finance facilities: maturity of up https://www.british- to 3 years. business- No personal guarantees required for loans of less than bank.co.uk/ourpartners/co £250,000. For any borrowing above £250,000 personal ronavirus-business- guarantees will be capped at 20% of the outstanding interruption-loan-scheme- value of the loan. cbils-2/current-accredited- lenders-and-partners/ No guarantee fee for SMEs.

Government to pay interest and lender-levied fees on the facilities for 12 months, so smaller businesses will benefit from no upfront costs and lower initial repayments. Applications to made via accredited lenders (not to the British Business Bank). Scheme to run for an initial period of 6 months.

-13- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Strategic No Yes No SCBI COVID-19 Working Capital Scheme Not eligible: Banking Government loan guarantee scheme for participating Enterprises involved in Corporation banks providing products to micro, small- and medium- primary agriculture and/or Ireland sized enterprises (SMEs) and Small Midcap enterprises. aquaculture sector. (“SBCI”) (supported by Maximum loan size of €1.5 million, with minimum loan Enterprises failing to meet the size of €25,000. certain criteria regarding Department past and current solvency The internal details of the scheme have not yet been of Business, (excluding solvency publicly released so it is not currently known whether the Enterprise, issues resulting from first €500,000 will be unsecured or whether the SBCI will and COVID-19). need collateral to provide a guarantee above this amount. Innovation https://sbci.gov.ie/scheme (“DBEI”)) Term up to 3 years. s/covid-19-loan- Interest rate cap of 4%. application Standard EU definition of SMEs (per Reg. 2003/361/EC) applies. Small Mid-Cap enterprises must have no more than 499 employees to avail of Scheme. Scheme is available immediately until March 2021 or until fully subscribed. There is an overall cap of €450 million, with the Government having announced an increase of funding on 8 April 2020.

3 Note: The information provided in this publication in respect of measures in Ireland is as at 11 May 2020. There are other schemes available which we have not documented for various reasons primarily the size of the scheme, the targeted business or the purpose of the scheme e.g. a Strategic Consultancy Grant (to assist SMEs develop a strategic response plan) and the Be Prepared Grant (for Enterprise Ireland clients who would benefit from further research and external expertise in examining their exposure to Covid-19 and exploring ways of addressing this); a business continuity voucher scheme for microenterprises.

Further, the five retail banks in Ireland and the main non-bank lenders have made a series of announcements setting out supports that are to be made available to customers affected by the COVID-19 pandemic. The measures have been endorsed by the Minister for Finance and the Central Bank of Ireland, but will be implemented by the banks themselves. As the terms of these supports will be a matter for the relevant bank, we have not included these in this tracker.

-14- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap SBCI No Yes No SME Credit Guarantee Scheme Not eligible: (supported by Partial Government guarantee to banks against losses on Enterprises involved in DBEI) qualifying loans to eligible SMEs. primary production of agriculture, horticulture or Applies to Term Loans, Demand Loans and Performance fisheries. Bonds. Enterprises seeking to Minimum loan amount of €10,000 and maximum loan refinance existing debts. amount of €1 million. Enterprises whose Loan term of up to 7 years. primary activities are De Minimis State Aid rules apply. No one business can property-related activities. receive more than €200,000 of De Minimis State Aid in https://sbci.gov.ie/scheme any rolling three-year period. s/sme-credit-guarantee- The overall cap for the scheme is €150 million as of 8 scheme-cgs April 2020. Scheme is available immediately. Changes are proposed to the existing Scheme which will be re-named the COVID-19 Credit Guarantee Scheme. It is envisaged that the Scheme will be capped at EUR 2 billion; other lenders will be able to join the Scheme and it will be extended to all SMEs (some SMEs involved in primary production are currently unable to benefit from the Scheme). Legislation will be needed to implement these changes. SBCI No Yes No https://sbci.gov.ie/scheme Future Growth Loan Scheme (supported by s/future-growth-loan- DBEI and the This is a Government loan guarantee scheme for banks. scheme Department The overall scheme is capped at €200 million. https://dbei.gov.ie/en/Wha of t-We-Do/Supports-for- Agriculture, This will be released in tranches, to provide longer-term SMEs/Access-to- Food and the loans to COVID-19 impacted businesses. Marine)

-15- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Maximum loan size will be €3 million (first €500,000 can Finance/Future-Growth- be unsecured). Minimum loan size will be €100,000. Loan-Scheme/ Loan terms range from 8 to 10 years. Initial maximum loan interest rate of 4.5% for loans < Not eligible: €250,000 and 3.5% for loans ≥ €250,000. Variable interest Excluded categories (non- rates are subject to change. exhaustive): An SME or Optional interest-only repayments available in certain Small Mid-Cap that: circumstances. - is in financial difficulty; Loans can be used for long term investment. Note that - is bankrupt or being there are certain activities which are excluded. wound up or having its This scheme is open and will be available for a 3 year affairs administered by period or until the scheme has been fully subscribed. courts; Applications are made through participating lenders. As of - in the last 5 years has 27 April 2020, each of AIB, Bank of Ireland and Ulster entered in to an Bank are fully subscribed for this scheme. KBC is still arrangement with accepting applications from SMEs and Small MidCaps not creditors, in the context of operating in the primary agriculture sector. being bankrupt or wound- up or having its affairs Eligibility: administered by the Applicants must be viable micro, small and medium sized courts; or enterprises (SMEs) and Small Mid-Cap enterprises which - is convicted of an comply with certain eligibility criteria. offense concerning professional misconduct by judgement, fraud, corruption, involvement in a criminal organisation, money laundering or any other illegal activity where such illegal activity is detrimental to the

-16- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap European Union’s financial interests. Ireland Yes No Yes ISIF are currently seeking Pandemic Stabilisation and Recovery Fund Strategic engagement from Investment €2 billion fund announced for investment on a commercial enterprises seeking Fund (“ISIF”) basis in medium and large enterprises in Ireland affected investment. Companies by COVID-19. ISIF (A sovereign development fund with a are encouraged to contact statutory mandate) will invest on a commercial basis in [email protected], providing an enterprises which present viable business models in the overview of the business, medium to long term. Investment will be made based on its financial statements the core ISIF mandate of commercial return and economic and its business plans. impact. Economic impact will be assessed primarily based Further information on the potential impact of the investment in supporting the regarding the documents stabilisation and recovery of the Irish economy. to be submitted can be found here. Eligibility: The fund is targeted at enterprises employing more than 250 employees or with an annual turnover in excess of €50 million. ISIF will consider investing in enterprises below the level outlined above if the enterprise in question is assessed to be of substantial scale and of significant importance at national or regional level. Enterprises must have been negatively and materially impacted by the pandemic. Enterprises must demonstrate that they were commercially viable prior to COVID-19, and that they can return to viability and contribute to the Irish economy in the medium to long term. Enterprises operating in all sectors will be considered subject to ISIF’s Responsible Investment Policies. Government No Yes No No further details publicly Restart Fund of Ireland available.

-17- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap (Administerin A new €250 million fund was announced on 1 May 2020 g Body TBC) providing funding to microenterprises and small enterprises through a system of rebates and waivers of 2019 commercial rates payments. Companies will receive the lower of: i) An amount equivalent to their 2019 commercial rates; and ii) €10,000 EI No Yes No https://globalambition.ie/s Business Financial Planning Grant Scheme upports/innovation- This scheme is the first part of Enterprise Ireland’s support/covid-19- Rescue and Restructuring Scheme, aimed at vulnerable business-planning-grant/ but viable businesses affected by COVID-19. The grant is worth up to €5,000 (being 100% funding up to €5,000 to access an approved financial consultant). The grant is designed to help companies to develop a robust financial plan, including preparation of documentation required to support applications for external finance from banks and/or other finance providers (including EI). While this scheme provides small-scale financial support, it is interconnected with the Sustaining Enterprise Fund, which is a substantially larger support for SMEs. This application process for this scheme is now open via online portal. Eligibility: The Business Financial Planning Grant is available to all Enterprise Ireland clients. It is also targeted at those manufacturing or internationally-traded service companies that employ 10 or more full-time employees. EI No Yes No Sustaining Enterprise Fund https://www.globalambitio n.ie

-18- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap This scheme is the second part of EI’s Rescue and Not eligible: Restructuring Scheme. This scheme is not open A €180 million package for Enterprise Supports will be to companies that: available through EI for viable but vulnerable businesses. were in financial difficulty The scheme will be operated by EI, providing repayable on 31st of December advances of up to €800,000. These grants will only be 2019 (within the meaning repayable if and when a business returns to financial good of the General Block health. exemption Regulation); The funding will be repaid as follows: are active in the primary agricultural, fishery or - 3-year grace period; aquaculture sectors; - repayment by the end of Year 5 on successful operate in the coal and achievement of the project objective. steel sector; or An annual administration fee of 4% will apply. are covered by specific The Sustaining Enterprise Fund will be used to support rules for Financial the implementation of a Business Sustainment Plan which Services. must be provided by the company outlining the eventual

stabilisation of the business and a return to viability. The Business Sustainment Plan must identify the extent of the immediate liquidity needs and outline how support provided through the proposed measures will remedy the company’s immediate problems. Eligibility: The funding is open to: i) All Enterprise Ireland, IDA and Údarás na Gaeltachta clients and other companies employing 10 or more in the manufacturing and internationally traded services sector, who have suffered a 15% or more reduction in in actual or

-19- IRELAND3 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap projected turnover or profits or an increase in costs as a direct result of COVID-19; and ii) For SMEs who have applied for funding from a financial institution, including, where appropriate, through the SBCI COVID-19 Working Capital Loan/Future Growth Loan Schemes. iii) For large companies who have applied for funding with an appropriate financial institution. BENELUX REGION4 BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Federal Yes if a Yes if a Yes if a non- Deferral of (mortgage) loan payments, up until 30 https://www.nbb.be/en/su Government, non- non- financial September 2020 mmary-covid-19- Belgian financial financial company economic-measures Corporate loans National Bank company company https://www.esma.europa. and the or self- Non-financial companies, SMEs, self-employed eu/press-news/esma- financial employed individuals and non-profit organisations (meeting certain news/esma-requires-net- sector individual criteria as set out below) who are borrowers under a short-position-holders- corporate loan (term loans, revolving loans, etc. other than report-positions-01-and- leasing or factoring arrangements), can request a deferral above of payment of principal of up to 6 months. Interest will remain due and payable during such period. The term of the credit agreement will be extended with a period equal to the length of the deferral period that was granted (i.e. a maximum extension of 6 months). Eligibility:

4 Note: The information provided in this publication in respect of measures in the Benelux region is as at 21 April 2020.

-20- BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Non-financial companies, SMEs, self-employed individuals and non-profit organisations can request a deferral if they meet each of the following criteria: i) The company or organisation can no longer meet its payment obligations due to the impact of the COVID-19 crisis, reflected by among other things: a) a decrease of turnover; b) all or part of its employees being temporarily unemployed; c) its business being closed by the government as a precautionary measure to prevent spreading of the virus; ii) The company or organisation has a permanent establishment in Belgium; iii) The company or organisation has: a) as at 1 February 2020, no overdue payments owed to creditors, on account of taxes or social security; or b) as at 29 February 2020, certain payments owed to creditors, on account of taxes or social security which are overdue for less than 30 days. iv) The company or organisation has complied with all its contractual obligations towards its credit institutions for the last twelve month period ending 31 January 2020 and is not involved in a debt restructuring process with its creditors. A similar scheme is available for private individuals (not detailed here).

