Website for Shareholders in Permanent TSB Group Holdings plc
INTRODUCTION

January 2015

Dear Shareholder in Permanent TSB Group Holdings plc ("PTSB GH"),

This website has been created for the shareholders in Irish Life & Permanent Group Holdings plc (currently PTSB GH), who collectively had represented 100% of the company's voting share capital, before the ex parte direction order effected by the Irish Minister for Finance (the "Minister") on 26 July 2011 (the "July 2011 Ex Parte Provisional Direction Order") reduced forcibly the stake of the original shareholders to less than 0.8% for the benefit of the Minister.

As you may know, a small group of shareholders in PTSB GH (the "Shareholder Litigants"), led by Piotr Skoczylas of Scotchstone Capital Fund Ltd, has been fighting the Minister / the Irish State in courts regarding, inter alia, the Minister's takeover of the 99.2% of the PTSB GH paid-in capital. The court proceedings against the Minister are still ongoing. However, the Shareholder Litigants have already achieved certain important milestones, including, among others, the following:

Firstly, following a three-week trial, the Irish High Court has been unable to uphold the legality of the July 2011 Ex Parte Provisional Direction Order. On 12 November 2014, the High Court ordered that the Court of Justice of the European Union (the "CJEU") be asked to interpret EU law and, in effect, determine legality of national measures such as the said ex parte provisional direction order. References to the CJEU are rare in Ireland. National courts must follow the CJEU rulings. Consequently, the said ex parte provisional Direction Order of July 2011 will be set aside or varied, if the CJEU rules against the Minister's position.

Secondly, the Irish High Court has recently delivered a ruling (subject to an appeal), the consequence of which is that, should the July 2011 Ex Parte Provisional Direction Order be determined to be illegal due to its incompatibility with EU law, then the PTSB GH shareholders who were affected by the illegality of that direction order may be able to apply for damages. Thus, should you have been affected by the July 2011 Ex Parte Provisional Direction Order, you may be eligible for damages. Specifically, as outlined in more detail on this website, the current state of litigation against the Minister opened a way for the affected shareholders in PTSB GH to potentially claim in due course damages estimated to be at least €1.8 per share (excluding damages that are non-calculable). Please note that if you were a shareholder in PTSB GH on 26 July 2011, you then have been affected by the said ex parte direction order and, therefore, may be eligible to apply for the potential damages, even if you sold your shares subsequent to that date. On that basis, you can work out yourself damages that would be potentially awarded to you (if you have been affected by the said ex parte direction order). Assuming that all the affected 135,000 PTSB GH shareholders (mostly from Ireland) joined the respective legal action, and assuming that such a legal action is successful, the total damages attributable to all the affected shareholders would then potentially amount to at least €500 million (excluding damages that are non-calculable).

The following letters have been sent to the largest affected shareholders in PTSB GH:

- Letter dated 7 January 2015 to the largest 200 affected shareholders
- Letter dated 22 January 2015 to the largest 10,000 affected shareholders

In the above context, this website describes briefly (and non-exhaustively) selected key aspects of the legal proceedings against the Minister, which may be relevant for you.

It is critically important that the affected PTSB GH shareholders close ranks. The more united the shareholders are, the more effective they can jointly be in influencing the current situation. All the shareholders may benefit from extending a shareholder coalition of common interest. Please let us know if, following the pending ruling of the Court of Justice of the European Union, you would be interested in seeking the aforementioned potential damages (assuming, inter alia, that the Court of Justice of the European Union rules in favour of the position of the affected shareholders in PTSB GH). Please provide your feedback via the feedback form available at "Your Feedback" tab. Additionally, please do not hesitate to contact us if you have any questions.

The information provided on this website is provided for general information purposes and/or as a general commentary only, and does not constitute a legal or professional advice or an offer or solicitation of any sort. By providing your feedback, you would be expressing your views, which will contribute towards extending a shareholder coalition of common interest.

By using this website, you acknowledge your assent without any limitation or qualification to the information and conditions of use, which are provided in the "Disclaimer" at the bottom of each of the web pages on this website . Please read the "Disclaimer" carefully.

Certain matters related to the court proceedings against the Irish Minister for Finance continue to be subject to further court proceedings. Nothing in this website should be misconstrued as prejudicing  or contradicting the position of the Shareholder Litigants in those court proceedings.

Yours faithfully,

Jonathan Flynn
Managing Partner
Flynn & O’Donnell Solicitors
10 Anglesea Street
Dublin 2, Ireland
E: jonathan.flynn@flynnodonnell.ie
F: +353(1)5327001

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