Apollo's £5.7 billion take-private bid for easyJet

Executive summary

Apollo Management X, L.P., on behalf of certain managed Apollo Funds, announced a Rule 2.4 possible cash offer for easyJet plc at £7.15 per share, valuing the fully diluted ordinary share capital at approximately £5.7 billion. The announcement follows a Castlelake, L.P. proposal at £6.90 per share submitted six days earlier on 4 July 2026. The easyJet Board has confirmed that the financial terms of the Apollo proposal are at a level it "would be minded to recommend" to shareholders (subject to satisfaction of all other terms and a firm Rule 2.7 offer being announced) and that it is "no longer minded to recommend the Castlelake Proposal".

The consideration includes a Stub Equity Alternative under which eligible easyJet shareholders may elect to roll their shareholding into the vehicle through which the Apollo Funds would hold their investment in easyJet. The Stub Equity Alternative would carry voting rights. Committed equity financing is provided by the Apollo Funds. Debt financing is subject to a "highly confident letter" from Barclays — not yet a commitment.

Apollo has until 5.00 PM on 7 August 2026 under Rule 2.6(a) of the City Code to announce a firm intention to make an offer or announce that it does not intend to do so. Pre-conditions to any firm Rule 2.7 announcement include satisfactory completion of due diligence, definitive documentation, unanimous board recommendation, and director irrevocables from each easyJet director holding easyJet shares. Apollo has committed to "all necessary steps" on merger control and EU Foreign Subsidies Regulation clearances, and to a "best endeavours" commitment on other regulatory conditions. The Rule 2.4 announcement does not explicitly address the EU airline ownership and control rule — the requirement under EU Regulation (EC) No. 1008/2008 that the majority (typically greater than 50%) of an EU air-operator-certified airline be owned and effectively controlled by EU nationals. That constraint is the structural elephant in the room.

The financial context matters. Apollo is bidding for a business that reported FY25 headline PBT of £665M — a peak year with +18% headline EBIT growth. But H1 FY26 (six months to 31 March 2026, reviewed) shows a Group headline loss before tax of £(552)M — a £158M year-on-year deterioration in the seasonally weak half. The Q3 FY26 trading update (three months to 30 June 2026) delivered £286M of Q3 headline PBT (up £50M YoY), but analyst consensus for FY26 was cut approximately 5.5% on French air traffic control strikes and elevated fuel costs. Apollo is not bidding at a moment of peak strength. It is bidding into early-stage margin compression, at a strategic-scale premium, on a hopeful medium-term thesis.

On valuation. At Apollo's bid, easyJet trades at 4.0x FY25 lease-adjusted EV/EBITDA — a 7-13% discount to the LCC peer median (Ryanair 5.0x, Wizz 4.2x, median 4.6x LTM / 4.3x FY26E). On management's medium-term £1B PBT ambition, the entry multiple compresses to 3.1x. Exit at even LCC median would deliver 40-50% multiple expansion. Apollo is paying LCC-median-minus-a-sponsor-discount to bet on a medium-term LCC-median-plus outcome — a defensible sponsor entry.

On debt paydown. The illustrative capital structure carries 2.34x traditional / 3.12x lease-adjusted leverage at close — materially lower than a standard sponsor LBO because airline collateral cannot support 5-7x without breaking rating. Operating FCF of £659M-£942M/year (after maintenance capex only; fleet financed separately via aircraft-secured drawdown) drives the £3B term loan to full repayment by FY28 and leverage to 0.53x by FY30. Apollo trades MOIC ceiling for capital-structure durability — Athene-linked permanent capital makes this rational at fund level.

That is the practitioner underwriting question this memo walks: what does Apollo need to believe about upgauging, Holidays, capital structure, regulatory threading, and fuel to earn a defensible return after paying an 81% premium?

The bid at a glance

The 10 July 2026 announcement is a Rule 2.4 possible offer under the City Code on Takeovers and Mergers. Rule 2.4 is a lower disclosure bar than a Rule 2.7 firm offer — it signals bidder intent and locks in a Rule 2.6 put-up-or-shut-up clock but does not commit the bidder to firm terms.

Source: easyJet plc RNS "Statement regarding possible offer for easyJet plc," 10 July 2026.

The premium walk — three reference points

The Rule 2.4 announcement discloses three premium reference points. Practitioners should read all three, not just the headline.

