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Sep

Sep 2019: Sports Direct – Under earning, undervalued and unloved

September 16, 2019

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Sports Direct – Under earning, undervalued and unloved

Sep 2019 (270p)

 

For clients that are brave enough or open-minded enough to still be interested in our views on Sports Direct we share some new thoughts below. These are mainly in response to a patient and thoughtful read of the company’s recently published accounts and our attendance of the AGM. Hopefully most readers will by now have seen the open letter we wrote to Mike Ashley in August[1]. We also offer some context: relative to 2012, SPD revenues have doubled but its share price is the same. Today we estimate the company to be trading on an EV/EBITDA of 4x and a PE of 6x.

Blood on the high street

Baron Rothchild famously talked about the right time to invest being “when there was blood on the streets”. John Templeton embraced the same logic but with a gentler refrain (saying “be greedy when others are fearful”). Mike Ashley is taking a similarly contrarian and blood thirsty approach to the UK high street.

Price is what you pay – value is what you get

We have spent much time reading Sports Direct’s just published report and accounts – we recommend it to interested investors particularly Ashley’s 16-page CEO letter.

Our findings lend much credence to Ashley’s contrarian vigour. For example:

  • Sports Direct acquired Evans Cycles for £8.7m. Included in the purchase was £7.4m of inventory.
  • Sports Direct acquired House of Fraser for £90m which included £82.8m of inventory.
  • Sofa.com was acquired for a pound. A cursory search of Companies House says this business had c.£1m of stock at the end of its prior financial year.
  • As each of these companies was acquired out of administration (CVA – company voluntary arrangement), Sports Direct is not thus liable for the terms of the legacy lease portfolio. Crucially, SPD can walk away or renegotiate.
  • These deals, and Sports Direct’s £120m sales and leaseback of the Shirebrook distribution centre follow a similar trend: Mike Ashley is going long the UK high street.

SPD sceptics and value-seekers should read the 2019 annual report – in detail.

We are very focussed on the House of Fraser deal, not least because its acquisition brought Sports Direct 4.6m sq.ft. of new city-centre store space over 54 stores. This compares to SPD’s existing UK sports retail estate of 5.6m sq.ft., an estate that still earns SPD a fairly stable £300m of gross cash flow per year – as we will show later.

HoF generated just £300m of revenues last year within SPD compared to c.£800m in each of the last two years for which it filed accounts as an independent business (2016 and 2015). House of Fraser’s £90m annual rental bill was a major factor in its demise – a factor that can be addressed resolutely by Ashley and team. More importantly HoF brings the prime located sites and space SPD’s premiumisation strategy needs. Mike Murray says this plainly:

“Earlier this year, Sports Direct’s head of elevation Michael Murray told the Sunday Times that the company planned to convert 31 stores to the Frasers format — provided it could secure three-year rent-free periods.” – Financial Times[2], August 5th, 2019 (emphasis ours)

We suspect that city by city locations are/have been renegotiated with a view to how each will fit in to supplement or replace the existing SPD store estate at a low rental cost. Additionally Ashley is busy buying up other brands (often for nearly free) to draw in future customers.

@AArmstrong_says • 16h Ashley Armstrong Sports Direct has already shut 8 Jack Wills stores after landlords refuse to cut rents according to @TheCcStarGrcup. SD's Michael Murray said last week it wasn't a "question of what's the right number of stores but what's the right rent". SD pushing for zero rent on some shops   Source: Ashley Armstrong, Times Retail Journalist

Other relevant points to consider:

  1. During the year to June 2019 HoF generated a £50m EBITDA loss within SPD, thus reducing SPD group ‘underling EBITDA’ and PBT.
  2. At group level, the growth in SPD’s headline group OPEX seems worrying. Until you realise that all of the OPEX growth in 2019 was all due to HoF. In fact underlying OPEX actually fell YoY in 2019. At the same time gross margins actually rose 300bps.
Method in his madness

To many the purchase of Evans/HoF, Jack Wills, BHS old stores etc looks ‘scattergun’. To us it looks opportunistic and a way to build scale. That is:

  • Scale in prime high street locations
  • Scale in the breadth of facia that space can be used for: USC, Flannels, Frasers
  • Scale in a wide variety of brands that may draw customers and scale in its efficient distribution network of retail and online fulfilment

Our main focus is to look at the core cash generation of the existing SPD business and how that could rise were an elevation strategy be executed successfully. However the evolvement of the Fraser’s idea (with low rents and owned brands to sell in-house) has echoes of Ashley’s purchase of sportswear brand 15-20 years ago. Any hint of success in this area would catch almost all observers off guard.

Underlying Cash flow is much better than realised

Our attached model on Sports Direct shows that this company is far more profitable than it seems at first glance.

First, a word on provisions: Both your authors have ‘served their time’ analysing gritty cashflow statements both to identify companies which were over-stating earnings and less often those that might be under-earning vs their true cash flows. With such experience under our belts, we are comfortable assessing provisions. There is nothing at all wrong with provisions per se: after all, depreciation is just a provision. But let’s be clear, many provisions are highly subjective to management whims and rarely make the headlines yet they can be vital to understand underlying cashflows and thus valuing businesses.

