International Investment International Investment Instruments for Ukrainian Capital Instruments for Ukrainian Capital

MarketsMarkets

DebtDebt::

- EUROBONDS- EUROBONDS - SYNDICATED LOANS - SYNDICATED LOANS

EquityEquity::

- IPO- IPO

Structured FinanceStructured Finance: :

- SECURITISATION OF ASSETS- SECURITISATION OF ASSETS- PROJECT FINANCE- PROJECT FINANCE

INTERNATIONAL FINANCE / INTERNATIONAL FINANCE / CAPITAL MARKETS INSTRUMENTSCAPITAL MARKETS INSTRUMENTS

EUROBONDS ISSUES IN UKRAINE“Issuer”/Borrower Settlement date Amount (USD) Maturity date

Life, Years

Coupon %

Lead-managers

Stirol 27.07.2005 125,000,000 27.07.2008 3 7.873 ING Bank (the Netherlands)

Ukrsibbank 29.06.2005 100,000,000 14.07.2008 3 8.95 Deutsche Bank AG and UBS limited

Ukrsotsbank 25.05.2005 100,000,000 06.06.2008 3 9,00 ABN AMRO and Moscow Narodniy Bank (UK)

Kyivstar GSM - 3 15.04.2005 175,000,000 15.04.2012 7 7.75 Citigroup and Dresdner Bank AG

Ukreximbank - 2 28.01.2005 100,000,000 23.09.2009 - 7.75UBS Limited and Dresdner

Kleinwort Wasserstein

Naftogaz 23.09.2004 500,000,000 30.09.2009 5 8.125 ABN AMRO Bank N.V.

Ukreximbank - 1 23.09.2004 150,000,000 23.09.2009 5 7.75UBS Limited and Dresdner

Kleinwort Wasserstein

Government of Ukraine - 4

05.08.2004 500,000,000 05.08.2009 56m LIBOR +

3.375

Citigroup, FSCB and Dresdner Kleinwort Wasserstein

Kyivstar GSM - 2 27.07.2004 265,000,000 17.08.2009 5 10.375Citigroup and Dresdner

Kleinwort Wasserstein

EUROBONDS 2004/2005

“Issuer”/Borrower Settlement date Amount (USD) Maturity dateLife, Years

Coupon %

Lead-managers

Kyiv City - 2 15.07.2004 200,000,000 15.07.2011 7 8.625 Deutsche Bank and Morgan Stanley

Ukrsibbank 23.03.2004 100,000,000 05.04.2007 3 10,5 Dresdner Kleinwort Wasserstein

Government of Ukraine - 3

26.02.2004 600,000,000 04.03.2011 7 6.875 Dresdner Bank AG and Merrill Lynch

Yuzhmash 02.02.2004 107,500,000 02.02.2009 5 8.00 JP Morgan

Privatbank 09.12.2003 100,000,000 19.12.2006 3 10.88 Credit Suisse First Boston

Kyiv City – 1 29.07.2003 150,000,000 08.08.2008 5 8.75 Dresdner Kleinwort Wasserstein, J.P. Morgan, UBS Warburg

Government of Ukraine - 2

11.06.2003 1,000,000,000 11.06.2013 10 7.65Dresdner Bank AG London Branch, "J.P.Morgan Europe Limited" and UBS Limited

Kyivstar GSM - 1

21.11.2002 160,000,000 21.11.2005 3 12.75 Dresdner Kleinwort Wasserstein

Government of Ukraine - 1

15.03.2000 1,129,329,000 15.03.2007 7 11.00 ING Barings

• The issuer is an immediate and final funds recipient • Possible only in sovereign Eurobond issues• Corporates may not issue bonds denominated in foreign currency resulting in

impossibility of a direct corporate Eurobonds (Commercial Code, Art.165, Securities Law, Art.12)

• Circulation of corporate bonds outside Ukraine is heavily and restrictively regulated by State Commission on Securities and Stock Market of Ukraine (the “SEC”) (Infamous Regulation 36 of 17.10.1977, as amended):

- charter capital of at least UAH 5 mln.;- purchase price may not be less than par value or market value, as indicated at a

Ukrainian stock exchange or OTC system;- listing at a foreign stock exchange or OTC system must be approved by the SEC after

domestic registration of the issue;- issuer must submit to the SEC an audited placement report and copies of transaction

documents, annual report and statement of interest paid to bondholders;- amount may not exceed capital fund of the issuer (Civil Code, Art. 158)

