FOIA
To support our case’s competition law claim (against GEMMs—Citigroup, HSBC, Morgan Stanley, Royal Bank of Canada—for anti-competitive behavior per the CMA’s 2019 infringement finding) and tort claims (negligence, misfeasance, breach of statutory duty, anti-competitive vertical agreement against HM Treasury/DMO), I have identified FOIA requests that target specific, recorded information held by public authorities (HM Treasury, DMO, CMA), ensuring compliance with FOIA’s scope and exemptions (e.g., section 41 for confidential information, section 23 for HMRC customer data, section 43 for commercial interests) as noted in,,. The requests focus on CMA enforcement, DMO mismanagement, gilt issuance practices, and BO opacity, aligning with “nationaldebt.cocoo.uk” and prior SEARCHLINK findings.[](https://www.gov.uk/government/organisations/hm-revenue-customs/about/publication-scheme)[](https://ico.org.uk/for-organisations/foi/what-is-the-foi-act-and-are-we-covered/)[](https://www.gov.uk/government/publications/hmrc-datalab/confidentiality-and-disclosure-of-information-by-hm-revenue-and-customs-hmrc-policy-and-legal-framework)
**Documents to Request**
– Full text of the CMA’s 2019 infringement decision (Case 50607) against GEMMs, including non-confidential annexes detailing chatroom communications and pricing strategies, to strengthen the competition claim’s legal basis in the CAT, as referenced in and “nationaldebt.cocoo.uk.” [](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)
– DMO’s internal risk assessments for index-linked gilt issuance (2009–2013), specifying inflation exposure calculations, to evidence negligence in the tort claim, per the Debt Management Report’s mention of inflation risk (UK DEBT_250414_154434.txt).
– HM Treasury’s oversight reports on DMO’s gilt auctions (2009–2013), including bidding irregularities or GEMM favoritism, to support tort misfeasance and anti-competitive vertical agreement claims, per NAO’s 2012 report (SEARCHLINK 3).
– DMO’s auction calendar and bidder records for gilt issuances (2009–2013), identifying GEMM participation and contract awards, to support competition and tort claims of procurement bias, per Bidstats.uk findings (SEARCHLINK 5,). [](https://www.whatdotheyknow.com/request/hm_treasury_issuing_money)
– HM Treasury’s correspondence with GEMMs (Citigroup, HSBC, Morgan Stanley, Royal Bank of Canada) on gilt market policies (2009–2013), to uncover regulatory capture, supporting competition claim opacity, per LobbyFacts.eu (SEARCHLINK 6).
– Non-confidential BO data from the DMO’s gilt register, detailing legal holders (2009–2013), to address opacity concerns, per “TI_ BORs.pdf” and, ensuring public interest overrides section 41 exemptions. [](https://www.thelondoneconomic.com/business-economics/who-owns-our-national-debt-its-a-secret-287907/)
– NAO audits of DMO’s compliance with the “full funding rule” (2009–2013), to evidence fiscal mismanagement, supporting tort claims, per Debt Management Report (UK DEBT_250414_154434.txt).
– CMA’s internal reviews of GEMM compliance post-2019 decision, to identify enforcement gaps, supporting the competition claim, per “SEARCHLINK Model.pdf” (Enforcement Gap strategy).
– HM Treasury’s Digital Gilt Instrument (DIGIT) feasibility studies (2023–2025), including supplier contracts, to explore modern procurement parallels, per. [](https://www.gov.uk/government/publications/announcement-of-preliminary-market-engagement-exercise-for-the-digital-gilt-instrument-digit-pilot/additional-information-and-engagement-on-the-digital-gilt-instrument-digit)
– OBR forecasts and correspondence with DMO on index-linked gilt risks (2009–2013), to support tort negligence, per IFS findings (SEARCHLINK 4).
**Questions to Ask**
– What specific risk mitigation measures did DMO implement for index-linked gilts in 2009–2013, given their 35% portfolio share, to address inflation risks noted in NAO reports (SEARCHLINK 3)? This supports tort negligence.
– Which GEMMs participated in DMO’s gilt auctions (2009–2013), and what was the allocation of contracts by value, to identify favoritism, per Bidstats.uk (SEARCHLINK 5)? This supports competition and tort claims.
– What internal HM Treasury communications addressed CMA’s 2019 GEMM infringement (Case 50607), and how did they influence DMO policies, to uncover regulatory inaction, per LobbyFacts.eu (SEARCHLINK 6)? This supports tort misfeasance.
