Breach 1:
Breach of  Section 356(1)(a) of the Capital
Markets and Services Act ("CMSA") read together with Section 206(b) of the CMSA.

Breach 2:
Breach of  Section 356(1)(a) of the Capital
Markets and Services Act ("CMSA") read together with Rule 3.24(n) of the Rules of Bursa Malaysia Derivatives Berhad ("Bursa Rules").

Breach 1:

1. Reprimand;
2. Requirement to make restitution to victim amounting to RM3,000.00;
3. Penalty of RM20,000.00.
   

Breach 2:
Reprimand

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with section 7(1) of the CMSA and Order 3(1) of the Capital Market and Services (Prescription of Securities) (Digital Currency and Digital Token) Order 2019 (“CMSA Order”)

Binance Holdings Limited had operated a recognized market (digital asset exchange) without registering with the SC under Section 34 of the CMSA via the website https://www.binance.com/en and also through its mobile applications (“Breach”)

1. Reprimand, pursuant to Section 354(3) of the CMSA; and
2. Directive to mitigate the effect of the Breach pursuant to Section 354(3)(d) of the CMSA where Binance Holdings Limited is required to:-
   1. disable Binance’s Website and Apps (in Apple Store, Google Play or any other digital application platform) in Malaysia within 14 business days from 26 July 2021, being 16 August 2021;
   2. immediately cease circulating, publishing or sending any advertisements, whether in email or otherwise, to Malaysian investors; and
   3. immediately restrict Malaysian investors from accessing Binance’s Telegram group and any other messaging platform which is operated by Binance.

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with section 7(1) of the CMSA and Order 3(1) of the Capital Market and Services (Prescription of Securities) (Digital Currency and Digital Token) Order 2019 (“CMSA Order”)

Binance Digital Limited had operated a recognized market (digital asset exchange) without registering with the SC under Section 34 of the CMSA via the website https://www.binance.com/en and also through its mobile applications (“Breach”)

1. Reprimand, pursuant to Section 354(3) of the CMSA; and
2. Directive to mitigate the effect of the Breach pursuant to Section 354(3)(d) of the CMSA where Binance Digital Limited is required to:
   1. disable Binance’s Website and Apps (in Apple Store, Google Play or any other digital application platform) in Malaysia within 14 business days from 26 July 2021, being 16 August 2021;
   2. immediately cease circulating, publishing or sending any advertisements, whether in email or otherwise, to Malaysian investors; and
   3. immediately restrict Malaysian investors from accessing Binance’s Telegram group and any other messaging platform which is operated by Binance.

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with section 7(1) of the CMSA and Order 3(1) of the Capital Market and Services (Prescription of Securities) (Digital Currency and Digital Token) Order 2019 (“CMSA Order”)

Binance UAB had operated a recognized market (digital asset exchange) without registering with the SC under Section 34 of the CMSA via the website https://www.binance.com/en and also through its mobile applications (“Breach”)

1. Reprimand, pursuant to Section 354(3) of the CMSA; and
2. Directive to mitigate the effect of the Breach pursuant to Section 354(3)(d) of the CMSA where Binance UAB is required to:-
   1. disable Binance’s Website and Apps (in Apple Store, Google Play or any other digital application platform) in Malaysia within 14 business days from 26 July 2021, being 16 August 2021;
   2. immediately cease circulating, publishing or sending any advertisements, whether in email or otherwise, to Malaysian investors; and
   3. immediately restrict Malaysian investors from accessing Binance’s Telegram group and any other messaging platform which is operated by Binance.