In the attached model, readers will find our work on the sizeable provisions that SPD has made in recent years. It shows that for the last three financial years SPD has been charging significant non-cash expenses to its Income Statement. These have had the effect to reduce headline profit measures such as EBIT, EBITDA and PBT. These provisions have been taken for a variety of reasons, mostly related to a more prudent assessment of inventory valuation levels and due to the cost of potentially having to exit onerous leases. Both very valid reasons, given the restructuring/repositioning of the SPD group, we might add.

In Figure 1, we outline more detail on the provisions giving both our work to show the effect on profitability and also in our model the significant notes that describe these provisions in the recent report and accounts. (As an aside: the 2019 footnotes are unusually long and suggest that auditors requested the company to fully justify them due to their size and recent year regularity).

Our point in bringing investors’ attention to these items is NOT to suggest that they were/are wrong to be charged. This company is clearly going through significant changes and challenges and thus all the sums provided might well be need to be utilised in the future.

However due to their rising size and regularity and the fact that they are designed to be today’s estimate of future issues that may occur (with property leases exit costs or inventory valuation levels) it is extremely unlikely that they would need to keep being charged at a similar rate to future group’s accounts. AKA – All else being equal, future profitability will be higher.

To get a feel for the future earnings power of this company investors would be better to look with reference to the cash/profit generated before these items were being charged.

The table below acts as a guide as to the effect these charges have had in depressing the headline profitability this group has reported over the last 3 years.

Fig.1: Provisions materially depress SPD reported underlying profits

Source: Sports Direct Report & Accounts/Holland Advisors

For those who might argue isn’t it possible that inventory write-downs/provisions are an every-year occurrence? In response, may we point you to FY16. It is notable that in that year, Sports Direct management deemed the level of provisions as being “fairly stated” and thus did not warrant adding to. It’s not that long ago, when Sports Direct was not building provisions.

Behind the Curtain & Margins of Safety

As Ashley and his team have been allocating cash produced by the business into buying freehold properties, the asset backing for the business has increased especially when compared to the lower share price.

Interestingly, the tangible book value of SPD at April 2019 is now £1.1bn (£1.25bn – £153m goodwill) which is after the deduction of all debt (£826m) AND assuming all provisions would become an actual cash liability. The Market Cap of the company by comparison, at 270p is £1.42bn. (when we stated writing the shares were 235p!). We must of course bear in mind that c. £978m of this tangible book figure comes from the company’s inventory position, but also that there is circa £180m provision carried against it. Also that whilst Ashley might not be most investors’ favourite entrepreneur, he is not known for overpaying for assets! As such, the freehold values that sit on his balance sheet are likely realisable and prudent. In that vein, we also note the company’s depreciation policies (4-10% on freehold properties, and 20-33% on PPE). Given all of this, perhaps it is less surprising that recent stated profits and cash tax paid has been low.

A question arises then, is Ashley really the fool as he is often portrayed as in the media, or, is he a Thorndike-like ‘Outsider’; a maverick entrepreneur who instinctively ‘gets’ value, market power, cash, tax efficiency and contrary thinking – and most of all, doesn’t care what anyone thinks of him (whilst in the process making a fortune in the long-run)….?

Debt, and the cost of Sports Direct’s reinvention

When Mike Ashley first outlined the switch to a premium model (or as he interchangeably calls it ‘Elevation’, ‘next-gen’ or ‘Selfridges of Sport’!) and the move to freehold high street sites, we like other investors, assumed this would be an expensive exercise. Whilst maybe the organic rollout growth of these new stores has been slower than some would have liked, we remind readers that the sizeable HoF square footage SPD now controls does give them a window into a much improved store estate in due course. As does their opportunistic purchase of freehold strategic sites when tenants have defaulted (BHS and HoF Glasgow).

In this regard, the cost that the company has incurred to get to this level of square footage today is interesting to note i.e. it is much lower than we might have once assumed. Debt today is at a reasonable £378m (1.25x EBITDA). Our cashflow table (aka “where did the money go”) in the attached model and Appendix (table 3) is a summary that enables you to see clearly how cash was generated and spent over the past 5 years to end up at this point.

Behind the curtain

We wrote a piece on owner-controlled companies in early 2018 that also spoke specifically about SPD; the report was titles “engine overhaul”. A recent quote by Ashley might seem as if he read the report (unlikely we think).

“Sports Direct is not the future of the company. It provides the engine. These guys are putting the beautiful, shiny new car on the outside,” he says, pointing across the table to Rowley on his right and Murray and Wootton sitting to his left.. “The only thing from SD that’s saveable is the engine. It’s a very reliable sound engine, but they have to put a whole new body on it, make it fantastic, and make it relevant for the next generation. The next generation of consumer does not want the old SD way of shopping, it’s as simple as that.”. – Retail Week[3] (trade magazine), July 2019

Mike’s points are interesting when we consider the new facia the SPD group now provide customers. Elevated products may sell better under USC or Fraser facia than Sports Direct.com. Even so the brand ownership and supply chain will still be the same.

We would unabashedly recommend our note ’Engine Overhaul’ again for putting the situation at SPD today into context. The Sports Direct business model has been taken apart and it is being remodelled. During this period, it is very very hard for outsiders of the company to have almost any idea what the true earnings potential of the company might be and the real risk to different outcomes. However a better understanding what it earns today surely may help us.