– What percentage of gilts (2009–2013) were held by foreign entities (e.g., banks, governments), and what steps ensured BO transparency, per and “TI_ BORs.pdf”? This supports competition claim opacity. [](https://www.whatdotheyknow.com/request/foreign_holders_of_uk_national_d)
– How did HM Treasury assess DMO’s compliance with the “full funding rule” in 2009–2013, and what discrepancies were reported, per Debt Management Report (UK DEBT_250414_154434.txt)? This supports tort breach of statutory duty.
– What due diligence did DMO conduct on GEMM bidders (2009–2013) to prevent anti-competitive practices, per CMA’s findings ()? This supports anti-competitive vertical agreement claims. [](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)
– What complaints or whistleblower reports were received by HM Treasury/DMO (2009–2013) regarding gilt market misconduct, to uncover suppressed evidence, per “SEARCHLINK Model.pdf” (Snowball strategy)? This supports both claims.
– How did HM Treasury respond to NAO’s 2012–2013 criticisms of DMO’s gilt management, per SEARCHLINK 3, to evidence negligence or misfeasance?
– What conflicts of interest were declared by HM Treasury/DMO officials (2009–2013) regarding GEMM interactions, per “TI_ BORs.pdf”? This supports tort misfeasance.
– What procurement processes governed DIGIT supplier selection (2023–2025), and how did they address transparency, per? This supports tort claim parallels.[](https://www.gov.uk/government/publications/announcement-of-preliminary-market-engagement-exercise-for-the-digital-gilt-instrument-digit-pilot/additional-information-and-engagement-on-the-digital-gilt-instrument-digit)
**FOIA Limitations Considered**
FOIA requests must target recorded information held by public authorities (,). Exemptions may apply: section 41 (confidential information, e.g., gilt holder identities,), section 43 (commercial interests, e.g., GEMM contracts), and section 23 (HMRC customer data,). I ensure requests are specific, avoiding personal data or national security exemptions, and emphasize public interest (e.g., transparency, fiscal accountability) to override section 41, per. Requests exclude MPs (not public authorities,) and focus on HM Treasury/DMO/CMA, which are covered (,). The 20-working-day response deadline is noted ().[](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)[](https://ico.org.uk/for-organisations/foi/what-is-the-foi-act-and-are-we-covered/)[](https://www.thelondoneconomic.com/business-economics/who-owns-our-national-debt-its-a-secret-287907/)
—
### Draft Freedom of Information Request Letter
[Your Full Name]
[Your Address]
[City, Postal Code]
[Email Address]
[Phone Number]
July 18, 2025
Information Rights Unit
HM Treasury
1 Horse Guards Road
London SW1A 2HQ
United Kingdom
Email: informationrights@hmtreasury.gov.uk
Dear Sir or Madam,
Under the Freedom of Information Act 2000, I request the following recorded information held by HM Treasury, the UK Debt Management Office (DMO), or the Competition and Markets Authority (CMA). If this letter does not reach the intended recipient, please forward it internally to the relevant department, as required by EU law (Regulation (EC) No 1049/2001, Article 7), to ensure prompt processing.
Please provide:
1. The full text of the CMA’s 2019 infringement decision (Case 50607) against Gilt-Edged Market Makers, including non-confidential annexes detailing chatroom communications and pricing strategies.
2. DMO’s internal risk assessments for index-linked gilt issuance from 2009 to 2013, specifying inflation exposure calculations.
3. HM Treasury’s oversight reports on DMO’s gilt auctions from 2009 to 2013, including any records of bidding irregularities or favoritism toward Gilt-Edged Market Makers (Citigroup, HSBC, Morgan Stanley, Royal Bank of Canada).
4. DMO’s auction calendar and bidder records for gilt issuances from 2009 to 2013, identifying Gilt-Edged Market Maker participation and contract award values.
5. HM Treasury’s correspondence with Citigroup, HSBC, Morgan Stanley, or Royal Bank of Canada regarding gilt market policies from 2009 to 2013.
6. Non-confidential beneficial ownership data from the DMO’s gilt register, detailing legal holders from 2009 to 2013, in the public interest of transparency.
7. National Audit Office audits of DMO’s compliance with the “full funding rule” from 2009 to 2013.
8. CMA’s internal reviews of Gilt-Edged Market Maker compliance following the 2019 infringement decision.
9. HM Treasury’s feasibility studies for the Digital Gilt Instrument (DIGIT) from 2023 to 2025, including supplier contracts.
