Harbour Fund III G.P. Limited

The Arrangement is the receipt by the Harbour Fund III Limited Partnership (the Fund) of proceeds under individual funding agreements that the Fund will enter into with litigation claimants in a proposed class action against Steel & Tube New Zealand Limited and/or Steel & Tube Holdings Limited (and possibly other steel manufacturing companies) under which the Fund will agree to pay all legal and other costs incurred by the claimants in return for a share of the proceeds.