The 81% headline premium is real — but it is being measured off a pre-speculation share price at which easyJet was trading at ~4.5x FY25 headline PBT (~6.0x FY25 P/E after tax). The 22% premium to the 4-year trading high of £5.88 is the more sobering read: even against easyJet's own best public-market valuation of the last four years, Apollo is paying only 22% up. This is the difference between paying a "public-market discount premium" and paying a "strategic-value premium." Apollo is paying the first, not the second.

The Castlelake reference matters too. Castlelake's proposal was £6.90. Apollo topped it by £0.25, or 3.6%. In sponsor-competitive dynamics, a 3.6% topper is a small margin — enough for the Board to pivot, but not enough to make Castlelake's proposal look uncompetitive on its face. What likely tipped the Board is the combination of higher cash price + Stub Equity Alternative + Apollo's aviation-investing pedigree.

Purchase price math — share count and equity value

The Rule 2.4 announcement includes the "Sources and Bases of Information" appendix, which discloses the fully diluted share count.

Source: easyJet plc RNS 10 July 2026, Sources and Bases of Information paragraphs 2 and 3.

The £5.68B fully diluted equity value rounds to the "approximately £5.7 billion" figure disclosed. From equity value to enterprise value, practitioners must add net debt and adjust for lease liabilities. easyJet's H1 FY26 balance sheet (31 March 2026) provides the fresh anchor.

From equity value to enterprise value — the balance sheet walk

An airline balance sheet has three characteristics that shape LBO math: substantial owned aircraft (collateralizable), material lease liabilities under IFRS 16 (a real fixed-cost claim), and material unearned revenue liabilities (customer prepayments). The H1 FY26 interim discloses each.

Source: easyJet H1'26 Combined RNS, 21 May 2026. Selected balance sheet lines.

The practitioner net debt reconciliation:

Enterprise value bridge at Apollo's £5.7B equity:

The lease-adjusted view is the honest one for airline LBOs — lease commitments are debt-equivalent obligations against the aircraft. All entry multiples in the next section are calculated against the £5.2B lease-adjusted EV.

Entry multiples — three earnings periods

The practitioner discipline: never quote an entry multiple against a single earnings period. Airlines are cyclical. The Institute standard is to quote multiples against three references — FY25 (audited peak), FY26 estimate (guidance-implied), and a normalized through-cycle earnings level.

Estimates: D&A add-back approximated from H1 FY26 D&A run-rate. FY26E consensus assumes ~5.5% cut to FY25 for ATC and fuel headwinds. Medium-term reflects management's stated ambition of >£1B Group PBT (H1'26 investor presentation).

Three observations. First, at 4.0x EV/EBITDA on lease-adjusted FY25 EBITDA, Apollo is paying a below-peer-average multiple against a peak year. Second, at 3.1x against management's own medium-term target, the entry looks generous only if that ambition delivers. Third, on P/E, 10.6x on peak FY25 earnings is neither cheap nor rich for a European short-haul carrier — Ryanair trades at ~10-12x, Wizz at 8-10x, IAG at 4-6x. Apollo is paying the top of the LCC range for a business currently underperforming that range.

European airline public-market comparables — is the price defensible?

Entry multiples in isolation prove nothing. The practitioner test is: what would easyJet trade at if it remained public alongside its European peers? Below is the trading comparable set with FY25 actuals or last-reported annual figures, benchmarked against Apollo's proposed EV.

Sources: Bloomberg trading data as of 10 July 2026 pre-market, easyJet H1 FY26 Combined RNS, Ryanair FY26 preliminary results, Wizz Air H1 FY26 interim, IAG H1 2026 interim, Lufthansa Group Q1 2026 report, Air France-KLM Q1 2026 report. All EV values lease-adjusted using IFRS 16 lease liability disclosures. LTM = last twelve months to most recent reporting date. FY26E consensus figures from S&P Capital IQ per each company's fiscal year.

What the comps say about Apollo's bid

Against the LCC peer set (the honest comp). Apollo is buying easyJet at 4.0x lease-adjusted FY25 EBITDA. The LCC peer median is 4.6x LTM and 4.3x FY26E. Apollo is paying a 7-13% discount to the LCC median on EBITDA-based metrics — a defensible sponsor entry point that leaves room for multiple recovery at exit. On P/E, easyJet at 10.6x is essentially at LCC median (10.4x), which reflects easyJet's currently lower FY26E PBT run-rate relative to peak.

