EMEA Special Sits Weekly: Drahi Waves Magic Wand to Make Altice International Assets Disappear; Not so Public Bond Reporting; Uni Teach-Outs; Rolled Steel – Celsa Bond Return

There are decades where nothing happens; and there are weeks where decades happen – Vladimir Ilyich Lenin

They say that a week is a long time in politics. After the events at the Altice complex last week, it can now be applied to the Leveraged Finance market too.

Too late to be included in the prior EMEA Special Sits Weekly, and by the time many of you might have been sinking into your first beer in the pub, late last Friday, Altice International announced it had dropped down its most valuable asset Altice Portugal into an unrestricted subsidiary raising €750 million of finance (with capacity for a lot more), and had dropped out its Dominican Republic, or DR, business from the group entirely.

Earlier in the week, Altice complex owner Patrick Drahi had launched litigation against Altice USA (aka Optimum Communications) creditors cooperation on antitrust grounds, and repaid the most restrictive TLB-06 debt from a drop-down – paving the way for further LMEs via much increased drop-down capacity, and further aggressive actions.

For the LevFin market, it’s probably the most important set of developments since that fateful week in March 2024, when Drahi dropped his bombshell for Altice France, Ardagh Group dropped down its most valuable asset and Intrum hired advisors for liability management.

Why the owner of the Altice complex chose the final week of November to go ballistic and unleash war on its creditors is unclear. The creditors are hoping/praying (btw never a great investment strategy) that this is just the same playbook as with Altice France and just a way of exerting pressure on them before reaching an agreement that will include them taking a haircut, and some/all of their collateral reinstated with Drahi keeping control of the equity.

Unlike with Altice France, there was no conference call, nor any indication of what Drahi wanted to achieve. And with Luxembourg (where International is domiciled) having less guardrails than France (see our LME jurisdiction piece HERE) the worst-case scenario is that creditors may have seen over 80% of value disappear from view, from the waving of his magic wand.

How could creditors allow this to happen? How did it make sense to allow the basket capacity to drop out assets grow to be far in excess of the enterprise value? And why after Altice France did they stand by and wait for this to happen?

Early trigger warning for long-only investors reading this – I’m about to go on a rant about bond and loan documentation and the erosion of covenants and investor protections – and the lack of collective pushback from investors to stem the tide.

I’ve lost count of the times over the past decade or more, where long-only investors have told me that when they are looking at new issuance it is all about the credit and the sponsor, and that the docs are a distant third in their assessment at time of issue.

The same investors 18 months later ask me to arrange a call with our covenant lawyers to understand how much flexibility there is under the docs, after the same business falls into distress and worse still the sponsor is ghosting them.

Yes, the imagination and creativity of covenant lawyers has been impressive, and it can be difficult to determine what is happening as the documentation is so complex, loose and flexible. The erosion and looseness in many present day deals means that it is not a case of what can you do under the docs, but what cannot you do.

A footnote to this, after the Altice France shock, there were calls for Altice blockers. An expansion of J.Crew and Envision blockers, these are present in 66% of EMEA loans, but just 40% of EMEA high-yield bonds issued in the last four quarters, according to Octus data.

Einstein’s definition of insanity springs to mind when I see this data.

Magic Wand Waved in Altice International Assets Disappearing Act

Altice International senior secured bonds fell by over nine points on the news.

So exactly how much value leaked away from Altice International creditors, how was the vanishing act executed and is there anything they can do about it?

Our legal team, assisted by our credit analysts, produced an excellent analysis piece earlier this week, which sought to address some of these questions – and we have a webinar next Monday at 4 p.m. GMT, hosted by yours truly, to expand on this. To register click HERE.

Last Friday’s release revealed that Altice Portugal SA and Altice Caribbean Sarl were designated as unrestricted subsidiaries under its debt documents. Altice Caribbean is now held by a direct subsidiary of Altice Group Lux Sarl and is no longer consolidated in the Altice International group, whereas the shares of Portugal are still owned by the restricted group.

A subsidiary of Altice Portugal SA completed a private financing transaction, raising €750 million to be used for general corporate purposes, including general working capital and funding of upcoming payments on existing Altice International debt. Altice International has also reserved €2 billion of incremental new debt capacity at Altice Portugal SA.

