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Montanaro European Smaller Companies TrustAnnouncement

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RNS Number : 4487N  Montanaro European Smaller C.TstPLC  19 June 2025

 

 

Montanaro European Smaller Companies Trust PLC

213800CWSC5B8BG3RS21

 

Final Results

2025 Annual Results and notice of annual general meeting

 

Montanaro European Smaller Companies Trust plc announces its annual results
for the year ended 31 March 2025 and the publication of its annual report and
accounts for the same period, which includes the notice of its 2025 annual
general meeting.

 

HIGHLIGHTS

for the year ended 31 March 2025

Performance

 Total return %                           1 year  3 year  5 year  10 year  MAM*
 Net Asset Value ("NAV") per share(( 1))  (1.1%)  (3.9%)  74.7%   208.3%   473.0%
 Share Price((1))                         5.1%    (9.6%)  74.6%   215.5%   475.3%
 Benchmark**((2))                         1.3%    3.8%    70.2%   120.7%   306.2%

 

 Capital return %     1 year  3 year   5 year  10 year  MAM*
 NAV per share(( 1))  (1.9%)  (5.5%)   69.3%   183.5%   373.9%
 Share Price((1))     4.2%    (11.6%)  68.8%   188.3%   365.2%
 Benchmark**((2))     (1.1%)  (3.3%)   53.8%   82.0%    184.4%

 

Sources: Morningstar Direct, Association of Investment Companies ("AIC"),
Montanaro Asset Management ("MAM").

 

 As at 31 March                    2025     2024     % Change
 Ordinary share price              148.5p   142.5p   4.2
 NAV per Ordinary share            162.0p   165.1p   (1.9)
 Discount to NAV((1))              (8.3%)   (13.7%)
 Net assets**(£'000s)              291,508  312,720  (6.8)
 Market capitalisation**(£'000s)   267,188  269,934  (1.0)
 Net gearing employed((1))         2.1%     2.9%

 For the year ended 31 March        2025   2024    % Change
 Revenue return per Ordinary share  1.50p  1.42p   5.6
 Dividends per Ordinary share((1))  1.26p  1.125p  12.0
 Ongoing charges((1))               1.0%   1.0%
 Portfolio turnover((1))            14%    16%

 

* From 5 September 2006, when MAM was appointed as Investment Manager.

** Details provided in the Glossary on pages 70 and 71 of the Annual Report.

(1) Refer to Alternative Performance Measures on page 68 of the Annual Report.

(2) From 5 September 2006, the benchmark was the MSCI Europe SmallCap Index.
The benchmark was changed on 1 June 2009 to the MSCI Europe ex-UK SmallCap
Index (in Sterling terms).

 

Chairman's Statement

For the year ended 31 March 2025

 

Results

The year saw a continuation of the trend seen since the end of 2021, namely a
significant style headwind partially offset by the positive influence of stock
selection. Montanaro Asset Management ("Montanaro", "MAM" or the "Manager")
seeks to invest exclusively in high quality growing companies based on the
belief that over the long term, a company's ability to compound earnings and
cash flows is the primary driver of investment returns. However, in the short
term, factors such as investor flows, political developments and macroeconomic
fluctuations can temporarily overshadow underlying fundamentals.

 

The Net Asset Value ("NAV") declined by 1.9% to 162.0p per share during the
financial year ended 31 March 2025. In comparison, the benchmark (the MSCI
Europe ex-UK Small Cap Index) rose by 1.3% (in Sterling terms). The share
price (with dividends reinvested) gained 5.1% as the discount to NAV tightened
from -13.7% to -8.3%.

 

Whilst shorter term performance has been somewhat disappointing, Montanaro
have a long-term investment approach. Over 5 and

10 years, your Company has delivered NAV total returns of 74.7% and 208.3%,
outperforming the benchmark by 4.5% and 87.6%

respectively. Since Montanaro were appointed in September 2006, the NAV total
return has been 473.0%, 166.8% ahead of the

benchmark (equivalent to an average annual outperformance of 2.0%).

 

Earnings and Dividends

Revenue earnings per share rose to 1.50p in the year (2024: 1.42p).

 

A first interim dividend of 0.3p per share was paid on 22 January 2025. A
second interim dividend of 0.96p will be paid on 7 August 2025 to shareholders
on the register on 27 June 2025. This will bring total dividends for the year
to 1.26p per share, an increase of 12.0%.

 

The Company holds substantial reserves available for distribution, which gives
the Board the ability to smooth any short-term income volatility.

 

Strategic Initiatives

On 27 March 2025, the Board announced three strategic initiatives designed to
strengthen the investment proposition and deliver value for all shareholders:

 

1. Regular tender offers targeted at improving liquidity;

2. An active share buyback policy aimed at reducing the volatility of the
discount; and

3. A reduction in the management fee.

 

Further details of each of the initiatives are set out in the Business Model
and Strategy Section of the Annual Report.

 

Introduction of Regular Tenders

Conscious of shareholders' desire to improve liquidity, the Board has proposed
a new initiative to offer shareholders the opportunity to tender shares to the
Company twice a year, around the Interim and Final Results announcements.
Shares will be bought back at a 5% discount to NAV, reflecting the higher
transaction costs associated with smaller companies. Each tender will be
capped at 5% of shares in issue to protect existing shareholders and manage
portfolio liquidity. Shareholder approval for the first tender offer was
granted on 15 May 2025 and the first tender offer is expected to take place in
Autumn 2025.

 

Share Buybacks and Treasury Shares

During the year, the Company bought back 9,502,921 Ordinary Shares. As a
result, the Company held 9,502,921 Ordinary shares in Treasury as at 31 March
2025.

 

Buying back Ordinary shares at a discount is accretive to the NAV per share.
As such, the buybacks conducted during the year contributed an uplift of 0.45%
to the NAV per share.

 

Since the end of the year, the Company continued to buy back Ordinary shares
and substantially utilised the authority granted at the 2024 AGM. Accordingly,
the Board secured additional authority at the General Meeting convened in May
2025 to cover the period until the next AGM.

 

Our stated policies on share buybacks and share issuances are set out on pages
18 and 32 of the Annual Reprt. The Board is seeking to renew the Company's
share buyback and issuance authorities at the forthcoming AGM.

 

Management Fee

The Manager has agreed to a reduction in management fees from 0.90% per annum
to 0.825% per annum of the market capitalisation of the Company up to £500
million and from 0.75% to 0.70% per annum between £500 million and £750
million. Above £750 million, the fee remains unchanged at 0.65% per annum.

 

This reduction in fees took effect on 1 April 2025, and is the second fee
reduction which we have negotiated in the past four years.

 

As a demonstration of their confidence in the Trust, Montanaro has continued
to invest in the Company and now hold 8.0% of the Company's shares.

 

Environmental, Social and Corporate Governance ("ESG")

Montanaro believe that strong ESG practices are closely linked to a company's
ability to create long-term value for its shareholders. ESG considerations are
therefore embedded within their definition of "Quality" and have been a
fundamental part of their investment process for many years.

 

The ESG Report can be found on pages 10 and 11 of the Annual Report. It
outlines developments in Montanaro's approach to ESG, their ongoing commitment
and their engagement with investee companies.

 

 

 

 

Borrowings

The Board, in consultation with the Manager regularly reviews the gearing
strategy of the Company and approves any gearing facility. Gearing amplifies
the returns from underlying profits or losses generated by the investment
portfolio.

 

The Board has set a maximum limit on borrowing (net of cash) of 30% of
shareholders' funds at the time of borrowing. At the end of the financial
year, the Company had borrowings (net of cash) of 2.1% compared to 2.9% at the
beginning of the year.

 

Board Succession

As part of our normal succession planning process, I intend to retire as
Chairman and from the Board on 31 December 2025. This will be after we have
conducted our first bi-annual tender. We are very fortunate that Gordon Neilly
has agreed to step into the role of Chairman and with his extensive experience
of the investment trust sector there can be no better person to lead our Trust
in the future.

 

Communication with Shareholders

Over the past few years, the composition of our shareholder base has changed
significantly with an increasing number of individual investors coming onto
the register via investment platforms. We are keen to encourage an open
dialogue to keep all shareholders up to date with key developments. Our
website - www.montanaro.co.uk/trust/mesct
(http://www.montanaro.co.uk/trust/mesct) - is continually updated with
factsheets, reports, presentations, webinar recordings and commentaries as
well as more details about the Manager, investment philosophy and process. We
encourage shareholders to visit regularly and welcome any feedback and
suggestions.