EUROBONDS STRUCTURE: DIRECT ISSUE

EUROBONDSINDIRECT ISSUE: LIMITED RECOURSE LPN STRUCTURE

Lender / Issuer

Proceeds of Notes

BorrowerNoteholders

Trustee

Loan

repayment of principal and interest

on the Notestrust

repayment of principal and interest

on the Loan

Lead Manager(s) /

Underwriter(s)Law Firms /

Counsel

Auditors

Rating Agency

trust

pledged rights under the Loan

Transfer agentPaying agent

Eurobonds• DEFINITION: Securities (i) denominated in currency other than

that of “issuer”, (ii) placed publicly (through listing at a stock exchange) or privately by a syndicate of underwriters among foreign investors to whom this currency is also foreign, and (iii) establishing a debt obligation of the issuer to pay a par value amount plus interest to the bondholders

• AMOUNT: from USD 100 mln.

• STRUCTURE

A. - offering in the US to “qualified institutional buyers” in reliance on Rule 144 A under US Securities Act of 1933,

and / or - offering outside the United States in reliance on Regulation S under US Securities Act of 1933

B. - Direct issue- Indirect Issue

• Preliminary Offering Circular• Offering Circular• Subscription Agreement• Loan Agreement• Trust Deed• Trustee Indemnification and Compensation Agreement• Agency Agreement (payment and transfer)• Agency Indemnification and Compensation Agreement• Listing Documentation• Legal Opinions• Auditors’ Letters

EUROBONDSLPN STRUCTURE: PRINCIPAL DOCUMENTS

• LENDER/ISSUER: Borrower’s SPV or an arm’s length intermediary• SPV: Individual license of the National Bank of Ukraine (“NBU”) to conduct investment

abroad (NBU Instruction № 122 dated 16.03.1999) (onerous requirement of a contract between parent and its “foreign partner” and documentary evidence of registration of SPV)

• INTERMEDIARY: bank, financial institution or not (Commercial Code, Art. 388).• LOAN vs. BORROWING: a by-pass surgery

- Civil Code, Art. 1046 allows borrowing from a non-financial lender; - Corporate Tax Law includes borrowings into “financial loans”;- Banks and municipalities may borrow only from foreign banks and financial

institutions.• REGISTRATION OF THE LOAN with the NBU (notification, if the borrower is a bank).• PRICE EVALUATION ACT is required for a payment for services in excess of EUR

50.000 to a non-resident, except for payment, inter alia, under loans registered by NBU, payments to EBRD or IBRD, or for financial services (when the borrower is properly licensed to carry out such business).

• STATEMENT OF PURPOSE, TERM AND INTEREST

EUROBONDS LPN STRUCTURE: LOAN AGREEMENT

EUROBONDSLPN STRUCTURE: LOAN AGREEMENT (continued)

• INTEREST RATE: Capped and Combined (NBU Regulation 270, dated 17.06.2004)- fixed rates are capped at: 9.8% for loans of up to 1 year;

10% for loans from 1 to 3 years;11% for loans of more than 3 years.

- floating rates are capped at 3-month USD LIBOR plus 750 bp. (floating interest challenges);- loans of “strategic importance” to Ukrainian economy, commercial (deferred payment) loans and loans guaranteed by the government are not subject to a cap- interest includes the lender’s fees, default interest, and other charges under the loan agreement- prepayment is subject to interest cap effective on the prepayment date (uncertain amount and interpretation)- registration of loan amendment may be denied by the NBU, if at the time of amendment interest rate under the loan exceeds the then effective cap

INTEREST RATES APPLICABLE UNDER DOUBLE TAX TREATIES OF UKRAINE

Full Rate (%)

Reduced Rate (%)

Reduced Rate Apply to

1 Belgium 5 2 Interest payments under bank loans and commercial loans; beneficial ownership requirement

2 Cyprus 0 0 —

3 Germany 5 2 Interest payments under bank loans and commercial loans; beneficial ownership requirement

4 France 10 2 Interest payments under bank loans and commercial loans; beneficial ownership requirement

5 Kingdom of Netherlands

10 2 Interest payments under bank loans and commercial loans; beneficial ownership requirement

