Sandell Asset Management Europe Limited

October 07, 2011 09:30 ET

Short Selling Disclosure

Form TR-5. FSA Version 1.0 August 2010

TR-51:     Disclosure of Short Position relating to securities which are the subject of a rights issue or a
           UK Financial Sector Company

1. Full name of person(s) holding the disclosable        Sandell Asset Management Corp.
short position2:                                         
                                                         Castlerigg Master Investments Ltd.
                                                         Castlerigg Merger Arbitrage and Equity Event
                                                         Master Fund, Ltd.
                                                         Castlerigg Merger Arbitrage UCITS Fund
2: Name of the issuer of the relevant securities         Investec Plc
3: Disclosable short position3                           0.27%
4. Date that disclosable short position was held         October 6, 2011

1  This form relates to the disclosure of short positions in compliance with chapter 2 of  the FSA's
Financial Stability and Market Confidence sourcebook (FINMAR) . The form, or the information contained
within it, should be disclosed via an RIS using the short code SSD.
2 Specify the holder of the net short position. The naming of nominees or vehicle companies is
insufficient. In the case of a discretionary investment manager managing assets on behalf of a client, the
disclosure obligation applies at the level of both the entity to which FINMAR 2.2.1 R or  2.2.3 R applies
and at the level of the discretionary investment manager. The discretionary investment manager may make a
net short position disclosure on behalf of its client.  In respect of itself, the discretionary investment
manager is required to disclose its aggregate net short position across all of the funds it manages.  Non-
discretionary investment managers may also make disclosure of a net short position on behalf of their

Where a disclosure by a discretionary investment manager is the same as that being made for its
client/fund/sub-fund, it is permitted to make a single disclosure provided that the disclosure makes it
clear that it applies to both parties.
3 Figure to be expressed as a percentage of issued capital. Disclosable short position is defined in the
Glossary of Definitions in the FSA Handbook. Positions must be disclosed on a net basis of all holdings.
All financial instruments that represent a direct or indirect economic interest in the shares of the issuer
must be included within such holdings.

Contact Information

  • Sandell Asset Management Europe Limited