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Electronic Transmission Disclaimer ELECTRONIC TRANSMISSION DISCLAIMER IMPORTANT: You must read the following disclaimer before continuing. The disclaimer applies to the document (including the documents incorporated by reference therein) following this disclaimer (the ‘‘Document’’) and you are advised to read this disclaimer carefully before reading, accessing or making any other use of the Document. In accessing this electronic transmission and the Document, you agree to be bound by the following terms and conditions, including any modifications to them from time to time, each time you receive any information from Sif Holding N.V. (the ‘‘Company’’), ABN AMRO Bank N.V., HSBC Bank plc, ING Bank N.V. or Coo¨peratieve Rabobank U.A (together, the ‘‘Underwriters’’) as a result of such access. You acknowledge that the delivery of this electronic transmission and the Document is confidential and intended for you only and you agree you will not forward, reproduce or publish this electronic transmission or the Document to any other person. IF YOU ARE NOT THE INTENDED RECIPIENT OF THIS ELECTRONIC TRANSMISSION AND THE DOCUMENT, DO NOT DISTRIBUTE OR COPY THE INFORMATION CONTAINED IN THIS ELECTRONIC TRANSMISSION AND THE DOCUMENT AND DELETE AND DESTROY ALL COPIES OF THIS ELECTRONIC TRANSMISSION AND THE DOCUMENT. IF YOU ARE IN ANY DOUBT AS TO WHAT ACTION YOU SHOULD TAKE, YOU ARE RECOMMENDED TO SEEK YOUR OWN PERSONAL FINANCIAL ADVICE IMMEDIATELY FROM YOUR STOCKBROKER, BANK MANAGER, SOLICITOR, ACCOUNTANT, FUND MANAGER OR OTHER APPROPRIATELY AUTHORISED INDEPENDENT FINANCIAL ADVISER. NOTHING IN THIS ELECTRONIC TRANSMISSION AND THE DOCUMENT CONSTITUTES AN OFFER OF SECURITIES FOR SALE IN ANY JURISDICTION WHERE IT IS UNLAWFUL TO DO SO. THIS ELECTRONIC TRANSMISSION AND THE DOCUMENT MAY ONLY BE DISTRIBUTED IN ‘‘OFFSHORE TRANSACTIONS’’ AS DEFINED IN, AND IN RELIANCE ON, REGULATION S UNDER THE U.S. SECURITIES ACT OF 1933, AS AMENDED (THE ‘‘SECURITIES ACT’’) OR WITHIN THE UNITED STATES TO QUALIFIED INSTITUTIONAL BUYERS (‘‘QIBs’’) AS DEFINED IN RULE 144A UNDER THE SECURITIES ACT (‘‘RULE 144A’’) IN RELIANCE ON RULE 144A OR PURSUANT TO ANOTHER EXEMPTION FROM THE REGISTRATION REQUIREMENTS OF THE SECURITIES ACT. ANY FORWARDING, DISTRIBUTION OR REPRODUCTION OF THIS ELECTRONIC TRANSMISSION AND THE DOCUMENT IN WHOLE OR IN PART IS UNAUTHORISED. FAILURE TO COMPLY WITH THIS NOTICE MAY RESULT IN A VIOLATION OF THE SECURITIES ACT OR THE APPLICABLE LAWS OF OTHER JURISDICTIONS. THE SECURITIES REFERRED TO HEREIN HAVE NOT BEEN AND WILL NOT BE REGISTERED UNDER THE SECURITIES ACT OR WITH ANY SECURITIES REGULATORY AUTHORITY OF ANY STATE OF THE UNITED STATES OR OTHER JURISDICTION AND MAY NOT BE OFFERED, SOLD, PLEDGED OR OTHERWISE TRANSFERRED EXCEPT (1) TO A PERSON THAT THE HOLDER AND ANY PERSON ACTING ON ITS BEHALF REASONABLY BELIEVES TO BE A QIB AS DEFINED IN, AND IN RELIANCE ON, RULE 144A OR ANOTHER EXEMPTION FROM THE REGISTRATION REQUIREMENTS OF THE SECURITIES ACT, OR (2) IN AN OFFSHORE TRANSACTION IN ACCORDANCE WITH RULE 903 OR RULE 904 OF REGULATION S UNDER THE SECURITIES ACT, IN EACH CASE IN ACCORDANCE WITH ANY APPLICABLE SECURITIES LAWS OF ANY STATE OF THE UNITED STATES. This electronic transmission, the Document and the offer are only addressed to and directed at persons in member states of the European Economic Area (the ‘‘EEA’’) who are ‘‘qualified investors’’ within the meaning of Article 2(1)(e) of the Prospectus Directive (Directive 2003/71/EC and amendments thereto, including Directive 2010/73/EU to the extent implemented in the relevant member state of the EEA) (‘‘Qualified Investors’’ and other relevant persons as defined in the remainder of this paragraph. In addition, in the United Kingdom, this electronic transmission and the Document are being distributed only to, and are directed only at, Qualified Investors who are persons who have professional experience in matters relating to investments falling within Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, as amended (the ‘‘Order’’) or who are high net worth entities falling within Article 49(2)(a) to (d) of the Order, and other persons to whom they may otherwise lawfully be communicated (all such persons together being referred to as ‘‘relevant persons’’). This electronic transmission and the Document must not be acted on or relied on (i) in the United Kingdom, by persons who are not relevant persons, and (ii) in any member state of the EEA other than the United Kingdom, by persons who are not Qualified Investors. Any investment or investment activity to which this electronic transmission and the Document relates is available only to relevant persons in the United Kingdom and Qualified Investors in any member state of the EEA other than the United Kingdom, and will be engaged in only with such persons. Confirmation of Your Representation: This electronic transmission and the Document are delivered to you on the basis that you are deemed to have represented to the Company and the Underwriters that (i) you (a) are a QIB acquiring such securities for your own account or for the