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with section 7(1) of the CMSA and Order 3(1) of the Capital Market and Services (Prescription of Securities) (Digital Currency and Digital Token) Order 2019 (“CMSA Order”)

Binance Asia Services Pte Ltd had operated a recognized market (digital asset exchange) without registering with the SC under Section 34 of the CMSA via the website https://www.binance.com/en and also through its mobile applications (“Breach”)

1. Reprimand, pursuant to Section 354(3) of the CMSA; and
2. Directive to mitigate the effect of the Breach pursuant to Section 354(3)(d) of the CMSA where Binance Asia Services Pte Ltd is required to:-
   1. disable Binance’s Website and Apps (in Apple Store, Google Play or any other digital application platform) in Malaysia within 14 business days from 26 July 2021, being 16 August 2021;
   2. immediately cease circulating, publishing or sending any advertisements, whether in email or otherwise, to Malaysian investors; and
   3. immediately restrict Malaysian investors from accessing Binance’s Telegram group and any other messaging platform which is operated by Binance.

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with sections 7(1) and 367(1) of the CMSA and Order 3(1) of the Capital Market and Services (Prescription of Securities) (Digital Currency and Digital Token) Order 2019 (“CMSA Order”)

Binance Holdings Limited Binance Asia Services Pte Ltd, (where Zhao Changpeng is the Chief Executive Officer and is a director) had operated a recognized market (digital asset exchange) without registering with the SC under Section 34 of the CMSA via the website https://www.binance.com/en and also through its mobile applications

1. Reprimand, pursuant to Section 354(3) of the CMSA; and
2. Directive to mitigate the effect of the Breach pursuant to Section 354(3)(d) of the CMSA where Zhao Changpeng is required to cause Binance to:-
   1. disable Binance’s Website and Apps (in Apple Store, Google Play or any other digital application platform) in Malaysia within 14 business days from 26 July 2021, being 16 August 2021;
   2. immediately cease circulating, publishing or sending any advertisements, whether in email or otherwise, to Malaysian investors; and
   3. immediately restrict Malaysian investors from accessing Binance’s Telegram group and any other messaging platform which is operated by Binance.

Breach 1
Breach of section 218(3) of the Capital Markets and Services Act 2007 (“CMSA”) read together with paragraph 4.01(b) of the Rules on Take-overs, Mergers and Compulsory Acquisitions (“Rules”).

Breach 2
Breach of section 354(1)(a) of the CMSA read together with sections 369(b)(A) and (B) of the CMSA.

Breach 1
The collective shareholding of TTSE and its PACs in Subur Tiasa Holdings Berhad (“STHB”) increased from 40.73% to 57.62% following the acquisition of 16.89% equity interest at RM0.48 per share on 20 February 2020.  The increase of more than 2% in any period of six months had resulted in TTSE and its PACs incurring a mandatory offer obligation in STHB.

Breach 2
Amat Abadi is a deemed person acting in concert with TTSE and its PACs under section 216(3)(i) of the CMSA pursuant to the financial assistance provided by TTSH to Amat Abadi for the acquisition of TTSH shares. Therefore, the representation to the SC that the subsequent disposal of the 16.89% to Amat Abadi, an unrelated party, is not accurate.

• Reprimand
• Directives for TTSE and its PAC to undertake the following:

1. a cash offer for all remaining shares not held by TTSE and its PACs at RM0.48 per share or at the highest offer price as may be required pursuant to Paragraph 6.03 of the Rules, to be determined (“Offer Price”); and
2. a compensation scheme to shareholders of STHB as at 20 February 2020, who had subsequently disposed their STHB shares at prices below the Offer Price. Such shareholders shall be compensated in cash on the difference per share between the Offer Price and their disposal price.

Breach of Section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with Section 214(1)(a)(A) of the CMSA (“Breach 1”);

Breach of Section 354(1)(a) of the CMSA read together with Section 246(1)(a) of the CMSA (“Breach 2”);

Breach of Section 354(1)(a) of the CMSA read together with Section 369(b)(B) of the CMSA (“Breach 3”); and

Breach of Section 354(1)(a) of the CMSA read together with Section 369(b)(B) of the CMSA (“Breach 4”).