The table in the Appendix and the charts in our model that show the historical Margins of SPD and how they compare with JD Sports. We think these give a glimpse behind the curtain. They also show our best guess of what today’s Sports Direct would be earning in a steady state environment. That is, an environment where lease-termination and inventory provisions are not being charged to the P+L, where HoF losses have been curtailed (but is not assumed to make any money) and where CAPEX and tax charges are normalised.

Fig.2: Underlying cash flow under reported

 Source: Holland Advisors (see Appendix for detail)

  • These figures show Sports Direct to be trading on an EV/EBITDA of 4x and a PE of 6x
  • They would also suggest this company is making a return on tangible equity of c20% and an EBIT margin similar to that of its past!
  • NB: current analyst forecasts have SPD making PAT of £100m for the next 3 years. Our work suggests its true PAT (owner earnings) is £227m TODAY (see Appendix)
  • NB: these are not forecasts of a better outlook for SPD they are just a clean look at today’s earnings power.
How is this so? How is SPD underlying cashflow so strong?

Firstly, let’s not forget that Sports Direct, despite losing the high ground (in so-called ‘Ath-leisure wear’) to JD Sports, still operates in a sportswear market that is ultimately a duopoly. Secondly, for all its apparent failings, it remains by far the lowest price operator in the sports market.

Let’s focus on that second point – pricing. We will not re-iterate here all our past comments on SPD and its relative pricing strategy, only stating two:

  1. Firstly that when other companies and brands increased their pricing post the Brexit fall in Sterling, SPD did not. This meant the already sizable gap in its pricing vs. peers like JD Sports was increased further still.
  2. Additionally we have long believed that a future SPD business that is, by-definition, less driven by discounting would also, by-definition, be a higher margin business than the old model. Whilst we accept that the transition period to get to that end point might be complex and difficult this view we think still holds.

Yet any assessment of SPD in recent years shows lower Gross and EBIT margin levels. That is, we believe this company was/is under-earning, possibly to a significant extent. Indeed we think higher margins are logical in a now consolidated UK sportswear market. With that in mind we highlight to readers the margin section of our spreadsheet that shows gross margin in the 2019 period rose 300bp. An extract from the report and accounts helps to understand how this occurred.

“Group gross margin increased to 42.8% from 39.7%, largely due to price resetting, prior year increased inventory provisions and prior year acquisition accounting” – 2019 annual report

This is very important and in isolation might have been seen as far better news by investors were there not so many other factors affecting stated profitability and distracting investors (Belgium tax issues, loss of FD and auditor to name but a few!). For a long while now we have suggested that SPD will take its average pricing up a little and the customer would be none the wiser. Indeed Ashley’s words still ring in our ears from some years ago when he was asked how customers felt about his new product and pricing strategy he responded:

“where else are they going to go?”

Post the collapse of JJB and with JD taking the market into premium price and fashions this observation remains key.

In some ways Ashley is one of the most difficult entrepreneurs we have analysed/invested-in due to his unpredictable nature and lack of access to him and his team. That said, we have always admired his brilliant understanding of market power and when and how to use it. For years he undercut all others with his pricing. As the brands no longer want him to do that, he has pivoted knowing that by gradually moving up-market he can please them and still offers customers value vs. competitors. But in time his profits would be higher crucially because no one is pricing beneath him.

This backdrop and recent rises in gross margins suggest to us SPD has some future untapped pricing power. To put the importance of this point into context we highlight the chart below. It shows how SPD always ran a more efficient organisation than JD when purely looking at OPEX costs. Today clearly these OPEX costs are higher than SPD’s past. However as provisions and one-off HoF costs normalise, we expect the group’s reported EBIT margins will recover strongly as OPEX falls.

Fig.3: Can SPD’s operational efficiency be regained?

 Source: SPD & JD Sports

Rose-tinted glasses off. What (more) could go wrong?

Clearly this is a heading that most other commentators spend a great deal of time on. As we have stated above and hopefully as was made clear by our open (and, we hope, constructive) letter to Mike Ashley, we think there are many things his organisation could be doing better to reduce risks. We highlight two:

Risk #1: Supplier relationships and stock availability.

The company openly admitted this point in their report and accounts:

“We feel our elevation strategy is being delivered in line with the requirements highlighted to us by these brands several years ago, however we feel there remains some scepticism on their part with regards to our commitment to the full roll out of our elevation strategy…

…relationships with some key brands remain challenging where we feel we are not given full access to the product the stores deserve as quickly as we would like” – candid comments in the 2019 annual report (emphasis ours)

Furthermore, when explaining at length why the provisions are of the scale that they currently are SPD also reiterated this point:

…A number of years ago our key third party suppliers said that the Sports Direct Group had to elevate its offering away from a traditional discount model of ‘stack them high sell them low’. As has been well documented in our Annual Reports and in the media in recent years we have been on a programme of serious investment in our elevation strategy including the purchase and superior fit out of freeholds. Even though our third party brand partners by their own admission think we have done a superb job of elevating our stores, we still do not receive as quickly as we would like the premium product we feel the stores deserve. This, combined with our competition getting stronger, increases the risk of us being cut off completely by these suppliers. When we are not providing the right product at the right time…

This is a genuine and dangerous risk to this company. Whilst the Nike and Adidas’ of the world were/are prepared to do trials with SPD in their new store formats it seems the desire to open wider channels of stock supply to SPD is still not fully there. As outsiders we cannot know the exact reason for this. We can only speculate:

  • Do they not trust that Ashley has changed his spots from a discounter?
  • Do they just not need him with other preferred suppliers in his regions selling through well?
  • Or do they not yet take SPD seriously yet as a grown-up counterpart?

The following view we did not air in in our letter to Ashley, but we should have. We think the shortcomings in the groups Finance, Management, PR, IR and other central functions might have wider ramifications for SPD than Mike and his team may realise. Local Nike executives might report up to their superiors that SPD’s in-store product profiling is indeed better, but Nike corporate head office will also see the Finance Director’s sudden departure or the lack of ability to sign an auditor as perhaps signs of unprofessionalism and delay committing to the partnership. Maybe this is understood by Ashley and his team, but the actions of the corporate centre suggest otherwise.

Also whilst we have respect for Mike Murray, would a more senior respected branded industry person/ambassador not be a good point of contact for the senior managers at Nike and Adidas? This is maybe analogous to lobbying. Few companies probably like doing it, but sometimes to get a big counterpart to move to you have to impress them from all sides.

We raised this very question at the AGM last week. The answers to which were we thought helpful. The new Chairman (ex-Nike) talked of significant efforts being made with the brands to ensure they do not judge SPD by some of the reports it gets. When we asked Ashley directly about his referencing of these risks in his CEO report (i.e. lack of quality stock availability) he said the reason for it was he did “not want to overpromise and under deliver.” Whilst we welcome this insight, this area does remain a risk for the company.

Risk #2: Management Capabilities

The more complex the operational challenges SPD faces, the less skilled hands are available to deal with them it seems.

Overall, we found the 2019 report and accounts of SPD to be encouraging as it reveals the real numbers behind the myriad of stories and distractions that take place at this company. Such as what did they pay and really get for the acquisitions they made, or how resilient is the underlying cash generation when so much else is changing.

We were far less impressed with the comments on management depth however.

“Karen Byers has been an invaluable member of the Sports Direct team for over 28 years, however as the focus of the Group moves to an elevated offering, including shop fits, this meant that Karen was no longer able to do the things she loved and was good at for so many years. Many elements at which Karen excelled now fall under the remit of third-party brands as we create the elevated stores they and our customers now demand. We wish her well for the future and consider the door to always be open if she wants to re-engage with the Group in a consultant role” – 2019 annual report

“…Mr Murray acknowledged that his arrival, unusual remuneration arrangements and closeness to Mr Ashley could cause ructions internally. It would be difficult for me as well,” he said when asked about Ms Byers. “If you’ve been part of an operating model that’s not really evolved or changed much for 30 years, it’s just got bigger . . . it’s hard for some people. Even if they want to, it’s difficult to change….But he said that elevation — steering the retailer founded by Mr Ashley away from pile-it-high outlets to a more upmarket offering — had to be about “changing every aspect of the business to modernise it”. – Financial Times, Michael Murray: the man with a mandate to take Sports Direct upmarket, Aug 9, 2019[4]

What attracts us to SPD today is the resilience of its underlying cash earnings power as we have tried to demonstrate above. However with complex tasks ahead of it such as the changing use of HoF space and the premiumisation of the company’s offering into new retail sites we think it striking that the group is losing senior talented executives staff rather than adding to them. The commentary around Ms Byers departure we find unusual and, frankly, weak.

Mike Murray’s promotion and pay must surely play a role here as maybe Ashley’s loyal lieutenants feel they are being usurped in favour of nepotism. Again, as outsiders we cannot really know. Again we will state that nothing Mike Murray has said suggests to us he is anything other than a highly capable individual, but as we outlined in our letter to Mike what this company is trying to do is highly complex and difficult. Ashley and Murray need all the help they can get especially in the areas they may be weak in. £2-5m spent on senior professionals in critical accounting, PR and branding functions twelve months ago we think could have been the difference between Nike fully stocking Sports Direct stores next summer or not. Surely that would have been worth it Mike?

A final observation we will make on skill shortages at the company is the selection of premium ranges in Flannels and Fraser’s. These we assume are also overseen by Mike Murray and his team? High priced branded fashion items is a specialist area. A look around a Flannels store shows how far this offering is from SPD’s core competency. We would feel far happier if SPD had added executive and non-executive depth in these areas. Seemingly it has not.

A word on staying rational and not fooling yourself.

“A lot of other people are trying to be brilliant and we are just trying to stay rational. And it’s a big advantage.”– Charlie Munger, 2017 Berkshire Hathaway Annual Meeting

As investors we are all aware of the pitfalls of confirmation bias – the filtering of information to suit and reinforce one’s pre-existing positions or opinions. A common trait shared by the great investors has been the ability to stay entirely rational, either to retain their position or stance in the face of what seems like new conflicting information or to change their mind based on such new information.

For us as longstanding Sports Direct and Mike Ashley supporters, in the midst of a barrage of seemingly unending and unconventional corporate chaos in the last twelve months, this is an important point to get right.

One of your authors (‘the professional worrier’) has been more resistant to accepting the Sports Direct revival story. Here’s what the worrier wrote in his personal journal back in early August upon reading the results statement:

“Significant restatements in the accounts. Not sure if the accounts can be relied upon. Not fraud, more that the accruals and m&a makes margin analysis moot. What other business has done a complete pivot on its business strategy and succeeded. Would you back M O’Leary to repeat his success if he decided to rebuild from scratch a Virgin Atlantic competitor? No – It’s a completely different strategy. – Worse, it was driven by suppliers – I.e. this business is at the behest of its suppliers – Could all of this be a red herring from the real plan – to counter cycle invest in period of high st distress to avail of huge rent concessions from landlords???? – Does this business have tech at its heart? JD seem more in tune with contemporary marketing techniques. Murray remunerated on his property investment prowess rather than his retailing” – internal Holland notes, August 2019

The point here is that just four weeks after that adlib was written, after more analysed consideration this view changed. In other words, the above initial analyst view clearly reflected emotion, not a rational analysis of the facts. Importantly, we think this is very much how the Market is approaching the Sports Direct story today – with fear, pessimism, scepticism and worse, apathy – all emotion based. By contrast, those few journalists and trade commentators[5] [6] who have had access to Sports Direct offer glimpses of an entrepreneurial culture and retail innovation.

We wrote the open letter to Mike Ashley as supporters who can see much to improve upon. Those improvements are still necessary.

Conclusion: In short – at its core, SPD is still the lowest priced operator in the market

A powerful negative narrative surrounds this company. Against that headwind, SPD generates a quarter of its Enterprise Value in gross cashflow. Additionally millions of customers rely-on Sports Direct as their go-to place for cheap sports and fashionwear. Even though these customers might not find (have found) the stores the prettiest, or staff the most helpful and even though the press and politicians have dragged the business through the mud, they still go there. In doing so they help Ashley and SPD generate £400m of gross cashflow annually. This all demonstrates that SPD has a sticky cash generative franchise and due to its starting prices vs. peers also some likely some future power.

Why do people go to SPD stores? For two reasons:

  1. To save money – The same reason they fly Ryanair or drink in Wetherspoons
  2. Because there is nowhere else to go

The risks we highlight in this report are real and do cause us some nervous reflections on this investment despite the seemingly amazing value on offer. To put them into some context however we found the following quote from the annual report of interest:

“We have continued our share buyback programme during the closed period to 26 July 2019 to continue to signal to the market our belief in the strength of the group. As our elevation strategy continues to materialise we have growing confidence in a successful future for the group in the mid to long term, thus until further notice all future buyback programmes will be up to the maximum daily volume allowed under MAR rules, currently 25%.” – 2019 Annual Report

…As the saying goes – actions speak louder than words! To sign off we will repeat a phrase we used in our letter to Ashley “To be an SPD shareholder in 2019 is to be someone who is backing Mike Ashley and taking the longer view”. Asset backing and the core business cash generation suggests there is likely little downside in these shares today. Whilst there are risks, the fact that some of these are acknowledged by the company openly gives us a little comfort.

We remain optimistic and hopeful that this group’s market position and current investment will see its true earnings power more visibly return. When it does so we think investors will reassess Ashley’s achievements more favourably than the current underlying 6x multiple of earnings today implies. Like the company itself we are very happy to be buyers of these shares.

We remain buyers of SPD.

Andrew Hollingworth & Mark Power

The Directors and employees of Holland Advisors may have a beneficial interest in some of the companies mentioned in this report via holdings in a fund that they also act as advisors to.

Appendix

Appendix 1: Adjusting for Provisions and HoF losses suggest stronger underlying profitability

Source: Holland Advisors, Sports Direct

Appendix 2: Sports Direct vs JD Sports

Source: Holland Advisors, Sports Direct

Appendix 3: Where does the cash come from and go to?

Source: Holland Advisors, Sports Direct

Disclaimer

This document does not consist of investment research as it has not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore even if it contains a research recommendation it should be treated as a marketing communication and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. Holland Advisors is authorised and regulated by the Financial Conduct Authority. This presentation is intended for institutional investors and high net worth experienced investors who understand the risks involved with the investment being promoted within this document. This communication should not be distributed to anyone other than the intended recipients and should not be relied upon by retail clients (as defined by Financial Conduct Authority). This communication is being supplied to you solely for your information and may not be reproduced, re-distributed or passed to any other person or published in whole or in part for any purpose. This communication is provided for information purposes only and should not be regarded as an offer or solicitation to buy or sell any security or other financial instrument. Any opinions cited in this communication are subject to change without notice. This communication is not a personal recommendation to you. Holland Advisors takes all reasonable care to ensure that the information is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. This communication is based on and contains current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of this communication may have been disclosed to the issuer(s) prior to dissemination in order to verify its factual accuracy. Investments in general involve some degree of risk therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investment discussed in this communication may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of this investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. This document is for informational purposes only and should not be regarded as an offer or solicitation to buy the securities or other instruments mentioned in it. Holland Advisors and/or its officers, directors and employees may have or take positions in securities or derivatives mentioned in this document (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manage conflicts of interest in regard to this communication internally via their compliance procedures.