10. Office for Budget Responsibility forecasts and correspondence with DMO on index-linked gilt risks from 2009 to 2013.
Additionally, please answer the following questions:
1. What specific risk mitigation measures did DMO implement for index-linked gilts in 2009–2013, given their significant portfolio share?
2. Which Gilt-Edged Market Makers participated in DMO’s gilt auctions from 2009 to 2013, and what was the allocation of contracts by value?
3. What internal HM Treasury communications addressed the CMA’s 2019 Gilt-Edged Market Maker infringement, and how did they influence DMO policies?
4. What percentage of gilts from 2009 to 2013 were held by foreign entities, and what steps ensured beneficial ownership transparency?
5. How did HM Treasury assess DMO’s compliance with the “full funding rule” in 2009–2013, and what discrepancies were reported?
6. What due diligence did DMO conduct on Gilt-Edged Market Maker bidders in 2009–2013 to prevent anti-competitive practices?
7. What complaints or whistleblower reports were received by HM Treasury or DMO from 2009 to 2013 regarding gilt market misconduct?
8. How did HM Treasury respond to National Audit Office criticisms of DMO’s gilt management in 2012–2013?
9. What conflicts of interest were declared by HM Treasury or DMO officials regarding Gilt-Edged Market Maker interactions in 2009–2013?
10. What procurement processes governed Digital Gilt Instrument supplier selection from 2023 to 2025, and how did they address transparency?
Please provide the information in electronic PDF format where possible. If any aspect of my request requires clarification, contact me at [Your Email Address] or [Your Phone Number]. I understand the 20-working-day response deadline under the FOIA and expect compliance unless valid exemptions apply, with a public interest test explained, per the Information Commissioner’s Office guidance (). [](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)
Yours faithfully,
[Your Full Name]
—
**Rationale for Requests and Questions**
The documents and questions target recorded information (e.g., reports, correspondence, audits) held by public authorities, as required by FOIA (). They focus on: [](https://ico.org.uk/for-organisations/foi/what-is-the-foi-act-and-are-we-covered/)
– **Competition Claim**: CMA’s 2019 decision details, GEMM auction records, and BO data to strengthen collusion and opacity evidence, supported by prior findings (SEARCHLINK 6, 8;). [](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)
– **Tort Claims**: DMO risk assessments, NAO audits, and OBR forecasts to evidence negligence/misfeasance, per NAO/IFS reports (SEARCHLINK 3, 4; UK DEBT_250414_154434.txt). Procurement and conflict records address vertical agreement and favoritism, per Bidstats.uk (SEARCHLINK 5).
– **Public Interest**: BO transparency and regulatory gaps align with “TI_ BORs.pdf” and,, overriding section 41 exemptions. [](https://www.whatdotheyknow.com/request/foreign_holders_of_uk_national_d)[](https://www.thelondoneconomic.com/business-economics/who-owns-our-national-debt-its-a-secret-287907/)
– **Sale Potential**: Detailed evidence enhances case valuation for buyers like Fortress (opportunities@fortress.com, “HOW 2 SELL MY LITIGATION.txt”).
**Limitations Addressed**
– **Exemptions**: Avoided personal data (section 23,) and overly broad requests (e.g., all gilt holders,). Specified non-confidential BO data and public interest to counter section 41/43 exemptions (). [](https://www.gov.uk/government/publications/hmrc-datalab/confidentiality-and-disclosure-of-information-by-hm-revenue-and-customs-hmrc-policy-and-legal-framework)[](https://www.thelondoneconomic.com/business-economics/who-owns-our-national-debt-its-a-secret-287907/)[](https://www.thelondoneconomic.com/business-economics/who-owns-our-national-debt-its-a-secret-287907/)
– **Scope**: Focused on HM Treasury/DMO/CMA, which are FOIA-covered (,). Excluded MPs (not covered,). [](https://www.dmo.gov.uk/about/who-we-are/)[](https://www.gov.uk/government/organisations/hm-treasury)[](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)
– **Practicality**: Requests are specific, time-bound (2009–2013, 2023–2025), and format-specified (PDF), ensuring compliance within 20 days (). EU forwarding instruction (Regulation 1049/2001) ensures delivery, per “Spanish Guidance.” [](https://commonslibrary.parliament.uk/making-a-freedom-of-information-request/)
This response provides a precise FOIA request list and letter, leveraging all provided documents and SEARCHLINK findings, critically examining establishment opacity (e.g.,), and avoiding duplication, per your instructions. Let me know if further refinement is needed.[](https://www.thelondoneconomic.com/business-economics/who-owns-our-national-debt-its-a-secret-287907/)
SELF-QUESTIONS – PROCUREMENT
Of course. Based on a synthesis of our entire case history and all the documents you have provided, I can now answer the strategic questions I previously posed, outlining a range of solutions and identifying the most viable path forward for each.