-21- BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Federal Yes if a Yes if a Yes if a non- Guarantee scheme that will backstop certain loans The new federal Government, non- non- financial made by the financial sector guarantee scheme will Belgian financial financial company exist in parallel to the National Bank company company The Federal Government of Belgium, together with the existing regional (Flemish, and the or self- financial sector, is in the process of developing a guarantee Walloon and Brussels) financial employed scheme that will backstop certain loans made by the measures. For example, sector individual financial sector. The details are still to be confirmed, yet on the statutory Flemish the basis of the information currently available, we Gigarant guarantee understand as follows: arrangement of 2009, managed by Participatie The guarantee scheme will apply to all new loans and Maatschappij Vlaanderen credit lines (term loans, revolvers, etc. including (“PMV”), will not be syndicated loans, it being understood that only Belgian replaced by the new credit institutions will be able to benefit from the federal scheme; instead, guarantee): both schemes will apply in i) made to “viable” (as further explained below) tandem. Additionally, the non-financial companies, SMEs, self-employed guarantee scheme at the individuals and non-profit organisations with at federal level will not least an activity in Belgium. Provisions will be replace the existing included in the loans to ensure that, in case of general guarantee an international group, the Belgian activities of arrangements at the the group will benefit from the funds made Flemish level applicable available under the loan; to SMEs. Similar measures exist in ii) with a maximum duration of 12 months; Wallonia, where iii) for a maximum amount equal to the lower of (i) companies such as €50 million per borrower (or group of affiliated SRIW, Groupe Sogepa companies) and, (ii) the borrower’s liquidity and SOWALFIN have needs for its activities for the next 12 months (or extended guarantees to 18 months for SMEs, including self-employed businesses undergoing traders), unless the government agrees, on a the consequences of the case-by-case basis, to a higher amount being COVID-19 crisis. made available; and Differences exist between the federal and the

-22- BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap iv) which have been entered into on or prior to 30 regional measures and September 2020. justify their parallel existence. First, with a The maximum interest rate for such bridge loans shall not maximum of a 12-month exceed 1.25% (excluding fees). Fees shall not exceed term for bridge loans, the 0.25% if the borrower is an SME, and 0.50% for larger federal measures are a companies. short-term solution. The Importantly, these loans can only operate as bridge loans. Gigarant guarantee and Refinancing loans as well as undrawn amounts of existing the Flemish SME credit lines are not covered by this guarantee scheme. guarantee scheme are longer-term solutions. Coverage: Second, the guarantee The guaranteed loans can only be used to finance a amounts under the federal company’s Belgian operations or its qualified foreign guarantee scheme are operations to the extent that such use is limited to 10% of distributed between banks the guaranteed loan and such use is not to the detriment on a portfolio basis, of the Belgian operations. proportional to the bank’s market share in credits The new scheme provides for a total guarantee amount of and credit lines to viable €50 billion offered by the Belgian federal government. non-financial businesses, However, the first losses will be borne by the financial SMEs and self-employed sector. In particular, upon expiry of the guarantee scheme, persons. Regional the amount of losses incurred on loans under the guarantees such as the guarantee scheme will be assessed. The burden will be Flemish and Walloon shared between the financial sector and the public sector schemes are granted on a as follows: case-by-case basis, as i) The first 3% of losses will be borne entirely by part of a three-party the financial sector. agreement between the lender(s), the borrower ii) For losses between 3% and 5%, 50% of the and the regional entity. losses will be borne by the financial sector and 50% by the government. https://www.nbb.be/en/su mmary-covid-19- economic-measures

-23- BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap iii) For losses higher than 5%, 80% of the losses https://www.esma.europa. will be borne by the government and 20% by the eu/press-news/esma- financial sector. news/esma-requires-net- short-position-holders- : Eligibility report-positions-01-and- A loan will only qualify for the government guarantee if above made to a “viable” person or entity that is a non-financial company, registered with the Crossroads Bank for Enterprises in Belgium. Based on the viability criteria, the following persons or entities are excluded: i) a person/entity which was in arrears on 1 February 2020 under its current credit agreements or in respect of taxes or social security contributions or was more than 30 days in arrears on 29 February 2020 under its current credit agreements or in respect of taxes or social security contributions; ii) a person/entity that was involved in an active credit restructuring process with a financial institution as at 31 January 2020; iii) a person/entity which, on the basis of the information available, is to be regarded as an undertaking in difficulty. Note: The new federal guarantee scheme will exist in parallel to regional (Flemish, Walloon and Brussels) measures, yet, based on the information published online by some regional guarantee providers, the understanding is that a loan which is guaranteed by the Federal Government can at the same time not benefit from a guarantee from a regional government.

-24- BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap For example, on 1 April 2020, the Flemish government approved a capital increase of €250 million of Participatie Maatschappij Vlaanderen (“PMV”) to grant subordinated medium-term loans in the context of the Corona crisis. In addition to the federally guaranteed bridge loans, which provide liquidity needs in the very short term, there is a need for financing instruments that create a financial buffer in the medium term. That is why PMV will provide subordinated loans over a period of 3 years. The measure is open only to SMEs. The focus is on start-up companies and scale-ups that are important for the future of the Belgian economy and need to strengthen their equity capital. Here too, companies that already had problems before the crisis will be excluded. In addition, only companies that bring their effective employment to a minimum of 80% of their workforce in the short term or keep their workforce that is at work are eligible. In particular, firms that remain active in these circumstances or become active again in the very short term will be supported. Further, in combination with the federal guarantee, PMV has a total guarantee capacity of €3.4 billion which will be fully deployed. In addition to this ordinary guarantee scheme and the federal guarantee, the guarantee capacity of Gigarant (a guarantee fund managed by PMV), which applies to guarantees in excess of €1.5 million, also doubles to €3 billion. Similar measures exist in Wallonia, where companies such as SRIW, Groupe Sogepa and SOWALFIN have extended guarantees to businesses undergoing the consequences of the COVID-19 crisis.

-25- BELGIUM Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Differences exist between the federal and the regional measures and justify their parallel existence. First, with a maximum of a 12-month term for bridge loans, the federal measures are a short-term solution. The Gigarant guarantee and the Flemish SME guarantee scheme are longer-term solutions. Second, the guarantee amounts under the federal guarantee scheme are distributed between banks on a portfolio basis, proportional to the bank’s market share in credits and credit lines to viable non-financial businesses, SMEs and self-employed persons. Regional guarantees such as the Flemish and Walloon schemes are granted on a case-by-case basis, as part of a three-party agreement between the lender(s), the borrower and the regional entity.

LUXEMBOURG Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Luxembourg Yes Yes5 Yes Stabilisation package The measures may also Government be adapted depending on Small-sized businesses with 9 employees with an annual future developments. turnover of at least €15,000 which had to close following the series of measures in the fight against Covid-19 can apply for an immediate and non-refundable, financial aid

5 Small-sized businesses with 9 employees with an annual turnover of at least €15,000 which had to close following the series of measures in the fight against Covid-19. Only companies having the following activities as described under the Grand Ducal Regulation of 3 April 2020 implementing the Temporary Aid Scheme Law (the Grand Ducal Regulation) are eligible to the aid scheme: manufacturing; construction; accommodation and food service activities; trade; repair of motor vehicles and motorcycles; transportation and storage; real estate activities; extractive industry; professional, scientific and technical activities; administrative and support service activities; information and communication; electricity, gas, steam and air conditioning supply; water supply; sewerage, waste management and remediation activities; education; human health and social work activities; arts, entertainment and recreation; and other service activities listed under section S of Regulation (EC) no 1893/2006 of the European Parliament and of the Council of 20 December 2006 establishing the statistical classification of economic activities NACE revision 2, as amended.

-26- LUXEMBOURG Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap of €5,000. Businesses of all sizes, including natural https://guichet.public.lu/en persons carrying out their activities as their main activity .html and in self-employment, can apply for a refundable financial aid amounting to up to €500,000 to cover certain of their operation expenses under the conditions set out by the Law of 3 April 2020 relating to the implementation of an aid scheme in favour of businesses in temporary financial difficulty and amending the amended law of 19 December 2014 relating to 1) social measures to the benefit of independent professional artists and workers in the entertainment industry, 2) the promotion of creative work (the Temporary Aid Scheme Law). The costs taken into account for calculating aid are the personnel expenses and rental costs (rent plus charges) of the business for the months falling within the period of the unforeseeable event (i.e. between the 15 March to 15 May 2020 as set out in the Grand Ducal Regulation). Applications must be sent to the Ministry of the Economy by no later than 15 August 2020 using a dedicated form available on the Guichet.lu website. The aid ought to be granted before 1 October 2020 and will amount to a maximum of 50% of the allowable costs for a maximum amount of €500,000 per eligible company. The aid shall be repaid in accordance with a repayment schedule submitted by the applicant business and approved by the State by the end of the first half of 2021. The advance is to be repaid at a simple interest rate of 0.5% and repayment shall start no earlier than 12 months after the first payment of the repayable aid, unless the business requests otherwise. i) BCEE, BGL BNP Paribas, BIL, Raiffeisen, Banque de Luxembourg and ING will postpone

-27- LUXEMBOURG Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap reimbursement of existing credits on a period and under specific conditions to be discussed on a case-by-case basis with each concerned client. ii) Government backed guarantee scheme up to a limit of €2.5 billion for new bank loans in favour of businesses in temporary financial difficulty as a result of the COVID-19 pandemic (a maximum of six years will apply). The new credit lines will be guaranteed at 85% by the State and 15% by the participating banks (BCEE, BGL BNP Paribas, BIL, Raiffeisen, Banque de Luxembourg, ING) for loans granted during the period from 18 March 2020 to 31 December 2020. These new credits are reserved for businesses that were viable before 18 March 2020. The assessment of whether a business was viable or not is the sole responsibility of the participating banks. In order to benefit from this State guarantee scheme, candidate companies must contact one of the participating banks to apply for a loan. The participant bank will then notify the State Treasury of the granting of the loan in order to benefit from the State guarantee. iii) Provision up to €400 million in loans to companies in difficulty by the State's investment bank Société Nationale de Crédit et d'Investissement (“SNCI”) as part of a special anti-crisis financing instrument (“SACF”). This instrument is aimed at Luxembourg SMEs and large companies having a business license in Luxembourg with a view to financing any exceptional needs that have arisen in light of the COVID-19 crisis, for financing decisions taken

-28- LUXEMBOURG Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap until 31 December 2020. This is indirect financing via the company’s usual bank. The SNCI up to 60% of the required amount, provided that the private bank finances 40%. Amount of SACF financed by the SNCI can vary between €12,500 and €10,000,000. Loans are made upon request of the client’s bank without further formalities. Maximum SACF duration is 5 years with an initial grace period on the repayment of capital of a maximum 2 years. In addition, SNCI decided in the context of the COVID-19 pandemic to suspend the reimbursement of capital for the quarterly terms of 31 March and 30 June 2020 of all its outstanding direct and indirect loans. No action from clients is required. The duration of all loans benefitting from said moratorium is automatically extended for 6 months. The above measures were adopted very recently and additional information should be available in the coming days. It is worth noting that the measures may also be adapted depending on future developments.

-29-

NETHERLANDS Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Dutch No No No Temporary lowering of systemic risk buffers for major The introduction of a floor Central Bank Dutch banks / The Dutch Central Bank (De for mortgage loan risk (De Nederlandsche Bank N.V.) weighting originally Nederlandsch scheduled for autumn DNB has lowered the systemic risk buffers, from its e Bank N.V.) 2020 will be postponed. current 3% of global risk-weighted exposures to 2.5% for (“DNB”) ING, 2% for Rabobank and 1.5% for ABN AMRO. https://www.dnb.nl/en/new s/news-and- Combined, these measures are expected to free up €8 archive/persberichten- billion in capital with the potential of €200 billion additional 2020/dnb387870.jsp lending. Released capital may only be used for lending or to absorb potential losses from defaults (i.e. not for dividend distribution or share repurchases). Ministry of Yes Yes Yes Business Finance Guarantee Scheme Not eligible: Economic Guarantee from the Ministry of Economic Affairs and Credit and guarantee Affairs and Climate Policy. facilities to borrowers who Climate have their main activities Policy : Eligibility in agriculture, fishing or (Ministerie van To participating banks. aquaculture, (speculative) Economische real estate investment, Zaken en For new non-convertible subordinated or unsubordinated, banking, insurance, Klimaat) secured or unsecured credit and/or bank guarantee brokerage, venture capital facilities from €1.5 million up to €50 million (in aggregate) or health services. to businesses with maturity of up to 8 years. https://www.rvo.nl/subsidi It is a requirement that the credit facilities bear fixed rate e-en- interest or floating rate interest linked to EURIBOR. In financieringswijzer/garanti addition, the purpose of the guaranteed facilities must be e- the funding of the activities of the borrower. ondernemingsfinanciering Coverage: -go

-30- NETHERLANDS Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Guarantee for up to 50% of the outstanding facility balance. Guarantee fee based on all revenues resulting from the guaranteed portion of the facilities. In response to the pandemic, the Dutch government has proposed to raise the maximum amount of the facilities to €150 million for each borrower and to expand the total budget for the scheme from €400 million to €1.5 billion. On 7 April, the Dutch government proposed further expansions, which are expected to result in a total budget of €10 billion as well as an increase of the portion of a loan facility that can be guaranteed under the scheme: up to 80% of loans made to businesses with more than €150 million in turnover and up to 90% of loans made to businesses with an annual turnover of €150 million or less. i) The facilities must provide for fresh funds; i.e. no refinancing of existing indebtedness provided by the same lenders. ii) The borrower must be substantially healthy. iii) No substantive capital withdrawals must have taken place during the last 12 months. iv) Participating banks: ABN-Amro, Bank of Tokyo- Mitsubishi UFJ (Holland), Deutsche Bank AG, Amsterdam Branch, ING, NIBC Bank, Riverbank, Royal Bank of Scotland (RBS), Société Générale and Triodos Bank. The application for a guarantee under the scheme must be made by the lender(s) with the Netherlands Enterprise Agency (Rijksdienst voor Ondernemend Nederland (MVO)).

-31- NETHERLANDS Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The application process takes not more than three weeks. Ministry of No Yes6 No Government-guaranteed Scheme for Loans to Small Not eligible: Economic and Medium-sized Enterprises (Borgstelling MKB- Credit facilities to Affairs and Kredieten) borrowers who have their Climate Guarantee from the Ministry of Economic Affairs and (main) activities in, inter Policy Climate Policy. alia, agriculture, fishing or (Ministerie van aquaculture, (speculative) Economische To participating banks and certain other creditors for credit real estate investment, Zaken en facilities up to €1.5 million (in aggregate) to SME banking, insurance, Klimaat) businesses. brokerage or venture Coverage: capital. Guarantee for up to 90% of the outstanding guaranteed Exporting activities are credit balance (which may not exceed 50% of the total not supported either. credit balances of the company (the “ Guaranteed Credit https://www.rvo.nl/subsidi ”). Balance Maximum e-en- Guarantee fee varies from 3.9% up to 8.35% depending financieringswijzer/borgst the tenure of the guaranteed credit. elling-mkb-kredieten- bmkb In response to the pandemic, the Dutch government has proposed to raise the Guaranteed Credit Balance Maximum to 75% for bridge credit facilities with a tenure

of not more than 1 year. Participating banks: ABN-Amro, Deutsche Bank AG, Amsterdam Branch, ING, Rabobank, Riverbank and Triodos Bank. The application for a guarantee under the scheme is made simultaneously with the credit application to the lender.