 

We would also encourage shareholders to sign up to receive regular updates by
email.

 

Dividend Policy

Following discussion on the timing of dividend payments to shareholders with
the Company's broker Cavendish, the Board has decided to move to a cycle of
paying two interim dividends per annum in or around January and August. This
represents a change from the previous dividend payment cycle of paying an
interim and final dividend. As the Company will no longer put a final dividend
to shareholders for approval, in accordance with recommended corporate
governance best practice, the new dividend policy will be put to shareholders
approval at the upcoming Annual General Meeting. The new dividend policy can
be found on page 18 of the Annual Report.

 

Annual General Meeting

The AGM will be held at the offices of Montanaro Asset Management, 53
Threadneedle Street, London EC2R 8AR, on 4 September 2025 at 11.00 a.m.
Shareholders are encouraged to attend the Meeting where there will be an
opportunity to meet and ask questions of the Board and the Manager.

 

Detailed instructions on how to vote on the AGM resolutions are provided on
pages 79 to 81 of the Annual Report. We encourage all shareholders to review
this guidance and ensure their votes are submitted.

 

Additionally, the AIC has prepared information on how to vote across the most
common investment platforms, this guidance is available at -
www.theaic.co.uk/how-to-vote-your-shares
(http://www.theaic.co.uk/how-to-vote-your-shares) .

 

Outlook

As 2024 drew to a close, the prevailing investment consensus - that US
mega-caps were the only place to be - reached a crescendo following the
election of Donald Trump as President. However, events since then have cast
doubt over this view. The tariffs announced on "Liberation Day" shocked the
world. The United States has made it increasingly clear that they now view its
relationships with the rest of the world - including Europe - as adversarial
or, at best, purely transactional.

 

Yet with change comes opportunity. Investor sentiment has shifted towards
European equities this year as they have seen improved performance. They
remain under-owned and still appear attractively valued.

 

Since the peak in August 2020, the forward P/E of SmallCaps in Continental
Europe has fallen from over 23x to around 13x at the end of March 2025. This
substantial de-rating leaves them trading at a discount to their long-term
historical average.

 

Moreover, European SmallCaps are valued at a discount to the wider market,
which is unusual. Indeed, the discount is at a level last seen in the depths
of the Global Financial Crisis of 2008.

 

We must, however, acknowledge that increasing global trade barriers and indeed
policy uncertainty are likely to hinder rather than support economic growth.
In this environment, owning a portfolio of very high quality, structurally
growing companies provides us with a strong degree of comfort. One of the
defining features of such quality companies is their ability to invest for the
future and capture market share in more challenging economic environments,
while weaker competitors have to focus on day-to-day survival.

 

In summary: European smaller companies have a long track record of delivering
strong returns to investors. Today, they are trading at a significant discount
to both their own history and to their larger counterparts. The previous
overwhelming investment consensus favouring the US over Europe has been
challenged and investor sentiment has shifted towards European equities.
Meanwhile, the companies in your portfolio are well positioned to invest and
grow even through difficult times, supported by strong balance sheets, high
returns on capital, and clear structural growth opportunities. The portfolio
continues to be managed by an exceptionally well-resourced and experienced
team at Montanaro. In addition, the Board has implemented a series of measures
aimed at improving liquidity, reducing discount volatility and further
reducing costs.

 

Against this backdrop, we continue to look forward to the future with
confidence.

 

R M CURLING

Chairman

18 June 2025

 

Manager's Report

 

The Attractions of Quoted European Smaller Companies ('SmallCap')

The key attraction of investing in smaller companies is their long-term record
of delivering higher returns to investors than large companies. In the UK,
over the last 70 years, this has amounted to an average of 3.1% per annum (the
"SmallCap Effect"). £1 invested in UK large companies on 1 January 1955 would
now be worth £1,503 whereas the same £1 invested in smaller companies would
now be worth £10,040 - almost seven times more.

 

There is less comprehensive data on Europe - it only goes back to 2000.
However, it suggests that the SmallCap Effect is even more pronounced on the
Continent: as the chart above illustrates, European 'small' companies have
outperformed 'large' companies by 4% per annum.

 

Remarkably, European SmallCaps have returned 9.2% p.a. (in Sterling terms)
since the turn of the century, thereby outperforming the vast majority of
SmallCap markets around the world including the UK, Japan, Australia the BRICs
and even the USA (based on the Russell 2000 Index).