account of another QIB or (b) are acquiring such securities in ‘‘offshore transactions’’ as defined in, and in reliance on, Regulation S under the Securities Act; (ii) if you are in the United Kingdom, you are a relevant person and/or a relevant person who is acting on behalf of relevant persons in the United Kingdom and/or Qualified Investors to the extent you are acting on behalf of persons or entities in the United Kingdom or the EEA; (iii) if you are in any member state of the EEA other than the United Kingdom, you are a Qualified Investor and/or a Qualified Investor acting on behalf of Qualified Investors or relevant persons to the extent you are acting on behalf of persons or entities in the EEA; (iv) if you are outside the United States, the United Kingdom and the EEA you are an institutional investor that is eligible to receive this electronic transmission and the Document; (v) you have understood and agree to the terms set out herein; (vi) you consent to delivery of the Document and any amendments or supplements thereto by electronic transmission; (vii) you acknowledge that this electronic transmission and the Document is confidential and intended only for you and you will not transmit the Document (or any copy of it or part thereof) or disclose, whether orally or in writing, any of its contents to any other person; and (viii) you acknowledge that you will make your own assessment regarding any legal, taxation, financial or other economic considerations with respect to your decision to subscribe for or purchase any of the securities. Prospective purchasers that are QIBs are hereby notified that the seller of the securities will be relying on the exemption from the provisions of Section 5 of the Securities Act pursuant to Rule 144A. You are reminded that you have received this electronic transmission and the Document on the basis that you are a person into whose possession this electronic transmission and the Document may be lawfully delivered in accordance with the laws of the jurisdiction in which you are located and you may not nor are you authorized to deliver or disclose this electronic transmission or the Document, electronically or otherwise, to any other person. If you have received this electronic transmission and the Document contrary to any of the foregoing restrictions, you will be unable to purchase any of the securities defined therein. None of the Underwriters nor any of their respective affiliates accepts any responsibility whatsoever for the contents of this transmission or the Document or for any other statement made or purported to be made by it, or on its behalf, in connection with the Company or the securities or the offer referred to therein. The Underwriters and each of their respective affiliates, each accordingly disclaims all and any liability whether arising in tort, contract or otherwise which they might otherwise have in respect of such electronic transmission, document or any such statement. No representation or warranty express or implied, is made by the Underwriters or any of their respective affiliates as to the accuracy, completeness or sufficiency of the information set out in this electronic transmission or the Document. The Underwriters are acting exclusively for the Company and no one else in connection with the Offer and will not regard any other person (whether or not a recipient of this document) as a client in relation to the offer described in the Document and will not be responsible to anyone other than the Company for providing the protections afforded to their respective clients nor for giving advice in relation to the offer described in the Document or any transaction or arrangement referred to in the Document. The materials relating to the offering do not constitute, and may not be used in connection with, an offer or solicitation in any place where offers or solicitations are not permitted by law. If a jurisdiction requires that the offering be made by a licensed broker or dealer and the Underwriters or any affiliate of the Underwriters is a licensed broker or dealer in that jurisdiction, the offering shall be deemed to be made by the Initial Purchasers or such affiliate on behalf of the Company in such jurisdiction. The Document has been sent to you or accessed by you in an electronic form. You are reminded that documents transmitted via this medium may be altered or changed during the process of electronic transmission and consequently none of the Company, the Underwriters or their respective affiliates, directors, officers, employees, representatives and agents or any other person controlling the Company, the Underwriters or any of their respective affiliates accepts any liability or responsibility whatsoever, whether arising in tort, contract or otherwise which they might have in respect of this electronic transmission and the Document or the contents thereof in respect of any difference between the document distributed to you in electronic format and the hard copy version available to you on request from the Company or any of the Underwriters.
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