6 Business with no more than 250 employees.

-32- NETHERLANDS Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Ministry of Yes Yes Yes Government-guaranteed Scheme for Loans to https://www.rvo.nl/subsidi Agriculture, Agricultural Enterprises (Regeling e-en- Nature and Borgstellingskrediet Landbouw) financieringswijzer/borgst Food Quality ellingskrediet-voor-de- Temporary additional guarantee scheme from the Ministry (Ministerie van landbouw-bl of Agriculture, Nature and Food Quality (Ministerie van Landbouw, Landbouw, Natuur en Voedselkwaliteit). Natuur en Voedselkwalite Guarantees to banks for (additional) bridge facilities with a it) maximum tenure of 2 years and a credit balance of not more than €1.2 million per enterprise. Guarantee for up to 70% of the outstanding credit balance. Ministry of No Yes7 No Covid-19 Compensation Scheme https://www.rvo.nl/subsidi Economic e-en- Payment of €4,000 per company as compensation for Affairs and financieringswijzer/tegem damages resulting from quarantine measures. Climate oetkoming-schade-covid- Policy The application period ends on 26 June 2020. Companies 19 (Ministerie van that have received an amount of €200,000 or more in Economische government aid in the two most recent fiscal years are Zaken en excluded from support under the scheme. Klimaat) Ministry of Supplier Credit Guarantee Scheme (Garantiefaciliteit Finance Leverancierskrediet) (Ministerie van On 7 April, the Dutch government announced that it Financiën) intends to create a new scheme under which the Dutch State will provide guarantees to credit insurers for supplier credit facilities made available to Dutch companies. The total budget for the scheme is €12 billion. Further details are expected to be published in the second half of April.

7 Companies with no more than 250 employees with their main activities in: retail trade, hospitality trade, movie theatres, dancing schools, artistic education, driving schools, art, museums, galleries, exposition, lotteries, games of chance and betting, sports and leisure, wellnessbeauty salons, hair stylists, travel agencies and conferences, food, taxi transportation, dentists, physioterapists and suppliers of restaurant and bars.

-33- NETHERLANDS Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The scheme is subject to approval from the European Commission.

-34- FRANCE8 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap French public Yes Yes Yes Government backed guarantees Not eligible: investment Government backed guarantees are granted to all Banking companies, civil bank (“BPI companies impacted by the epidemic, regardless of their building companies, France”) size, for loans having the following contractual terms: financial companies.

i) Contracted between 16 March 2020 and 31 https://www.gide.com/en/ December 2020. news/covid-19-measures- in-banking-law-at- ii) One year maturity, repayable at maturity. european-level-and-in- iii) Convertible at term by unilateral decision of the france beneficiary company into amortizable credits

with a maximum additional maturity of 5 years.

iv) Not subject to any other guarantee or security, except on a case-by-case basis for companies with 5,000 employees or more, or with a turnover of more than €1.5 billion. Coverage: The guarantee covers from 70% of the loan for large companies with a turnover of more than €5 billion, to 90% of the loan for SMEs. BPI France No Yes Yes Guarantees for SMEs and Medium size enterprises Specific guarantees are also provided exclusively for SMEs (small medium enterprises having less than 250 employees+ annual turnover of no more than €50 million) and ETIs (mediums size enterprises having between 250- 4999 employees +annual turnover of no more than €1.5 billion) for: i) investment and working capital loans with an initial maturity of between 2 and 6 years; and

8 Note: The information provided in this publication in respect of measures in France is as at 1 April 2020.

-35- FRANCE8 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap ii) confirmed credit lines, with an initial maturity of between 12 and 18 months, renewable once. Coverage: Such guarantees are given subject to the following conditions: i) The guarantee will not cover more than 90% of the loan amount. ii) The commitment ceiling per beneficiary is €5 million for SMEs and €30 million for ETIs. iii) The maximum amount of guarantees may represent up to 25% of the beneficiary company’s turnover in France in 2019. Guarantee fee is paid by the borrower. The fee is determined based on borrower’s size and maturity of the loan. BPI France - Yes Yes Other credit facilities Unguaranteed loans between 3 to 5 years up to €5 million for SMEs and €30 million for ETIs, with deferred payment. In a cooperation with French regions, possibility for companies to be granted a loan from €10 to €300,000, subsidised over a period of 7 years with a 2-year deferral. Extension for BPI France clients of the invoices deadlines and granting of cash credit facility equivalent to 30% of the receivables’ amount. Suspension, as of 16 March 2020, of repayments for loans granted by BPI France, for a duration up to 6 months.

-36- FRANCE8 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Readjustment upon request of medium and long-term loans for BPI France clients.

-37- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Economic No No, unless Yes Not Eligible: Guarantees by ESF of up to €400 billion for debt Stabilisation company Two criteria instruments/established liabilities of companies to Regulated financial sector Fund (“ESF”) is active in to be met eliminate liquidity bottlenecks and support refinancing. entities / credit or bridge one of the German out of three institutions sectors Loans by BMF of up to €100 billion to cover expenses Federal in past two acc. to and measures of ESF within scope of participation in Highly leveraged Ministry of years: section 55 direct recapitalisation measures of companies. companies (acc. to EU Finance Foreign (i) balance definition of companies in (“BMF”) and Loans by BMF of up to €100 billion for ESF to refinance Trade and sheet total difficulties). German loans granted by KfW (as defined below). Payments of more than Federal https://www.bmwi.de/Red Regulatio €43 million; Prerequisite for application: Ministry of n or is of aktion/DE/Coronavirus/W SF/wirtschaftsstabilisierun Economics comparabl (ii) more i) company was not already in “difficulty” (financial (“BMWi”) than €50 gsfonds.html e distress) on 31 December 2019; importanc million in sales ii) company has no other financing options e for available; security or revenues; the (iii) more iii) company has a clear independent going concern economy than 249 perspective after the COVID19 pandemic has employees been overcome as a result of the stabilisation on annual measure; average. iv) company can guarantee a sound and prudent business policy (by contributing to stabilisation of production chains and safeguarding jobs); and v) no other means of financing must be available for the company. Applications are decided upon by the BMF in accordance with the BMWi based on inter alia the importance of the applicant for the German economy.

9 Note: The information provided in this publication in respect of measures in Germany is as at 24 April 2020.

-38- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap State No Yes No Support measures for start-ups worth €2 billion have been Programme announced programme adopted which include: on 1 April 2020 for start-ups i) Public venture capital investors at fund-of-funds Further information BMF and and individual fund level will receive additional regarding prerequisites for BMWi public funds for co-investments with private application and amounts investors in start-up financing rounds; will follow by BMWi / BMF ii) fund-of-funds investors KfW Capital and https://www.bmwi.de/Red European Investment Fund will be enabled to aktion/EN/Pressemitteilun take over shares of failing fund investors with gen/2020/20200401- additional public funding; and customised-support-for- new-businesses-affected- iii) young start-ups without venture capitalists as by-the-coronavirus- shareholders and small/mid-sized companies will crisis.html receive support in assuming venture capital and equity-replacing financing. Prerequisite for application Private investors would have granted equity financing irrespective of the current Covid-19 crisis; further requirements and details have not yet been communicated. Loan No Yes Yes KfW Entrepreneur Loan / ERP Start-Up Loan - Not Eligible: programmes Universal by Regulated financial sector Kreditanstalt Loan programme covering up to 90% of the risks of loans entities / credit or bridge für for SMEs / 80% for large/mid-cap companies. institutions. Wiederaufbau Available for investments, working capital purposes, Highly leveraged (“KfW”) warehouses, acquisition of other enterprises. companies (acc. to EU definition of companies in Amount of up to €1 billion per group, depending on further difficulties). defined liquidity needs, i.e. not more than: Financed project must be i) 25% of the annual turnover in 2019; or in Germany (including investments by foreign

-39- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap ii) 25% or twice the wage costs of 2019; or companies investing in Germany or financing iii) the current financing requirements for the next working capital for their 18 months for SMEs or 12 months for large German subsidiaries or enterprises; or the financing of working iv) 50% of the overall indebtedness for loans capital for German exceeding €25 million. companies with foreign subsidiaries). Term is maximum 6 years. Profit and dividend Prerequisite for application: distributions (the latter i) the company was not already in “difficulty” only to the extent not (financial distress) on 31 December 2019; required by law) are not permitted during the term ii) no deferral agreements which are attributable to of the loan, with the creditworthiness-related suspension of exception of market repayment and are therefore equivalent to a loss standard compensation to of creditworthiness or covenant breaches business owners (natural equivalent to a loss of creditworthiness persons, but no respectively as of 31 December 2019; distributions / withdrawals to private equity iii) company must be in a position to bear the investors). This also respective loans. After the crisis, company must applies to profit and - assuming that the overall economic situation dividend distribution returns to normal after three months at the latest resolutions already - continue to be viable beyond resolved by general 31 December 2020 and thus be in a position to meetings. take out appropriate follow-up financing; KfW Entrepreneur Loan: iv) in order to qualify under the KfW Entrepreneur https://www.kfw.de/inland Loan, companies must have been active on the sfoerderung/Unternehmen market for at least 5 years. Under the KfW ERP /Unternehmen-erweitern- Start-up loan, companies may not have existed festigen/Finanzierungsan for 5 years, but must have been active on the gebote/KfW- market for 3 years (or be able to present two annual financial statements); and

-40- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap v) domestic and foreign companies for projects in Unternehmerkredit- Germany (including investments by foreign Fremdkapital-(037-047)/ companies investing in Germany or financing ERP Start-Up Loan: working capital for their German subsidiaries or https://www.kfw.de/inland the financing of working capital for German sfoerderung/Unternehmen companies with foreign subsidiaries). /Gr%C3%BCnden- Nachfolgen/F%C3%B6rde rprodukte/ERP- Gr%C3%BCnderkredit- Universell- (073_074_075_076)/ Loan funding No No Yes Direct participation for syndicated loans - Not Eligible: via KfW Direktbeteiligung für Konsortialfinanzierung Regulated financial sector Loan programme in which KfW participates together with entities / credit or bridge private banks to provide larger loans as a consortium. institutions. Risk coverage by KfW of up to 80% of loan amount Highly leveraged (minimum €25 million) but not more than 50% of companies (acc. to EU company’s overall indebtedness. definition of companies in difficulties). Term of participation limited to 6 years. Company must be Capped at an amount of either: predominantly owned i) 25% of the annual turnover in 2019; privately. ii) double the employee costs incurred in 2019; or Financed project must be in Germany (including iii) the actual financial need for the next 12 months. investments by foreign Prerequisite for application: companies investing in Germany or financing i) company was not already in “difficulty” (financial working capital for their distress) on 31 December 2019; German subsidiaries or ii) no deferral agreements which are attributable to the financing of working creditworthiness-related suspension of capital for German

-41- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap repayment and are therefore equivalent to a loss companies with foreign of creditworthiness or covenant breaches subsidiaries). equivalent to a loss of creditworthiness Profit and dividend respectively as of 31 December 2019; distributions (the latter iii) company must be in a position to bear the only to the extent not respective loans. After the crisis, company must required by law) are not - assuming that the overall economic situation permitted during the term returns to normal after three months at the latest of the loan, with the - continue to be viable beyond exception of market 31 December 2020 and thus be in a position to standard compensation to take out appropriate follow-up financing; and business owners (natural persons, but no iv) domestic and foreign companies for projects in distributions / withdrawals Germany (including investments by foreign to private equity companies investing in Germany or financing investors). This also working capital for their German subsidiaries or applies to profit and the financing of working capital for German dividend distribution companies with foreign subsidiaries). resolutions already resolved by general meetings. https://www.kfw.de/inland sfoerderung/Unternehmen /Erweitern- Festigen/F%C3%B6rderpr odukte/Direktbeteiligung- f%C3%BCr- Konsortialfinanzierung- (855)/

Loan funding No Yes No KfW Express Loan 2020 - Programme announced via KfW KfW-Schnellkredit 2020 on 6 April 2020 by BMWi / BMF and approved by the

-42- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Loan programme serves as a funding loan for investments EU Commission on and operating costs for medium-sized companies. 11 April 2020. The bank receives a 100% back-to-back guarantee to Company must be finance investments and working capital from KfW, predominantly owned secured by a guarantee from the federal government. privately. Term is maximum 10 years. Profit and dividend distributions (the latter Capped at an amount of only to the extent not i) 25% of turnover 2019; required by law) are not permitted during the term ii) maximum €500,000 for companies with up to of the loan, with the 50 employees; or exception of market iii) maximum €800,000 for companies with more standard compensation to than 50 employees. business owners (natural persons, but no Prerequisite for application: distributions / withdrawals i) companies with more than 10 employees; to private equity investors). This also ii) with business seat in Germany; applies to profit and iii) that were active on the market since at least dividend distribution 1 January 2019 and have reported profit on resolutions already average over the years 2017 to 2019 - or in a resolved by general shorter period if the respective company has not meetings. yet been on the market since 2017; and https://www.kfw.de/inland iv) that were not already in “difficulty” (financial sfoerderung/Unternehmen distress) as of 31 December 2019. /Erweitern- Festigen/F%C3%B6rderpr odukte/KfW-Schnellkredit- (078)/

-43- GERMANY9 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Large State No Yes Yes Large State Guarantee Programme Company must be Guarantee Großbürgschaftsprogramm predominantly owned Program privately. The guarantee programme issued by the BMWi is BMWi available for collateralization of investments and working Applications are to be capital, if the surety requirements exceed €50 million (or filed to €20 million in structurally weak regions). PricewaterhouseCoopers. The programme provides a guarantee of up to 90% of the https://www.foerderdatenb overall loan amount. ank.de/FDB/Content/DE/F oerderprogramm/Bund/B Prerequisite for application: MWi/buergschaften- i) company predominantly owned privately; laender-bund.html ii) with a sustainable business concept, having their business seat in Germany. iii) only eligible if an alternative way of financing and collateralization is not available. Domestic No Yes Depends on Grants, Guarantees and loan programmes established Depending on respective state level respective on domestic state level programme and state. programme Guarantees provided by Guarantee Banks of respective e.g. Bavaria: and state federal state, up to 90% and up to €2.5 million (Bavaria up https://www.stmwi.bayern. to €5 million). de/soforthilfe-corona/ Loan programmes in various amounts.

