ESMA Opinion on CONSOB Emergency Measure under SSR

1 In accordance with Article 44(1) of Regulation (EU) No 1095/2010, the Board of Supervisors has adopted the following opinion: I. Legal basis

1. In accordance with Article 27(2) of Regulation (EU) No 236/2012 of the European Parliament and of the Council of 14 March 2012 on short selling and certain aspects of credit default swaps1 (the Regulation), the European Securities and Markets Authority (ESMA) shall within 24 hours of the notification made by a competent authority under Article 26 of that Regulation, issue an opinion on whether it considers the measure or proposed measure is necessary to address the exceptional circumstances as further specified in Article 24 of Commission Delegated Regulation (EU) No 918/2012 of 5 July

II. Background 2. On 16 March 2020, pursuant to Article 26 of Regulation (EU) No 236/2012, the Italian Commissione Nazionale per le Società e la Borsa (CONSOB) notified ESMA of its intention to make use of its powers of intervention in exceptional circumstances and to introduce an emergency measure under Article 20(2)(a) and (b) of that Regulation. 3. In particular, the concerned measure bans any legal or natural person from entering into transactions which might constitute or increase net short positions on all shares traded on the Italian MTA regulated market, for which CONSOB is the relevant competent authority under Directive (EU) No 2014/65 and Regulation (EU) No 236/2012, listed in Annex I to this Opinion (the “Restricted Shares”) as well as to all related instruments relevant for the calculation of the net short position as determined in Annex I, part 1, 1 OJ L 86, 24.3.2012, p. 1–24. 17 March 2020 ESMA70-155-9565 OPINION OF THE EUROPEAN SECURITIES AND MARKETS AUTHORITY of 17 March 2020 on a proposed emergency measure by the Commissione Nazionale per le Società e la Borsa under Section 1 of Chapter V of Regulation (EU) No 236/2012

2 Articles 5 and 6 of Commission Delegated Regulation (EU) No 918/2012. The ban applies to transactions executed both on a trading venue or over the counter. 4. The measure applies to any natural or legal person domiciled or established within the Union or in a third country. 5. The measure does not apply to the following: a. Instruments: index-related instruments if the Restricted Shares represent less than 20% of the index weight (in other words, the ban applies to index-related instruments only if the restricted shares represent 20% or more of the index weight), and b. Activities: market making activities, as defined in Articles 2(1)(k) and 17 of Regulation (EU) No 236/2012, with reference to market makers included on the list maintained by ESMA. c. Transactions: i. the creation of, or increase in, net short positions when the investor who acquires a convertible bond has a delta-neutral position between the equity component of the convertible bond and the short position taken to cover that component; ii. the creation of, or increase in, net short positions where the creation of, or increase in, the short position in shares is hedged by a purchase that is equivalent in terms of proportion on subscription rights. Consob will re-evaluate these exemptions depending on market circumstances and could amend the decision accordingly if the need arises. 6. The proposed measure is expected to enter into force on 18 March 2020 before the opening of the trading session and to expire after the close of the trading session on 18 June 2020. The proposed measure may also be lifted before the deadline, taking into account market conditions. 7. CONSOB indicated that the temporary prohibition of short selling in some shares traded in the MTA regulated market, already adopted pursuant to Article 23 of Regulation (EU) No 236/2012 (Resolution No. 21302 of 16 March 2020), in force on 17 March 2020, will not be renewed. 8. As regards the Global Depositary Receipts on the shares subject to the proposed restrictive measure for which CONSOB is not the relevant competent authority, pursuant to Article 22 of Regulation (EU) No 236/2012, the consent of the relevant competent authority is requested.

3 9. CONSOB considers that the measure is justified by the existence of specific adverse circumstances that constitute a serious threat to market confidence in Italy, especially regarding the confidence of a fair price determination. 10. Namely, following the outbreak of the COVID-19 pandemic in Italy, the Italian financial market has started a strong downside price movement with a high price volatility. The downside price movement increased in the last days, and the Italian main index (the FTSE MIB) fell from the value of 20,799 on 6 March 2020 to the value of 14,894 on 12 March 2020, with an overall decrease of 28.39%. 11. CONSOB notes that in the same period a relevant increase in trading volumes took place, thus the fall of the FTSE MIB value was not caused nor intensified by a lack of liquidity on the market. Namely, from 6 March till 12 March 2020, CONSOB observed an increase of around +22,35% in net short positions reported to CONSOB in Italian shares in respect to FTSE MIB market capitalisation (from 1.19% of 6 March 2020 to 1.46% of 12 March 2020). 12. CONSOB also notes that the 22,35% increase represents only part of the overall increase in net short positions, as net short positions as a result of market making activities are not reported, and, as at the date of the notification, that was also the case for net short positions below the threshold of 0.2% of the issued share capital. 13. Thus, CONSOB believes that the overall increase of net short positions in Italian shares is greater than 22,35%. 14. CONSOB notes that a partial recovery of stock market prices was observed during the trading day of 13 March 2020, when the FTSE MIB value passed from 14,894 to 15.954, with an increase of around 7,12% compared to the closing value of 12 March 2020 due to, inter alia, the ban to short selling adopted by CONSOB pursuant to Article 23 of Regulation (EU) No 236/2012 on 12 March 2020. However, on 16 March 2020 a new relevant fall of the FTSE MIB value was observed. 15. CONSOB also deems that, since the FTSE MIB index includes all main Italian financial issuers (e.g. Intesa Sanpaolo, UNICREDIT, Assicurazioni Generali), and that the prices of these financial issuers have registered the same large downward price movement of the index, the criteria and factors indicated in letter c) of Article 24(1) of Commission Delegated Regulation (EU) No 918/2012 apply. 16. Finally, according to CONSOB, the proposed ban on net short positions should minimise the risk of a loss of market confidence in the Italian financial market.