To designate an unrestricted sub or transfer assets to it, primarily requires sufficient capacity under the restricted payments covenant. Incredibly, under the builder and general RP baskets and permitted investment baskets, we calculated that it has €12 billion of drop-down capacity.

Yes, €12 billion, that is easily in excess of its entire enterprise value. Let that sink in for a moment – how could investors have so badly underestimated and/or misunderstood the implications of allowing this under the docs?

Most of that capacity comes from a builder basket, which began in 2012, based on 100% of EBITDA less 1.4x net interest during the period.

Making restricted payments for dividends or repayment of subordinated/shareholder debt is subject to a 4x test. Sweet, Altice International is at least 5.5x levered.

Not so fast, the builder basket exempts use of the accrued capacity for investments from the ratio test compliance. As a result, the accrued capacity can be used for designating unrestricted subsidiaries without complying with the 4x net leverage test – so rendering the test in practical terms worthless in this instance.

Yikes. We see this a lot in the covenant world – the carveouts and exemptions really matter.

It is worth noting the seriousness of what happens when the assets are dropped down into unrestricted subs. There is no longer any credit support from Portugal or DR; the unrestricted subs are no longer subject to the debt covenants, and they could be spun off (as was the case with the Dominican Republic biz according to the recent announcement), asset sales are permitted and the proceeds are not required to repay debt in or to be reinvested in the restricted group.

Some creditors have hinted to us that they might be able to trigger a change of control based on the latest announcement. But if no assets have been sold or physically transferred – and Drahi owns and controls both restricted and unrestricted groups – it feels like a stretch.

Our legal team, however, doesn’t think it is a slam dunk – but we would caution that a lot of clever lawyers would have looked into this for Drahi – to avoid this being triggered.

The following need to be answered to determine a change-of-control triggering event:

• Does it involve the “direct or indirect sale, lease, transfer, conveyance or other disposition (in one or a series of related transactions)”?;
• Does it relate to “all or substantially all of the assets” of Altice International and its restricted subsidiaries, taken as a whole?;
• Is it to a person other than a Permitted Holder (or a group controlled by one or more Permitted Holders)?; and
• As a change-of-control triggering event for the 101% put right also requires a ratings decline, would a ratings decline occur?

The announcement suggests that no unrestricted HoldCo was set up to buy or transfer the assets. The move to an unrestricted subsidiary is likely to have been done using a magic wand – in indenture speak, files a copy of the board resolution designating the relevant entities and an officer’s certificate that the designations comply with the restricted payments covenant. No direct transfer or sale has happened, but as our legal team notes, assets cannot magically disappear into thin air – and could be captured by the indirect wording at the start of the clause.

The sheer size of the drop-down would suggest that the second bullet could come into play, with Portugal representing 61% of LTM EBITDA – and 75% pro forma the DR spinoff. But the former number might not quite be enough to constitute all or substantially all of the assets.

The definition of permitted holder is broad and even if the unrestricted subsidiary doesn’t qualify as a permitted holder, this could be cured by spinning off the shares to an affiliate, which is not Altice International or any of its subsidiaries. But this move could be subject to dividend paying capacity and 4x net leverage test, and note that the designation has to happen before the spinoff, potentially leaving a brief time between the two actions whereby its owner is not a permitted holder.

A prize to those who are still following all of this (please refer to the disposal proceeds covenants on how this can, or more realistically cannot be paid, or at least within your lifetime).

The change-of-control musings from above could be academic, because even if all the above leads to a trigger, it is still subject to a ratings decline or ratings withdrawal, and one determined within just 60 days of the event. Lacking information or the motive for the moves, the agencies may not be able to act in time.

We may find out more on the creditors thinking later today (Dec. 5.) Gibson Dunn, representing Altice International senior secured creditors, 87% of which have signed a co-op agreement, is hosting a conference call to discuss their options.

The above is skimming the surface of all the issues. What could happen to asset sale proceeds, there is a lot of flexibility on how the funds are to be applied? Who provided the €750 million of financing (the release teasingly talks about a related party)? Could Portugal be used to finance a pari plus financing or back an exchange offer into new paper?

Could there be other legal moves? For example, could creditors file a fraudulent conveyance complaint – similar to what Ardagh creditors did after they dropped down Ardagh Metal Packaging? Could International decide to litigate the co-op – and if so, on what grounds?