(Non-)Refundable grants mostly determined on head- count (e.g. Bavaria) of up to €60,000.

-44- NORDIC REGION DENMARK10 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Danish No Yes Yes Government-backed guarantee SME: Growth Fund www.vf.dk/finansiering/co This scheme is an extension of the Danish Growths Funds vid-19-garanti-smv/ existing guarantee scheme.

Eligibility: Large companies: SME (as EU defined): www.vf.dk/finansiering/co SMEs have (i) below 250 full-time employees, (ii) net vid-19-kaution-store- turnover of no more than €50 million, and/or virksomheder/ (iii) assets worth no more than €43 million.

Large companies (as EU defined): Large companies have (i) more than 250 full-time employees, (ii) net turnover of more than €50 million, and/or (iii) assets worth more than €43 million. Conditions: To financial institutions providing credit facilities, lease arrangements, and similar, which loans shall cover entities’ realised or expected loss of turnover of more than 30% (as a result of the COVID-19 outbreak) over a minimum period of 14 days within the period from 1 March 2020 to 30 September 2020. To become eligible, entities must be deemed creditworthy by the financial institution. The loan amount cannot exceed the realised loss of revenue and the largest amount of the following: i) the company's liquidity requirements the next 12 months (18 months for SMEs),

10 Note: The information provided in this publication in respect of measures in Denmark is as at 11 May 2020.

-45- DENMARK10 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap ii) twice the company's yearly expenditure on wages and salaries or the latest available year, or for new companies the estimated expenditure on wages and salaries for the first two years, or iii) 25 % of the total revenue of 2019.

If a business has received a COVID-19 related guarantee from the Danish Growth Fund, it is not eligible for a Covid-19 related guarantee from EKF, and vice versa.

Coverage: A guarantee under the scheme covers up to 70 % of a financial institution's exposure under the loan. For large companies, the guarantee cover is written down on during the term of the loan is following the bank's amortisation profile. For SME's it is written down on a straight-line basis.Guarantee fees: SME: i) Upfront fee: DKK 2,500. ii) Annual fee: 1.0% of outstanding guaranteed loan from time to time. Large companies: i) An upfront fee of 0.25 % of the amount of the guarantee cover, the upfront fee is capped at DKK 250.000. ii) A semi-annual guarantee fee calculated on the basis of the financial institution's "all-in-marginal"

-46- DENMARK10 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap less funding marginal which is dependent on the and guarantee period. Expiry: The term of such guarantee is up to 6 years) (7 years for SME's) regardless of the type of loan covered. Danish No Yes Yes Government-backed schemes SME: Export Credit www.ekf.dk/en/about- Liquidity Guarantee Agency ekf/ekf-s- (“EKF”) Purpose: organisation/news/2020/e kf-ready-to-facilitate- Supporting Danish exporters having liquidity difficulties liquidity-for-several- during the COVID-19 period, e.g. to meet supplier and hundred-danish-smes- payroll costs. This is a DKK 1.25 billion extension of EKF’s impacted-by-the-corona- current Working Capital Guarantee. crisis Conditions: Exports must represent at least 10% of the entity's annual Large companies: turnover. www.ekf.dk/en/about- The entity must prove realised or expected loss of ekf/ekf-s- turnover of more than 30% (as a result of the COVID-19 organisation/news/2020/c outbreak) over a minimum period of 14 days within the orona-crisis-relief-ekf-to- period from 1 March 2020 to 30 September 2020. guarantee-liquidity-for- The entity must be deemed creditworthy, and must not even-more-large- have had financial difficulties prior to the COVID-19 businesses-disrupted-by- outbreak (as per 31 December 2020). the-crisis In addition, the entity must comply with labour and environmental regulation in Denmark and in each country the entity has business. If a business has received a COVID-19 related guarantee from the Danish Growth Fund, it is not eligible for a Covid- 19 related guarantee from EKF, and vice versa.

-47- DENMARK10 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Eligibility: SMEs and large companies.

Coverage: For SMEs: Up to 80% of bank loss on new credit lines extended to secure exporter liquidity. Such credit line must not be in excess of the realised or expected loss of turnover. For large companies: Up to 70% of bank loss on new credit lines extended to secure exporter liquidity. Such credit line must not be in excess of the realised or expected loss of turnover. Guarantee fees: SME: 1.0% of outstanding guaranteed loan from time to time. Large companies: i) An upfront fee (in Danish: stiftelsesprovision) of 0.25 % of the amount of the guarantee cover, the upfront fee is capped at DKK 250.000. ii) A semi-annual guarantee fee calculated on the basis of the financial institution's "all-in-marginal" less funding marginal which is dependent on the currency and guarantee period. of private trade credit insurance companies Purpose: Reinsurance of private trade credit insurance companies to ensure that such insurance companies do not refrain

-48- DENMARK10 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap from underwriting Danish exporters’ export orders due to the COVID-19 situation. Thereby coverage of Danish exporters’ risk will be secured in connection with receiving due consideration if customers abroad becomes unable to pay. This is an extension of EKF’s existing reinsurance scheme by way of including EU and OECD countries. Eligibility: SME and large companies.

Coverage: Up to 90% of trade credit insurers’ exposed risk in connection with new export orders.

FINLAND11 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Bank of See No Yes Commercial paper https://www.suomenpankk Finland summary i.fi/en/media-and- The BoF has decided to restart its activities in the (“BoF”) publications/releases/202 domestic commercial paper markets with a €1 billion 0/the-bank-of-finland- programme for the purpose of increasing the supply of decided-on-new- funding to businesses and preservation of jobs, as part of measures-to-safeguard- national and euro area crisis measures. funding-for-businesses- Eligibility: and-households-during- the-corona-virus- All issuers fulfilling BoF’s risk control parameters and pandemic/ investment criterion. https://www.suomenpankk i.fi/en/media-and-

11 Note: The information provided in this publication in respect of measures in Finland is as at 07 May 2020.

-49- FINLAND11 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap publications/speeches- and- interviews/2020/governer- olli-rehn-economic- effects-of-the-corona- crisis-and-measures-by- the-central-banks/ The State See No Yes Commercial paper https://www.ver.fi/en- Pension Fund summary US/Publications/The_Stat VER has increased its purchases of commercial paper of Finland e_Pension_Fund_of_Finla and may further increase its investments to up to €1 billion ("VER") nd_Increa(840) (from EUR 311 million as per 8 April 2020). https://www.ver.fi/en- : Eligibility US/Publications/VERs_in i) Return on the commercial papers must accrue vestments_in_the_comme according to normal market practices; rcial_paper(859) ii) A maximum of €50 million may be invested in any single company; iii) The maximum maturity of the commercial papers is 12 months; and iv) The issuer of commercial papers must have a minimum credit rating of BBB- or an equivalent short-term rating or be deemed to present a low credit risk in VER’s assessment. Finnvera Oyj See Yes Only in Finnvera Oyj provides guarantees for the working Not eligible: summary exceptional capital needs of small and medium-sized (“SME”) Businesses operating in cases enterprises: the farming, forestry and The Start Guarantee in the amount of €10,000-80,000 the building developer’s (and up to €160,000 in case of multiple guaranteed sectors. projects) is directed towards SMEs which have been https://www.finnvera.fi/en operating for a maximum of 3 years, are owned by private g/growth/current-news-

-50- FINLAND11 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap individuals and need working capital due to the for-smes/current-news- coronavirus. for-smes/ The Start Guarantee cannot be used for financing company acquisitions, acquisitions of company’s own shares or purchases of business premises or cars or for the purposes of export financing. The SME Guarantee in the amount of €10,000–120,000 (and up to €240,000 in case of multiple guaranteed projects) is directed towards SMEs which have been registered for more than 3 years and at least 50% of which are owned by private individuals. The SME Guarantee may in exceptional cases be used for working capital needs caused by the coronavirus. Moreover, the financing to which the guarantee relates to cannot be used for paying arrears to financiers or reorganization of liabilities towards financiers, company acquisitions, acquisitions of company’s own shares or purchases of business premises or cars or for the purposes of export financing. The Finnvera Guarantee, which can be used for the increased working capital needs of SMEs (and, on special grounds, for larger corporates) due to the coronavirus in cases where the Start Guarantee or SME Guarantee is not suitable in the company’s situation for example due to the amount of loan needed. No additional collateral is required when guaranteeing for a €150,000–1,000,000 corporate debt bond granted by a bank. Finnvera has put into operation a hastened and a simplified procedure to deal with applications and to validate guarantees.

-51- FINLAND11 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Eligibility: With respect to SME Guarantee and Finnvera Guarantee, the applicant company must have a minimum Rating Alfa classification of A (Suomen Asiakastieto Rating Alfa classification). Coverage: Finnvera will guarantee up to 80% of the loan.

Finnvera is currently in the process of preparing changes which would enable it to provide guarantees for SMEs amounting to up to 90% of the loan in cases where such guarantees are strictly necessary in order for a company to secure financing. Business No Yes (if 6– Yes (own or Business Finland has introduced 2 new forms of de Business Finland is Finland 250 group minimis funding targeted at nearly all industries the expected to launch a new employee turnover up operations of which are currently suffering due to market research and

s) to €300 and production chain disruptions as a consequence of the development and million) coronavirus: innovation (RDI) loan of up to €150,000 (not yet in i) funding for preliminary studies on business force). disruptions (up to €10,000); and Business Finland also ii) development funding for business disruptions offers eased terms on (up to €100,000). previously granted grants, Eligibility: aids and loans. i) SMEs with 6-250 employees and mid-cap Not eligible: companies with own or group turnover of up to Private traders, €300 million. companies with less than ii) A company may receive the funding primarily 6 employees, and only once, with the exception of special cases. companies in agricultural primary production or the

-52- FINLAND11 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap iii) Funding is aimed at companies that had fishing or fish farming prerequisites for profitable business operations industries. before the coronavirus crisis. A company that has lost Coverage: more than half of its share capital due to incurred Funding will cover maximum 80% of the approved total loss is not eligible. costs. https://www.businessfinla nd.fi/en/for-finnish- customers/services/fundin g/funding-during- coronavirus/ Finnish See Yes Yes Tesi will apply its stability programme to invest in medium- http://www.industryinvest Industry summary sized companies encountering sudden and temporary ment.com/about- Investment difficulties, but which however have the potential to us/news/news- Ltd. ("Tesi") overcome their financial problems with further financing. archive/tesi-s-stability- The investments will be targeted at safeguarding the programme-and-how-to- continuity of companies’ business operations. The size of apply/ the programme is €150 million in total and the size of an investment in a company is between €1 and €10 million. Investments are made in companies' shares or by way of convertible loans. Eligibility: Tesi will mainly finance companies that have an appreciable impact on employment and net sales in Finland, fulfilling the following criteria: i) Net sales of at least €10 million in 2019; ii) Employing over 50 people in Finland; iii) Profitable business before the corona crisis and the framework to remain profitable in future – i.e.

-53- FINLAND11 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap positive EBITDA in 2019, or in two of the preceding three years (2017–2019); iv) Substantial deterioration of financial position due to the Corona crisis; and v) Company not over-indebted before the corona crisis.

-54- NORWAY12 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Yes No Yes Debt securities to be bought by https://www.regjeringen.n Government Fund o/en/aktuelt/mandate- established-for- Unsecured debt securities to be bought by the Fund (“Fund”) / management-of- operated by the Government Pension Fund Norway Norwegian government-bond- (Folketrygdfondet). Government fund/id2695345/ Debt securities to be purchased may be denominated in

NOK, USD, GBP, EUR, SEK or DKK (all foreign to be hedged). Eligibility: i) Only for companies headquartered in Norway. ii) At least 50% of the Fund capital to be invested in investment grade securities, and up to 50% at BB+ and below, however not below CCC+ (S&P or similar). iii) Folketrygdfondet shall carry out internal credit rating if the issuer is not rated. iv) The Fund may hold bonds which are later downgraded to CCC or lower. v) 50-100% of the Fund’s capital shall be invested in non-financial institutions bonds and 0-50% in financial institutions bonds. vi) Maximum exposure towards one single issuer is 5% of the Fund’s capital (i.e. NOK 2.5 billion) Other key terms: Investments shall be made on market terms in accordance with the market economy investor principle.

