20 March 2024
Keller Group plc
Director/PDMR Shareholding
Keller Group plc (the "Company") announces that on 19 March 2024 it was
notified of the following transactions in the Company's Ordinary shares of 10
pence each (“Shares”) undertaken by Executive Directors and other Persons
Discharging Managerial Responsibilities ("PDMRs").
Long Term Incentive Plan (“LTIP”) vesting
As a result of the vesting of Shares under the Company’s LTIP, on 18 March
2024 the following Executive Directors and PDMR acquired Shares for nil
consideration:
LTIP Deferred Bonus Awards granted on 15 March 2022 – in respect of the year
ended 31 December 2021
Director / PDMR Number of Shares awarded Number of Shares released* Number of Shares sold to cover tax liability Net number of Shares acquired
David Burke 16,206 17,956 9,487 8,469
Eric Drooff 5,647 6,256 4,538 1,718
Michael Speakman 24,684 27,349 12,900 14,449
*Includes dividend equivalents added as Shares since the date of grant.
The Shares were sold at 1,006 pence each to cover tax liabilities (which
includes employee social security charges) and the transaction took place as
an off-market transaction using Shares in the Company’s employee benefit
trust (“EBT”). The sale price was agreed with the trustees of the EBT as
representative of the Shares’ prevailing market value (being based on the
prevailing mid-market closing price of a Share as shown on the London Stock
Exchange at the time of the transfer).
LTIP Performance Share Awards granted on 15 March 2021 – for the period
2021/23
Director / PDMR Number of Shares awarded Number of Shares released* Number of Shares sold to cover tax liability Net number of Shares acquired
David Burke 56,273 62,126 29,302 32,824
Eric Drooff 28,879 31,881 8,751 23,130
Michael Speakman 102,858 113,557 53,560 59,997
Kerry Porritt 20,709 22,862 10,783 12,079
John Raine 20,409 22,530 7,586 14,944
Katrina Roche 22,059 24,352 11,486 12,866
Peter Wyton 28,012 30,924** N/A N/A
*Includes dividend equivalents added as Shares since the date of grant.
**Peter Wyton received an equivalent cash payment in place of Shares on
vesting of the award.
The 2021 LTIP Performance Share Awards were measured over a three-year
performance period which began on 1 January 2021 and ended on 31 December
2023, and were subject to four performance conditions (listed below). The
performance conditions were partially met and the awards vested as follows:
Measures Vesting schedule and outcome 3
% of award that will vest O V
u e
t s
c t
o i
m n
e g
%
0% 25% 100%
25% weight Less than 245p 245p 310p 338.8p 25.0
Cumulative EPS over three years 1
25% weight Less than median Median Upper quartile or higher Upper quartile 25.0
Keller’s TSR ranking relative to the constituents of the FTSE 250 comparator index 2
25% weight Below 12% 12% 18% 17.2% 22.5
ROCE over three years 3
25% weight Less than 5.2% 5.2% 6.2% 6.1% 23.1
Operating profit margin
Total vesting 95.6
1 EPS and ROCE are before non-underlying items on an IFRS 16 basis.
2 Excluding investment trusts and financial services.
3 Average of the three-year ROCE for 2021–23.
The Shares were sold at 1,006 pence each to cover tax liabilities (which
includes employee social security charges) and the transaction took place as
an off-market transaction using Shares in the EBT. The sale price was agreed
with the trustees of the EBT as representative of the Shares’ prevailing
market value (being based on the prevailing mid-market closing price of a
Share as shown on the London Stock Exchange at the time of the transfer).
LTIP Conditional Share Awards granted on 15 March 2021
PDMR Number of Shares awarded Number of Shares released* Number of Shares sold to cover tax liability Net number of Shares acquired
Deepak Raj 5,419 6,254 0 6,254
Craig Scott 2,147 2,478** N/A N/A
*Includes dividend equivalents added as Shares since the date of grant.
**Craig Scott received an equivalent cash payment in place of Shares on
vesting of the award.
The Shares were sold at 999.3 pence each to cover tax liabilities (which
includes employee social security charges) and the transaction took place in
the London Stock Exchange.
The Notification of Dealing Form for each Executive Director and PDMR can be
found below.
LTIP grant
On 18 March 2024 the Company granted the following awards under the LTIP:
* Deferred Bonus Awards totalling 44,796 Shares; and
* Performance Share Awards totalling 300,908 Shares.
The grant to the Executive Directors and PDMRs listed in the tables below was
approved by the Remuneration Committee under the terms of the LTIP.
LTIP Deferred Bonus Awards – in respect of the year ended 31 December 2023
Executive Directors are subject to a deferral of 25% of any annual bonus
payment into Shares for a period of two years. Other PDMRs are subject to a
deferral into Shares of any annual bonus payment in excess of 100% of salary,
also for a period of two years. The Deferred Bonus Awards retain eligibility
for dividend equivalents from the date of grant until the vesting date. Malus
and clawback apply.
Director / PDMR No. of Ordinary Shares awarded 1/3 Total Deferred Bonus Awards outstanding 3
David Burke 11,912 12,729
Eric Drooff 14,740 14,740
Michael Speakman 18,144 19,389
LTIP Performance Share Awards – for the period 2024/26
Director / PDMR No. of Ordinary Shares awarded 1/2/3 Total Performance Share Awards outstanding 3
David Burke 52,765 186,118
Kerry Porritt 19,426 68,521
John Raine 20,410 70,063
Deepak Raj 22,478 22,478
Katrina Roche 20,684 72,959
Craig Scott 14,426 14,426
Michael Speakman 96,441 340,174
Peter Wyton 54,278 122,218
The measures selected by the Remuneration Committee together with the
associated targets are shown on the table below. The weightings are all set at
25% in order to provide balance between measures and materiality to each of
them individually.
Measures Vesting schedule
%
of
awa
rd
tha
t
wil
l
ves
t
0% 25% 100%
25% weight Below 330p 330p 400p
Cumulative EPS over three years 1
25% weight Below median Median Upper quartile
Keller’s relative TSR performance vs FTSE 250 2 Index over three years
25% weight Below 12% 12% 18%
Average ROCE over three years
25% weight Below 5.5% 5.5% 6.5%
Operating profit margin in year three
1 EPS and ROCE are before non-underlying items on an IFRS 16 basis.
2 Excluding investment trusts and financial services.
The Performance Share Awards performance conditions are measured over a three
year period ending on 31 December 2026, except for the OPM which is measured
in year three. The Performance Share Awards performance conditions are
expected to vest in March 2027. Executive Directors are subject to a further
two-year holding period and a post-employment shareholding requirement. Malus
and clawback apply.
The price used to calculate the maximum number of Ordinary Shares under the
Deferred Share Awards and Performance Share Awards was 1,004p, being the
average closing price on 13, 14 and 15 March 2024 of the Company's shares on
the main market of the London Stock Exchange.
2 The amounts shown above represent the maximum possible number of Shares that
may be granted to the above named participants under the 2024 Performance
Share Awards.
3 The awards above exclude notional dividends.
Enquiries:
Keller Group plc
Silvana Glibota-Vigo, Group Head of Secretariat
Tel: 020 7616 7575
LEI number: 549300QO4MBL43UHSN10
Classification: 2.2 Inside information
Notes to editors:
Keller is the world's largest geotechnical specialist contractor providing a
wide portfolio of advanced foundation and ground improvement techniques used
across the entire construction sector. With around 9,500 staff and operations
across five continents, Keller tackles an unrivalled 5,500 projects every
year, generating annual revenue of c.£3bn.
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name David Burke
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
Chief Financial Officer N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 62,126
Nil 17,956
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Nil 80,082
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
£10.06 29,302
£10.06 9,487
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
£10.06 38,789
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction London Stock Exchange
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Eric Drooff
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
President, North America N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 31,881
Nil 6,256
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Nil 38,137
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
£10.06 8,751
£10.06 4,538
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
£10.06 13,289
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction London Stock Exchange
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Michael Speakman
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
Chief Executive Officer N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 113,557
Nil 27,349
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Nil 140,906
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
£10.06 53,560
£10.06 12,900
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
£10.06 66,460
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction London Stock Exchange
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Kerry Porritt
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
Group Company Secretary and Legal Advisor N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 22,862
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
£10.06 10,783
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction London Stock Exchange
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name John Raine
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
Group HSEQ Director N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 22,530
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
£10.06 7,586
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction London Stock Exchange
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Katrina Roche
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
Chief Information Officer N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 24,352
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
£10.06 11,486
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction London Stock Exchange
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Peter Wyton
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
President, EME N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Conditional right to receive a cash payment determined by reference to the value of ordinary shares of 10p each
b) Indicate nature of the transaction Acquisition Disposal Subscription Other - receipt of a cash payment determined by reference to the value of a specified number of ordinary shares of 10p each
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
N/A –
A
cash
payme
nt of
£311,
095.4
4
deter
mined
by
refer
ence
to
30,92
4
share
s at
a
price
of
£10.0
6
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not
appli
cable
-
singl
e
trans
actio
n
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Deepak Raj
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
President, APAC N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Ordinary shares of 10p each
GB0004866223
b) Indicate nature of the transaction Acquisition Disposal Subscription Other
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
Nil 6,254
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not applicable - single transaction Not applicable - single transaction
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
1 Details of persons discharging managerial responsibility (“PDMR”) / person closely associated (“PCA”)
a) Name Craig Scott
2 Reason for the notification
a) Position / status PDMR (Provide job title) PCA (Provide name of job title of relevant PDMR)
Group HR Director N/A
b) Initial notification/Amendment Initial notification
3 Details of the issuer
a) Name Keller Group plc
b) LEI and classification 549300QO4MBL43UHSN10 2.2 Inside information
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
a) Description of the financial instrument Identification code Conditional right to receive a cash payment determined by reference to the value of ordinary shares of 10p each
b) Indicate nature of the transaction Acquisition Disposal Subscription Other - receipt of a cash payment determined by reference to the value of a specified number of ordinary shares of 10p each
ii) Is the transaction linked to an exercise of a share award? Yes No
X
iii) Was the transaction conducted pursuant to an investment programme or a trading plan? Yes No If yes, provide date at which investment programme or trading plan was entered into:
X
c) Price(s) and volume(s) Price(s) (Please state currency) Volume(s)
N/A –
A
cash
payme
nt of
£24,7
63.82
deter
mined
by
refer
ence
to
2,478
share
s at
a
price
of
£9.99
d) Aggregated information Aggregated price(s) Aggregated volume(s)
(Please state currency)
Not
appli
cable
-
singl
e
trans
actio
n
e) Date of the transaction Date: 18.03.2024 Time zone: GMT
f) Place of the transaction Outside trading venue
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