Regarding the question of whether there is any justification for the banks to delay restitution for their proven cartel activity, their predictable answer will be to claim the regulator’s finding did not prove any actual harm was caused. However, the most viable solution is not to simply accept a long and arduous court battle over the quantum of damages. Instead, drawing from the multi-lever strategy in the campaign documents, we will apply pressure on multiple fronts simultaneously. While our follow-on damages claim proceeds, we will lodge parallel complaints with financial regulators concerning the banks’ failure of internal controls and market integrity. We will combine this with a targeted media campaign highlighting the pattern of misconduct. The viable solution is to make the cost of delaying a settlement—in legal fees, regulatory scrutiny, and reputational damage—so high that a swift and fair compensation agreement becomes the only logical commercial outcome for them.
On the critical question of why the government should be held to a lower standard of competence than a private fund manager, their certain defence will be to invoke the non-justiciable nature of high policy. The most viable solution is not to challenge this head-on, but to reframe the issue entirely. We will argue that the standard is not lower, but is enforced through different means which we will activate. We will launch a multi-pronged assault: our tort claim in the High Court will focus on specific administrative negligence; simultaneously, we will petition the Public Accounts Committee, using its own language of accountability and value for money, to investigate the immense taxpayer losses from the flawed debt structure. We will also submit a formal report to the CMA’s Subsidy Advice Unit, arguing that the government’s mismanagement creates market distortions inconsistent with its own subsidy control principles. The viable solution is to create a political and administrative pincer movement, where reforming their processes becomes the path of least resistance.
On the matter of intergenerational fairness, and whether it is lawful to push unsustainable costs onto future generations, the government will dismiss this as a political issue. The most viable solution is to give it legal and international force. Drawing inspiration from the environmental campaign model, we will frame intergenerational equity as a core public interest principle, similar to environmental sustainability, which public bodies have a legal duty to consider. We will submit our findings to international bodies, such as the relevant UN Special Rapporteurs, to internationalise the debate and build pressure. The aim is to create a context where our domestic tort claim is not seen as an isolated, radical action, but as part of a global standard of accountability, making it much harder for a UK court to simply dismiss.
When we pose our tactical questions to the parties, the solutions become clearer still. When we ask the pension funds what they have done to fulfil their fiduciary duty, it is a precursor to offering them our no-risk, fully-funded collective action, making it the most obvious and viable way for them to act. When we ask the public bodies to justify their risk management of inflation-linked debt, their technical answer is less important than the fact of the question being asked. Our viable solution is to use such specific, technical questions in our reports to parliamentary committees, demonstrating a level of expert scrutiny they cannot ignore and forcing them to engage on our terms.
Finally, on the question of our role as mediator, we will ask both parties if a generic mediator could possibly grasp the unique complexities of this dispute. The obvious answer is no. The most viable solution is to position ourselves as the only credible, expert facilitator. Our proposal will not just be to mediate, but to offer a unique, phased dispute resolution process. We would first act as a neutral “expert evaluator,” providing both sides with a confidential analysis of the legal risks and likely damages. This creates a shared, fact-based reality. From that point of common understanding, we can effectively facilitate the final settlement negotiations, having demonstrated that our unique expertise is not a source of bias, but is in fact the indispensable ingredient for reaching a lasting and intelligent resolution for all.
SELF-QUESTIONS – COMPENSATION
Of course. Having developed a series of strategic questions, it is crucial that we now anticipate the range of possible answers and formulate our own view on the most viable solutions. This will prepare us for the complex road ahead, whether it leads to the courtroom or the mediation table.
Regarding the central question of the Gilt-Edged Market Makers’ collusion—why restitution should be delayed when the wrongdoing is already proven—we must anticipate a defensive response. The banks will likely argue that their settlement with the regulator was not an admission that any specific harm was caused, and that any claims for damages are purely speculative. However, a more probable outcome, driven by the immense legal and reputational risk they face, is a negotiated settlement. The most viable solution for all is not a decade of litigation, but the establishment of a global settlement fund to compensate the victims. Our role is to use the leverage of the infringement finding to bring the banks to this point, making a reasonable settlement the only logical business decision for them.