12 Note: The information provided in this publication in respect of measures in Norway is as at 12 May 2020.

-55- NORWAY12 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Investments exceeding 50% of a bond issue in the primary market, and 70% of the outstanding issue in the secondary market, can only be made to the extent Folketrygdfondet can verify that the investment is on market terms. The board of Folketrygfondet may implement further guidelines and restrictions. Norwegian Yes Yes Yes State guarantee scheme As the guarantees are Export Credit granted directly from the Financial institutions can issue loans to companies Guarantee banks (on behalf of the suffering from sudden liquidity crisis due to the Covid-19 Agency state), only companies pandemic. The loans will be backed with a state that are eligible for bank guarantee to be managed by The Norwegian Export financing may benefit Credit Guarantee Agency (“GIEK”) of 90% of the loan from the scheme. amount on a basis. https://www.regjeringen.n : Eligibility o/no/aktuelt/garantiordnin i) The borrower must have operations in Norway. gen-for-lan-til-sma-og- mellomstore-bedrifter- ii) The guarantee scheme applies to Norwegian kan-tas-i-bruk/id2695485/ SMEs as defined under EU law, and larger businesses. iii) The borrower must be deemed profitable under normal circumstances (absent the Covid-19 crisis). iv) Requirement for “sudden liquidity shortfall”, must be directly or indirectly linked to Covid-19. v) Borrowers cannot have been in financial difficulties (as defined in EU law) prior to 31 December 2019. vi) Purpose of the loans is limited to operational expenses and investments, the latter only to the

-56- NORWAY12 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap extent necessary to recover from the Covid-19 crisis. vii) The lenders assess whether the conditions for granting the guarantee are met, which will be controlled by GIEK in the event of guarantee enforcement. Coverage: Companies may receive multiple loans under the guarantee scheme from different lenders. The loans cannot exceed (i) NOK 50/150 million (SME/larger businesses), or (ii) 200% of the borrower’s labour costs or 25% of its turnover from 2019 on an aggregate basis.

Norwegian No No Yes Financial aid for: Export Credit State guarantees of 90% on a pro rata basis for loans in a Guarantee total amount of NOK 6 billion is allocated to aviation Agency companies with operational licence in Norway, as follows: NOK 3 billion to Norwegian Air Shuttle, NOK 1.5 billion to SAS and NOK 1.5 billion to Widerøe and other aviation companies. Availability of the state guarantees is subject to the aviation companies meeting certain criteria, such as a minimum equity requirement of 8% which means that Norwegian Air Shuttle must restructure its current debts in order to become eligible for the guarantees. The government’s financial aid for aviation companies also includes other easements, such as deferral of certain taxes, reduced employer’s contribution, reduced VAT on transport and exemption from the aviation duty. Norwegian Yes Yes Yes Grant scheme for businesses experiencing Tax substantial drop in turnover

-57- NORWAY12 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Administratio A grant scheme whereby companies experiencing n substantial turnover drops will receive compensation to pay unavoidable fixed expenses, such as rent, and accounting costs. Eligibility: The scheme applies to all taxable companies registered in Norway, with some exceptions which include: i) the financial industry; ii) production, transfer and distribution of electricity and water supply; iii) foreign shipping and transport of goods; iv) oil and gas production; v) aviation companies (as they are under a separate support scheme); vi) companies without employees, non-active companies and companies subject to insolvency procedures. Companies must be taxable in Norway and have experienced a drop in turnover of at least 20% for March and 30% for April or May compared to 2019 results to be eligible. Companies without 2019 results will have to make calculations based on an average of January and February 2020. Amount: The compensation granted will be adjusted by an adjustment factor of 0.9 for companies that have been instructed to shut down and 0.8 for other companies. Additionally, the former mentioned companies will not have to make a co-payment to receive compensation,

-58- NORWAY12 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap whereas the latter mentioned companies will be required to pay a monthly co-payment of NOK 10,000. The compensation will be based on the following formula: turnover decrease (in %) * (fixed expenses minus co- payment) * adjustment factor. Amount to be granted must be at least NOK 5,000 and no more than NOK 80 million per month. Compensation amounts based on the above formula exceeding NOK 30 million per month will be multiplied by 0.5.

-59- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Swedish No Yes Yes Turnover based support The support may need to Tax Agency be approved by the The Swedish Government has presented a support European Commission. scheme for companies that have suffered a turnover decrease during March and April 2020 which will be paid https://www.government.s via the Swedish Tax Agency. The size of the support will e/press- depend on how much a company's turnover has releases/2020/04/busines decreased and may vary between 22.5-75% of a ses-to-receive-support- company's fixed costs, excluding wage costs, for March based-on-loss-of- and April 2020. The measure is proposed to enter into turnover/ force on 1 July 2020. Eligibility: In order to be eligible for the support, a company must have (i) had turnover of not less than SEK 250,000 during the past financial year, and (ii) suffered a decrease in its turnover during March and April 2020 of at least 30% compared to March and April 2019. The support will not be available for businesses that are resident in a tax haven. Coverage: The support is proposed to be capped at SEK 150 million per company. The Swedish No Yes Yes Credit guarantees The Swedish National National Debt Debt office has contacted The Swedish National Debt Office offers airlines credit Office all airlines that are eligible guarantees in the aggregate amount of up to SEK 5 billion for the guarantees. (Sw. (of which SEK 1.5 billion has been issued for SAS AB) Riksgälden) during 2020. https://www.riksgalden.se/ sv/var-

Eligibility: verksamhet/garantier-och-

13 Note: The information provided in this publication in respect of measures in Sweden is as at 7 May 2020.

-60- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The credit guarantees target airlines that as of 1 January lan/flygforetag- 2020 held a Swedish permit to operate commercial garantiprogram/ aviation activities and have their main operations or https://www.riksgalden.se/ headquarters in Sweden. In order to obtain a guaranteed en/press-and- loan, the airlines must undertake not to decide on publications/press- dividend payments or other form of remuneration to senior releases-and-news/press- executives during the term of the loan. Airlines that is not releases/2020/debt-office- operating regularly scheduled traffic for passengers in receives-mandate-to- their main business are not covered by the guarantee prepare-credit-guarantee- programme. programme-for-swedish- airlines/ https://www.riksgalden.se/ en/press-and- publications/press- releases-and-news/press- releases/2020/sweden- provides-guarantee-for- sas-ab/ The Swedish See Yes See Loan guarantees Banks will have to pay a National Debt summary summary guarantee fee to the The Swedish National Debt Office guarantees 70% of new Office Swedish National Debt loans provided by banks to companies that are Office for issued experiencing financial difficulty due to the COVID-19 virus guarantees. The fee will but that are otherwise robust. The guarantee is issued to be determined on the banks, which in turn will provide guaranteed loans to basis of the borrower’s companies. actual risk class, which is Eligibility: set by the credit institution. The loan guarantee primarily targets non-financial SMEs. However, there is no formal limit on company size to take https://www.riksgalden.se/ part in the programme. en/press-and- publications/press- releases-and-news/press- releases/2020/the-deb-

-61- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The risk assessment of the borrowers under this office-prepares- programme will be carried out in accordance with each guarantee-programme- bank’s credit assessment process. for-swedish-companies/ Coverage: https://www.riksgalden.se/ en/press-and- The Swedish National Debt Office will administer the publications/press- guarantee and each company may borrow up to SEK 75 releases-and-news/press- million, although exceptions can be made. releases/2020/Governme nt-guarantee-programme- for-companies-now- accepting-applications/

The Swedish Subject to a Yes No Bridge loans Not eligible: Government case-by- The Swedish Government has injected SEK 3 billion into Companies with more and Almi case Almi (a company wholly owned by the Swedish state). than 250 FTEs. Företagspart assessment Almi are using these funds to provide 12-month bridge ner AB https://www.almi.se/vara- loans to Swedish SMEs who need financing as a result of (“Almi”) tjanster/tjanster/lan-och- the effects of COVID-19. ovrig-

finansiering/brygglan/ https://www.government.s e/articles/2020/03/almi- receives-sek-3-billion- capital-injection-to- increase-lending-to-small- and-medium-sized- enterprises/

The Swedish Subject to a Subject to Subject to a Increased credit framework https://www.sek.se/press/ Export Credit case-by- a case-by- case-by- arkiv/atgarder-att-oka- SECC’s credit framework has been increased from SEK Corporation case seks-utlaningskapacitet/ 125 billion to SEK 200 billion. SECC provides finance to

-62- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap (Sw. Svensk case assessme case export companies with turnover exceeding SEK 200 https://www.government.s Exportkredit) assessment nt assessment million and the customers of such companies. e/articles/2020/03/almi- receives-sek-3-billion- (“ ”) SECC makes individual risk assessments on a case-by- SECC capital-injection-to- case basis. increase-lending-to-small- and-medium-sized- enterprises/

The Swedish Subject to a Subject to Subject to a Increased credit ceiling https://www.ekn.se/en/ab Export Credit case-by- a case-by- case-by- out- EKN's ceiling for credit guarantees has been increased Guarantee case case case ekn/newsroom/archive/20 from SEK 450 billion to SEK 500 billion. EKN insures Agency assessment assessme assessment 20/press- export companies and banks against the risk of non- nt releases/increase-in- (Exportkreditn payment in export transactions. guarantee-limit/ ämnden) EKN makes individual risk assessments on a case-by-

(“EKN”) case basis. EKN See Yes Yes New guarantees https://www.ekn.se/en/ab summary out- In order to support Swedish exporting companies, EKN ekn/newsroom/archive/20 has decided to implement the following new guarantees: 20/press-releases/new- i) new guarantee with coverage of 80% of the and-extended- banks’ risk in working capital financing for SMEs. guarantees/ This guarantee is offered in relation to bank

loans to companies with turnover of less than SEK 5 billion and may be used by both exporting companies as well as their sub-suppliers; ii) new guarantee with coverage of 75% of the banks’ risk in working capital financing for large companies; and

-63- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap iii) new guarantee for sub-suppliers of large companies in order to ensure that such sub- suppliers get paid more quickly and securely. The Riksbank See See See Loans https://www.riksbank.se/e (Sweden’s summary summary summary n-gb/press-and- The Riksbank is offering loans to banks in the aggregate central bank) published/notices-and- amount of SEK 500 billion and at a zero-interest rate press-releases/press- against collateral. Such loans are conditional on them releases/2020/riksbank- being passed on to companies operating in Sweden. lends-up-to-sek-500- Eligibility: billion-to--safeguard- credit-supply/ The banks themselves decide which companies may receive the loans. https://www.riksbank.se/e n-gb/press-and- Normally, only banks that are “monetary policy published/notices-and- counterparties” of the Riksbank, i.e. banks that fulfil press-releases/press- certain criteria and have been approved by the Riksbank, releases/2020/measures- are eligible to borrow from the Riksbank (there are to-further-improve-credit- currently 22 monetary policy counterparties). However, supply-to-companies/ the Riksbank has decided to temporarily also give institutions that are under the supervision of the SFSA, but are not monetary policy counterparties, an opportunity to participate in the loan programme in order for the loans to reach non-financial corporations to a larger extent. The Riksbank N/A N/A N/A Extended purchase of securities https://www.riksbank.se/e n-gb/press-and- The Riksbank intends to buy government bonds, published/notices-and- municipal bonds and mortgage bonds for up to an press-releases/press- additional amount of SEK 300 billion during 2020 in order releases/2020/the- to facilitate credit supply and mitigate the downturn in the riksbank-to-increase- economy. asset-purchases-and- take-measures-to- facilitate-credit-supply/

-64- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Riksbank See See See Reduced interest rate for overnight loans https://www.riksbank.se/e summary summary summary n-gb/press-and- The Riksbank is reducing the lending rate for overnight published/notices-and- loans to banks from 0.75 to 0.20 percentage points above press-releases/press- the repo rate in order for banks to take out overnight loans releases/2020/the- at the Riksbank at lower interest rates than previously. riksbank-to-increase- Eligibility: asset-purchases-and- take-measures-to- Only banks that are “monetary policy counterparties” of facilitate-credit-supply/ the Riksbank.

The Riksbank See See See Borrowing of unlimited amounts against collateral https://www.riksbank.se/e summary summary summary n-gb/press-and- The Riksbank is offering banks the opportunity to, on a published/notices-and- weekly basis, borrow an unlimited amount of money press-releases/press- against collateral at three months’ maturity at an interest releases/2020/the- rate of 0.20 percentage points above the repo rate in riksbank-to-increase- order to enable the banks to borrow money from the asset-purchases-and- Riksbank at a low interest rate for a long period. take-measures-to- Eligibility: facilitate-credit-supply/ Only banks that are “monetary policy counterparties” of the Riksbank. The Riksbank See See See Increased flexibility regarding collateral https://www.riksbank.se/e summary summary summary n-gb/press-and- The Riksbank is increasing flexibility regarding the published/notices-and- collateral that banks may use when borrowing money from press-releases/press- the Riksbank. This will, among other things, give banks releases/2020/the- increased possibilities to use mortgage bonds as riksbank-to-increase- collateral. asset-purchases-and- Eligibility: take-measures-to- facilitate-credit-supply/ Only banks that are “monetary policy counterparties” of the Riksbank.