And we’ve not even started to think about scenario analysis – but we will leave this section, with our assessment on the worst-case scenario, which leaves only Israel in the restricted group, would result in 30% recoveries to the SSNs and the SUNs being wiped out.

One of the most overlooked covenants for investors is the financial reporting covenant. Over the years this requirement has also been severely eroded. Companies can keep investors at arm’s length and go dark.

It is not only the amount of days from the end of the reporting period that companies have to provide their financials, some now have up to 180 days, which is an age to wait for a company in stress/distress and is likely to be in much more of a mess than it was it was half a year ago – for which period you are only now getting clarity (if you are lucky) on.

As an aside, how frustrating is it for a stressed company’s management to say in late April on the release of its full-year numbers, that it cannot comment on the performance in the first quarter, and you will have to wait (in a fortnight’s time!) for the release of its Q1 numbers?

Some companies are not obliged to host live conference calls, and/or just once/twice a year. Even if they do so, the ability to access the call, and to ask questions can be severely limited.

Which is crazy, as in most high-yield bond documentation, there is an obligation to host calls for investors, prospective investors and analysts. They are public bonds and are in the main listed, and therefore should be subject to exchanges’ reporting requirements.

Despite this, we often see conference calls, which only consist of softball questions from analysts from the lead banks, and from the odd institutional long-only investor. I’m sure they must have other concerns than just the minutiae of movements in working capital?

Rarely do the savvier analysts from credit and hedge funds get an opportunity to ask difficult questions to management – who rarely deviate from the presentation and the script – and if they are asked a difficult question, they either say that they can take this offline (who knows if they deliver on this promise) depriving the rest of those on the call with the information, or claim that they don’t know and will email the answer.

For an increasing number of companies, management asks for emailed questions in advance. This allows them to pick and choose the easier and less controversial questions over the difficult ones.

I’ve lost count of the number of times over the years that a company says it has no further questions, and I get a bunch of investors complaining to me that they were in the queue or had submitted a question, and they were ignored.

Emailed questions and selectively answering those submitted is an orange flag, especially if this is a change of behavior from prior calls. As is access, increasingly stressed/distressed companies are placing barriers to entry and restricting those who can dial in, by asking for proof of holdings and watermarking their presentations. No prospective investors or analysts, please.

Then we have a new phenomenon, and another orange flag, the recorded call. This further restricts the ability of investors to grill management, or at least gauge their body language and the uneasy pregnant pauses. This is also happening for new issues, I’m sure there are older investors who miss the physical bond roadshow (and the tasty food) and the ability to look management in the eye, and to mix with other creditors to gain their views – replaced by the one-on-ones, if you are a lucky winner, as invitations lists are heavily controlled by the leads.

Other gripes include – I’m already feeling much better in writing this rant, it’s so cathartic – companies giving short notice (and out-of-hours announcements for calls) – Casino and Atos were prime offenders, and despite a huge international investor base the former regularly used to host its calls in French and at 7 a.m. too.

Or management saying that it cannot discuss the proposed LME transaction, whose scant details have created fear among non-AHG members, it can only talk about the financials.

Which brings us back to Altice International. There was no presentation over the proposed moves, no ability to grill management about the Q3 underperformance and ask it about the motives of the shareholder and the rationale behind the asset leakage. Seemingly, there is no compulsion for it to engage and explain.

Was this really what investors signed up to at issuance, and part of the implied bargain between companies and their creditors when they agreed to the documents?

One of the most commented upon sections of the Weekly in recent months, was the problems facing the U.K. universities.

Based on subsequent interaction with the market, and undertaking some impressive deep research, my colleague Connor Lovell, this week published his two-part dissertation on the problems facing the sector and the associated legal issues.

Part one is HERE, and part two is HERE.

Time for me to peer review – and with permission – reproduce some excerpts.

The university sector is facing a funding squeeze, after domestic fees were frozen for over seven years, which has left higher education institutions increasingly reliant on foreign students who pay on average 2.6x more:

“The resulting rise in student visas, which peaked in 2022, has become politically fraught for the government, trapped between defending the sector as a major export success, second only to the United States, and voter concerns over immigration. The squeeze has been compounded by rising costs, many of them driven by government policy and a slowdown in student numbers. The sector also faces a demographic crunch from 2030 when the number of 18 year olds is expected to peak and then fall sharply. Universities UK, or UUK, an advocacy organization for 141 British universities, estimates a £2.5 billion reduction in funding to higher education providers in England across two academic years 2024-25 to 2026-27, compared with 2023-24.”

