IN THE HIGH COURT OF JUSTICE

BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES

INSOLVENCY AND COMPANIES LIST (ChD)

Claim No. CR-2022-000596

SOVA CAPITAL LIMITED (IN SPECIAL ADMINISTRATION)

Company Number: 04621383

Trading Name: Sova Capital and Sova Capital Limited (previously trading as Otkritie Capital International, Otkritie Capital and ABC Clearing)

Registered office: C/o Teneo Financial Advisory Limited, The Colmore Building, 20 Colmore Circus, Queensway, Birmingham B4 6AT

Principal trading address: 12 Floor, 88 Wood Street, London EC2V 7RS

CLIENT MONEY HARD BAR DATE NOTICE

IN ACCORDANCE WITH REGULATIONS 12C AND 12E OF THE INVESTMENT BANK SPECIAL ADMINISTRATION REGULATIONS 2011

CLIENT MONEY HARD BAR DATE: 17.00 (GMT) on 13 DECEMBER 2023

David Philip Soden (IP 015790), Ian Colin Wormleighton (IP014230) and Stephen Roland Browne (IP 009281), of Teneo Financial Advisory Limited, the Colmore Building, 20 Colmore Circus, Queensway, Birmingham, B4 6AT were appointed as special administrators (the “Joint Special Administrators”) of Sova Capital Limited (in special administration) (the “Company”) on 3 March 2022 pursuant to an application made by the directors of the Company under regulation 5(1)(b) of The Investment Bank Special Administration Regulations 2011 (as amended) (the “Regulations”).

On 27 July 2023, the Joint Special Administrators posted a notice on the Company’s website stating that they intended to apply to the Court for (among other things) directions in relation to the setting of a hard bar date in respect of claims for the return of client money (“Client Money”) which has been pooled in accordance with the Financial Conduct Authority’s client money distribution and transfer rules (“Client Money Claims”). That application was granted by Mr Justice Miles on 3 October 2023 (the “Order”).

Hard Bar Date Notice

The Joint Special Administrators hereby give notice, in accordance with Regulation 12C and the Order, as follows:

(1) The Joint Special Administrators consider that it is necessary, in order to achieve Objective 1 under Regulation 10(1)(a) (to ensure the return of client assets (including client money) as soon as is reasonably practicable), to close the client money pool and treat any further claim for the return of Client Money as an unsecured claim.

(2) the Joint Special Administrators hereby set a hard bar date of 17.00 (GMT) on 13 December 2023 for Client Money Claims (the “Client Money Hard Bar Date”).

(3) The Client Money Hard Bar Date only applies to Client Money Claims and does not apply to clients’ safe custody assets received or held by the Company. This notice does not require clients to take any action in relation to any claims, other than Client Money Claims, that they may have.

(4) After the expiry of the Client Money Hard Bar Date, the Joint Special Administrators:

(a) may, in accordance with the rules in the Financial Conduct Authority’s Client Asset Sourcebook, transfer to the Company’s own bank accounts any balance of the client money pool which the Company holds after the return of Client Money to eligible claimants; and

(b) may not meet any further final money claims.

(5) For the purposes of this notice:

(a) an “eligible claimant” is a person:

(i) to whom the Joint Special Administrators have already made a distribution of Client Money without receiving a claim for the return of Client Money to that person;

(ii) who has submitted a claim for the return of Client Money other than a final money claim; or

(iii) who submits a final money claim on or before the Client Money Hard Bar Date.

b) A “final money claim” is a claim for the return of Client Money which is submitted in response to the setting of the Client Money Hard Bar Date.

Next Steps

In accordance with Regulation 12E, this notice will be:

(1) sent to all clients of the Company whose claims for the return of Client Money the Joint Special Administrators are aware of, provided the Joint Special Administrators have a means of contacting those clients;

(2) sent to all those persons whom the Joint Special Administrators believe have a right to assert a security interest or other entitlement over Client Money, provided the Joint Special Administrators have a means of contacting those persons;

(3) sent to the Financial Conduct Authority;

(4) advertised once in the London Gazette;

(5) advertised in the Financial Times and the Financial Times International; and

(6) placed on the Company’s website at www.sovacapital.com.

A hard copy of this notice may be requested from the Joint Special Administrators using the contact details below.

If you believe that you have a Client Money Claim, please return your signed CASS Client Statement to the Joint Special Administrators on or before the Client Money Hard Bar Date. Your CASS Client Statement is available upon request by emailing  CASS.SovaCapital@teneo.com or crm@sovacapital.com.

If you have been sent this notice, it does not mean that you necessarily have a Client Money Claim or are otherwise entitled to receive a distribution of Client Money.

Any general queries in relation to this notice should be directed to CASS.SovaCapital@teneo.com or crm@sovacapital.com. Alternatively, the Joint Special Administrators can be contacted at sovacapital@teneo.com and telephone queries can be made at 01133960166. You may wish, however, to consult your own legal and other professional advisers for advice in relation to the scope and effect of this notice.

David Philip Soden, Ian Colin Wormleighton and Steven Roland Browne

(as Joint Special Administrators of Sova Capital Limited (in special administration))

The Joint Special Administrators act as agents of Sova Capital Limited (in special administration) without personal liability

13 November 2023