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Taxation of Employee - OPTION

Tax on spread at exercise.

Tax on gain at sale.

Sub Deduction - OPTION
Yes, if subsidiary reimburses parent.
Withholding and Reporting - OPTION

Income Tax:
No withholding. Reporting requirements apply.

Social Insurance Contributions:
No.

Securities Restrictions - OPTION

No securities law restrictions or obligations apply.

Non-transferable stock options are not considered a public offering of securities for purposes of the EU Prospectus Regulation.

Exchange Controls - OPTION
Minor employee reporting requirements may apply.
Plan Entitlement - OPTION

Written disclaimer important to reduce risk of plan entitlement. Irregular grants reduce risk.

Exclusion of part-time employees may be deemed discriminatory.

The EU Council Directive 2000/78/EC prohibits age discrimination. Most, if not all, countries have adopted local rules implementing this Directive, which may have an impact on design of equity and other incentive plans in the EU, particularly on age or age and service provisions which give different treatment (e.g., accelerated or continued vesting) for those meeting the criteria.

Data Privacy - OPTION

A valid basis is required to collect, process and transfer personal data.

The EU Data Protection Regulation ("GDPR") became effective in all EU/EEA countries on 25 May 2018. It introduces new requirements and increases the powers of data protection authorities, rights of data subjects and potential penalties for non-compliance.

Accordingly, companies should review their approach to data privacy compliance in the context of equity plan administration and consider on which basis they may be able to rely to collect, process and transfer data.