Strengthening REIT regulations

Transcription

Strengthening REIT regulations
Singapore Industry Focus
Singapore REITs
Refer to important disclosures at the end of this report
DBS Group Research . Equity
Strengthening REIT regulations

Proposed enhancements for Singapore REIT industry

Better governance and transparency; proposals to
instill confidence for investors

Stock Picks: MAGIC, MCT, FCT, FCOT and Cache
New proposed enhancements to Singapore’s REIT
industry . The Monetary Authority of Singapore (“MAS”)
released a consultation paper highlighting potential tweaks to
the current regulatory regime governing REITs and REIT
managers. Key proposals include: (i) improving the corporate
governance and disclosures for REIT managers (ii) minimising
instances of “conflicts of interests” between REIT managers
and investors through refining REIT managers’ compensation
methodologies; and (iii) operational tweaks like having REITs
adhere to a higher leverage limit of 45% (vs 35% currently)
and eliminating the 60% cap on REITs with a credit limit. In
addition, MAS proposes to raise the development limit for
REITs to 25% from the current 10% of total assets. These
measures are likely to be implemented from 1st Jan 2016
onwards
Better governance and confidence for investors in SREITs. Some details and our views on the key proposals: (i)
REITs adopting a single-tier gearing limit of 45% (vs the
current 35%/60% limits subject to a credit-rating) would allow
more flexibility in acquisitions. This will also place S-REITs in
line with regulations in Malaysia / HK which have gearing limits
of 45% and 50%, respectively. (ii) Performance fees to be
pegged to a methodology that improves alignment of interests
and is linked to NAV or DPU to take into account unitholders’
long term interests. In addition, MAS is proposing to reduce
acquisition fees to a “cost recovery basis” to mean that
acquisition quality of acquisitions should improve. However,
while we acknowledge that taking on development risks
generally results in higher returns, we remain cautious on
proposals to raise the development limit to 25% of deposited
properties which implies potentially higher earnings volatility
for an otherwise stable sector.
Positive boost for REIT/property sector. We see the
proposals as generally positive for the REIT sector. When
passed, these should result in (i) a reduction in fees; and (ii)
greater transparency and alignment between REITs and their
unitholders. This should increase confidence and attractiveness
of REITs to investors. A strong and functioning REIT sector is
also a long term positive for sponsor/property developers who
have another avenue to recycle assets efficiently. Our picks for
the sector are Magic, FCT, MCT , Cache and FCOT.
Potential negative impact on ARA Asset Management.
These proposals when passed could potentially have a
detrimental impact on ARA, which is estimated to derive c. 5560% of its revenues from fees from its managed REITs. When
passed, we might see earnings cut when implemented in 2016.
www.dbsvickers.com
ed-JS / sa- JC
10 Oct 2014
STI : 3,259.25
Analyst
Derek TAN +65 6682 3716
[email protected]
Mervin SONG CFA +65 6682 8189
[email protected]
Rachael TAN +65 6682 3713
[email protected]
STOCKS
Cache Logistics Trust
Frasers Centrepoint Trust
Frasers Commercial Trust
Mapletree Commercial
Trust
Mapletree Greater China
Commercial Trust
Target Price Performance (%)
3 mth 12 mth
S$
Price
Mkt Cap
S$
US$m
1.17
1.90
1.36
1.44
713
1,362
723
2,373
1.37
2.04
1.49
1.46
(4.5)
2.2
(1.8)
5.1
0.4
3.0
11.0
18.5
BUY
BUY
BUY
BUY
0.93
1,966
1.04
3.9
4.5
BUY
Rating
Source: DBS Bank
S-REIT historical yield
16.0%
Yield Spread
S-REIT Yield
14.0%
- 1 SD
+1 SD
Mean
12.0%
10.0%
8.0%
6.0%
4.0%
2.0%
0.0%
Jan-06
Jan-07
Source: DBS Bank
Jan-08
Jan-09
Jan-10
Jan-11
Jan-12
Jan-13
Jan-14
Industry Focus
Singapore REITs
Selected key proposals and our thoughts
Corporate Governance – Tighter requirements
Proposed :
Current:
A. MAS seeks views on its proposal to impose a statutory duty on a
REIT manager and its individual directors to prioritise the interests of
unitholders over those of the REIT manager and its shareholders, in
the event of a conflict of interest.
A. Statutory duty not imposed on REIT manager
REIT manager and any director who breaches this duty will be subject
to criminal and civil liability.
B. To enhance the independence of the board of directors through
either (i) half the Board to comprise of independent directors, if
unitholders of the REIT are not given a right to appoint the directors
and if such a right is given, the requirement that the Board to consist
of at least one-third of independent directors will continue to apply to
that REIT manager or (ii) at least a majority of the Board to comprise
of independent directors.
B. One third of the board to be independent. Currently, it is noted
that 24 out of the 33 REIT managers have Boards that are at least
half-independent, while 15 out of 33 REIT managers have Boards that
are majority-independent.
C. The REIT manager is required to disclose in the annual report, the
REIT manager’s remuneration policies and procedures in setting
remuneration of directors and executive officers. The remuneration of
each individual director and CEO and at least top five executive
officers in bands of S$250,000 to be disclosed.
C. No requirement to disclose remuneration bands of the REIT’s top
executives
D. To stipulate a minimum of three directors for the audit committee.
In the case of a sponsor’s nominated member, to have a minimum of
three other directors who are independent.
D. No requirement on minimum number of directors
E. A review on whether the current approach of relying on unitholders
to initiate a review on REIT managers appointment is effective.
E. Unitholders to call for a vote (general meeting) on removal of REIT
manager and will likely exercise this right only in the scenario where
the REIT manager fails in its duties
DBS View:
We believe that REIT managers already exercise strong corporate governance and transparency and have board of directors that are at least halfor-majority independent. The above proposals will further improve the transparency and independence of the REIT boards and will boost
investors’ confidence on the REIT managers. This will eventually benefit minorities.
The disclosure of remuneration bands for REIT managers will close the gap between requirements under CG code for listed companies. This will
enable unitholders to understand the link between remuneration paid to directors and key executive officers and their performance.
Source: DBS Bank, MAS
Page 2
Industry Focus
Singapore REITs
Alignment of incentives - Pegging fees to long term unitholder interests
Fee Structure
Proposed Amendments
Current
Base fee:
Aligned with long term interest of interest of the REIT
and its unitholders
Typically based on fixed percentage of the value of the
REIT's deposited properties
Performance fees:
Crystallisation of performance fee should be no more
frequent than once a year
Most REITs usually pay a performance fee on an annual
basis
Linked to an appropriate metric which takes into
account the long term interest of the REIT and its
unitholders such as NAV or DPU/unit
Pegged to certain metrics such as REIT's gross revenue,
net property income or distributions per unit
Should not be linked to the REIT's gross revenue
Acquisition fee:
Fee determined on a cost recovery basis
Usually 1% of purchase consideration
Divestment fee:
Fee determined on a cost recovery basis
Usually between 0.5-1% of the sale consideration
DBS View
Impact on REITs
Impact on Sponsor
Generally positive as it lowers the fees for the REITs.
However, REITs may miss out on value accretive
acquisitions, as their sponsor has less incentive to find
acquisitions for the REIT.
Negative. Lower fee income
Disclosure requirements
Proposed Amendments
Current
For disposal of properties by
REIT to an interested party
Audit Committee of REIT manager to certify that if is
not aware of any other offer with, and has no reason
to believe that the divestment can be made on terms
that are more favourable than those offered by the
interested party.
Interested party transactions to be carried out on normal
commercial terms and at arms length
DBS View
Impact on REITs
Impact on Sponsor
Positive - Improved transparency and confidence in
divestment process
Positive - Increased confidence in alignment of interest
between REIT, interested parties, sponsor and
unitholders
Source: DBS Bank, MAS
Page 3
Industry Focus
Singapore REITs
Alignment of incentives - Pegging fees to long term unitholder interests
Remuneration
Proposed Amendments
Current
Directors and executive
officers
Prohibit directors of the REIT manager to be
(1) paid in the form of shares or interests in the
Sponsor or its related entities
(2) linked in any way to the performance of any
entities other than the REIT
Due to the limited disclosure on how directors are paid,
we are unable to ascertain whether the remuneration
structure of REIT managers is inconsistent with the
proposed changes.
Prohibit remuneration of executive directors of a REIT
manager from being linked to revenue of the REIT.
Fees payable to the non-executive directors of a REIT
manager to be a fixed sum
DBS View
Impact on REITs
Impact on Sponsor
Positive - Increases alignment between REIT, Sponsor
and unitholders
Negative. However, we are unaware of any sponsors
who have consistently acted against the best interest
unitholders by only acquiring properties solely to boost
their assets under management.
Source: DBS Bank, MAS
Operational flexibility – Higher gearing limits for all un-rated REITs/doing away with a need for credit rating.
Proposed Amendment
Current
Single tier gearing limit of 45%, regardless of whether credit limit is
obtained
35% gearing limit for REITs without a credit rating
60% gearing limit if a credit rating is obtained
REITs may engage in development activities up to 25% of deposited
properties, contingent upon (a) receipt of approval by unitholders for
the higher development limit, and (b) the additional 15% allowance is
used only to refurbish existing properties that have been held for at
least three years, and will be held for at least three years thereafter
Property development activities should not exceed 10% of the REIT's
deposited property
DBS View:
We are positive about the new gearing limits, as these will streamline and limit the amount of leverage that a REIT may take; this reinforces the
notion that all REITs must employ the same level of stringency when it comes to capital management, regardless of whether the REIT has
obtained a credit rating or not.. That said, the sector has maintained an average gearing of c.33-34% over the years, with the exception of
certain REITs (K-REIT, which is nearer to the 43% level). We also note that Croesus’ gearing is c. 50% but it is a business trust with REIT-like
features. There might be changes when the new policies are in place.
We are slightly cautious about higher development limits, as this could increase the amount of risk associated with a REIT, which, by virtue of its
structure, is meant to provide stable dividends to unitholders. While higher development limits may be positive for smaller REITs, which
occasionally may have to complete a development project in phases in order to comply with existing limits, we think that the additional 15%
development allowance for existing properties is a little high - most asset redevelopment works rarely require such a steep capex requirement,
and large ticket redevelopments could in turn adversely impact distributions as operations are disrupted.
Source: DBS Bank, MAS
Page 4
Industry Focus
Singapore REITs
REIT Structuring – Further tightening and clarity from income support arrangements
Proposed amendments
Current
REITs must disclose total operating expenditure (a) in absolute terms;
(b) as a percentage of NAV; and ( c) as a percentage of distributions
declared for the FY in their annual reports
Although REITs are compelled to disclose total operating expenses,
the level and manner of disclosure is not regulated and may vary
among different REITs
All REITs must both report and provide a detailed explanation of any
material deviation of actual DPU from forecast DPU in their annual
reports
While REITs are required to highlight any deviation of actual DPU
from forecast DPU, no explanation for the deviation is mandated
REITs must disclose the WALE of new leases entered into in the past
year (and their % of contribution to total revenue), as well as debt
maturity profile in their annual reports
No requirements for disclosure of average WALE or debt expiry
profile
Where there is income support, REITs must disclose (a) the amount of
income support received by the REIT for the year, and (b) the difference
between underlying rents and the implied rents under income support,
in their annual reports
There are no mandatory disclosure guidelines for master leases
embedded with income support (i.e. where underlying rents are
lower than master lease rent)
DBS view:


We are upbeat on the enhanced disclosure guidelines concerning income support, as these would encourage REITs to only consider
acquisitions where the underlying rent levels could eventually be DPU accretive on a sustained basis, and discourage REITs from purchasing
assets whose underlying NPI yield is not and may not be accretive to unitholders.
Disclosure of WALE and debt expiry profile could also help investors make more informed investment decisions based on their risk appetite
concerning these additional categories
Source: DBS Bank, MAS
Page 5
Industry Focus
Singapore REITs
REIT Regulations across the Asia Pacific region
Gearing limits
Tax transparency
REIT manager
Development limit
Australia
-
"Safe harbour" debt limit
of 60% of adjusted
Australian asset base for
income years
-
REIT is taxed on a "flowthrough" basis, i.e. at the
hands of unitholders rather
than the trust.
-
REIT must be managed
by a corporate trustee,
responsible entity or
fund manager
-
Hong Kong
-
45% of the gross asset
value
-
No tax transparency
-
Property manager must
be considered
acceptable to the
Securities and Futures
Commission
-
Japan
-
All loans must be
borrowed from qualified
institutional investors
-
20% withholding tax
-
Asset management
must be outsourced
-
If a REIT undertakes
development
activity, it will be
subject to
Australian
corporate tax
No development
activity is permitted
save for
refurishments,
retrofitting or
renovations
NA
Malaysia
-
50% of total asset value
All borrowings must be
through licensed
institutions, or through
issuance of debentures
-
Tax deduction allowed for
initial expenses pertaining
to the establishment of a
REIT
-
Asset must be
managed by a qualified
property manager
-
NA
Philippines
-
35% of Deposited
Properties for non-credit
rated REITs
70% gearing limit for
REITs with an investment
grade credit rating
-
REIT is not subject to
minimum corporate income
tax
-
N.A
-
35% of Deposited
Properties for non-credit
rated REITs
60% gearing limit for
REITs which have
disclosed its credit rating
-
REIT is taxed on a "flowthrough" basis
-
REIT manager must
have a physical office in
Singapore and
minimum shareholders'
funds of S$1m
-
REIT is not
permitted to
undertake property
development unless
it plans to hold the
completed property
for three years
Development cap
of 10% of
Deposited
Properties
-
Singapore
-
South Korea
-
Borrowings may not
exceed two times net
equity without an
extraordinary resolution
of shareholders' meeting,
and capped at 10 times
-
No tax transparency
-
N.A
-
NA
Taiwan
-
35% of total asset value
without a credit-rating;
50% of asset value if the
REIT discloses its credit
rating
-
REIT funds are taxed on a
"flow through" basis
-
-
NA
35% of Deposited
Properties for non-credit
rated REITs
60% gearing limit for
REITs which have
disclosed their credit
rating
-
Income is taxed at the
unitholder level, but there is
no regulation concerning
taxation of cash dividends
yet.
-
REIT funds must be
managed by a trust
enterprise, which has
been established for
more than three years
and is rated above a
certain level by a
recognised credit rating
institution
REIT manager must be
approved and licensed
by the Securities and
Exchange Commission
-
NA
-
Thailand
-
Source: DBS Bank, APREA
Page 6
Industry Focus
Singapore REITs
Peer Comparisons
REIT Code
FYE
Price
Rec
Target
Price
(S$)
Total
Return
Mkt
Cap
Yield
Yield
Yield
DPU
Growth
CAGR
P/Bk
(%)
S$'m
