New Reporting Requirements Pursuant to Holding Foreign Insiders Accountable Act

Beginning March 18, 2026, each director or officer of a foreign private issuer that has securities registered under Section 12(b) or 12(g) of the Securities Exchange Act of 1934 (“Exchange Act”) must file reports under Section 16(a) of the Exchange Act, pursuant to the Holding Foreign Insiders Accountable Act (enacted December 18, 2025).

To file these reports, the reporting person must have an account on the SEC’s EDGAR system.

If a reporting person does not have an EDGAR account, the person or an authorized representative should prepare and submit the Form ID application for EDGAR access as soon as possible. Extensive instruction and information about Form ID is available at Prepare and Submit My Form ID Application for EDGAR Access. Applicants should allow time to obtain necessary Login.gov individual account credentials to accurately complete Form ID and to secure the required notarized signature and upload the Form ID authenticating document. Please be aware that SEC staff review each Form ID, and applicants should be prepared to provide any additional information staff request as part of that review.

For more information about EDGAR, see Filer Support & Resources or contact Filer Support at 202-551-8900, option 3.