-65- SWEDEN13 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Riksbank N/A N/A N/A US dollar swap agreement https://www.riksbank.se/e n-gb/press-and- The Riksbank has entered into a published/notices-and- agreement with the in order to improve press-releases/press- access to US dollars for banks and their customers in a releases/2020/central- situation where the markets are functioning poorly. banks-have-entered-into- swap-agreements-in-us- dollars-with-the-federal- reserve/ The Swedish N/A N/A N/A Lowering of the countercyclical capital buffer https://www.fi.se/en/publis Financial hed/press- The SFSA, Sweden’s financial supervisory authority, has Supervisory releases/2020/fi-lowers- lowered the countercyclical capital buffer requirement for Authority the-countercyclical- banks from 2.5% to 0%. capital-buffer-to-zero/ (Finansinspekt The capital requirements of the Swedish banks will be ionen) approximately SEK 45 billion lower following the reduction (the “SFSA”) in the countercyclical buffer requirement, which, according to the SFSA, should create a capacity of approximately SEK 900 billion for new lending.

-66- SOUTHERN EUROPEAN REGION ITALY14 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Banks and No Yes No Moratorium Not eligible: Financial Eligibility: SMEs whose debt intermediarie exposures are classified s and other Italian-based small and medium-sized enterprises having as “non-performing” entities (i) less than 250 employees; and (ii) annual turnover not (esposizioni creditizie authorized to exceeding €50 million and/or a total annual balance sheet deteriorate) under the carry out not exceeding €43 million. provisions applicable to lending Measures: credit intermediaries. activity in Italy The following debt exposures of a SME can benefit from It is expected that similar the following financial support measures: measures will soon be implemented also for large i) short-term overdraft facilities and corporations. commercial bank lines existing as of 29 February 2020: the outstanding credit lines https://www.gazzettauffici (including the facility made available and not ale.it/atto/serie_generale/ drawn down) shall not be revoked (neither in full caricaArticolo?art.progres nor in part) until 30 September 2020; sivo=0&art.idArticolo=56& art.versione=1&art.codice ii) bullet loans with contractual maturity date Redazionale=20G00034& falling before 30 September 2020: such art.dataPubblicazioneGaz agreements can be extended, together with the zetta=2020-03- relevant ancillary agreements, automatically 17&art.idGruppo=4&art.id without any formality, until 30 September 2020, SottoArticolo1=10&art.idS under the same conditions originally agreed; ottoArticolo=1&art.flagTip iii) amortizing loans and other amortizing oArticolo=0#art facilities: the payment of instalments or lease payments due before 30 September 2020 shall be suspended until that date and the relevant repayment schedule shall be automatically extended without further formalities, and without new or additional charges to be borne by any parties; the requesting SME may also demand the sole suspension of principal payments (i.e. interest payments are not suspended). Procedure: The borrower shall send a written request to the relevant lender requesting the application of the measure submitting

14 Note: The information provided in this publication in respect of measures in Italy is as at 09 May 2020. -67- ITALY14 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap a self-declaration (dichiarazione sostitutiva di atto notorio) stating that a temporary liquidity shortage has occurred as a direct consequence of the spread of COVID-19. Guarantee N/A Yes N/A Guarantee in favour of banks and other authorized The operations addressed Fund for intermediaries which have granted the Moratorium16 by the support measures SMEs15 (the indicated in the section Eligibility: “SME Fund”) above shall be admitted, Banks, financial intermediaries or other entities authorized without any prior approval to carry out lending activity in Italy, which have granted the required and free of moratorium described above (each, an “Eligible Lender”). charge, to benefit from the guarantee provided under The access to the guarantee schemes is also allowed to a special section of the companies with up to 499 employees and to companies Fund. which, as of 31 January 2020, had exposures towards the relevant lender classified as "unlikely to pay" or "past due", Please consider that, until except for those which have exposures classified as "non- 31 December 2020, the performing" (sofferenze). The guarantee may also be guarantee of the Fund issued in favour of beneficiaries, in relation to which a issued in favour of SMEs business crisis settlement procedure (procedura di is, among other things: (i) composizione della crisi di impresa) is pending, provided granted for free; that they are in a situation of substantial regularity of (ii) extended to a payments and likeliness of the full repayment of the same. maximum amount per Measure: single borrower equal to €5 million; The SME Fund shall grant in favour of an Eligible Lender a guarantee covering up to 33% of the support measures (iii) eligible for debt taken in favour of the SMEs financed by that Eligible rescheduling operations; Lender17. (iv) automatically Procedure for the Guarantee: extended if a moratorium or a suspension related to the Covid-19 emergency has been granted with

15 Note: Being the guarantee fund set forth in Article 2, paragraph 100, letter a), of Law no. 662 of 23 December 1996, established to facilitate the access of SMEs to financial credit, by issuing a public guarantee in addition to (or as an alternative to) the securities created by the SMEs themselves to secure the obligations arising from loans granted by banks or, inter alios, financial intermediaries. 16 The operational framework of the SME Fund was previously regulated under Article 49 of the Law Decree no. 18 of 17 March 2020 (“Cura Italia Decree”), which is currently fully replaced by the Law Decree no. 23 of 8 April 2020 (the “Liquidity Decree”). 17 In particular: (a) as to the irrevocability of overdraft facilities and short term loans, the guarantee of the SME Fund covers up to 33% of the additional utilized amounts, as at 30 September 2020, compared to the amounts utilized as at the date of publication of the Decree; (b) as to the extension of bullet loans, the guarantee of the SME Fund covers up to 33% of the amount of the extended bullet loans; and (c) as to suspension of the payment instalments of amortizing loans and financial leases, the guarantee of the SME Fund covers up to 33% of the amount of the suspended instalment of the loans, or the suspended financial lease payments, due by 30 September 2020. -68- ITALY14 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The Eligible Lender shall send to the SME Fund an respect to the same loan; electronic request, indicating also the maximum and guaranteed amount requested. (v) granted to companies Enforcement of the Guarantee: which are only evaluated on their economic- The guarantee may be enforced by the Eligible Lender financial standing, without provided that, within the 18 month-period following the end considering the criterion of the support measure, enforcement proceedings have relating to the financial been commenced in relation to: performance. i) total or partial default on the obligations arising

from short-term overdraft facilities and loans granted as advance payments of receivables; Moreover, the guarantee can be granted to: (i) new ii) non-payment, or partial payment, of the amounts loans for companies due by way of principal and interest relating to affected by the epidemic, bullet loans; and which can benefit from a iii) non- payment of one or more of the suspended 100% coverage; (ii) loans’ instalments or financial lease payments beneficiaries showing pursuant amortizing loans and other amortizing revenues not exceeding facilities. €3,200,000, who can cumulate it with the Procedure for the enforcement of the Guarantee: “Confidi”; (iii) financing If the conditions provided in the paragraph above are met, already granted after 31 the Eligible Lender shall send to the SME Fund an January 2020; (iv) enforcement request, along with an estimate of the final operations in the tourism loss that the SME Fund will be required to bear. industry; (v) guarantees on loan portfolios; (vi) loan Payment by the SME Fund: portfolios for companies Once the validity of the request has been assessed, the with a rating not exceeding SME Fund shall pay within 90 days an amount equal to "BB"; (vii) ; (viii) 50% of the lower of the maximum guaranteed amount and guarantee consortia; and 33% of the estimated final loss to be borne by the SME (ix) microcredit. Fund; the remaining amount shall be paid to the Eligible https://www.gazzettauffici Lender provided that the relevant request is submitted to ale.it/atto/serie_generale/ the SME Fund within 180 days from the completion of the caricaArticolo?art.progres enforcement procedures. sivo=0&art.idArticolo=13& art.versione=1&art.codice Redazionale=20G00043& art.dataPubblicazioneGaz zetta=2020-04- 08&art.idGruppo=2&art.id

-69- ITALY14 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap SottoArticolo1=10&art.idS ottoArticolo=1&art.flagTip oArticolo=0#art Cassa N/A N/A N/A Guarantee in favour of banks and other authorized It is envisaged that the Depositi e intermediaries which have granted support measures Italian State may grant Prestiti S.p.A. to enterprises counter-guarantee up to (“CDP”) 80% of CDP’s exposures. : Eligibility The Italian State’s Banks and any other authorized intermediaries granting guarantee is first demand, financings in any form to certain Italian companies whose unconditional and turnover (fatturato) has decreased as a consequence of irrevocable. COVID-19 emergency and which do not have access to the A budget equal to €500 guarantee of the SME Fund (each, an “ ”). Eligible Lender million has been set to Measure: implement this measure.https://www.gaz As of 17 March 2020, CDP is authorized to grant liquidity to zettaufficiale.it/atto/serie_ companies that have suffered a significant loss in turnover generale/caricaArticolo?ar due to the Covid-19 emergencyby setting up funding t.progressivo=0&art.idArti plafonds, granting guarantees and/or first-loss portfolio colo=57&art.versione=1& guarantees in relation to exposures held by the banks art.codiceRedazionale=20 themselves. G00034&art.dataPubblica Procedure: zioneGazzetta=2020-03- 17&art.idGruppo=4&art.id Criteria, procedures and conditions upon which the CDP’s SottoArticolo1=10&art.idS Guarantee may be granted will be set forth in a decree of ottoArticolo=1&art.flagTip the Ministry of Economy and Finance, which as of 5 May oArticolo=0#art; 2020 is yet to be published. https://www.gazzettauffici Banks, with the support of CDP (through specific ale.it/atto/serie_generale/ instruments), can more easily grant credit to businesses caricaArticolo?art.progres who suffered a contraction in revenues. To this end, the sivo=0&art.idArticolo=1&a State grants CDP a guarantee of up to 80% of the exposure rt.versione=1&art.codiceR assumed. edazionale=20G00043&ar Moreover, a counter-guarantee of the Italian State within t.dataPubblicazioneGazze the plafond of €200 billion can be granted, until 31 tta=2020-04- December 2020, also in respect of guarantees issued by 08&art.idGruppo=1&art.id CDP covering portfolios of loans of any kind granted to SottoArticolo1=10&art.idS enterprises located in Italy. ottoArticolo=1&art.flagTip oArticolo=0#art. Issuance of N/A Yes N/A Temporary measures to support the liquidity To benefit from the first demand, Guarantee, the business

-70- ITALY14 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap explicit and Eligibility: must pay annual fees, irrevocable ranging from 25 to 200 Businesses with registered offices in Italy, other than banks guarantees to basis points depending on and other credit institutions, SMEs, self-employed workers enterprises the duration of the and professionals with VAT number (the “Beneficiaries”), and to SMEs financing and the size of provided that, as at 31 December 2019, they do not fall by SACE the business. within the category of distressed companies. S.p.A. Please note that on 21 (“SACE”). : Measure April 2020, the Italian

The guarantee is issued for loans granted to Beneficiaries Banks Associations (the after 9 April and before 31 December 2020 and is aimed at so-called ABI) issued a funding costs or investments in business activities in Italy. circular setting out the operational procedures for The total amount deployed for this measure is €200 billion, issuing this guarantee and of which at least €30 billion is intended to support SMEs. recalling the general Procedure: conditions adopted by SACE. Please find this The guarantee is issued subject to certain conditions, circular at the link below: including: (i) loans with maturity date falling no later than 6 years after the execution of the loan agreement; and (ii) for https://www.abi.it/DOC_In an amount not exceeding the higher of the following fo/Lettere%20circolari%20 amounts: (1) 25% of the annual turnover in 2019, as Covid/Imprese/UCR- resulting from the financial statements; or (2) twice the 000766%2021%20aprile employment costs borne in 2019. %202020.pdf. Such a guarantee covers (i) 90% of the amount of the loan, https://www.gazzettauffici for business with less than 5,000 employees in Italy and ale.it/atto/serie_generale/ with a turnover up to €1.5 billion; (ii) 80% of the amount of caricaArticolo?art.progres the loan, for businesses with a turnover from €1.5 billion to sivo=0&art.idArticolo=1&a €5 billion or with more than 5,000 employees in Italy; and rt.versione=1&art.codiceR (iii) 70% of the amount of the loan, for businesses with a edazionale=20G00043&ar turnover of more than €5 billion. t.dataPubblicazioneGazze tta=2020-04- 08&art.idGruppo=1&art.id SottoArticolo1=10&art.idS ottoArticolo=1&art.flagTip oArticolo=0#art Measures N/A No N/A Eligibility: Procedures and to support conditions upon which Banks and any other financial intermediaries ad other export and SACE's guarantee and the entities authorized to carry our lending activity in Italy (the internationali State's guarantee may be “Eligible Lender”) which grant financings in any form to sation granted will be set forth in businesses with registered offices in Italy. a decree of the Ministry of

-71- ITALY14 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap and Measure: Foreign Affairs and investments International Cooperation SACE is authorised to release guarantees in favour of any of foreign and the Ministry of of the Eligible Lender, in order to support the funding enterprises Economic Development, granted to businesses based in Italy with the aim to support which as of 05 May 2020 the internationalization process of the productive sector in is yet to be published. Italy and any export activity. https://www.gazzettauffici This additional guarantee activity shall be carried out by ale.it/atto/serie_generale/ SACE within the maximum total amount of Euro 200 billion. caricaArticolo?art.progres With reference to this activity, SACE is granted, on first sivo=0&art.idArticolo=2&a request, the State guarantee. rt.versione=1&art.codiceR edazionale=20G00043&ar t.dataPubblicazioneGazze tta=2020-04- 08&art.idGruppo=1&art.id SottoArticolo1=10&art.idS ottoArticolo=1&art.flagTip oArticolo=0#art

-72- PORTUGAL18 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Banks Yes Yes Yes Credit Line - Capitalizar 2018 – COVID-19 Guarantee: Mutual Guarantee Schemes: up Financing of companies describing negative impacts of Mutual to 80% of principal Covid-19 outbreak that justify the financing needs for up Guarantee amount. Schemes to €400 million. Counter-Guarantee of the Capped at €3 million per company. Fundo de Contragarantia Term: 4 years for operating funds and 1 to 3 years for Mútuo (Mutual treasury. Contraguarantee Fund): 100%.

https://www.spgm.pt/pt/ca talogo/linha-de-credito- covid-19/ The State N/A N/A N/A Export Credit - Increase of credit insurance lines Additional terms of this guaranteed by the State scheme TBC. In €100 million for the metallurgy, metalworking and https://dre.pt/home/- mould sector. /dre/130243054/details/m aximized In €100 million for construction abroad. In €50 million for short term export credit. Portugal 2020 No Yes Yes Adjustments in existing incentives schemes https://dre.pt/home/- and QREN /dre/130243054/details/m Extension of the term of certain repayment instalments aximized due in respect of reimbursable subsidies granted under QREN or Portugal 2020 operational programs. https://dre.pt/web/guest/p esquisa/- Negative impact of Covid-19 causing failure to comply /search/130602980/detail with actions/targets under Portugal 2020 may be deemed s/maximized as force majeure. Turismo de No Yes No Micro-Credit Line – Tourism https://dre.pt/home/- Portugal, I.P. /dre/130600838/details/m TPt. financing micro-enterprises upon evidence of the aximized (“TPt”) negative impact of Covid-19 outbreak for up to €60 million.

Banks No Yes Yes Announced Credit Lines for Certain Sectors Credit lines:

18 Note: The information provided in this publication in respect of measures in Portugal is as at 24 April 2020. -73- PORTUGAL18 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap • Up to €600 million for the catering sector; https://covid19estamoson. gov.pt/medidas-de-apoio- • Up to €200 million in the sector of travel agencies, emprego-empresas/ tourist entertainment and events organization (or similar);

• Up to €900 million in the sector of tourism companies;

• Up to €1,300 million (a possible increase to €4,500 million is currently being discussed) in the sector of textile, clothing, footwear, extractive industry and woodworking.

Maximum amount per company: €1.5 million (a possible increase to €2 million to small and mid-caps companies is currently being discussed).

Term: 4 years (a possible increase to 6 years is currently being discussed).

Guarantee: up to 90% of principal amount.

Spread charged by banks: capped at 1.5%.

State No Yes No Support measures for start-ups worth up to €25.3 million Programme announced programme have been adopted which include: on 21 April 2020 for start-ups i) “StartupRH Covid19”: financial support “through https://covid19estamoson. an incentive”. The value will apparently be gov.pt/wp- equivalent to minimum wage per employee (up content/uploads/2020/04/I to a maximum of 10 employees per start-up). niciativas-COVID-19-for- Startups-V9.pdf ii) “Start-up Voucher”: a three month extension of the start-up voucher scheme (€2,075 per entrepreneur). iii) “Vale Incubação — COVID19”: support for start- ups with less than five years of business activity, through the contracting of incubation services based on a non-refundable incentive of €1,500;

-74- PORTUGAL18 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap iv) “Mezzanine financing for start-ups”: a loan convertible into share capital after 12 months, applying a discount rate that allows start-ups to avoid the founders’ dilution. Average investment ticket between €50,000 and €100,000 per start- up. v) “Covid-19 — Portugal Ventures”: opening of a call for investment by Portugal Ventures, the Portuguese state venture capital company, with tickets starting at €50,000. Eligibility: Depending on the relevant measure.

SPAIN19 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Spanish No Yes Yes ICO to guarantee financing provided to banks Financial institutions shall Government be registered and coordinated financing/refinancing to cover liquidity needs of up to €100 supervised by the Bank of by ICO20 billion. Spain (or CNMV in its Three tranches have been released: (i) first tranche of €20 case): financing could not billion (50% of the total amounts is being granted to SMEs be provided by foreign funds. and self-employed and the remaining 50% to large companies); (ii) second tranche of €20 billion (100% to be Promissory note granted to SMEs and self-employed); and (iii) €24,500 programs registered on the Fixed-Income Market million (€10,000 millions is being granted to SMEs and of the Association of self-employed, €10,000 million to large companies, Financial Assets €4,000 million is for the benefit of issuers of commercial Intermediaries paper and €500 million is addressed to CERSA). (Asociación de Intermediarios de Activos The guarantee will cover partially the amount of the Financieros, or AIAF) and operations, as follows: the Alternative Fixed- Income Market (Mercado

19 Note: The information provided in this publication in respect of measures in Spain is as at 15 May 2020. 20 Note: The Ico (Instituto de Crédito Oficial) is a Spanish public bank. -75- SPAIN19 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap i. 80% of the new loans and refinancing of operations Alternativo de Renta Fija, requested by self-employed and SMEs. In the case or MARF), can benefit of large companies, the guarantee will cover 70% of from these guarantees. the new loans and 60% of the refinancing operation. More than 86 financing entities have entered into ii. 70% of the amount of the issue of commercial paper. the collaboration 80% if the facility is addressed to CERSA. agreement with the ICO and therefore, are entitled iii. Not applicable to the cancellation and early to grant financing backed repayment of existing debt. by ICO’s guarantee. Maximum amount: for transactions exceeding €1.5 Regulation: million, according to a EC Decision, the maximum https://www.boe.es/busca secured amount cannot exceed either (a) two times the r/act.php?id=BOE-A- total employment costs, including salaries and social 2020-3824 security contributions, or (b) 25% of total turnover. In duly https://www.boe.es/diario justified cases, financing may cover up to 12 months of _boe/txt.php?id=BOE-A- liquidity needs of the borrower 2020-4414 https://boe.es/buscar/act. Eligibility: php?id=BOE-A-2020- Companies and self-employed affected by COVID-19 but 4554 not involved in a late payment situation as of 31 ICO’s website: December 2019 or insolvency/bankruptcy as of 17 March https://www.ico.es/web/ic 2020. With respect to loans over €1.5 million, not be o/linea-avales under a “crisis situation” according to the EU commission’s regulation 651/2018).

ICO No Yes Yes Financing by ICO of up to €10 billion to be made To be implemented available, either directly to large companies or through through the ICO’s current Spanish banks for SMEs or self-employed. financing lines. Most common line: capped at €12.5 million per client / year and repayment periods between 1 to 20 years (with the of a 3- year grace period).

-76- SPAIN19 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Regulation: https://www.boe.es/busca r/act.php?id=BOE-A- 2020-3824 ICO’s website: https://www.ico.es/web/ic o/empresas-y- emprendedores ICO No Yes Yes Financing by ICO of up to €400 million to be made Capped at €500,000 per available to companies and self-employed operating in the client / year and tourism sector. repayment periods between 1 to 4 years (with the option of a 1 year grace). Regulation: https://www.boe.es/eli/es/r dl/2020/03/12/7 ICO’s website: https://www.ico.es/web/ic o/empresas-y- emprendedores The No Yes Yes Extraordinary line of insurance coverage of up to €2 billion Regulation: Internationali which will have a period of six months from 17 March https://www.boe.es/busca zation 2020. r/act.php?id=BOE-A- Reserve Fund Eligibility: 2020-3824 (Fondo de Companies that fulfil at least one of the following Reserva de los requirements: (i) having an international business, as Riesgos de la appearing in the most recent financial information Internacionaliz available, representing at least 33% of their turnover; or ación) (ii) carrying out export transactions on a regular basis. Comañia No Yes No Up to €60 million to be made available to SMEs and self- Regulation: española de employed workers by the Spanish Refinancing Company https://www.boe.es/busca refinanciamien CERSA through the “Small and Medium-Sized r/act.php?id=BOE-A- to (“CERSA”) Enterprises Support Program”. 2020- 4208&p=20200401&tn=1

-77- SPAIN19 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap

http://www.cersa- sme.es/garantias-y- avales/avales-para- pymes/. ICEX No Yes Yes ICEX España Exportación is authorized to return Regulation: irrecoverable expenditure to companies that have paid https://www.boe.es/busca such expenses to take part in international promotion r/act.php?id=BOE-A- activities when such activities have been cancelled, 2020- severely affected or postponed due to the COVID-19 4208&p=20200401&tn=1 crisis. Spanish No Yes Yes Deferred payment of principal or interest that should have Regulation: Banks been paid within the remaining months of 2020. https://www.boe.es/busca Applicable to companies and self-employed workers that r/act.php?id=BOE-A- have been granted with a loan by the public administration 2020- sector. 4208&p=20200401&tn=1

AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Government N/A N/A N/A Government Covid-19-Crisis Management Fund Currently, there is no Covid-19- official restriction on Currently the overall contribution to the fund shall amount Crisis granting financial to €38 billion. If necessary, such amount will be increased Management measures to companies by the government. Fund / which are structured via ABBAG Out of this sum portions of funds shall be made available so-called tax havens. to Austrian ministries for the implementation of measures On 22 April 2020 the in connection with the crisis by way of a range of schemes Austrian parliament has as described in the sections below (i.e. €15 billion for the resolved to prohibit the emergency fund, €9 billion for guarantees and liabilities, payment of state aid in connection with the Covid-19 crisis to

21 Note: The information provided in this publication in respect of measures in Austria is as at 11 May 2020. -78- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap €4 billion for the hardship fund and €10 billion for tax "companies based in tax deferrals). havens". Therefore, we assume that The allocation of funds is based on the decision of the corresponding laws might Minister of Finance in alignment with the Vice Chancellor be implemented in the and other guidelines issued by official decree. course of the next few In addition, an amendment to the so-called ABBAG-Law weeks. The scope of such authorizes the newly founded Covid-19 financing agency regime will depend on (“COFAG") as a subsidiary of Abbaugesellschaft des what such new law will Bundes (“ABBAG" – a governmental company) to set define as "located in a tax financial measures required by Austrian companies in haven." Potentially this order to maintain their financial liquidity or to bridge might relate to holding liquidity constraints. The government shall consistently structures that are routed provide COFAG with necessary portions of the fund (up through a so-called tax to €15 billion). haven. Eligibility: There is no legal entitlement to benefit from such measures, but it is expected for the funds to be widely available. The Minister of Finance needs to issue regulations which contain information on (i) the companies which are to be beneficiaries, (ii) structure and purpose of financial measures and (iii) amount and term of financial measures. Emergency Yes Yes Yes Emergency fund Not eligible for fund financing to be provided €15 billion shall be contributed to the emergency fund. (Notfallfonds) under new working The fund is primarily intended for companies in sectors capital loans: particularly affected by the crisis and which had to close down due to government regulations (this mainly includes Debt rescheduling, 1. Guarantees companies in the retail, tourism and leisure industries). investments or dividend payments from 16 March Covid-19 A combination of governmental guarantees for new loans 2020 until 16 March 2021, financing and grants (for the coverage of fixed costs) will be made bonuses to management agency available to ensure the liquidity of the companies. Grants (“COFAG”) board members of more do not have to be repaid. together with: than 50% of last year's 1. Guarantees and direct loans bonuses and share Österreichisch buybacks. e Hotel- und The Ministry of Finance published a guideline on 8 April Tourismus- 2020 which sets out the details of the legal regime for Not eligible for grants: bank (“ÖHT”) applying for loans and guarantees under the Emergency for companies Fund ("Guideline"). An additional guideline to be issued in

-79- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap in the tourism the near future will specify such details for grants under Companies which were and leisure the Emergency Fund. not economically stable industry before the crisis. The Guideline provides for the following main Austria requirements and rules: Companies which had Wirtschaftsser more than 250 employees i) In order to qualify for a loan or guarantee, the vice (“AWS”) as of 31 December 2019 applicant must be an enterprise with its seat or a for SMEs and which dismissed place of business in Austria; the enterprise must (except for employees instead of have significant operations in Austria; SMEs in the using the short-time work tourism and ii) Banks, insurance companies, investment firms, model after the outbreak leisure investment services companies and pension of the crisis. industry) funds are not eligible; Companies in the Österreichisch iii) The applicant must have been in a healthy financial and insurance e Kontrollbank financial condition as of 31 December 2019 (not sector (banks, credit (“OeKB”) for insolvent; equity capital to exceed accumulated institutions, insurance all other losses; not a recipient of other forms state aid; companies, investment companies book value based leverage of not more than 7.5; firms and other financial etc.); companies subject to 2. Grants supervisory regulations) iv) There is no eligibility criteria with respect to COFAG in are also excluded. company size in terms of revenues or work force cooperation or a specific legal form; Companies which pursue with AWS an aggressive v) The financial measures in the form of loans and and/or are based in a low- guarantees must only be used to maintain the tax country. Entities liquidity of the relevant company and to bridge majority-owned by local the liquidity shortfall brought about by COVID-19 authorities and other (mainly as result of insufficient revenues). This bodies governed by public includes, rent, leasing instalments, wages, taxes, law. services, payment for supplies which are required to maintain operations and insurance NOTE: The government is premiums; currently still in the process of drafting and vi) The applicant must demonstrate that it has used official guideline for grants reasonable measures to mitigate or avoid under the Emergency payment obligations for which it seeks a loan or Fund. guarantee under the program; it also must disclose other types of financial support received; COFAG, the state agency established to manage the €15 billion fund, must duly examine whether such alternative measures can