On Nov. 25, MPs were told during a select committee hearing that 50 institutions are at risk of exiting the market, including one before the end of the year. In Scotland, under a different regime, their government had to intervene to bail out the University of Dundee earlier this year.

The concern is to avoid what regulators call “a disorderly exit,” i.e. where a university shuts its doors overnight, which would be a “total disaster” not just for staff and students, but for regional economies.

The aim is to allow teaching to continue to the end of term – a teach-out – allowing students to complete their course modules. But this can take years to complete and courses at different institutions are not standardized, complicating the transfer of students.

“Across the sector, providers are disbanding courses, merging departments and enacting swingeing cuts and redundancies. Queen Mary University maintains a live page of all the redundancies and operational reorganizations taking place across the UK Higher Education, or UKHE, sector HERE. Institutions have also merged, with weaker providers being taken over by stronger ones, but these combinations can take as much as three years to complete. Recent high profile examples include Kent and Greenwich and St George’s and City University.”

The higher education sector has total borrowing of around £13.7 billion in the 2025-26 year, or 27.4% of total income, according to regulator Office for Students, or OfS, forecasts. As well as traditional bank loans provided mostly on an unsecured basis, a chunk of the financing is via private placement notes sold to institutional investors with a maturity wall starting in 2030.

Restructuring and insolvency options for universities are limited by their method of incorporation, as most are incorporated via royal charter. They cannot grant floating charge security, which can lead to a land grab by creditors when in financial difficulty. And they can’t file for administration or use a CVA, as they are not registered under the Companies Act.

This means their options are limited to the appointment of a fixed-charge receiver or compulsory liquidation. Which means there is a terminal insolvency and no duty to students:

“At present, there is a recognition by the sector that there is a ‘regulatory gap’ regarding current insolvency options available to universities. The Department for Science, Innovation & Technology said in its annual report that the government is working on legislative programs to ‘ensure higher education sector access to an insolvency regime.’ This could be a special administration regime, or SAR, tailored to higher education institutions.”

Universities may be what one of my MBA lecturers used to call a “wicked problem” – a complex, persistent and difficult to solve issue, often involving multiple, interconnected social, economic and environmental factors.

And if we see the higher education facility fail, as predicted, it might be a puzzle that the government might be drawn into solving.

Most weeks, the primary issuance fare is dull, mostly a crop of refinancings for familiar names. But the launch of Celsa’s senior secured bond issue piqued my interest, not just given the sector – steel, which is struggling across Europe – but also due to its history and ownership.

The politically sensitive steelmaker was at odds with its creditors from 2017 to 2023, as the controlling family rejected a debt-for-equity swap that would have seen KKR taking control.

Instead, Celsa’s debt was restructured into an Opco/HoldCo structure, with a €900 million OpCo jumbo loan paying 3% due in 2022 and €1.25 billion of HoldCo convertible debt paying 11% PIK due in 2023, which in addition to being convertible to equity, could be elevated and converted into bank debt based on a 4.25x leverage test as part of a rebalancing agreement – whose terms were subsequently triggered.

Income collapsed during Covid and Celsa failed to secure agreement from bank creditors to suspend amortization payments. The company then went to the courts to enact an arcane rebus sic stantibus clause, which stymied attempts by creditors to enforce.

The case was eventually overturned by a Madrid court in January 2021, forcing the company back to the negotiating table. Another stakeholder was brought into the mix, SEPI, the Spanish state fund set up during Covid to support the solvency of strategic companies – which was lined up to provide a €550 million loan, placing creditors at odds with SEPI over the use of proceeds.

By September 2022, the SEPI funds were yet to be disbursed and the loans were in default after failing to repay at maturity. Taking advantage of the new Spanish Restructuring Plan, which had new cramdown provisions and the ability for creditors to submit a plan without company consent, they filed at one minute past midnight on the day that the new regime came into force.

The shareholders were not giving up without a fight. The Rubiralta family claimed there was significant equity value of €6 billion versus the €1.8 billion-€2.8 billion from a court-appointed restructuring expert.