Against the full-service peer set (context, not comp). Apollo is paying a 25-29% premium to the full-service median. This is expected and correct — LCCs trade at structural premiums to full-service carriers because of higher unit economics, lower cost per seat, and asset-lighter operating models. The premium is not evidence of overpayment; it is evidence that the LCC categorisation is the right frame.

The multiple expansion sponsor case. If easyJet's medium-term Group PBT target of >£1B lands (upgauging + Holidays + ancillary + private-co discipline delivering by FY30), the entry multiple compresses to approximately 3.1x EV/EBITDA on a medium-term basis. Exit at even the LCC median of 4.3-4.6x would deliver 40-50% multiple expansion. That is the sponsor case in one number.

The Ryanair benchmark. Ryanair is the peer that matters. It trades at 5.0x LTM / 4.7x FY26E — a premium to easyJet at Apollo's bid because Ryanair has stronger unit economics, faster ancillary growth, and superior fleet leverage on A320neo/737MAX. If Apollo executes easyJet toward Ryanair-comparable economics (which is Apollo's implicit underwriting), the medium-term EV/EBITDA gap closes and drives approximately 15-20% multiple expansion at exit alone, before any EBITDA growth.

The two bidders — Apollo vs. Castlelake

The competitive dynamic matters. Castlelake surfaced the auction; Apollo won the auction. Whether Castlelake returns with a higher bid before 7 August depends on: (a) whether Castlelake's aircraft-credit-first thesis can support a materially higher offer, (b) whether the Board's pivot forecloses further engagement, and (c) whether Castlelake is willing to bid competitively against a sponsor with committed equity and a Barclays financing letter.

The latest publicly-filed financials — walked

Under UK Disclosure and Transparency Rules, easyJet is required to publish an audited annual report (within four months of year-end) and a reviewed half-year interim (within three months of half-year end). Quarterly trading updates are voluntary. As of the announcement date, the complete public dataset comprises FY25 audited, H1 FY26 reviewed, and the Q3 FY26 trading update.

FY25 audited (year ended 30 September 2025)

H1 FY26 reviewed (six months ended 31 March 2026)

H1 is structurally the loss-making half. Northern-hemisphere winter demand does not cover fixed cost. What matters is the deterioration versus prior year: airline LBIT worsened by £180M, group LBIT by £164M. Management attributes this to (i) strategic investment in Milan Linate and Rome Fiumicino, (ii) continued capacity growth to drive winter utilisation, (iii) competitive overcapacity in specific beach markets, and (iv) cost inflation weighted toward H1. The March quarter took an additional £25M unexpected fuel cost from Middle East escalation and £32M net increase in legal provisions across historic cases.

Q3 FY26 trading update (three months ended 30 June 2026)

Q3 is the seasonally strong Easter-plus-early-summer quarter. Delivery was in line with consensus but analysts cut FY26 consensus approximately 5.5% on French air traffic control strike costs and elevated fuel costs impacting H2. Management raised H2 fuel CASK guidance to -7% from -8%.

9-month FY26 cumulative build

Q4 is easyJet's strongest quarter historically (July-September peak summer). For FY26 to approach FY25's £665M PBT, Q4 would need to deliver approximately £930M of headline PBT — a run-rate materially above historical Q4 delivery. The reduced analyst consensus implies FY26 PBT of approximately £620-640M — a Q4 requirement of approximately £885-905M, still stretched.

Apollo's strategic thesis — three levers

Apollo's Rule 2.4 announcement is unusually explicit about its strategic thesis. Three levers are named:

Illustrative sources and uses — the sponsor structure

Because this is a Rule 2.4 announcement, not a firm Rule 2.7 offer, the sources and uses table below is illustrative. It shows how a sponsor structure could be capitalized at the disclosed £5.7B equity value. Actual terms will disclose at Rule 2.7 by 7 August 2026.

This structure is illustrative only. Actual terms will be disclosed at Rule 2.7. Committed equity in the Rule 2.4 announcement is provided by Apollo Funds; Barclays has provided a "highly confident letter" for debt (not committed).

Pro-forma leverage — both bases

Airline LBOs are read on two leverage bases. Traditional (excluding IFRS 16 leases) is the credit-committee number for term-loan pricing. Lease-adjusted (including the £995M IFRS 16 lease liability retained) is the honest read for the covenant package and the sponsor economics.