 

The market for European smaller companies is inefficient. While some large
companies are analysed by more than 50 brokers, many smaller companies in
Europe have little or no coverage. We believe that this makes it easier for
those with a high level of internal resources to identify attractive,
undervalued and overlooked investment opportunities. This in turn makes it
possible to deliver long-term performance over and above that of the
benchmark.

 

Montanaro Asset Management

Montanaro was established in 1991. We have one of the largest and most
experienced specialist teams in the UK dedicated exclusively to researching
and investing in quoted small companies. Our large team of analysts and
portfolio managers gives us the breadth of resources to conduct thorough
in-house research.

 

At 31 March 2025, we were looking after around £3 billion of client assets.
We have been the Manager of your Company since September 2006.

 

Investment Philosophy and Approach

We specialise in researching and investing in quoted smaller companies. We
have a disciplined, two-stage investment process.

 

In the first stage, we identify "good businesses" within our investable
universe. We look for high quality companies in markets that are growing. They
must be profitable; have good and experienced management; deliver sustainably
high returns on capital employed; enjoy high and ideally growing profit
margins reflecting pricing power and a strong market position; and provide
goods and services that are in demand and likely to remain so. We prefer
companies that can deliver self-funded organic growth and remain focused on
their core areas of expertise, rather than businesses that spend a lot of time
on acquisitions.

 

Conversely, we avoid those with stretched balance sheets; poor free cash flow
generation; incomprehensible or heavily adjusted accounts; unproven or
unreliable management; or that face structurally challenged business models
with stiff competition.

 

A company must also pass our stringent quality and ESG checklists. ESG has
been integrated into our disciplined investment process for almost two
decades.

 

When we have identified a company that we believe is high quality, has
structural growth and is well managed from a business and ESG perspective, it
is reviewed by our Investment Committee before it can proceed to the next
stage. Companies that do not possess these attributes are rejected.

 

Companies that pass the first stage then undergo a valuation & risk
assessment. We determine their intrinsic value, typically through a
proprietary discounted cashflow analysis, to ensure they will make a "good
investment" ("good businesses" and "good investments" are not always the
same). The Investment Committee scrutinises the forecasts and assumptions made
for each business. While the biggest risk - that we invest in poor or
declining businesses - is addressed in the first stage, in stage two we take a
more quantitative approach, with in-depth analysis of liquidity, factor risk
and correlations and how these might affect position sizing and the subsequent
portfolio characteristics. Only once this is complete will we add it to our
Approved List.

 

Companies that are on the Approved List and which we also believe are
attractively valued are then eligible for inclusion in your portfolio.

 

Our Investment Team use their industry knowledge and a range of proprietary
screens to continually search for new ideas. With thousands of quoted
companies from which to choose, we are spoiled for choice.

 

We believe that a deep understanding of a company's business model and the way
it is managed are essential. We visit our investee companies on a regular
basis. We examine management's past track record in detail as we seek to
understand their goals and aspirations. In smaller companies, the decisions
and motivation of the entrepreneurial management can make or break a company,
which is why meeting them is so important. We look closely at the board
structure; the level of insider ownership; and examine remuneration and
corporate governance policies carefully.

 

Once a company has been added to the portfolio, our investment team conducts
ongoing analysis. We will sell a holding if we believe that the company's
underlying quality is deteriorating or if there has been a fundamental change
to the investment case or management. We will get things wrong and make
mistakes, but we try to learn from them.

 

In summary, we invest in well managed, high quality, growing companies bought
at sensible valuations. We keep turnover and transaction costs low and follow
our companies closely over many years. We would rather pay more for a higher
quality, more predictable company that can be valued with greater certainty.
Finally, we align our interests with our investors by investing meaningful
amounts of our own money alongside yours. We are significant shareholders in
the Trust.

 

The Portfolio

At 31 March 2025, the portfolio consisted of 49 companies of which the top ten
holdings represented 38.3% of net assets. Sector and country distributions
within the portfolio are driven by stock selection. Although weightings
relative to the market are monitored, overweight and underweight positions are
based on where the greatest value and upside are perceived to be.