Breach 1
Submitting to the SC the CAP Prospectus that contained financial statements that were false or misleading, in particular the cash and cash equivalents disclosed (“Disclosed CCE”) in the Statements of Financial Position of QuanZhou FenSun Automobile Parts Co., Ltd.  (“FenSun”) for the financial year ended 31 December (“FYE”) 2009, FYE 2010, FYE 2011 and financial period ended 30 September 2012 (“Disclosed CCE of FenSun”)

Breach 2
Causing the issuance of the CAP Prospectus dated 11 January 2013 that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 3
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to overstatement of bank balances to Bursa Malaysia. The financial statements concerned are:

• CAP’s  Quarterly Report on Consolidated Results for the First Quarter Ended 31 March 2015 (“1Q 2015”) until Quarterly Report on Consolidated Results for the Fourth Quarter Ended 31 December 2016 (“4Q 2016”); and
• CAP’s Audited Financial Statements for the Financial Year Ended 31 December 2012 (“AFS 2012”), Audited Financial Statements for the Financial Year Ended 31 December 2013 (“AFS 2013”), Audited Financial Statements for the Financial Year Ended 31 December 2014 (“AFS 2014”), Audited Financial Statements for the Financial Year Ended 31 December 2015 (“AFS 2015”) and Re-Issued Audited Financial Statements for the Financial Year Ended 31 December 2015 (“Re-Issued AFS 2015“)

Breach 4
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to non-disclosure of litigations and non-recognition of outstanding liabilities to Bursa Malaysia. The financial statements concerned are:

• Quarterly Report on Consolidated Results for the First Quarter Ended 31 March 2014 (“1Q 2014”) until 4Q 2016; and
• AFS 2014, AFS 2015 and Re-Issued AFS 2015.

Breach of Section 354(1)(a) of the CMSA read together with Section 214(1)(a)(A) of the CMSA (“Breach 1”)
Breach of Section 354(1)(a) of the CMSA read together with Section 246(1)(a) of the CMSA (“Breach 2”)

Breach of Section 354(1)(a) of the CMSA read together with Sections 369(b)(B) and 367(1) of the CMSA (“Breach 3”)

Breach 1
Causing the submission of the CAP Prospectus to the SC that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 2
Authorising the issuance of the CAP Prospectus dated 11 January 2013 that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 3
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to overstatement of bank balances to Bursa Malaysia.

Breach 4
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to non-disclosure of litigations and non-recognition of outstanding liabilities to Bursa Malaysia.

• Reprimand for each breach; and
• The SC has issued a public statement to the effect that, in the SC’s opinion, the retention of office by Wang YuYun as an Executive Chairperson of CAP is prejudicial to the public interest.

Breach of Section 354(1)(a) of the CMSA read together with Sections 369(b)(B) and 367(1) of the CMSA (“Breach 1”)

Breach of Section 354(1)(a) of the CMSA read together with Sections 369(b)(B) and 367(1) of the CMSA (“Breach 2”)

Breach 1
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to overstatement of bank balances to Bursa Malaysia.

Breach 2
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to non-disclosure of litigations and non-recognition of outstanding liabilities to Bursa Malaysia.

• Reprimand for each breach; and
• The SC has issued a public statement to the effect that, in the SC’s opinion, the retention of office by Chen Xunze as an Executive Director of CAP is prejudicial to the public interest.

Breach of Section 354(1)(a) of the CMSA read together with Section 214(1)(a)(A) of the CMSA (“Breach 1”)

Breach of Section 354(1)(a) of the CMSA read together with Section 246(1)(a) of the CMSA (“Breach 2”)

Breach of Section 354(1)(a) of the CMSA read together with Sections 369(b)(B) and 367(1) of the CMSA (“Breach 3”)

Li Guo Qing, former Managing Director of CAP

Breach 1
Causing the submission of the CAP Prospectus to the SC that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 2
Authorising the issuance of CAP’s Prospectus dated 11 January 2013 that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 3
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to overstatement of bank balances to Bursa Malaysia.

Breach 4
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to non-disclosure of litigations and non-recognition of outstanding liabilities to Bursa Malaysia.