The practitioner read on leverage. 2.3x traditional and 3.1x lease-adjusted are materially lower than the standard sponsor LBO band of 5-7x total leverage. This is not a bug; it is the constraint. Airline collateral cannot support 5-7x leverage without breaking the investment-grade rating that underpins aircraft-secured financing at attractive rates. Apollo trades sponsor equity efficiency (higher check) for capital-structure durability (lower leverage). The result is a lower MOIC ceiling but a more resilient hold profile through cyclical stress — and Apollo's Athene-linked permanent-capital orientation makes this trade rational at fund level. Rating-agency treatment: expect S&P BBB+ / Moody's Baa2 to drop to BB+ / Ba1 crossover immediately at Rule 2.7, with a further one-notch potential downgrade if the EU ownership resolution introduces execution uncertainty.

Key observations. Total debt of £3.0B against LTM (FY25) EBITDA of £1.3B = 2.3x traditional leverage — but on a lease-adjusted basis with the £995M lease liabilities retained, effective leverage is 3.1x. That is lower than a typical sponsor LBO. Reason: airline collateral cannot support the standard 5-7x leverage without breaking rating. The sponsor equity check is correspondingly higher — ~£1.81B, or 23% of total sources.

This shapes returns math substantially. A higher equity check with lower leverage means MOIC and IRR ceilings are lower than a leveraged tech or services LBO. Apollo is not underwriting 25%+ IRRs — they are underwriting mid-teens on stable long-hold capital.

Sponsor return sensitivity — MOIC and IRR under alternate outcomes

Illustrative sponsor MOIC on the £1.81B equity check assuming a 5-year hold, exit at year 5 EBITDA multiple, 100% of FCF to debt paydown, and management's stated £250M cost efficiency programme delivered on schedule. The two variables are (a) how far the medium-term £1B PBT ambition delivers and (b) what exit multiple the market ascribes.

Illustrative. Assumes 5-year hold, EBITDA-multiple exit, 100% FCF sweep to debt paydown, flat interest rates. Not a forecast. See the Baratelli LBO Reference for methodology.

The read: Apollo's underwriting case is likely 75-100% of ambition delivery at 4.5-5.0x exit — producing 2.1-3.1x MOIC and 16-25% IRR. That range is defensible sponsor-scale economics but requires the strategic ambition to substantially deliver. A downside case where only 50% of ambition materialises AND the exit multiple compresses to 4.0x produces a 1.3x MOIC and 5% IRR — below LP hurdle. The sensitivity is stark.

The regulatory path — EU merger control, EU FSR, and the ownership rule

Apollo's Rule 2.4 announcement commits to "all necessary steps" on merger control and EU Foreign Subsidies Regulation and "best endeavours" on other regulatory conditions. Three distinct regulatory regimes are relevant.

1. Merger control

Standard EU/UK merger control review. easyJet operates in multiple EU jurisdictions plus UK. Filings likely required at European Commission (turnover thresholds), UK CMA, and potentially US HSR (given Apollo's US portfolio interactions). Timing: typically 3-6 months to first-phase clearance. Not a material impediment absent horizontal overlaps with other Apollo aviation holdings.

2. EU Foreign Subsidies Regulation (EU FSR)

The EU FSR came into force in July 2023 and applies to concentrations meeting two thresholds: (i) the target has EU turnover greater than €500 million, and (ii) the acquirer has received more than €50 million in foreign financial contributions in the three years prior. easyJet clears the target-turnover test comfortably (EU-attributable revenue ~£6.5-7B), and Apollo Funds' aggregate foreign financial contributions materially exceed €50 million, so FSR notification is mandatory. Apollo's investment vehicle is likely to trigger notification (target turnover threshold met, financial contribution threshold met). This is a newer, more uncertain regime — the European Commission's first cases have involved conditional clearances and remedies. Timing adds 3-4 months to the clearance path. Apollo's explicit commitment to "all necessary steps" here is meaningful — it means Apollo will accept EC-imposed remedies.

3. UK National Security & Investment Act 2021 (NSIA)

Aviation is a “sensitive sector” under the UK NSIA regime. Any acquisition resulting in >25% control of easyJet UK Ltd triggers mandatory pre-completion notification to the UK Investment Security Unit. Timing: 30 working days from acceptance for initial review, extendable by 45 working days. NSIA clearance is a firm condition of a Rule 2.7 announcement in aviation-sector take-privates. Apollo's Rule 2.4 announcement does not mention it, but it will be an explicit condition of the offer document.

