There are no specific rules for core investments and, therefore, the nature of the investment will be the subject of trade negotiations between the parties. It is not uncommon for Hong Kong IPOs, particularly in difficult market conditions, to invite major investors such as well-known institutions, sovereign wealth funds and celebrities to buy shares as part of the investment tranche in order to boost investor popularity and confidence. The greatest advantage available to key investors is the preferred investment – a guarantee that these investors will receive a stock allocation regardless of the final price of the offer. On the effective date or as soon as possible, Spinco enters into an agreement with investors on Spinco and spinco-Warrants shares, the same terms as those set out in Section 6.4 of Cornerstone`s Investment Agreement, but replaces references to (A) „the entity” with Spinco, (B) „New GGP Common Stock” with Spinco Common Stock, C) „Shares” with Spinco shares and (D) „Warrants” or „New Warrants” by Spinco Warrants. Given that issuers and selling shareholders are working to reduce the risk of IPOs in the UK, it is likely that there will be other key investments as the IPO market returns. While the lack of regulation leaves the possibility of developing new market practices in this area, it remains to be seen whether investors will take advantage of market conditions to obtain more favourable terms for their investments and, if so, how these conditions could affect the participation of other potential IPO investors. This potentially affects the liquidity of equities and may be unattractive to other potential investors, despite the potential IPO benefits of a quality investment investor. Liquidity problems can be reinforced if a keystone investor accepts a barrier. The guarantees granted to the investor in the keystone investment agreement are generally very limited, since the investment decision is made on the basis of the information contained in the prospectus.

This reflects the approach taken in the Hong Kong market, but the obligation to treat each IPO investor in the same way does not apply in the UK and the investor could therefore, in theory, strive for broader protection. Glencore`s first public offering in 2011 is often heralded as the introduction of key investments in IPOs in Europe. At the time, commentators were prepared to suggest that key investments – for which one or more investors agree to buy a certain number or value of shares before the IPO – could become the new standard in European markets, reflecting Asian practice.