Breach of Section 354(1)(a) of the CMSA read together with Section 214(1)(a)(A) of the CMSA (“Breach 1”)

Breach of Section 354(1)(a) of the CMSA read together with Section 246(1)(a) of the CMSA (“Breach 2”)

Breach of Section 354(1)(a) of the CMSA read together with Sections 369(b)(B) and 367(1) of the CMSA (“Breach 3”)

Breach 1
Causing the submission of the CAP Prospectus to the SC that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 2
Authorising the issuance of CAP’s Prospectus dated 11 January 2013 that contained financial statements that were false or misleading, in particular the Disclosed CCE of FenSun.

Breach 3
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to overstatement of bank balances to Bursa Malaysia.

Breach of Section 354(1)(a) of the CMSA read together with Sections 369(b)(B) and 367(1) of the CMSA (“Breach 1”)

Breach 1
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to overstatement of bank balances to Bursa Malaysia.

Breach 2
Knowingly permitting the furnishing of CAP’s financial statements that were false or misleading due to non-disclosure of litigations and non-recognition of outstanding liabilities to Bursa Malaysia.

Knowingly permitting the furnishing of CAP’s financial statement that was false or misleading due to overstatement of bank balances to Bursa Malaysia.

• Koon Yew Yin
• Tan Kit Pheng
• David Chew @ Chew Hooi Boon
• Yap Sung Pang

(collectively known as "Group")

• Failure to undertake a mandatory offer on JAKS Resources Berhad pursuant to the Group increasing their collective shareholding to above 33% on 29 November 2017.

• Reprimand
• Penalty of RM520,000 against the Group collectively

Breach of Section 356(1)(a) of the CMSA read together with the provisions of the following:

Paragraph 7.1.1, 7.1.2 and 7.14 of the Guidelines on Prevention of Money Laundering and Terrorism Financing for Capital Market Intermediaries as at 31 March 2004; and

Paragraph 8.2.1, 8.2.3 and 8.2.4 of the Guidelines on Prevention of Money Laundering and Terrorism Financing for Capital Market Intermediaries as at 15 January 2014.

Breach 1
Failure to conduct on going due diligence and scrutiny of EIB's customers throughout the course of the business relationship and to monitor the customer's account on a regular basis to ensure that transactions conducted are consistent with, amongst others, EIB's knowledge of the customers and their risk profile, as well as monitoring of suspicious transactions.

Breach 2
Failure to reclassify its customer(s) as higher risk and lodge a suspicious transaction report to the relevant authority in circumstances where, amongst others, the pattern of account activity of the customer appears unusual or inconsistent with EIB's profile or knowledge of the customer.

• Reprimand; and
• Penalty of RM400,000.00

30 June 2021

On 23 July 2021, EIB had applied for a review to the SC on the quantum of penalty imposed against them. The appeal was then dismissed by the SC and EIB was informed of the SC’s decision on 24 September 2021.

Imposition of sanctions under Section 220 of the Capital Markets and Services Act 2007 (“CMSA”) for non-compliance of Paragraphs 1.07, 3.01 and 3.05 of the Rules on Take-overs, Mergers and Compulsory Acquisitions (“Rules”) and breach of Section 221 of the CMSA

• UOBKH, being the principal adviser to the take-over offer in GETS Global Berhad, failed to consult the Securities Commission Malaysia (“SC”) in advance for guidance on the application of presumed concert party relationship.
• Such failure resulted in failing to advise its clients on compliance with the Rules and CMSA and submission of false or misleading information to the SC and investors.
• UOBKH did not take cue from the SC's earlier enquiries and should have applied the same diligence pertaining to the possible concert party relationships with regard to the joint offeror’s siblings.
• In addition, UOBKH failed to document material issues satisfactorily.

• Reprimand
• Directive for UOBKH to do the following:
  • Conduct a comprehensive review and assessment for compliance with the identification of concert parties pursuant to the Rules and CMSA. Results of such review and assessment together with recommendations (if any) must be reported to the SC within 3 months from date of sanction; and
  • Table the SC's decision at a meeting of the Board of Directors of UOBKH and a copy of the minutes of meeting together with the relevant Board papers discussing the issues must be forwarded to the SC within 1 month from date of sanction.

• Teong Lian Aik
• ADA Capital Investments Limited
• Low Bok Tek

• Teong Lian Aik, ADA Capital Investments Limited and Low Bok Tek (the “Parties”) jointly and severally accept full responsibility for the accuracy of the information contained in the submission to the SC (“Submission”) and confirm that having made all reasonable inquiries, that to the best of their knowledge, opinions expressed in the Submission have been arrived at, after due and careful consideration and there are no other facts not contained in the Submission, the omission of which would make any statement in the Submission false or misleading. However, the Submission was found to contain false or misleading statements.
• Notwithstanding, the Parties, when informing their concert parties on their obligations or restrictions in relation to the offer, did not specify on the applicable timing of such obligations or restrictions, knowing that the letter of obligations was not circulated to them; and
• The Parties did not take cue from the SC's earlier enquiries and should have applied the same diligence pertaining to the possible concert party relationships with regard to the siblings of the Parties.

Two (2) breaches under Section 354(1)(b)(iii) of the Capital Markets and Services Act 2007 read together with Clause 3.1.3(a) of the Code of Ethics and Rules of Professional Conduct (Unit Trust Funds) as at 22 January 2013 of The Federation of Investment Managers Malaysia

As a Unit Trust Consultant of Bank Kerjasama Rakyat Berhad (“Bank Rakyat”), Rohaini had:-

• Executed 15 unauthorised transactions on the unit trust account of Bank Rakyat’s client; and
• Knowingly provided statements to Bank Rakyat’s client which contained false or misleading information

• Reprimand for each breach; and
• Penalty of RM100,000.00

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with section 7(1) of the CMSA and Order 3(1) of the Capital Market and Services (Prescription of Securities) (Digital Currency and Digital Token) Order 2019 (“CMSA Order”)

Remitano had operated a recognized market (digital asset exchange) without registering with the SC under Section 34 of the CMSA via the website https://remitano.com/btc/my and also through its mobile applications

• Reprimand

Datuk Wira Lye Ek Seang

Non-compliance 1
Datuk Wira Lye, being a person acting in concert with the offeror and the ultimate offeror, had disposed 8,875,770 shares held by him in Caring Pharmacy Berhad (“Caring”) via off-market transactions during the offer period in relation to the take-over offer of Caring without the SC’s consent.

Non-compliance 2
Late disclosure of dealings in relation to some of his Caring shares disposed.

• Reprimand
• Penalty of RM38,500

Non-compliance of Paragraphs 19.01 and 19.04 of the Rules on Take-overs, Mergers and Compulsory Acquisitions

Datuk Seri Syed Ali bin Syed Abbas Al-Habshee

Non-compliance 1
Datuk Seri Syed Ali, being a person acting in concert with the offeror and the ultimate offeror, had disposed 6,527,035 shares held by him in Caring Pharmacy Berhad (“Caring”) via off-market transactions during the offer period in relation to the take-over offer of Caring without the SC’s consent.

Non-compliance 2
Late disclosure of dealings in relation to some of his Caring shares disposed.

• Reprimand
• Penalty of RM38,500

Non-compliance of Paragraphs 19.01 and 19.04 of the Rules on Take-overs, Mergers and Compulsory Acquisitions

Encik Arsam bin Damis

Non-compliance 1
Encik Arsam, being a person acting in concert with the offeror and the ultimate offeror, had disposed 5,085,160 shares held by him in Caring Pharmacy Berhad (“Caring”) via off-market transactions during the offer period in relation to the take-over offer of Caring without the SC’s consent.

Non-compliance 2
Late disclosure of dealings in relation to some of his Caring shares disposed.

• Reprimand
• Penalty of RM38,500

Four (4) breaches of section 354(1)(b)(iii) of the Capital Markets and Services Act 2007 (“CMSA”) read together with:-

• Clauses 5(a)(i) and 5(f) of the Code of Ethics and Standards of Professional Conduct for the Unit Trust Industry as at 1 September 2001 of The Federation of Malaysian Unit Trust Managers
• Clauses 2.1.9(g), 2.1.14(b) and 2.6.4(b) of the Code of Ethics and Rules of Professional Conduct (Unit Trust Funds) as at 22 January 2013 of the Federation of Investment Managers Malaysia (“FIMM”); and
• Paragraphs 9(e) and (f) of the Circular entitled “Duties and Responsibilities of Members and Registered Persons in Helping Investors to Make Informed Investment Decisions under Switching Transactions” issued by FIMM dated 14 July 2015

1st Breach
Bank Rakyat had failed to ensure that its Unit Trust Consultants (“UTCs”) remained fit and proper as they had committed various misconduct against their clients.

2nd Breach
There was no proper segregation of duties between the front office and back office. Bank Rakyat’s UTCs were able to perform both the front office and back office functions.

3rd Breach
There was no oversight by Bank Rakyat’s branches and Head Office over the UTCs.

4th Breach
There were no systems and procedures in place for Bank Rakyat to monitor or review the transactions executed by its UTCs which includes churning.

• Reprimand for each of the Breaches,
• Directive to carry out the following:-
  • Bank Rakyat shall allocate and utilise the sum of not less than RM1,260,000.00 within a period of three (3) years from the sanctions towards:-
    • continuous enhancement of Bank Rakyat’s monitoring systems and internal control measures with respect to its unit trust activities; and
    • ensuring effective implementation of its controls and processes including upskilling of staff through training or capacity building;
  • Bank Rakyat shall appoint an independent consultant to review and enhance Bank Rakyat’s internal controls in relation to its unit trust activities which shall be completed within six (6) months from the date of the sanctions, which would include the following:
    • to review that sufficient controls are in place in marketing and distributing unit trust funds and to ensure all lapses in controls are effectively rectified; and
    • to review the effectiveness of Bank Rakyat’s current and planned initiatives particularly in relation to system enhancements, implementation of Suitability Assessment Exercise, on-going monitoring of clients’ transactions and monitoring of marketing and distribution activities (including the competency of bank personnel involved);
  • Bank Rakyat shall only resume its unit trust activities which would include the marketing and distribution of unit trust funds (investment via cash) upon satisfactorily completing paragraph 2(b) above;
  • Bank Rakyat shall report to the SC on the implementation of paragraph 2(a) above every six (6) months from the date of the sanctions until the end of the three (3) year period; and
  • Bank Rakyat shall report to the SC on the implementation of paragraph 2(b) above within six (6) months from the date of the sanctions; and
  • Bank Rakyat shall table these sanctions to Bank Rakyat’s Board of Directors and forward the Board minutes to the SC within one (1) month from the date of the sanctions.

Breach of 354(1)(a) of the Capital Markets and Services Act read together with  Section 25(4) of the Securities Industry (Central Depositories) Act 1991

• Reprimand;
• Penalty of RM84,000.00.

16 February 2021

Breach of section 354(1)(a) of the Capital Markets and Services Act 2007 (“CMSA”) read together with Section 369(b)(B) of the CMSA

Reprimand

Breach 1
Breach of Section 218(2) of the Capital Markets and Services Act ("CMSA"), read together with Section 9(1)(a) of the Malaysian Code on Take-overs and Mergers 2010 ("2010 Code") and Paragraph 5.2 of Practice Note 9 of the 2010 Code

Breach 2
Breach of Section 218(2) of the CMSA, read together with Paragraphs 4.01(b) and 4.07(1) of the Rules on Take-overs, Mergers and Compulsory Acquisitions

Breach 1

• Failure to undertake a mandatory offer or to seek exemption, in relation to his acquisition of shares in Grand Hoover Berhad ("GHB") on 5 January 2015, which increased his shareholding when aggregated with the shareholding of Dynamic Merchant Limited, his wholly owned company to above 33% in GHB.

Breach 2

• Failure to undertake a mandatory offer or to seek exemption, in relation to shares transferred to him pursuant to a Grant of Probate with respect to his late mother's GHB shares on 7 January 2020, which increased his shareholding in GHB by more than 2% in a period of six months.