4. The elephant — EU airline ownership and control

Under EU Regulation (EC) No. 1008/2008, air carriers holding an EU operating licence must be majority-owned and effectively controlled by EU nationals. The specific test is complex (majority of paid-up capital + effective control over the "acts of the undertaking" + majority of board), but the substantive requirement is that non-EU ownership cannot exceed 50% and cannot exercise effective control.

easyJet operates under multiple licences. easyJet UK Ltd (British AOC, post-Brexit UK-only operations). easyJet Europe (Austrian AOC, EU-wide operations from Vienna). easyJet Switzerland (Swiss AOC, Swiss routes).

The Austrian AOC is the critical one for EU-wide operations. For easyJet Europe to retain the Austrian AOC under EU 1008/2008, majority EU ownership and effective control of the licenced entity must be maintained. Apollo is a US-domiciled asset manager. Absent structural remedies, a straight Apollo take-private would put the Austrian AOC at risk.

The Rule 2.4 announcement is conspicuously silent on this point. Practitioners should watch the Rule 2.7 firm offer document for one of three approaches: (a) segregation of easyJet Europe into a majority-EU-owned holding structure with Apollo as minority economic beneficiary, (b) a strategic EU co-investor commitment (analogous to how Wizz Air was structured with a majority-EU trust arrangement), or (c) a straight political-risk gamble that the AOC survives Apollo control on "effective control" arguments.

The Ryanair Holdings 2019-2021 voting-trust structure is the closest practitioner precedent. Ryanair used a “Restricted Share Register” and voting-trust arrangement to ring-fence non-EU shareholders' voting rights and preserve majority-EU control of the operating AOC despite substantial non-EU economic ownership. IAG’s Spanish holdco + dual UK/Spanish AOC structure is a related precedent, though it primarily solved the post-Brexit UK-loss-of-EU-AOC problem. Any Apollo structure will need equivalent legal engineering — and the Austrian licensing authority (Austro Control / BMK) is the actual regulator whose sign-off matters, not “the EU” in the abstract. Note that easyJet Switzerland operates under a separate Swiss AOC via the EU-Swiss bilateral air-transport agreement and is outside the Reg 1008/2008 regime.

The Stub Equity Alternative — sponsor alignment or dilutive gimmick?

The Rule 2.4 announcement offers eligible shareholders the option to elect the Stub Equity Alternative — roll their existing shareholding into the vehicle through which the Apollo Funds would hold their investment. The terms specify voting rights.

Practitioner read:

What's positive: Voting rights are meaningful. Many sponsor rollover structures grant only economic exposure with no governance. Apollo giving voting rights suggests genuine long-term partnership orientation. Existing large shareholders (particularly Stelios family holdings and long-only institutions with airline expertise) can participate in Apollo's operational upside without cashing out.

What matters in the terms: Rollover valuation basis (par or premium to entry), lockup period, tag-along rights on Apollo exit, ratchet if Apollo underperforms, minority protection covenants (transfer restrictions, RoFR/RoFO, drag-along thresholds), information rights, and the tax treatment of the rollover (UK CGT rollover relief requires specific conditions to defer gain).

What could make it a gimmick: If Apollo values the stub at cash-price parity (£7.15) but structures the vehicle with punitive economics on exit (below-market ratchets, hurdle rates paid to Apollo first, or dilutive management incentive plans), stub holders participate in downside without commensurate upside.

Note that under Rule 24.11 of the City Code, any partial-consideration alternative offered at Rule 2.7 must include an independent valuation of that alternative — so terms will be forced to disclose at the firm-offer stage. The terms remain "subject to further discussion and agreement" — watch the Rule 2.7 firm offer document.

Comparable European airline take-privates and sponsor deals

The pattern: airline sponsor deals are binary. Successful outcomes have been almost exclusively low-cost, structurally-cost-advantaged carriers (Indigo playbook — Wizz, Frontier, Volaris) or specialised niches (Sun Country hybrid ULCC). Full-service and mid-market carriers have struggled — Monarch, Alitalia, and Silver Airways all resolved through bankruptcy. easyJet is closer to the successful cluster (LCC with structural cost advantage) than the failure cluster. But the take-private math at this scale — £5.7B equity — has no direct European precedent. Aer Lingus at €1.4B is the closest European scale-comparable.

The downside case — what breaks Apollo's underwriting

Six risks the practitioner should track.

The Baratelli view

On the price. Apollo's £7.15 offer is defensible but not compelling. The 81% headline premium is measured off a pre-speculation share price at which the market was penalising easyJet for post-COVID cyclical uncertainty and airline-sector volatility discount. The 22% premium to the four-year trading high is the honest read — Apollo is paying only modestly above easyJet's own best public-market valuation.

On the Board's pivot. The pivot from Castlelake at £6.90 to Apollo at £7.15 is defensible on cash-price alone (3.6% higher). The Stub Equity Alternative with voting rights is a meaningful differentiator — Castlelake's aircraft-credit orientation makes an equivalent structure hard to offer. The Board's decision reflects fiduciary discipline plus strategic alignment on Apollo's aviation-investing track record. Fine.

On execution risk. Apollo's underwriting requires three things to substantially land: (a) the £250M upgauging efficiency programme by FY28, (b) Holidays scaling from ~£150M to £450M PBT by FY30, and (c) a workable resolution of the EU airline ownership constraint. Any one of these failing produces sponsor returns below LP hurdle. Two failing is a distressed hold. All three failing is a partial writedown.

On the timing. Apollo is bidding at a specific inflection point. FY25 was the peak. H1 FY26 shows margin compression. Q3 FY26 shows in-line delivery but with FY26 consensus cut. Apollo is not buying an obvious steal — they are buying a franchise business at a moment of operating pressure, on a bet that operating pressure is transient and the long-run compounding thesis is intact.

For shareholders considering the offer. The decision splits three ways. (1) Tender at £7.15 is defensible for mandate-constrained holders — the price is 80% above 90-day VWAP and materially above 4-year public-market range. Most long-only funds cannot hold private-vehicle paper for regulatory reasons, so this is the default path. (2) Elect the Stub Equity Alternative makes sense for natural long-term holders with the mandate flexibility — primarily easyGroup Ltd (Stelios family), family offices, and specialist aviation credit funds. Voting rights and Rule 24.11-mandated independent valuation are meaningful protections. (3) Hold out for a Castlelake topper is a 4-week bet on whether Castlelake returns before the 7 August deadline — and if Apollo walks, the share price probably retraces to £4-4.50, so downside is 30-40%. Base case: mandate-constrained majority tenders; ~10-15% of shares elect stub; hold-out is small and speculative.

On what to watch before 7 August. Three items. First, the firm Rule 2.7 announcement's treatment of the EU 1008/2008 ownership constraint. Second, whether Castlelake returns with a topping bid. Third, whether the definitive Stub Equity Alternative terms disclose stub-holder-favourable protections (economic tag-along, information rights, ratchet mechanics) or whether they read as legally-obligated boilerplate.

The bigger question. This deal will index as the largest sponsor take-private of a European short-haul low-cost carrier ever announced. If Apollo executes, it validates the LBO playbook for aviation at a scale European markets have not previously accepted. If Apollo underdelivers, the failure mode will be visible — and the sector will absorb that as a cautionary tale about paying strategic-scale premia at cyclical inflection points.

Related Baratelli references

Sources

Primary source documents (in order of importance for this memo):

1. easyJet plc, "Statement regarding possible offer for easyJet plc," Rule 2.4 announcement, 10 July 2026.
2. easyJet plc, "H1'26 Combined RNS," 21 May 2026 (six months ended 31 March 2026, reviewed).
3. easyJet plc, "H1'26 Investor Presentation," 21 May 2026.
4. easyJet plc, "H1'26 Results Transcript," 21 May 2026.
5. easyJet plc, Q3 FY26 pre-close trading update, July 2026.
6. easyJet plc, Annual Report and Accounts 2025 (audited, year ended 30 September 2025).
7. Castlelake, L.P. possible offer statement, 4 July 2026 (via easyJet RNS reference).
8. EU Regulation (EC) No. 1008/2008 on common rules for the operation of air services in the Community.
9. EU Foreign Subsidies Regulation (Regulation (EU) 2022/2560), in force July 2023.
10. City Code on Takeovers and Mergers (UK Takeover Code), Rules 2.4, 2.6, 2.7.