6 Switzerland 10 0 Interest payments under bank loans and commercial loans; beneficial ownership requirement

7 United Arab Emirates 3 3 Beneficial ownership requirement

8 Great Britain 0 0 Beneficial ownership requirement

9 USA 0 0 Relief from taxation is granted to banks, insurance companies and other companies that are engaged in the active conduct of business

10 Spain 0 0 Beneficial ownership requirement; application of reduced rate only to amounts that payer and beneficial owner would agree on absent special relationship between them

EUROBONDS LPN STRUCTURE: TAX ISSUES

• BENEFICIAL OWNERSHIP as a condition of a reduced interest rate

• TAX RESIDENCY CERTIFICATE• NON-APPLICABILITY OF A DOUBLE-TAX TREATY

in case of assignment of the loan to the Trustee• GROSS-UP AND TAX INDEMNITY may be challenged as

providing for payment of tax on behalf of the other party (Corporate Tax Law, Art.16.14 and 18.2)

• ACTS OF ACCEPTANCE OF SERVICES• TAX RULES IN THE LENDER’S JURISDICTION

SYNDICATED LOANS 2004 / 2005

Borrower Amount (USD)

Industrial Union of Donbas 85,000,000 (2005)

Kyivstar GSM 75,000,000

Aval 14,500,000

47,000,000 (2005)

Ukrsotsbank 13,000,000

45,000,000 (2005)

Ukrsibbank 10,000,000

37,000,000 (2005)

FUIB 20,000,000

30,000,000 (2005)

Ukreximbank 30,000,000

Prominvestbank 18,000,000

Deutsche Bank, ING, Citibank, Standard Bank, Raiffeisenbank, Societe Generale, Parex Bank are among arrangers of syndications in Ukraine

SYNDICATED LOANS

• LOAN PROVIDED JOINTLY BY SEVERAL BANKS OFTEN FROM DIFFERENT JURISDICTIONS WITH THE BORROWER

• ARRANGER(S)/LEAD MANAGER(S), MANAGER(S), CO-MANAGER(S), PARTICIPANTS

• ASSIGNMENT (SUBPARTICIPATION) vs. SYNDICATION

SYNDICATED LOANSSUBPARTICIPATION

Funded Subparticipation

Commitment

Risk

Subparticipation

(scheduled deposit)

Risk Subparticipation

Indemnity

Risk

Subparticipation

(default deposit)

SYNDICATED LOANSFEATURES

• BORROWERS: sovereigns and large banks/corporates • AMOUNT: USD 10-50 mln. (average), larger amounts than under

bilateral loans• SECURITY: unsecured (often) or secured• CURRENCY: mostly USD• TERM: 1 to 5 years • INTEREST RATE: floating (libor + 3.65%-3.95%)• COST: participation fees and commission, cheaper facility than

Eurobonds (cost is under 7% PA)• PRE-CONDITIONS: does not require borrower’s audited financials and

rating • TIMING: shorter period for arrangement• DIVERSIFIED RISKS FOR THE LENDERS

IPOBENEFITS/CHALLENGES

• Access to equity capital markets to fund future growth

• Attractive valuation and liquidity for shareholders

• Operational and management control

• High international profile and publicity

• Reputational benefits for marketing and regulatory review

• Higher share value

• Development of internal accounting and reporting standards

• Dependency on capital market condition

• High degree of finance transparency and disclosure

• Established corporate governance policies and protection of minority rights

• Compliance with listing rules• Offering size of at least USD 100

mln.• 3-year internationally audited

accounts• Restructuring of business

operations• Long preparation period

IPOTypes

· Direct- Same restrictions as for direct Eurobonds issue

· Indirect - SPV controlling the “Issuer” (Ukrproduct Group)- SPV controlled by the “Issuer”- Jurisdiction

· ADR (New York, NASDAQ, PORTAL)/GDR (London, Frankfurt, Berlin, Luxemburg, USA)- Negotiable certificates representing ownership of shares in a foreign corporation for US

and/or international investors- Main Market vs. Alternative Investment Market at SE (London, Luxemburg)- Sponsored and unsponsored programs - 4 levels for sponsored programs:

· I – existing shares, OTC, release from data disclosure, not expensive private placement (37 issues for Ukrainian companies: Ukrneft, Styrol, Dneproenergo,