  1. http://www.hollandadvisors.co.uk/cms/resources/hollandadvisors-open-letter-to-spd-final-copy-26919.pdf ↑
  2. https://www.ft.com/content/456ed954-b79e-11e9-96bd-8e884d3ea203 ↑
  3. https://www.retail-week.com/sports-and-leisure/analysis-can-sports-direct-woo-next-generation-of-shoppers/7032533.article?authent=1 ↑
  4. https://www.ft.com/content/3bd16468-ba9e-11e9-8a88-aa6628ac896c ↑
  5. https://www.telegraph.co.uk/business/2019/04/14/godfather-sports-direct-inside-world-mike-ashley/ ↑
  6. https://www.retail-week.com/sports-and-leisure/analysis-can-sports-direct-woo-next-generation-of-shoppers/7032533.article?authent=1 ↑

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Terms and Conditions of Use IMPORTANT LEGAL NOTICE THE FOLLOWING TERMS AND CONDITIONS OF USE (“TERMS OF USE”) APPLY TO YOUR ACCESS TO AND USE OF THE HOLLAND ADVISORS (LONDON) LTD WEBSITE (THE “WEBSITE”). EACH TIME YOU ACCESS OR USE THIS WEBSITE, YOU AGREE TO COMPLY WITH, AND BE BOUND BY, THE TERMS OF USE AND ACKNOWLEDGE THAT WE MAY RELY UPON YOUR AGREEMENT. PLEASE READ THE FOLLOWING TERMS OF USE CAREFULLY AND IF YOU DO NOT ACCEPT ANY TERMS OR CONDITIONS, PLEASE DO NOT ACCESS OR USE THIS WEBSITE. 3. Information on the Website Except where stated otherwise, the information, content and services on this Website (the “Information”) are provided by Holland Advisors (London) Ltd (referred to as “we” and “us”) as at the date indicated on the relevant material. The Information is provided for personal use and information purposes only. The Information does not take account of the investment objectives, financial situation and particular needs of any particular person and is not general advice to any class of persons. Therefore, you should not rely on the Information and should obtain relevant and specific professional advice in making any investment decision. Furthermore, nothing on this Website constitutes or should be construed to constitute: (i) an offer, advice, invitation or solicitation from us or our affiliates to buy or sell any investments or securities, futures, options or other financial instruments; (ii) an invitation or inducement to engage in investment activity or a financial promotion of any kind; or (iii) investment advice or recommendation. 4. Stock exchange prices and exchange rates The prices/values shown on this Website in relation to different underlying securities are based on the prices notified to Holland Advisors (London) Ltd as the last sale price of the relevant securities on the stock exchange on which they are traded as at the time and date shown. Those figures may vary throughout the course of, and between, stock exchange trading days, market trading times and business days in general. Holland Advisors (London) Ltd has not verified the figures with the relevant stock exchange and you should verify the accuracy of those figures separately before relying on them. 5. Permitted users of the Website The laws and regulations of the country from which you access this Website may include restrictions on the distribution of the Information. This Website is not directed at or intended for distribution to or use by any person or entity in any jurisdiction where (by reason of that jurisdiction’s applicable securities laws, person’s nationality, residence or otherwise) such distribution, publication, availability or use of this Website or any part of its contents would be contrary to applicable law or regulation or would subject Holland Advisors (London) Ltd to any registration or licensing requirement within such jurisdiction. If you are such a person or entity, you are not authorised to enter the Website. It is your responsibility to ensure that your use of this Website complies with any restrictions or any applicable local laws regarding use of the Information on this Website. Persons or entities in respect of whom such restrictions apply must not access the relevant pages on this Website. The Information displayed on this Website contains material that may be interpreted by the relevant authorities in the country where you are viewing this Website as a financial promotion or an offer to purchase securities. Accordingly, if you reside in any such country or fall within the scope of any law that seeks to regulate financial promotions in the country of your residence or in the country in which you are viewing this Website, please cease accessing or using this Website immediately. If you are uncertain about your position under the laws of the country in which you are viewing this Website, then you should seek clarification by obtaining legal advice from a lawyer practicing in the country of your residence or in the country in which you are viewing this Website before accessing this Website. You may not use any part of the material or Information on this Website to establish, maintain or provide or assist in establishing, maintaining or providing a stock market for trading in securities. 6. Investment Performance and Accuracy of Information The Site contains material about the past performance of our Funds. The value of an investment in a Fund may go up as well down so that an investor’s investment in a Fund, when redeemed, may be more or less than the original investment amount. By its nature, investment in a Fund managed by Holland Advisors (London) Ltd is only suitable for sophisticated investors who do not require immediate liquidity for their investment, for whom an investment in a Fund does not constitute a complete investment programme and who fully understand and are willing to assume the high risk involved in the investment programme of a Fund. THE PAST PERFORMANCE OF ANY INVESTMENT, INVESTMENT STRATEGY OR INVESTMENT STYLE IS NOT INDICATIVE OF FUTURE PERFORMANCE. Whilst the information contained on the Website has been given in good faith and every effort has been made to ensure its accuracy, the Information may not be complete or accurate for your purposes. This Website and the Information is provided on an “as is” basis and Holland Advisors (London) Ltd may not, and has no obligation to, update the Information or correct any inaccuracy which subsequently becomes apparent. The Information and/or opinions and estimates comprised in the Information may be changed or withdrawn without notice and may become outdated. You, therefore, should verify any information or other material obtained from this Website before you use it. HOLLAND ADVISORS (LONDON) LTD, ITS DIRECTORS OR OFFICERS DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING BY WAY OF EXAMPLE BUT NOT LIMITATION AS TO RELIABILITY, COMPLETENESS, FITNESS FOR PURPOSE OR ACCURACY OF THE INFORMATION ON THIS WEBSITE OR ON ANY THIRD PARTY WEBSITE LINKED TO THIS WEBSITE. IN ADDITION, WE DO NOT REPRESENT OR WARRANT THAT THIS WEBSITE OR THE SERVERS THAT MAKE THE WEBSITE AVAILABLE WILL BE UNINTERRUPTED, ERROR FREE, OR FREE FROM INFECTION, VIRUSES, WORMS OR ANY OTHER HARMFUL CODE WHICH MAY HAVE CONTAMINATING OR DESTRUCTIVE PROPERTIES. YOU ARE FULLY RESPONSIBLE FOR ENSURING PROTECTIVE STEPS TO BE TAKEN SUCH AS VIRUS CHECKING. The Information is assembled from material prepared by Holland Advisors (London Ltd) or its agents but may not include Information made known to Holland Advisors (London) Ltd officers (or agents) subsequent to the date of publication of the Information indicated on the Website. If you use the Information, you do so at your own risk. Please recognise that the previous performance of securities or other instruments does not guarantee or predict future performance. 