On the question of why the government should be held to a lower standard of competence than a private fund manager, the state’s inevitable response will be to invoke the doctrine of sovereign policy. They will argue that managing a national economy is a political, not a legal, task and is immune from such comparisons. While this is a formidable legal shield, our most viable solution is not to attack it head-on, but to bypass it. We will do this by focusing on specific, operational failures. Our legal argument will be that while the overall decision to borrow is policy, the specific administrative choice to create a debt structure with an extreme and foreseeable vulnerability to inflation was an operational act of negligence. The most viable path forward is to argue not that their policy was wrong, but that their execution of it was negligent, a standard to which any competent administrator should be held.
When we pose the moral and legal question of intergenerational fairness—whether it is lawful to push unsustainable costs onto future generations—the government will again dismiss it as a philosophical matter for democratic debate. The most viable solution this question leads to is not necessarily a direct victory in court on this ground alone, but legislative change. By raising this as a credible legal challenge, we create the political pressure necessary to make a new “Fiscal Legacy Act,” requiring transparent accounting for long-term liabilities, the government’s preferred way to resolve the issue and claim a political victory from the crisis we have created for them. Our legal action becomes the catalyst for a lasting, systemic solution.
When we engage directly with the parties, our questions are designed to lead them towards these solutions. When we ask pension funds what steps they have taken to fulfil their fiduciary duty to recover the cartel-related losses, we are presenting them with a problem to which our fully-funded collective action is the only rational solution. The viability of them joining us is therefore very high. When we ask the banks to propose a mechanism for compensation, we are steering them away from debating their guilt and towards a practical negotiation on the quantum of damages, making a settlement more likely.
When we confront the public bodies with the OBR’s “unsustainable” verdict, their answer will be that this is a forecast, not a legal finding. Our counter is that persisting in a course of action after it has been officially declared unsustainable is the essence of the negligence. The most viable solution here is not a court-ordered change in fiscal policy, but a mediated agreement where the public body commits to specific, measurable improvements in its risk management and transparency frameworks in return for a settlement of our claim. By questioning them on the specific, technical failure to manage inflation risk in the debt portfolio, we make the claim less about abstract policy and more about concrete, provable administrative malpractice, which is far more difficult for them to defend.
Finally, when we pose the questions that position COCOO as the essential mediator, we anticipate that both parties will recognise the truth in them. They know a generic mediator would be lost. The most viable solution is to propose ourselves in a unique, two-stage role. First, as a neutral expert evaluator, providing a confidential “case and damages assessment” to all parties to create a common understanding of the facts and risks. Following that, we can transition to the role of a traditional mediator, facilitating negotiations based on the foundation of shared reality we have built. This approach leverages our unparalleled expertise while cementing the neutrality required to bring all parties to a final, comprehensive settlement.
First, to shape the public and political narrative for our campaign and to frame the mindset of the court, we must pose questions that cut through the complexity. To the public and media, we will ask: when the official regulator has already proven that a cartel of global banks rigged the market for our national debt, is the question really if victims should be compensated, or simply how much they are owed and why there should be any delay? We can also draw a powerful analogy: if a private company that managed your pension were to fail so catastrophically, we would expect accountability and compensation. Why should the standards of competence be any lower for the public bodies managing the entire nation’s finances?
To mobilise our claimant class, our questions will be direct and focused on their duties and their losses. When we approach the pension funds and institutional investors, we will ask: given the definitive finding of cartel activity by the Competition and Markets Authority, what specific steps have you taken to fulfil your fiduciary duty to your members by quantifying and recovering the proven losses from your gilt portfolios? To the wider business community, we will inquire: our research shows that capital costs have been inflated and private investment has been crowded out; have you calculated the excess financing costs your business has borne or the growth opportunities you have been forced to abandon as a result? This encourages them to view the macroeconomic harm as a concrete loss to their own balance sheet.
In a direct legal or mediation setting with the perpetrators, our questions become sharper and more tactical. To the banks, we would begin from a position of established fact: your institutions have already settled with the regulator for this unlawful conduct, so is it now your position that this admitted wrongdoing caused no financial harm to anyone in the market? If you concede that harm was caused, what is your proposal for a fair and efficient mechanism to compensate the victims without resorting to years of costly litigation?
For the public bodies, our questions will probe the line between policy and negligence. We will ask: at what precise point does adhering to a fiscal strategy that your own independent watchdog has officially labelled “unsustainable” cease to be a political choice and become a justiciable act of administrative negligence? We will become more granular: could you provide the specific risk assessments that justified maintaining one of the world’s highest proportions of inflation-linked debt, a structure which created a foreseeable and severe exposure to the subsequent inflation shock? How was that decision consistent with your core objective to manage risk? We will also link the two sides of our case with a question of joint responsibility: given that the exclusive market system you designed and oversaw was proven to have harboured a secret cartel for years, what specific oversight mechanisms failed, and why should the taxpayer be expected to bear the cost of that supervisory failure?
Finally, to position COCOO as the only credible mediator, we will pose strategic questions to all parties. We will ask them to consider: given the unprecedented complexity of this dispute, which intersects competition law, sovereign finance, and public administrative law, do you believe a generic commercial mediator can possess the essential subject-matter expertise to facilitate a credible settlement? Further, we will compel them to confront the reality of the alternative: have you realistically calculated the immense legal costs, the decade or more of litigation, and the severe reputational damage that will inevitably result from fighting this multi-faceted case through the courts? Our final question to them all will be simple: are you open to a confidential process, guided by an expert neutral, that is designed to achieve a rational and certain outcome for all parties, and in a fraction of the time?
Our new Unsolicited Proposal will be framed not as a demand, but as an invitation to avoid a catastrophic legal conflict. It will be presented as a confidential “Mediation and Dispute Resolution Proposal.”
The core of this proposal is a redefinition of the problem. The problem is no longer simply the harm suffered by victims or the failings of perpetrators. Instead, the problem is the existence of a looming, multi-faceted dispute that poses immense and unacceptable financial, reputational, and operational risks to all parties involved. For the institutional investors and business claimants, the risk is decades of uncertain, complex, and costly litigation with no guaranteed outcome. For the banks, the risk is compounding reputational damage, endless legal fees, and the potential for enormous damages awards. For the public bodies, the risk is a crisis of public confidence and a legal challenge that strikes at the heart of their administrative competence. Our proposal will state that conventional litigation is a mutually destructive path, and that a structured, expert-led mediation is the only rational alternative.
Our solution, therefore, is to offer COCOO’s services as the exclusive, neutral mediator for this entire matter. Our unique selling proposition is our unparalleled subject-matter expertise. We will make it clear that standard commercial mediation providers, while skilled in process, lack the deep, granular understanding of competition law in financial markets, the intricacies of sovereign debt structures, and the principles of public administrative law that are all central to this dispute. Our prior investigative work is now reframed as the source of our unique qualification to act as an informed and effective neutral. We understand the technical arguments, the commercial pressures, and the political sensitivities of all sides. This positions COCOO not just as a mediator, but as the only plausible architect of a workable settlement.
The steps to achieve this role are now fundamentally different. Our media campaign will pivot from one of advocacy to one of thought leadership. We will publish a high-level white paper, perhaps titled “Averting a Crisis: A Resolution Framework for the UK’s Sovereign Debt Dispute,” which outlines the immense costs and risks of protracted litigation for all parties and presents a blueprint for a non-adversarial resolution. This establishes our credentials as a neutral and constructive thought leader.
Subsequently, we will dispatch our confidential Mediation Proposal simultaneously to the general counsel of the defendant banks, the Government Legal Department representing the public bodies, and the leadership of the key institutional investors and business associations we have identified as the claimant class. This proposal will outline the principles of a voluntary, non-binding, and strictly confidential mediation process facilitated by COCOO. It will propose a clear framework, a timeline for engagement, and a transparent fee structure for our mediation services, typically to be shared between the parties contingent on reaching a successful settlement.
The final and most critical step is the diplomatic process of securing the agreement of all parties to come to the table. This will involve a series of private, pre-mediation consultations with each party to build trust, demonstrate our neutrality, and establish that we understand their core interests and red lines. Our goal is to have all stakeholders sign a single “Mediation Agreement,” the contract that formally appoints COCOO as the mediator and binds all parties to the process and its rules of confidentiality. Once this agreement is in place, our primary objective is achieved, and we can begin the crucial work of facilitating a comprehensive and lasting settlement that avoids a generation of destructive legal conflict.