Azovstal, Centroenergo, etc) · II - existing shares, listing at SE · III – public placement of new and existing shares at SE · Unregistered underwritten private placement (Rule 144A/Res S) among QIB –

qualified institutional buyers (USD 100mln.) data disclosure is not required

IPOGDR / ADR STRUCTURE

Depositary

GDR / ADR

IssuerInvestors

shares / dividends

purchase price

CustodianBroker

purchase price

dividends

IPOGDR/ADR STAGES

Selection of Investmentbank(lead manager, underwriter),

legal counsel, auditors

Business / Corporate

decision

Businessanalysis

Due diligence / restructuring

Share issue registration by SCSSM

Audited financials

(IAS, GAAP)GMS

Transaction documents; offering memorandum, listing documents,

depository agreement

Registration by regulators

end SE

Road ShowSubscription for ADR /

GDR, purchase of shares by Depositary

IPOLegal issues

• ACQUISITION OF SHARES: brokers and investment accounts• NON-DOCUMENTARY SHARES• ANTIMONOPOLY FILING• BENEFICIARY HOLDING OF SHARES under the depository

agreement vs. “true ownership” under Ukrainian corporate law• SPLIT VOTING RIGHT and other corporate rights• DISCRETIONARY PROXY PROVISION in the depository

agreement (management voting rights)• ADR/GDR HOLDERS may seek protection in international

dispute resolution forums• TAX ON DIVIDENDS

Jurisdiction

Tax on Dividends

Full Rate (%) Reduced Rate (%) Reduced Rate Applies if beneficial owner of

dividends is a holder of at least:

1 Belgium 15 5 20 % of the issuer’s capital

2 Cyprus 0 0 —

3 Germany 10 5 20 % of the issuer’s capital

4 France 15

5 10 % of the issuer’s capital

050 % of the issuer’s capital and the investment equals to 5 million francs.

5Kingdom of Netherlands

15

5

20 % of the issuer’s capital

050 % of the issuer’s capital and the investment equals to $300.000 US

6 Switzerland 15 5 20 % of the issuer’s capital

7United Arab Emirates

15 5 10 % of the issuer’s capital

8United Kingdom

10 5 20 % of the issuer’s capital

9 USA 15 5 20 % of the issuer’s capital

IPO

IPOCOST/TIMING

• Ukrprodukt IPO- GBP 6 mln. Placement- total cost: GBP 700,000- timing: 1 year

STRUCTURED FINANCE

Financing structured to free the provider of funds from concerns over credit-worthiness of the recipient of funds. The financier relies for payment on assets that are legally isolated from the funds recipient resulting in elimination of bankruptcy risk of the latter.

• Securitization of assets

• Project Finance

Limited recourse or Non-Recourse Financing

Target: • limit or remove liability of a “true” recipient of funds (sponsor in project finance or

originator in securitization)

• reduce or eliminate risk of financier (investor or lender) related to performance or bankruptcy of the

originator (sponsor)

Method: • “True Sale” of Assets (Securitization) • Establishment of a Project SPV

STRUCTURED FINANCE

Features

Credit EnhancementA. In Securitization: All asset-backed securities are credit enhanced to

provide greater investor’s protection against losses (defaults by the obligors), reducing the credit risks of the underlying pool of assets and increasing securities rating. Credit enhancement may be provided by the originator or a third party in the form of a guarantee (by the originator, bank or insurance company), reserve fund or cash collateral (by the SPV), overcollaterization, a revolving facility (bank or the originator), and/or senior/subordinated structures (by the SVP).

B. In Project Finance: Sponsor’s or third party’s security in the form of pledge, mortgage, guarantee, including performance guarantee, letter of credit, and/or a contingent equity commitment.

STRUCTURED FINANCE

Features

• Financing (loan) to an SPV created (sponsored) by one or several business enterprises for the purpose of building and operating a large-scale, long-term, revenue-generating infrastructure project;

• Loan is repaid from receivables generated by the project under off-take contracts with customers (clients) rather than from assets of sponsors;

• Typical examples include power plants, oil and gas systems, ports, and telecommunications networks. Examples of Ukrainian project finance include:- EBRD’s Euro 75 mln. financing of reconstruction of highway Chop-Striy (2000) and anticipated Euro 100 mln. financing of reconstruction of MO 6 highway Kyiv-Chop;- EBRD’s USD 10 mln. financing of Energy Alliance (sponsored by Western N IS Enterprise Fund) to develop independent energy generating facilities; - USD 171.75 mln. loan from the Government of Japan to the Government of Ukraine to reconstruct Boryspil airport;- Deutsche Bank’s USD 700 mln. and USD 480 mln. loans to the Ukrainian Railroad Agency and the State Road Service of Ukraine under the guarantee of Ukrainian Government for construction of the bridge and highway Kyiv- Odessa.