FY14/15F
FY15/16F
FY16/17F
FY13-15
FY14-16
(x)
Office
CCT
FCOT
K-REIT
OUECT
Dec
Sep
Dec
Dec
1.61
1.36
1.20
0.80
Hold
Buy
Hold
NR
1.67
1.49
1.29
0.85
10%
16%
14%
14%
4,717
920
3,602
691
9,930
5.3%
6.1%
6.4%
6.8%
5.9%
5.4%
6.7%
5.7%
6.9%
5.7%
5.9%
6.8%
5.8%
7.0%
6.0%
3%
7%
-6%
11%
2%
9%
-11%
0%
0.96
0.87
0.92
0.78
Retail
CRCT
CMT
CRT
FCT
SPH REIT
Dec
Dec
Jun
Sep
Aug
1.58
1.93
0.93
1.90
1.07
Buy
Hold
Buy
Buy
Hold
1.70
2.14
1.10
2.04
1.01
14%
17%
28%
13%
0%
1,307
6,663
472
1,735
2,678
12,855
6.8%
5.7%
8.9%
5.9%
5.5%
5.9%
7.5%
5.9%
9.0%
6.1%
5.1%
6.0%
8.3%
6.0%
9.0%
6.2%
5.1%
6.2%
15%
5%
-4%
2%
45%
10%
4%
1%
3%
-8%
1.08
1.11
1.23
1.19
1.20
Commercial
MCT
MAGIC
SGREIT
Suntec
Mar
Mar
Dec
Dec
1.44
0.93
0.79
1.80
Buy
Buy
Buy
Hold
1.46
1.04
0.90
1.85
7%
19%
21%
8%
3,021
2,503
1,701
4,483
12,310
5.5%
6.7%
6.5%
5.0%
5.4%
5.9%
7.2%
6.7%
5.5%
5.8%
6.1%
7.5%
7.0%
6.0%
6.5%
7%
3%
3%
3%
6%
8%
3%
10%
1.25
0.88
0.85
0.90
Industrial
a-itrust
A-REIT
Cache
CREIT
MINT
MLT
SBREIT
Mar
Mar
Dec
Dec
Mar
Mar
Dec
0.75
2.23
1.17
0.72
1.45
1.17
0.80
Hold
Buy
Buy
Hold
Buy
Buy
Buy
0.85
2.51
1.37
0.77
1.53
1.24
0.89
21%
19%
25%
15%
13%
13%
20%
686
5,361
908
903
2,480
2,881
645
13,863
6.4%
6.6%
7.4%
7.2%
7.0%
6.5%
7.7%
6.8%
6.9%
6.8%
8.0%
7.7%
7.1%
6.6%
8.3%
7.0%
7.0%
6.8%
8.5%
7.8%
7.1%
6.8%
8.5%
7.1%
6%
3%
4%
5%
2%
3%
71%
7%
3%
9%
6%
1%
2%
8%
1.13
1.11
1.19
1.05
1.22
1.05
1.00
Hospitality
ASCHT
ART
CDREIT
FEHT
FHT
OUEHT
Mar
Dec
Dec
Dec
Sep
Dec
0.73
1.23
1.69
0.81
0.90
0.91
Hold
Buy
Hold
Hold
Buy
Buy
0.77
1.33
1.84
0.88
0.94
0.95
14%
14%
16%
16%
12%
13%
811
1,883
1,649
1,435
1,067
1,194
8,039
8.2%
6.7%
6.8%
6.7%
6.6%
7.5%
7.0%
8.4%
7.0%
7.2%
7.0%
6.9%
7.8%
7.3%
8.8%
7.2%
7.4%
7.2%
7.0%
8.1%
7.5%
6%
2%
5%
0%
6%
55%
2%
5%
6%
4%
5%
4%
1.23
0.86
1.03
0.83
1.07
1.01
Healthcare
P-Life
RHT
Dec
Mar
2.32
0.95
Buy
Hold
2.62
0.82
18%
-5%
1,404
753
2,157
5.1%
8.6%
6.3%
5.2%
7.6%
6.1%
5.3%
7.8%
6.2%
6%
42%
3%
-12%
1.42
1.07
IREIT
Dec
0.90
Buy
0.95
13%
375
375
59,529
7.3%
7.6%
7.5%
4%
1.20
6.2%
6.4%
6.7%
Sector Average
Source: DBS Bank
Page 7
Industry Focus
Singapore REITs
DBS Bank recommendations are based an Absolute Total Return* Rating system, defined as follows:
STRONG BUY (>20% total return over the next 3 months, with identifiable share price catalysts within this time frame)
BUY (>15% total return over the next 12 months for small caps, >10% for large caps)
HOLD (-10% to +15% total return over the next 12 months for small caps, -10% to +10% for large caps)
FULLY VALUED (negative total return i.e. > -10% over the next 12 months)
SELL (negative total return of > -20% over the next 3 months, with identifiable catalysts within this time frame)
Share price appreciation + dividends
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This report is prepared by DBS Bank Ltd. This report is solely intended for the clients of DBS Bank Ltd and DBS Vickers Securities (Singapore) Pte
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may be (i) copied, photocopied or duplicated in any form or by any means or (ii) redistributed without the prior written consent of DBS Bank Ltd.