-80- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap be used by the company which applies for funding out of the Emergency Fund; Coverage: The maximum loan or guarantee amount is the lower of: i) uncovered payment obligations (typically the shortfall for the period between 1 March 2020 and 30 September 2020 but it can be a longer coverage period, depending on the type of operations of the company); ii) two times the total annual wages of the company; iii) 25% of the annual revenues; and iv) Maximum of €120 million (higher amounts are possible on a by-exception basis and subject to a special board approval of COFAG). Maximum term of the loan/guarantee is 6 years - can be extended in certain circumstances. Loans are subject to interest, not exceeding 1% per annum. The guarantee is to cover 90% of the loan amount; for SMEs the coverage can be up to 100%. Guarantee fees ranging from 0.25% to 2%, become payable, depending on the size of the company and term of the loan. Loans are in principle repayable on maturity but the company must, in the transaction documentation, undertake to repay the loan amount earlier if it is able to do so, including if it subsequently receives a grant that is to fund the same payments which the loan or guarantee were to fund. A company which has secured such loan/guarantee must only use the funds for the exact purpose applied for. In addition, the company must take all reasonable measures to protect jobs. The company must not make unduly high payments to members of its corporate bodies or employees. Bonus payments to members of the

-81- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap management board must not exceed 50% of the bonus amount paid in 2019. During the period between 16 March 2020 and 16 March 2021 the company must not pay out dividends or profits. The application must be made via the house bank of the company concerned (which will also provide the loan to be secured by the guarantee) and, depending on the size of the company, COFAG will use sub-agents that hold a banking license to administer the granting of the guarantee (AWS for SMEs and OeKB for companies with annual revenues in excess of EUR 50 million and a work force exceeding 250 people; the ÖHT will assume that role for companies active in the tourism sector).

2. Grants covering fixed costs Grants covering fixed costs shall be provided to companies which suffered a loss of turnover of at least 40% from 16 March 2020 until the end of the COVID-19 measures (but not later than 15 September 2020) caused by the crisis. The companies must be located in Austria and fixed costs must have arisen from operating activities in Austria. In order to qualify for a grant, such companies must take all reasonable measures to reduce fixed costs and maintain jobs. Eligible companies may not make bonus payments to members of the management board exceeding 50% of the bonus amount paid in 2019. The grant amount depends on the loss of turnover of the company; if it exceeds €2,000 the following reimbursement scheme becomes applicable: - 40 - 60% loss: 25% reimbursement - 60 - 80% loss: 50% reimbursement - 80 - 100% loss: 75% reimbursement The grant is limited to a maximum of €90 million per company and company group. The payments will be made in the following three tranches: (i) the first third can be applied for from 20 May -82- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap 2020, (ii) a further third can be applied for from 19 August 2020 and (iii) the remainder can be applied for from 19 November 2020. Companies which do not have seasonal goods, and which submit a balance list can already apply for the remaining two thirds starting from 19 August 2020. Applications can be made via FinanzOnline (an online platform of the tax authority). Applications must be approved by COFAG. Payments are expected to be made starting from the end of May/beginning of June. Applications must include a presentation of the fixed costs actually incurred and the actual loss of revenues. The information contained in the application must be examined and confirmed by a tax advisor/auditor before submission. Grant payments will only be made subject to a confirmation by a tax advisor or auditor. Austria No Yes No State guarantee Not eligible: Wirtschaftsse Guarantee in the amount of 80% in order to secure credit SMEs with an annual rvice (“AWS”) facilities of up to €2.5 million granted to the SME by its turnover of more than €50 house bank. The purpose of the guarantee is to enable million. financing of working capital or the deferral of existing SMEs which (i) are in credit lines. need of reorganisation Applications for the guarantee can be made via the house (i.e. equity ratio less than bank of the borrowing entity. 8% and fictitious debt amortisation period of The maximum term of the guarantee is 5 years. more than 15 years) In most cases a guarantee fee is not applicable, if and/or (ii) meet the permitted under EU state aid law. In case a guarantee fee statutory requirements for becomes applicable, it shall amount to at least 0.3% p.a. the opening of insolvency (risk-based) of the loan commitment. proceedings at the request of creditors. No collateral or personal liability of the SME owner is required for the guarantee. SMEs in the tourism and leisure industry. Please see the financial measures for such companies in the next section below. SMEs in the banking and insurance sector (except

-83- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap for eligible insurance agents and brokers). SMEs in the real estate sector (except for eligible real estate brokers and property management (Hausverwaltung)) Associations (Vereine) https://www.aws.at/aws- garantie/ueberbrueckungs garantie/ Österreichisc No Yes No State guarantee SMEs with mixed he Hotel- und business operations are Only granted to SMEs in the tourism and leisure industry. Tourismusba also eligible. nk (“ÖHT”) Guarantee in the amount of 80% in order to secure https://www.oeht.at/produ bridging loans (overdraft facilities) granted to the SME by kte/coronavirus- its house bank. massnahmenpaket-fuer- The maximum liability amount is €400,000. den-tourismus/ Applications for the guarantee can be made via the house bank of the borrowing entity. ÖHT takes over the costs for the one-off handling fee of 1% and the liability commission of 0.8%. Österreichisc Yes Yes Yes Credit line to be granted to export companies Not eligible: he Credit line to be granted to export companies which Export companies whose Kontrollbank generally have an Austrian added value of at least 25%. supplies and services are (“OeKB”) covered by the Security The credit line is based on a bill guarantee. The conditions Control Act and/or the of the assumption of liability are determined individually. War Material Regulation. Applications for the credit line can be made via the house Companies in the tourism bank of the borrowing entity. and leisure industry. Only economically healthy exporting companies are https://www.oekb.at/expor eligible. The balance sheet as of the last balance sheet t-services/sonder-krr- date (provisional form sufficient) shall serve as evidence. covid-hilfe.html The amount of the loan is limited to 10% (large

companies) or 15% (SMEs) of the company’s last year export turnover.

-84- AUSTRIA21 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap The individual loan is subject to a maximum upper limit of €60 million per company group. There is no lower limit. The financing is initially limited to two years. The government can assume the entity’s insolvency risk - depending on its credit rating between 50% and 70% of the credit line. The bill guarantee fee amounts to 0.3% p.a. of the amount drawn down if the house bank bears the insolvency risk, and 0.6% p.a. for the part for which the government bears the risk. The processing fee is payable once and amounts to 0.1% of the credit volume applied for (minimum €10 and maximum €720). The current applicable interest rate is 0.5%.

-85- SWITZERLAND22 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Swiss Federal Yes Yes Yes Emergency ordinance on granting of credits with joint https://www.admin.ch/gov/ Counsil and several federal guarantees en/start/documentation/m edia-releases.msg-id- Government guarantees for credit facilities between SMEs 78572.html and banks. A company may request : Eligibility additional financial Any Swiss, small and medium-sized, company to which support from the cantons the following criteria are applicable: (federal states), provided that the canton in which i) incorporated before 1 March 2020; the company is domiciled ii) not in bankruptcy, insolvency or liquidation; implemented financial support measures. iii) significantly affected by pandemic;

iv) no other federal submission pending or received; v) turnover of less than CHF 500 million; vi) UID number (for COVID-19-PLUS). Types of Loans: Loan of up to CHF 500,000 (COVID-19- CREDIT), loan from CHF 500,000 to CHF 20,000,000 (COVID-19-PLUS). Maturity: maximum term of 5 years (exceptionally extendable). Government Guarantee: For COVID-19 CREDIT 100%, for COVID-19-CREDIT-PLUS 85%. Interest Rate: COVID-19-CREDIT 0.0%; COVID-19- CREDIT-PLUS ca. 0.9% (0.5% for guaranteed amount, 2- 3% for non-guaranteed amount). Purpose: Securing current liquidity needs. Negative Covenants: No distribution of dividends, bonuses reimbursement of capital contributions, no granting of loans or refinancing, no repayment of group loans and no transfer of proceeds to direct or indirect affiliate of the borrower not situated in Switzerland. Effect on Balance Sheet: Assistance is not taken into account as borrowed capital until 31 March 2022.

22 Note: The information provided in this publication in respect of measures in Switzerland is as at 6 May 2020. -86- SWITZERLAND22 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Sanctions: Fine up to CHF 100,000 for wilfully false declarations or uses of the loan funds in contravention of the negative covenants. Total Amount: Swiss Federal Assembly approved under this programme: CHF 20 billion. Swiss Yes Yes Yes https://www.snb.ch/en/ifor SNB COVID-19 refinancing facility (CRF) National Bank /finmkt/operat/id/finmkt_cr (SNB) This measure is aimed to strengthen credit supply to the f Swiss economy by making additional liquidity available to the banking system. The CRF is unlimited in amount and drawdowns can be made at any time. The CRF operates in connection with the Federal Council's guarantees for COVID-19 credit facilities (see above). The facility allows banks to obtain liquidity in return for depositing the loans guaranteed by the Confederation as collateral with the SNB. In this way, the SNB enables the banks to expand their lending rapidly on a large scale, while at the same time having the necessary liquidity at their disposal. Eligibility: Any bank domiciled in Switzerland or Liechtenstein to which the following criteria are applicable: i. connected to the SIC system; ii. significant corporate client base in Switzerland; iii. issued COVID-19 credit facilities (as collateral). Maturity: The loan transaction has no fixed term. The bank has the option on a daily basis to increase or reduce the loan. Interest Rate: The interest rate corresponds to the SNB policy rate. It is calculated on a daily basis and according to the Actual/360 convention customary in the money market. Default Interest: If the bank defaults under the contractual agreement, default interest is payable to the SNB until the day when the payment is made. The default

-87- SWITZERLAND22 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap interest rate is calculated as the SNB policy rate plus twice the special-rate surcharge, but is at least 1%. Termination: The termination modalities are defined in the contracts. Accordingly, the SNB is entitled to terminate the loan subject to three months’ notice. In addition, the SNB has the right under the terms of the contract to terminate the loan at any time with immediate effect if there is a material change to the legal framework with respect to the guaranteed COVID-19 loans (see above). Swiss Federal Yes Yes Yes Sector Specific Financial Support (Aviation Industry) Council / Swiss Federal Government guarantees for credit facilities between Swiss Assembly airlines or airline-related companies and banks. The granting of such financial support is at the sole discretion of the federal government. Eligibility: Any Swiss airline, airport or other company providing services within the aviation industry (e.g. airport ground handling services, catering etc.) without which the operation of the airlines/airports cannot be maintained. Furthermore, the following criteria must be met: i. applicant's business activities must be in the public interest ii. exhausted financial resources of the applicant iii. stakeholder participation in financial support, (e.g. holding company or federal states) Government Guarantee: Between 85% and 100%. Interest Rate: Customary interest rate. Purpose: Securing current liquidity needs. Negative Covenants: No distribution of dividends, no transfer of proceeds to direct or indirect affiliate of the borrower not situated in Switzerland and no pledging of treasury shares. Further restrictions may be imposed as the credit facilities are only guaranteed on a case-by-case basis.

-88- SWITZERLAND22 Provider Investment SME Leveraged Scheme and high level summary Other comments and grade mid/ large related links cap Collateral: The federal government may require the shares of the applicant or of a Swiss operations hive-off vehicle as collateral.

This publication provides a high level summary of the targeted measures taken in the United Kingdom and other major European jurisdictions designed to support businesses and provide relief from the impact of COVID-19 as at 20 May 2020 unless otherwise stated, and does not purport to deal with every term or criteria of such measures. The information contained in this publication should not be construed as legal advice and is not to be relied upon.

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For further information, please contact:

Loans Malcolm Hitching Carol Van der Vorst Partner Partner [email protected] [email protected] +44 20 3847 9030 +44 20 3201 1515 Alexander Robb Pinar Celebi Partner Associate [email protected] [email protected] +44 20 3201 1572 +44 20 3201 1519

High Yield Michael Kazakevich Jane Rogers Partner, Co-head of global finance practice Partner [email protected] [email protected] +44 20 3201 1634 +44 20 3201 1643 Robert Haak Aditya Khanna Partner Partner [email protected] [email protected] +44 20 3201 1532 +44 20 3201 1545

Private Equity Will Rosen Elizabeth Todd Partner Partner [email protected] [email protected] +44 20 3201 1644 +44 20 3201 1578

Helen Croke Kiran Sharma Partner Partner [email protected] [email protected] +44 20 3847 9035 +44 20 3201 1647

John Newton Partner [email protected] +44 20 3201 1640

International law firm relations

-90- Rachel Kennedy European Law Firm Business Development Manager [email protected] +44 20 3201 1633 The invitation to contact is not a solicitation for legal work under the laws of any jurisdiction in which Ropes & Gray lawyers are not authorised to practice.

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