7. Exclusion of liability TO THE FULLEST EXTENT PERMITTED BY LAW, HOLLAND ADVISORS (LONDON) LTD ACCEPT NO LIABILITY TO YOU OR ANY THIRD PARTY FOR ANY LOSSES OR DAMAGES, INCLUDING, WITHOUT LIMITATION, DIRECT OR INDIRECT DAMAGES, CONSEQUENTIAL OR SPECIAL DAMAGES, LOSS OF USE, DATA OR PROFITS, COSTS OR EXPENSES INCURRED OR SUFFERED BY YOU OR THIRD PARTY, WHETHER IN CONTRACT OR DUE TO NEGLIGENCE OR OTHER TORTIOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH THE ACCESS TO, USE OF, RELIANCE ON, OR PERFORMANCE OF THIS WEBSITE OR ANY INFORMATION CONTAINED ON THIS WEBSITE, WHETHER DUE TO INACCURACY, ERROR, OMISSION OR ANY OTHER CAUSE AND WHETHER ON THE PART OF US, OUR SERVANTS, AGENTS OR ANY OTHER PERSON. NOTHING IN THE TERMS OF USE EXCLUDES, RESTRICTS OR MODIFIES ANY CONDITION, WARRANTY OR LIABILITY WHICH MAY AT ANY TIME BE IMPLIED BY STATUTE OR ANY OTHER APPLICABLE LAW WHERE TO DO SO IS ILLEGAL OR WOULD RENDER ANY PROVISION OF AN AGREEMENT VOID. 8. Third Party Websites We may provide, on our Website, links to websites operated by third parties as a convenience to you. If you use these other sites, you will leave this Website. If you decide to visit any linked site, you do so at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive elements. Holland Advisors (London) Ltd makes no representations, warranties or guarantees of any kind about any of the content of any other website which you may access by hypertext link through this Website. When you access any other website by means of a link from this Website, you should understand that your access to that other website is independent of Holland Advisors (London) Ltd and Holland Advisors (London) Ltd has no control over the content of the website, nor does Holland Advisors (London) Ltd in any way endorse or approve the content of that website. In no event will Holland Advisors (London) Ltd in any way be liable to you or any other person(s) or organisation(s) for loss or damage (whether direct, indirect, consequential, special or other) for any use of any site linked to it by means of hypertext or otherwise. 9. Indemnity You agree to indemnify Holland Advisors (London) Ltd and its officers from and against any claim brought by third parties against Holland Advisors (London) Ltd and its officers as a consequence of your breach of the Terms of Use. Furthermore, if your use of this Website results in the need for servicing, repair or correction of equipment, software or data, you assume all costs thereof. 10. Intellectual Property Rights and Licence The copyright, trade mark or any other intellectual property rights in the Website and the Information are owned by or licensed to Holland Advisors (London) Ltd. You may download or print out a hard copy of individual pages and/or sections of this Website provided you do not remove any copyright or other proprietary notices. Any downloading or other copying from this Website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link to or use for any public or commercial purpose this Website without the prior written permission of Holland Advisors (London) Ltd. Any rights not expressly granted in the Terms of Use are reserved. 11. Operation of the Website You should be aware that the internet, being an open network, is not secure. If you choose to send any electronic communications by means of this Website, you do so at your own risk. Holland Advisors (London) Ltd cannot guarantee that such communications will not be intercepted or changed or that they will reach the intended recipient safely. 12. Privacy Any personal data relating to you will be collected, used and recorded by us in accordance with current data protection legislation, the Terms of Use and our Privacy Policy. You must read our Privacy Policy as it forms part of the Terms of Use. 13. Governing law The Terms of Use are governed by the laws of England and Wales and the courts of England and Wales will have exclusive jurisdiction over any disputes arising under them. 14. Waiver If you breach the Terms of Use and we take no action, we will still be entitled to use our rights and remedies in any other situation where you breach the Terms of Use. 15. Our details This website is owned and operated by Holland Advisors London Ltd. You can contact us at: Holland Advisors London Ltd, The Granary, 1 Waverley Lane, Farnham, Surrey, GU9 8BB. Updated and effective as of  31st March 2024
Disclaimer
Please read the following conditions of use of this website. This website is directed at high net worth experienced investors and institutional investors who understand the risks involved with the investments being promoted and it should not be relied upon by retail clients (as defined by Financial Conduct Authority). The information on this website is issued by Holland Advisors (London) Limited (hereafter referred to as “Holland Advisors”), a limited liability company (7431314) incorporated in England and Wales, which is authorised and regulated by the Financial Conduct Authority (FRN: 538932). This website is for information purposes only and does not constitute an offer or solicitation to buy or sell securities, funds or any other financial instrument. The information is directed inside the United Kingdom and is not directed at any persons in jurisdictions where it would be against local law or regulation.  In particular, information on this site is not directed at any person, partnership or corporation being resident in the United States of America. Holland Advisors disclaims all responsibility if you access or download any information in breach of any law or regulation of the country in which you reside. Information on this site The information provided does not constitute advice. Holland Advisors believes that the sources of the information in this website are reliable. However it cannot and does not guarantee, either expressly or implicitly, and accepts no liability for, the accuracy, validity, timeliness or completeness of any information or data (whether prepared by it or by any third party) for any particular purpose or use or that the information or data will be free from error. Holland Advisors does not undertake any responsibility for any reliance which is placed by any person on any statements or opinions which are expressed herein. Neither Holland Advisors nor any of its directors, officers or employees will be liable or have any responsibility of any kind for any loss or damage that any person may incur resulting from the use of this information. This does not exclude or restrict any duty of liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. All Information may be changed or amended without prior notice although Holland Advisors does not undertake to update this site regularly. Marketing Communications Documents on this site do not constitute investment research as they have not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore, even if they contain research recommendations they should be treated as marketing communications and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. These communications are not personal recommendations to you and any opinions cited are subject to change without notice. Holland Advisors takes all reasonable care to ensure that the information on this site is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. Documents on this site are based on, and contain, current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of these documents may have been disclosed to the issuer(s) prior to dissemination in order to verify their factual accuracy. Investments in general involve some degree of risk, therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investments discussed on this website may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of an investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action. Holland Advisors and/or its officers, directors and employees may have or take positions in securities, funds or derivatives mentioned on this site (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manages these potential conflicts of interest internally via its compliance procedures. Fund Information Parts of this site may refer to Funds managed or advised by Holland Advisors. These are not solicitations to invest and any potential investors should refer to the “Our Funds” section of the website in order to learn more about these Funds and find out how and where to obtain the relevant full legal documentation. Linked Websites This site may be linked to third party websites or contain information provided by third parties. Holland Advisors does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. Holland Advisors does not accept any liability arising out of the information contained on any linked website or Information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. Indemnity You agree to indemnify and defend Holland Advisors, its affiliates and licensors, and the officers, directors, employees, and agents of Holland Advisors and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information. Use of Cookies If you agree to these terms and conditions a “cookie” might be placed on your computer. A cookie is a packet of information that does not identify individual users of a website, but allows the collection of website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). We can use this information for statistical purposes, which allows us to analyse and improve our website. The cookie will expire automatically after 6 months or you can manually remove cookies in your browser settings. Copyright, Trademarks and Other Rights Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Holland Advisors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The information contained herein and any supplemental documentation provided is confidential and should not be copied, reproduced or redistributed without the prior consent of Holland Advisors. Governing Law You agree that your use of this site and any dispute arising from this use is subject to English law and you submit to the jurisdiction of the Courts of England & Wales.
Privacy Notice
This is the privacy notice of Holland Advisors London Ltd our company number is 07431314. Our registered office is at The Halt, Smugglers Way, The Sands, Farnham, Surrey, GU10 1NB.
Introduction
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you. In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’. This notice applies to personal data collected through our website www.hollandadvisors.co.uk. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Data Protection Officer
We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed. If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Claire Brunt at  claire@hollandadvisors.co.uk.
Personal data we process
1. How we obtain personal data The information we process about you includes information:
  • you have directly provided to us
  • that we gather from third party databases and service providers
  • as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly When you use our website, you may provide personal data by submission of data by our Sign Up or Contact Us forms. This can be categorised into the following groups:
  • personal identifiers, such as your first and last names
  • contact information, such as your email address and your telephone number for communication
  • records of communication between us including messages sent through our website, email messages and telephone conversations
  • marketing preferences that tell us what types of marketing you would like to receive
3. Types of personal data we collect from your use of our services By using our website and our services, we process:
  • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
4. Our use of aggregated information We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity. For example, we may aggregate usage information to assess whether a feature of our website is useful. However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice. 5. The bases on which we process information about you The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category. If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information. 6. Information we process with your consent Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, you provide your consent to us to process information that may be personal data. Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us  claire@hollandadvisors.co.uk. 7. Information we process for the purposes of legitimate interests We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:
  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
  • improving our services
  • record-keeping for the proper and necessary administration of our business
  • responding to unsolicited communication from you to which we believe you would expect a response
  • preventing fraudulent use of our services
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting your interests where we believe we have a duty to do so
How and when we process your personal data
8. Your personal data is not shared We do not share or disclose to a third party, any information collected through our website.
Use of information we collect through automated systems
9. Cookies Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date. They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered. They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors. Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them. Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate. The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website. 10. Personal identifiers from your browsing activity Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
Other matters
11. Your rights The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at  http://www.knowyourprivacyrights.org 12. Communicating with us When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service. 13. Complaining If you are not happy with our privacy policy, or if you have any complaint, then you should tell us. When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint. 14. Retention period Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us to provide you with the services you have requested. 15. Compliance with the law Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’). 16. Review of this privacy policy We shall update this privacy notice from time to time as necessary.

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