The research set out in this report is based on information obtained from sources believed to be reliable, but we (which collectively refers to DBS
Bank Ltd., its respective connected and associated corporations, affiliates and their respective directors, officers, employees and agents
(collectively, the “DBS Group”)) do not make any representation or warranty as to its accuracy, completeness or correctness. Opinions expressed
are subject to change without notice. This document is prepared for general circulation. Any recommendation contained in this document does
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can be no assurance that future results or events will be consistent with any such valuations, opinions, estimates, forecasts, ratings or risk
assessments. The information in this document is subject to change without notice, its accuracy is not guaranteed, it may be incomplete or
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assumptions and are inherently subject to significant uncertainties and contingencies. It can be expected that one or more of the estimates on
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COMPANY-SPECIFIC / REGULATORY DISCLOSURES
1.
DBS Bank Ltd., DBS Vickers Securities (Singapore) Pte Ltd (“DBSVS”), their subsidiaries and/or other affiliates do not have a
proprietary position in the securities recommended in this report as of 31 Aug 2014, except for CapitaCommercial Trust, Keppel
REIT, Capitamall Trust, CapitaRetail China Trust, SPH REIT, Starhill Global REIT, Suntec REIT, Mapletree Commercial Trust,
Mapletree Greater China Commercial Trust, Ascendas REIT, Ascendas India Trust, Mapletree Industrial Trust, Mapletree Logistics
Trust, Cambridge Industrial Trust, Cache Logistics Trust, Soilbuild Business Space Reit, Ascendas Hospitality Trust, Ascott
Residence Trust, CDL Hospitality Trusts, Far East Hospitality Trust, Frasers Hospitality Trust, OUE Hospitality Trust, Parkway Life
Real Estate Investment Trust, Religare Health Trust, Croesus Retail Trust.
2.
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DBS Bank Ltd., DBSVS, DBSVUSA, their subsidiaries and/or other affiliates beneficially own a total of 1% of any class of common
equity securities of the Keppel REIT, Starhill Global REIT, Mapletree Greater China Commercial Trust, Soilbuild Business Space
Reit, Ascendas Hospitality Trust, Ascott Residence Trust, Far East Hospitality Trust, Frasers Hospitality Trust, Croesus Retail Trust as
of 31 Aug 2014.
DBS Bank Ltd., DBSVS, DBSVUSA, their subsidiaries and/or other affiliates beneficially own a total of 5% of any class of common
equity securities of Ascendas Hospitality Trust as of 31 Aug 2014.
Industry Focus
Singapore REITs
3.
Compensation for investment banking services:
DBS Bank Ltd., DBSVS, DBSVUSA, their subsidiaries and/or other affiliates have received compensation, within the past 12
months, and within the next 3 months may receive or intends to seek compensation for investment banking services from the
Frasers Centrepoint Trust, Suntec REIT, Soilbuild Business Space Reit, Ascott Residence Trust.
DBSVUSA does not have its own investment banking or research department, nor has it participated in any investment banking
transaction as a manager or co-manager in the past twelve months. Any US persons wishing to obtain further information,
including any clarification on disclosures in this disclaimer, or to effect a transaction in any security discussed in this document
should contact DBSVUSA exclusively.
RESTRICTIONS ON DISTRIBUTION
General
This report is not directed to, or intended for distribution to or use by, any person or entity who is a citizen or resident of or
located in any locality, state, country or other jurisdiction where such distribution, publication, availability or use would be
contrary to law or regulation.
Australia
This report is being distributed in Australia by DBS Bank Ltd. (“DBS”) or DBS Vickers Securities (Singapore) Pte Ltd (“DBSVS”),
both of which are exempted from the requirement to hold an Australian Financial Services Licence under the Corporation Act
2001 (“CA”) in respect of financial services provided to the recipients. Both DBS and DBSVS are regulated by the Monetary
Authority of Singapore under the laws of Singapore, which differ from Australian laws. Distribution of this report is intended
only for “wholesale investors” within the meaning of the CA.
Hong Kong
This report is being distributed in Hong Kong by DBS Vickers (Hong Kong) Limited which is licensed and regulated by the
Hong Kong Securities and Futures Commission.
Indonesia
This report is being distributed in Indonesia by PT DBS Vickers Securities Indonesia.
Malaysia
This report is distributed in Malaysia by AllianceDBS Research Sdn Bhd ("ADBSR") (formerly known as HwangDBS Vickers
Research Sdn Bhd). Recipients of this report, received from ADBSR are to contact the undersigned at 603-2604 3333 in
respect of any matters arising from or in connection with this report. In addition to the General Disclosure/Disclaimer found
at the preceding page, recipients of this report are advised that ADBSR (the preparer of this report), its holding company
Alliance Investment Bank Berhad, their respective connected and associated corporations, affiliates, their directors, officers,
employees, agents and parties related or associated with any of them may have positions in, and may effect transactions in
the securities mentioned herein and may also perform or seek to perform broking, investment banking/corporate advisory
and other services for the subject companies. They may also have received compensation and/or seek to obtain compensation
for broking, investment banking/corporate advisory and other services from the subject companies.
Wong Ming Tek, Executive Director, ADBSR
Singapore
This report is distributed in Singapore by DBS Bank Ltd (Company Regn. No. 196800306E) or DBSVS (Company Regn No.
198600294G), both of which are Exempt Financial Advisers as defined in the Financial Advisers Act and regulated by the
Monetary Authority of Singapore. DBS Bank Ltd and/or DBSVS, may distribute reports produced by its respective foreign
entities, affiliates or other foreign research houses pursuant to an arrangement under Regulation 32C of the Financial
Advisers Regulations. Where the report is distributed in Singapore to a person who is not an Accredited Investor, Expert
Investor or an Institutional Investor, DBS Bank Ltd accepts legal responsibility for the contents of the report to such persons
only to the extent required by law. Singapore recipients should contact DBS Bank Ltd at 6327 2288 for matters arising from,
or in connection with the report.
Thailand
This report is being distributed in Thailand by DBS Vickers Securities (Thailand) Co Ltd. Research reports distributed are only
intended for institutional clients only and no other person may act upon it.
United
Kingdom
This report is being distributed in the UK by DBS Vickers Securities (UK) Ltd, who is an authorised person in the meaning of
the Financial Services and Markets Act and is regulated by The Financial Conduct Authority. Research distributed in the UK is
intended only for institutional clients.
Dubai
This research report is being distributed in The Dubai International Financial Centre (“DIFC”) by DBS Bank Ltd., (DIFC Branch)
rd
having its office at PO Box 506538, 3 Floor, Building 3, East Wing, Gate Precinct, Dubai International Financial Centre (DIFC),
Dubai, United Arab Emirates. DBS Bank Ltd., (DIFC Branch) is regulated by The Dubai Financial Services Authority. This
research report is intended only for professional clients (as defined in the DFSA rulebook) and no other person may act upon
it.
United
States
Neither this report nor any copy hereof may be taken or distributed into the United States or to any U.S. person except in
compliance with any applicable U.S. laws and regulations. It is being distributed in the United States by DBSVUSA, which
accepts responsibility for its contents. Any U.S. person receiving this report who wishes to effect transactions in any securities
referred to herein should contact DBSVUSA directly and not its affiliate.
Other
jurisdictions
In any other jurisdictions, except if otherwise restricted by laws or regulations, this report is intended only for qualified,
professional, institutional or sophisticated investors as defined in the laws and regulations of such jurisdictions.
DBS Bank Ltd.
12 Marina Boulevard, Marina Bay Financial Centre Tower 3
Singapore 018982
Tel. 65-6878 8888
Company Regn. No. 196800306E
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