Judge Alvaro Loberto Lavin, said the reports from PwC and Laínez (used to justify the lofty €6 billion valuation) “reach the erratic conclusion that Grupo Celsa is solvent because they eliminate all financial debt from the equation by remitting to a limbo, previously designed by the debtor, the amount of two thousand three hundred million euros that Grupo Celsa owes to its financial creditors.”

Once the debt is amputated through this kind of “accounting surgery,” it can be concluded, as the PwC solvency report does, that “Group Celsa Spain as of the date of analysis (March 31, 2023), does not show any indication of insolvency …”

Sticking with his medical similes, Lavin said in his judgment “it is as if [in giving] a diagnosis a doctor concludes by stating that the patient is in very good health because he presents excellent analytical results, but his heart has stopped working.”

How is the patient today?

The €1.2 billion of new senior secured notes together with an €800 million equity injection from its fund owners, led by SVP and Attestor, will refinance €1.954 billion of existing debt. Net leverage will reduce from 4.3x to 2.6x based on €451 million of pro forma run-rate adjusted EBITDA (€354 million of reported EBITDA).

The difference is explained by a value creation plan that has already delivered €100 million of run-rate EBITDA, and the presentation claims that this will generate around €378 million of unlevered free cash flow on a normalized through the cycle basis.

Celsa claims to be one of the largest vertically integrated producers of recycled low-emission long steel products in Europe, with leading market shares in construction, automotive and industrial sectors. It says it has a well-invested future-proof asset base with scrap electric arc furnace technology “eliminating significant capex risk borne by European blast furnace operators, who will need to invest €100 billion in CapEx to transition to a low-CO2 portfolio.”

This is still a challenging sector, and successful investor-led turnarounds for steel companies are rare. It is worth noting that in late 2024, the company launched a process to find an industrial partner that would retain at least 20% in the business, in line with obligations agreed with the Spanish government as part of the debt restructuring. In April this year, Celsa reached a preliminary agreement with investment holding company CriteriaCaixa to sell the 20% stake, with the deal expected to delever the company and facilitate a refinancing down the line.

However, at the eleventh hour CriteriaCaixa pulled out of the transaction, after a change in the governance. As a result, the refinancing of Celsa’s debt, initially slated for before the summer break, was delayed, and management focused on improving the performance to present prospective investors a good turnaround story.

One positive tailwind is steel safeguarding measures being brought in by the EU next year, to prevent dumping from cheaper cost producers, most notably from China. Once this is implemented, the company believes it will raise EBITDA by €90 million-€140 million per year.

Starved of yielding paper, investors appear to be buying into the positive story rolled out (pun intended) by the leads, with the fixed-rate SSNs being priced at 8.25% and par (from 9% IPTs), and the FRNs at E+550 bps at 99.

Key Analyses

We are still awaiting further announcements and newsflow at Lowell after Arini’s debt for securitization uptier, which is part dependent on a comprehensive recapitalization, which many believe could be implemented via an intercreditor, or ICA drag, by the majority holder of the second lien. But does the value break in the second lien or 1.5 lien? Find out in our analysis HERE

Part two of our restructuring analysis for Kloeckner Pentaplast suggests that the post-emergence story shows little improvement and with weak cash generation and high LTVs, the long-term profile for the German packaging company remains fragile.

Spanish B2B energy transition solutions provider Amara NZero posted a mixed set of third-quarter results with revenue showing some good growth, which did not translate yet into an increase in EBITDA. Its bonds are languishing in the low 20s. Our earnings report is HERE

With LME risk rising in Europe, our legal team has been ramping up production of its LME Risk in Briefs series for stressed/distressed names, with new reports for Reno De Medici and Pfleiderer.

The Altice USA co-ops litigation has not deterred investors from signing new agreements. Our legal analysis on the litigation is available HERE.

Aside from Altice, the biggest story of the week was the commitment from Deutsche Glasfaser sponsors EQT and Omers to put in €1.1 billion of preferred equity into the German fiber optic provider. In return, lenders will provide €600 million of super senior financing. The new funding aims to cover operations until 2032.

Staying in Germany, toymaker Schleich is in discussions with lenders to restructure its capital and transfer ownership from sponsor Partners Group, with Latham & Watkins and Ankura advising the company. Lenders, including Blackstone, Investec, Allianz and HIG Bayside, are preparing to inject new funds as part of the takeover, advised by Linklaters.

