Note 8 to Rule 8 of the Takeover Code published by the Panel on Takeovers and Mergers makes clear that where the pension scheme trustees have delegated investment decisions to a fund manager, that fund manager, and not the person on whose behalf the fund is managed, will be seen by the Panel as being interested in and having dealt with the securities concerned for the purposes of disclosure of interests during an offer period. The trustees would not be concerned with disclosure obligations.

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