Common Contracts

SETTLEMENT AGREEMENT BETWEEN BONDHOLDER PLAINTIFFS AND

Settlement Agreement • March 26th, 2020

• Contract Type
  Settlement Agreement
• Filed
  March 26th, 2020

This Settlement Agreement is made and entered into on March 25, 2020 (the “Execution Date”), between Plaintiffs Ellen Gelboim and Linda Zacher (collectively, the “Bondholder Plain- tiffs”), individually and on behalf of the Bondholder Class in the Bondholder Action, and The Royal Bank of Scotland plc (“RBS plc,” now known as NatWest Markets Plc) and defendant The Royal Bank of Scotland Group plc (“RBS Group,” and together with RBS plc, “RBS”), by and through Bondholder Plaintiffs’ Counsel and RBS’s Counsel, respectively. This Agreement is in- tended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof.