Disclaimer :

The Competition DG makes the information provided by the notifying parties in section 4 of Short Form CO available to the public in order to increase transparency. This information has been prepared by the notifying parties under their sole responsibility, and its content in no way prejudges the view the Commission may take of the planned operation. Nor can the Commission be held responsible for any incorrect or misleading information contained therein.

SECTION 4

Description of the concentration

The notified concentration concerns the proposed (indirect) acquisition of joint control within the meaning of Article 3(1)(b) and Article 3(4) of the EU Merger Regulation by (i) Oakley Sotogrande Luxco S.à r.l. (“Oakley Luxco”), a Luxembourg SPV indirectly owned by Oakley Capital V Master SCSp (“Oakley Capital V”), a fund advised by Oakley Capital Limited, the investment adviser to Oakley Capital V (Oakley Luxco and Oakley Capital V, together, “Oakley Capital”) and (ii) funds advised by Eurazeo Global Investor SAS (“Eurazeo” and, together with Oakley Capital, the “Parties”) of I-TRACING Group SAS, including each of I-TRACING Group SAS’s direct and indirect subsidiary undertakings (“I-TRACING”) (the “Proposed Transaction”). The shareholders of I-TRACING would transfer, directly and/or indirectly, to a new holding company (“BidCo”) to be wholly-owned by a new dedicated vehicle (“TopCo”, itself jointly controlled by Eurazeo and Oakley Capital) 100% of the share capital and voting rights of I-TRACING, either by way of sale or contribution. Eurazeo already exercises sole control over I-TRACING pre-transaction and would invest into TopCo (either through a continuation fund with new equity or through currently invested funds rolling over a portion of their shareholding into TopCo) such that Eurazeo and Oakley Capital would jointly control TopCo and therefore I-TRACING post-Proposed Transaction. The Proposed Transaction thus constitutes a concentration under Article 3(1)(b) and Article 3(4) of Council Regulation (EC) 139/2004.

Oakley Capital is a pan-European private investment firm that specializes in investing in businesses across the core sectors of technology, consumer, business services and education. Oakley Capital has assets under management over EUR 10 billion across seven funds. Oakley Capital has a presence in London, Luxembourg, Munich, Madrid and Milan. For further information, please see: www.oakleycapital.com.

Eurazeo SE (“Eurazeo”) is a listed investment company headquartered in Paris, France, with a portfolio of several billions of euros in diversified assets. Its purpose is to detect, accelerate and enhance the potential transformation of companies of all sizes in which it invests. It has three main activities: private equity, private debt and real assets. For further information, please see www.eurazeo.com.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111

I-TRACING is a French cybersecurity solutions company specialising in the provision of cybersecurity consulting services, cybersecurity integration services and cybersecurity managed services. For further information, please see: www.i-tracing.com.

Please see Table 1 below for the country of incorporation of all companies mentioned in the non-confidential summary:

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111