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REG - Sainsbury(J) PLC - Director/PDMR Shareholding

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RNS Number : 8731N  Sainsbury(J) PLC  06 June 2022

 

6 June 2022

 

J Sainsbury plc

(the 'Company')

 

Directors/PDMRs Shareholding

 

On 1 June 2022, the following Directors and Persons Discharging Managerial
Responsibility ('PDMRs') were granted awards under the J Sainsbury plc Long
Term Incentive Plan 2016 ('LTIP'). The awards were granted as nil-cost options
over ordinary shares of 28(4)/(7) pence each in the Company ('Shares') as set
out below:

 

Leaders' Share Award ('LSAs')

 

 PDMRs                     Core Award         Maximum Award Number of Shares

                           Number of Shares
 Simon Roberts (Director)  245,773            983,092
 Kevin O'Byrne (Director)  166,188            664,752
 Rhian Bartlett            107,468            429,872
 Graham Biggart            97,698             390,792
 Jim Brown                 28,864             115,456
 Tim Fallowfield           75,838             303,352
 Mark Given                101,118            404,472
 Philip Jordan             126,397            505,588
 Clodagh Moriarty          107,468            429,872
 Paula Nickolds            101,118            404,472
 Angie Risley              90,473             361,892

 

(1)  The LSAs are subject to performance conditions measured over three
financial years. The LSAs will normally vest after three years, subject to the
achievement of the performance conditions.

(2)  The LSAs for Simon Roberts and Kevin O'Byrne will be subject to an
additional retention period, meaning that any vested LSAs will be released
five years after the date of grant.

(3)  Should maximum vesting be achieved, participants would receive four
times the number of Shares of their core award.

(4)  Dividend equivalents may be delivered (either in cash or Shares) in
respect of dividends accrued on any Shares which subsequently vest.

(5)  The share price to determine the number of Shares awarded was based on
the five dealing day average Share price prior to the grant date.

(6)  For CRDV banking regulatory purposes, the number of shares awarded to
Jim Brown will not be increased to reflect any dividends accrued during the
award's vesting period. However, a one time fair value adjustment to his award
was made at the point of grant based on a forecasted dividend yield over the
vesting period to reflect the absence of dividend equivalents accrued during
the vesting period.

 

The PDMRs were also granted Shares under the LTIP as set out below:

 

Bonus Share Awards ('BSAs')

 

 PDMRs                     Number of Shares
 Simon Roberts (Director)  363,601
 Kevin O'Byrne (Director)  223,511
 Rhian Bartlett            153,334
 Graham Biggart            63,465
 Jim Brown                 184,741
 Tim Fallowfield           112,353
 Mark Given                147,438
 Philip Jordan             188,884
 Clodagh Moriarty          158,442
 Paula Nickolds            109,060
 Angie Risley              135,200

 

(1)  The BSAs were granted based on performance during the 2021/22 financial
year.

(2)  The BSAs will vest following a two-year retention period, except for Jim
Brown's award, which will vest after a three-year retention period.

(3)  Dividend equivalents may be delivered (either in cash or Shares) in
respect of dividends accrued on any Shares which subsequently vest.

(4)  The share price to determine the number of Shares awarded was based on
the five dealing days average Share price prior to the grant date.

(5)  For CRDV banking regulatory purposes, the number of shares awarded to
Jim Brown will not be increased to reflect any dividends accrued during the
award's retention period. However, a one time fair value adjustment to his
award was made at the point of grant based on a forecasted dividend yield over
the retention period to reflect the absence of dividend equivalents accrued
during the retention period.

 

 

The Notification of Dealing Forms for each PDMR can be found below.

 

This notification is made in accordance with the requirements of the UK Market
Abuse Regulation.

 

For further information please contact:

 

Enquiries

 

Investor Relations: James Collins +44 (0) 20 7695 0080

 

Media: Rebecca Reilly +44 (0) 20 7695 7295

 

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Simon Roberts
 2   Reason for the notification

 a)  Position/status                                              Chief Executive Officer
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 983,092
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 363,601
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Kevin O'Byrne
 2   Reason for the notification

 a)  Position/status                                              Chief Financial Officer
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 664,752
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 223,511
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Rhian Bartlett
 2   Reason for the notification

 a)  Position/status                                              Food Commercial Director
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 429,872
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 153,334
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Graham Biggart
 2   Reason for the notification

 a)  Position/status                                              Chief Transformation Officer
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 390,792
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 63,465
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Jim Brown
 2   Reason for the notification

 a)  Position/status                                              Chief Executive Officer, Sainsbury's Bank
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 115,456
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 184,741
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Tim Fallowfield
 2   Reason for the notification

 a)  Position/status                                              Company Secretary and Corporate Services Director
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 303,352
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 112,353

 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Mark Given
 2   Reason for the notification

 a)  Position/status                                              Chief Marketing Officer
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 404,472

 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 147,438
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Phil Jordan
 2   Reason for the notification

 a)  Position/status                                              Chief Information Officer
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 505,588
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 188,884
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Clodagh Moriarty
 2   Reason for the notification

 a)  Position/status                                              Retail and Digital Director
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 429,872
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 158,442
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Paula Nickolds
 2   Reason for the notification

 a)  Position/status                                              General Merchandise & Clothing Commercial Director
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 404,472
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 109,060
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

Notification of dealing form

 1   Details of the person discharging managerial responsibilities / person closely
     associated

 a)  Name                                                         Angie Risley
 2   Reason for the notification

 a)  Position/status                                              Group HR Director
 b)  Initial notification /Amendment                              Initial notification
 3   Details of the issuer, emission allowance market participant, auction
     platform, auctioneer or auction monitor

 a)  Name                                                         J Sainsbury plc

 b)  LEI                                                          213800VGZAAJIKJ9Y484

 4   Details of the transaction(s): section to be repeated for (i) each type of
     instrument; (ii) each type of transaction; (iii) each date; and (iv) each
     place where transactions have been conducted

     Transaction 1
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Awards of nil-cost options granted under the J Sainsbury plc Long Term
                                                                  Incentive Plan 2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 361,892
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue
     Transaction 2
 a)  Description of the financial instrument, type of instrument  Ordinary shares of 28(4)/(7) pence each

     Identification code                                          ISIN: GB00B019KW72
 b)  Nature of the transaction                                    Award of Shares granted under the J Sainsbury plc Long Term Incentive Plan
                                                                  2016
 c)  Price(s) and volume(s)                                       Price(s)                                Volume(s)
     £nil                                                                                                 135,200
 d)  Aggregated information                                       Aggregated price                        Aggregated volume

     N/A                                                                                                  N/A
 e)  Date of the transaction                                      1 June 2022

 f)  Place of the transaction                                     Outside a trading venue

 

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