STRUCTURED FINANCEPROJECT FINANCE

PROJECT FINANCE

repayment

loan

Insurance company

Project SPVLender

Sponsor(s)

Clients / customers

Suppliers / contractors

guarantee

mortgage and pledge of project assets

payments services

receivables

sales / lease

Financial consultant

Law Firms

equity

• Developed embrionically in the 1970s it now represents one of the dominant means of capital formation in the United States and increasingly throughout the world.

• Conversion of assets, such as bank loans and credit receivables, into marketable securities for sale to investors by means of sale of such assets by a bank (originator) to an SPV (issuer) on a non-recourse basis

• Assets transfers where the buyer has recourse against the selling institution are financing, e.g., borrowing secured by assets

• A bank appealing instrument: securitized assets may include residential mortgages, auto loans, leases, credit card receivables

STRUCTURED FINANCE SECURITIZATION OF ASSETS

SPV

assets-backedsecurities (bonds)

Originator /Servicer

Investors

sale of asset

purchase price(securities)

purchase price(assets)

Listing AgentTrustee

Law FirmsLead Manager

Obligors

assets(receivables)

credit

Credit agency

Credit enhancer(s)

credit

ratingenhancement

Administrator

Paying Agent

agency to servicereceivable accounts

pledge ofreceivable account

Enhancement (overcollaterization,

guarantee, loan)

SECURITIZATION OF ASSETS

SECURITIZATION OF ASSETSPARTICIPANTS

• Originator: sells and securitize a portfolio of assets removing them from its balance sheet through a “true sale” operation, such as factoring. Originators are likely to be banks, leasing companies and operators.

• Assets are mortgage receivables, trade receivables, commercial loans, credit card revolving loans, automobile loans, consumer loans, leases (including automobile leases), should be for at least USD 100 mln.

• Obligors (e.g., individual consumers and highly rated corporations) make payments on the securitized assets.

• SPV is a company or trust set up in a tax friendly jurisdiction to be bankruptcy remote. It buys securitisized assets and funds its payment of the purchase price with the capital provided by investors for securities issued by the SVP. The SVP is often managed by the administrator or a corporate service provider.

• Servicer (often originator) is a designated agent of the SPV to administer the portfolio of securitized assets, including collection of receivables.

• Investors are typically large institutional investors. The size and complexity of issues and tickets make asset-backed securities unsuitable for retail investors.

• Lead manager is usually an investment bank advising the Originator on the transaction structuring, managing the issue of securities and liasing with other parties, such as rating agencies, lawyers, and credit enhancers. The lead manager is responsible for advising on the pricing, the underwriting and the placement of securities and is responsible for compliance of the issue with applicable securities law and regulation.

• Auditor issues a de-consolidation opinion regarding Originator’s sale of assets under relevant GAAP (IAS).

• Credit Enhancer may be the SPV, the Originator and/or third party providing a guarantee, reserve fund or cash collateral, overcollaterization, and/or senior/subordinated structures to reduce the credit risk of the securitized assets and increase credit rating of the SPV’s securities. A third-party guarantee may be a letter of credit from a bank or a policy from an insurance company.

SECURITIZATION OF ASSETSPARTICIPANTS (continued)

• Trustee (usually a specialist trust corporation or part of a bank) appointed to act on behalf of investors, including controlling cash flows and holding security over securitized assets.

• Law firms. There are usually two sets of law firms, one acting for the lead manager/trustee and the other – for the Organizator. Law firms draft and review the transaction documentation covering all structuring and funding aspects of a transaction, draft offering circular, and issue legal opinions addressing such issues as “true sale” of assets, enforceability, perfection of ownership rights in future receivables, and regulatory issues.

• Rating Agencies. There are three main rating agencies operating in Europe: Fitch Rating Ltd., Moody’s Investors Service Limited, and Standard & Poor’s Rating Group. They (i) provide investors with an independent opinion on the creditworthiness of a debt instrument through a standard matrix of rating levels identified by way of symbols and (ii) periodically survey closed transactions during their lifetime.

• Paying agent is an internationally reputable Bank (often a Trustee’s or Administrator’s affiliate) responsible for making payments on the securities to the investors (usually through a clearing system, such as Clearstream and Euroclear)

SECURITIZATION OF ASSETS

A. Benefits for Originators• Attractive financing alternative at reduced cost of funds as a result of segregation of the

assets from the credit risk and higher credit rating of the securities issues by the SPV

• Effective Management tool based on non-recourse financing

• Ideal way to tap the capital markets on an anymous basis for unrated companies facing difficulty in issuing debt in their own name

• As an off-balance sheet funding technique, it reduces debt to equity ratio by selling assets and using the proceeds to repay more expensive long-term debt (e.g., releasing credit lines for future business)

If Originator is a bank:• Greater liquidity

• Diversification of finance sources and risks

• Improvement of capital indicators (reserve fund, debt ratios)

B. Benefits for Investors• Diversification of investments within an investment portfolio

• Spreading risk between different sectors of economy by reference to assets generated in such sectors

• Comfort from the highest level of structural and legal review

• Transparency of the securitization risks

• Supply of highly rated instruments

SECURITIZATION OF ASSETSLEGAL ISSUES

The concept of factoring under Ukrainian law and general theory of obligations (contacts) appear to accommodate securitization structure.

А. Origination of Assets

• Asset is not void or unenforceable, but there are remedies against the Originator in the event of

the Originator’s breach under an asset underlying contract

• Originator’s liability is not transferred to the SPV (financier)

• Standard asset documentation permit securitization without obligors’ consent

• Assets include present and future receivables (Civil Code, Art. 1078)

- right of future claim is assigned when it arises

SECURITIZATION OF ASSETSLEGAL ISSUES (CONTINUED)

B. Currency Control• Receivables under contracts with non-residents obligors (export factoring) are subject to currency

control limitations, e.g., requirement of a 90-day payment by the Obligor to the Originator’s bank account, and therefore may not be eligible for securitization.

• Receivables payable by Obligors in local currency must be converted to foreign currency by the Servicer for the subsequent transfer to the SPV. However, Ukrainian law currently does not allow such conversion. The solution may be in amending applicable regulation or modification of the transactional structure, e.g. by combining an LPN structure with assignment of assets by the Originator to the borrower (SPV):

LPN loan

funds

SPV(issuer)

SPV(borrower)

Investors Originator Obligors

assets

lender

SECURITIZATION OF ASSETS LEGAL ISSUES (continued)

C. Bankruptcy • Recognition of legal separateness of the SPV from the Originator, even if the SPV is

part of the same group of companies

• Sale of assets to the SPV is not subject to adjustment or unwinding in case if Originator’s bankruptcy, except if conducted (Art. 81 of the Banking law):- within 6 months before appointment of a bankruptcy officer to benefit certain creditors of the Originator;- within 1 year of appointment of a bankruptcy officer and SPV is Originator’s affiliate and the sale does not comply with legal requirements or threatens interests of Originator’s creditors;- within 3 years before appointment of a bankruptcy officer and the purchase

price significantly exceeded the market value of assets or the sale was aimed at keeping assets from the creditors

• Servicer’s bank account pledge. Cash held on pledged accounts will fall into the assets of the Originator in bankruptcy, but will be a priority payment to the SVP as secured creditor

• No disposal of assets following the start of bankruptcy proceedings• If Originator is a leasing company, its bankruptcy may disrupt obligor’s payments.

This requires a scrutinized disclosure of Originator’s business in early stage.

SECURITIZATION OF ASSETS LEGAL ISSUES

D. Banking data secrecy laws

• Disclosure of client’s information to a third party is allowed only upon consent of the Obligor,

except for requests of law enforcers

• A solution may be to enforce law/regulation expressly excepting assets-backed financing from the scope of regulatory limitation (as in the US data protection law).

SECURITIZATION OF ASSETSCOST APPROXIMATION FOR USD 150 MLN. PROJECT*

Lead-manager up to 3% (USD 3-4.5 mln.)

Underwriters up to 0.05% (USD 15,000)

Trustee up to 0.03% (USD 45,000)

Service Agent up to 0.005% - 0.008% (USD 1,500-USD 12,000)

Auditors up to 0.033% - 0.01% (USD 50,000-USD 150,000)

Rating Agencies up to 0.033% - 0.07% (USD 50,000-USD 100,000)

Law Firms 0.2% - 0.33% (USD 300,000-500,000)

Total 3.6% (USD 5.382 mln)

* Information of Business (Ukraine)