A couple of Q3 earnings updates from stressed loan names:

French pharmaceutical solution and specialty chemicals producer Seqens’ earnings were broadly flat year over year in the third quarter ended Sept. 30, but remained far below budget amid continued weakness across all its divisions. Free cash flow remained negative, further depleting the group’s stretched liquidity. Seqens’ €930 million term loan B due October 2028 fell to the high 30s from 48/49 in the wake of the results.

German chemicals company Roehm’s adjusted EBITDA dropped another 22% year over year in the third quarter ended Sept. 30, partly driven by falling prices for its key product methyl methacrylate, or MMA.

Some M&A news for a couple of distressed names:

Shareholders of Norwegian cruise ship operator HRN, previously part of Hurtigruten, are considering different exit options for the business in 2026, including a potential IPO subject to general market conditions and business performance, sources told Octus. Other options include a sale to a sponsor or a strategic investor, or a delay of the sale to 2027.

Lenders to G Network have relaunched a sale process for the London-based full-fiber broadband provider following an unsuccessful attempt by shareholders to sell the company earlier this year. The relaunched process is in the final round, with binding bids due this week.

Our Emerging Markets team was busy covering the impacts of the offer by Ukraine to exchange GDP warrants into C bonds at 134% of par, with six articles – one, two, three, four, five and six.

Some important updates from our legal litigation team:

Some more detail on Waldorf Production’s court schedule, which has much wider market significance, given that a lot of its hopes rest on the case being heard by the Supreme Court. It has secured three High Court dates in February and March 2026 for its proposed English scheme of arrangement. Hearings are penciled in for Feb. 4, March 3 and March 26, 2026.

The February convening hearing comes before the company’s appeal hearing at the U.K. Supreme Court over its failed Part 26A restructuring plan. The Supreme Court appeal, the first for a Part 26A plan, will be heard between Feb. 24 to Feb. 25, 2026.

A bondholder to crypto miner Argo Blockchain C2 Capital Management, has objected to the fairness of the company’s proposed Part 26A restructuring plan, according to letters seen by Octus. C2 contends that the plan is manifestly unfair because it provides senior unsecured noteholders with only 10% equity in the restructured group while existing shareholders, who they say should be subordinated to all creditor claims, will retain a 2.5% stake. Reminds us of Ben Affleck’s famous line in Argo, the film of the same name.

The Netherlands Commercial Court, or NCC, will consider whether some of Selecta’s former creditors have standing to appeal a May 2025 share pledge enforcement at a hearing scheduled for April 16, 2026. Deltroit has since been joined in the Dutch proceedings by CQS, Algebris, Mercer and Fineco Asset Management, who are also plaintiffs in a New York suit alleging a breach of antitrust law, among other things, as reported.

The Royal Court in Jersey has granted an application by Petrofac seeking reciprocal assistance to place Petrofac International Ltd., or PIL, into administration in England. PIL is a subsidiary of the group’s Jersey holdco, Petrofac Ltd., which is already in administration. Petrofac’s application, seeking a letter of request under section 426 of the Insolvency Act 1986, was heard and granted on Nov. 28. The directors of PIL said they will apply to the English High Court to appoint administrators to PIL. Administrators to Petrofac Ltd. from Teneo, have received a handful of bids for the group’s North Sea operations and are attempting a sale by Christmas, according to Sky News.

While we are fixated on the Altice complex, in Asia, we have another huge Chinese Real Estate developer, China Vanke, which is seen as systemically important, to the point where the Shenzen-backed developer has been effectively nationalized by the city. My Asian colleagues detail its fall from grace in the APAC Special Sits Weekly, after having broken the news it was set to address its debt stack via restructuring in late November.

Prices of Graanul, the beleaguered Estonian, wood pellets manufacturer’s bonds rose this week after it signed a memorandum of understanding with a new biofuel client that is expected to be 750,000-1 million tons per year beginning in 2029/2030 for a minimum of 10 years.

Scottish oil services and engineering company John Wood Group said all outstanding conditions under the amend-and-extend implementation deed, the Sidara interim funding agreement and escrow agreement have been satisfied, and the A&E effective date occurred on Dec. 3.

Octus hosted a webinar on Dec. 4 at 10 a.m. GMT to discuss the state of the law and market practice around the English Law Part 26A Restructuring Plan. For the replay, click HERE