 

Performance Attribution

The largest positive contributors over the period were:

 

Plejd is a Swedish developer of smart lighting, heating and other electrical
products, which are sold to professional electricians. The company had an
excellent year, with operating profit more than doubling thanks to both
significant revenue growth and a well invested cost base that allowed for
significant operating leverage.

 

VZ Holding is a Swiss independent financial consultant and wealth manager. The
company was a top three contributor last year too - another demonstration that
"running your winners" is often a fruitful strategy. The company had a good
year thanks to continued demand for financial advice and an independent
approach which continues to appeal to customers.

 

MTU Aero Engines manufacture and maintain aircraft engines and components. The
company successfully improved efficiency in the Geared Turbofan fleet
management plan, while continuing to deliver growth elsewhere in the business.

 

Inevitably the year was not without some stock price declines as well. The
largest detractors were:

 

Tecan develop automated instruments and solutions that are used in
laboratories. The company endured a difficult year as biopharma companies
pulled back spending and research budgets in the US in particular came under
threat from the new administration.

 

Bachem is a leading manufacturer of peptides. The share price declined as the
timing for the new manufacturing facility (and, therefore, the associated
revenues) was pushed out.

 

IMCD is one of the world's largest specialty chemical distributors. Hopes of a
volume recovery in 2024 proved to be premature, with investors de-rating the
stock through the year.

 

Portfolio Changes

 

We try to keep portfolio turnover as low as possible. However, we typically
make a few changes each year as we identify new investment ideas that we
expect will provide stronger long-term returns than existing holdings.
Companies that become too large, are acquired or where the investment case
deteriorates are also replaced with new ideas from our Approved List.

 

The year to 31 March 2025 was notable for its M&A activity: we are clearly
not the only ones who believe these companies are attractively valued and have
strong growth prospects.

 

Esker and Epsilon Net, both niche software providers, were bought out. The
merger of Chr. Hansen, the probiotic developer, and Novozymes was completed
and we subsequently sold our holding in the combined company on size grounds.
Esker and Chr. Hansen both exited the portfolio having risen by multiple times
their initial purchase price. Epsilon Net was sold at a premium to our
purchase price and made a respectable return for the portfolio, but did not
achieve the same feat due to being taken over less than a year after we bought
the stock.

 

Dynavox, the supplier of augmentative and alternative communication devices
used by people with disabilities to communicate more effectively, and cBrain,
which develops modular software primarily for government and state
departments, were added to the portfolio.

 

Continual Improvement

Each year we take time to look back at our successes and mistakes to assess
how our systems and processes can be improved.

 

We have made significant strides in our ability to dynamically quantify and
monitor our risk profile, especially with respect to factor risks. Our
objective - as with all our risk management processes - is not to eliminate
risk entirely; rather, it is to take risk selectively and thoughtfully where
we believe it is well rewarded. Our focus is on ensuring that we are exposed
to the right risks while actively minimising our exposure to those factor
risks on which we have either a negative view or no conviction at all.

 

We have been systematically collecting data on the companies we research -
from new idea fruition to exit - for many years. We have now reached a point
where the dataset is sufficient to extract meaningful patterns and insights.
Our analysis has already revealed several interesting findings, leading to
refinements in both our idea generation process and the way we conduct
Investment Committee meetings.

 

How to Invest

We have invested a great deal of time and effort to make the Company readily
available to all investors. We have continued to grow our presence across the
UK's investment platforms and are delighted to see a steady increase, year
after year, in the Trust's retail following. With the Board, we have appointed
Marten & Co to provide sponsored research - you can find the initiation
report, here: https://www.montanaro.co.uk/mesct-quality-business/
(https://www.montanaro.co.uk/mesct-quality-business/) and update reports on
our website: www.montanaro.co.uk/trust/mesct
(http://www.montanaro.co.uk/trust/mesct) .

 

MONTANARO ASSET MANAGEMENT

Lead Porfolio Manager, George Cooke

18 June 2025

Top 10 Holdings

as at 31 March 2025

 

1.     VZ Holding - A Swiss financial consultancy and wealth manager with
a tech-enabled platform. Its focus on fee-based advice and recurring revenues
makes it a standout in a traditionally commission-driven industry.

2.     Kitron - An electronics manufacturing services (EMS) provider for
defence, healthcare, and electrification markets. Kitron offers resilient
growth through long-term contracts, reshoring trends, and rising demand for
high-reliability electronics.

3.     ATOSS Software - A leader in workforce management software. Its
scalable cloud solutions help companies optimise labour costs, with a
high-margin SaaS model driving recurring revenue and impressive long-term
growth.

4.     MTU Aero Engines - A key player in aircraft engine manufacturing
and maintenance. Benefiting from global air travel recovery and a strong order
book, MTU offers a powerful combination of engineering excellence and
after-market revenue.

5.     CTS Eventim - Europe's leading ticketing and live events platform.
Its dominant digital position, asset-light model and the return of large scale
events has delivered strong earnings growth.

6.     Reply - An IT consultancy focused on AI, cloud and digital
innovation. Reply's decentralised model and blue-chip client base drive
consistent growth and strong returns in the fast-evolving tech landscape

7.     Fortnox - Cloud-based accounting and admin software for SMEs. With
a near-monopoly in Sweden, high switching costs and expanding product suite,
Fortnox is a classic high-margin compounder. The company received a takeover
offer on 31 March 2025.

8.     NCAB - A global printed circuit board supplier offering premium
service and logistics. With an asset-light model and consolidation strategy,
NCAB delivers reliable cashflows and market share growth.

9.     Plejd - Develops smart lighting control systems for homes and
businesses. Its intuitive products and strong network of electricians make it
a high-growth disruptor in Nordic smart homes

10.   Brunello Cucinelli - The Italian luxury brand known for "humanistic
capitalism" and timeless craftsmanship. Its focus on sustainable growth,
exclusivity and global demand for quiet luxury support premium positioning and
pricing power.

 

Twenty Largest Holdings

as at 31 March 2025

 

                                       31 March  31 March  31 March     31 March     31 March

                                       2025      2024      2025         2024         2025

 Holding                  Country      Value     Value     % of         % of         Market cap

                                       £'000     £'000     net assets   net assets   £m
 VZ Holding               Switzerland  13,270    9,663     4.6          3.1          5,903
 Kitron                   Norway       13,179    9,964     4.5          3.2          654
 ATOSS Software           Germany      12,602    14,058    4.3          4.5          1,657
 MTU Aero Engines         Germany      12,063    14,121    4.1          4.5          14,484
 CTS Eventim              Germany      11,588    13,075    4.0          4.2          7,455
 Reply                    Italy        10,103    8,976     3.5          2.9          4,724
 Fortnox                  Sweden       10,048    12,493    3.4          4.0          4,090
 NCAB                     Sweden       9,884     14,350    3.4          4.6          740
 Plejd                    Sweden       9,563     3,813     3.3          1.2          402
 Brunello Cucinelli       Italy        9,286     9,518     3.2          3.0          6,012
 Belimo Holding           Switzerland  8,763     7,186     3.0          2.3          5,825
 IMCD                     Netherlands  8,727     11,870    3.0          3.8          6,070
 AAK                      Sweden       7,566     6,597     2.6          2.1          5,602
 Invisio                  Sweden       7,397     3,980     2.5          1.3          1,349
 Rational                 Germany      7,029     7,558     2.4          2.4          7,297
 Viscofan                 Spain        6,679     6,296     2.3          2.0          2,488
 Thule                    Sweden       6,634     7,177     2.3          2.2          2,394
 Sectra                   Sweden       6,456     5,396     2.2          1.7          3,600
 Biogaia                  Sweden       5,934     3,484     2.0          1.1          859
 Merlin Properties        Spain        5,774     5,959     2.0          1.9          4,652
 Twenty Largest Holdings               182,545             62.6         56.0

 

 

FURTHER INFORMATION

 

Montanaro European Smaller Companies Trust plc's annual report and accounts
for the year ended 31 March 2025 (which includes the notice of meeting for the
Company's AGM) will be available today on
https://montanaro.co.uk/trust/montanaro-european-smaller-companies-trust/
(https://montanaro.co.uk/trust/montanaro-european-smaller-companies-trust/) .

 

It has also been submitted in full unedited text to the Financial Conduct
Authority's National Storage Mechanism and is available for inspection at
data.fca.org.uk/#/nsm/nationalstoragemechanism
(https://data.fca.org.uk/#/nsm/nationalstoragemechanism) in accordance with
DTR 6.3.5(1A) of the Financial Conduct Authority's Disclosure Guidance and
Transparency Rules.

 

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