4 III. Opinion 17. ESMA considered the information provided by CONSOB and is adopting the following opinion on the notified measure, on the basis of Article 27(2) of Regulation (EU) No 236/2012: On the adverse events or developments 18. First, as also indicated in ESMA Decision ESMA70-155-9546 and in the ESMA Opinion (ESMA70-155-9556) on a proposed emergency measure by the Comisión Nacional del Mercado de Valores under Section 1 of Chapter V of Regulation (EU) No 236/2012, ESMA agrees that the outbreak of the COVID-19 pandemic is having serious adverse effects on the real economy and on the financial markets of the Union. As regards the latter, since 20 February 2020 the stock markets in the EU lost up to or more than 30% in value, and all sectors and types of issuers were affected by severe share price falls (details in Annex II). 19. ESMA considers that the adverse situation linked to the COVID-19 has greatly increased the vulnerability of EU financial markets, and there is a concrete risk that the observed downward trend will continue in the coming days and weeks, with the consequent adoption by EU Member States of restrictive measures which impact all economic sectors. 20. Pursuant to Article 20(1)(a), the measure under Article 20(2) of Regulation (EU) No 236/2012 requires the presence of adverse events or developments which constitute a serious threat to financial stability or to market confidence in the Member State concerned. 21. CONSOB considers in its notification that the measure is justified by the adverse circumstances which constitute serious threats to market confidence in Italy, especially regarding the confidence of a fair price determination. 22. Namely, following the outbreak of the COVID-19 pandemic in Italy, Italian stocks were subject to severe downward price movements and high price volatility, and the Italian main index (the FTSE MIB) fell from the value of 20,799 on 6 March 2020 to the value of 14,894 on 12 March 2020, with an overall decrease of 28.39%. CONSOB considers that the steep decrease in the prices is also due to the increase of net short positions on the Italian stocks. Namely, net short positions reported to CONSOB in Italian shares in respect to the FTSE MIB market capitalisation increased by approximately 22,35% from 6 to 12 March 2020 (passing from 1.19% of 6 March 2020 to 1.46% of 12 March 2020). CONSOB further considers that the notified net short positions do not constitute the overall net short positions on Italian stocks, due to the thresholds and exemptions from notification obligations, and therefore estimates that the increase in net short positions in Italian stocks from 6 to 12 March 2020 should be higher than 22,35%.

5 23. Following a partial recovery of stock market prices observed on 13 March 2020, the day on which the ban to short selling adopted by CONSOB pursuant to Article 23 of Regulation (EU) No 236/2012 with Resolution No 21301 of 12 March 2020 was effective, a new relevant fall of the FTSE MIB value was observed in the trading day of 16 March 2020. In that respect, as indicated above, CONSOB temporarily prohibited short sales in some shares traded in the MTA regulated market, pursuant to Article 23 of Regulation (EU) No 236/2012 (Resolution No. 21302 of 16 March 2020), for the trading day of 17 March 2020. 24. ESMA agrees with CONSOB that the severe losses observed, the incertitude as regards the spreading of the COVID-19 contagion and the possible consequent further volatility and downward price spirals risk the loss of market confidence. ESMA also considers that the observed increase in net short positions in the last days may further exacerbate the downward price spirals, thereby further weakening market confidence in Italy. ESMA therefore agrees that the threats to market confidence on the Italian market amount to serious threats. 25. Furthermore, taking also into account that the losses and the increase of net short positions were observed on the main Italian index, ESMA agrees that such circumstances impact market confidence in general, with consequences for all listed issuers. 26. CONSOB also indicated that, since the FTSE MIB index includes all main Italian financial issuers (e.g. Intesa Sanpaolo, UNICREDIT, Assicurazioni Generali), and that the prices of these financial issuers have registered the same strong downward price movement of the index, the situation of substantial selling pressure or unusual volatility causing significant downward spirals in financial instruments related to banks and other financial institutions deemed important to the global financial system, described in Article 24(1)(c) of Commission Delegated Regulation (EU) No 918/2012, is present. 27. ESMA agrees with CONSOB’s assessment that the conditions of Article 24(1)(c) of Commission Delegated Regulation (EU) No 918/2012 are met, and therefore agrees that the serious threats concern also financial stability. In line with that, and given the significant increase of net short positions in Italy, ESMA deems that the prohibition to open or increase net short positions would eliminate a factor that could play a role in exacerbating the fall of prices of shares of financial issuers admitted to trading on Italian trading venues and therefore threaten financial stability in Italy. 28. With reference to the broader EU-markets scenario, ESMA has assessed that there are existing threats to market integrity, orderly functioning of markets and to financial stability. On that basis, on 16 March 2020 ESMA has adopted a decision to temporarily lower the notification thresholds of net short positions to national competent authorities in accordance with point (a) of Article 28(1) of Regulation (EU) No 236/2012 (ESMA70- 155-9546). ESMA considers that its decision will enable national competent authorities to better monitor the existing threats.

6 29. At the same time,ESMA considers that the circumstances described above concerning Italian markets are adverse events or developments which constitute a serious threat to market confidence and financial stability in Italy and are consistent with the adoption of the measure of Article 20(1)(a) of Regulation (EU) No 236/2012. On the appropriateness and proportionality of the measure 30. In order to assess whether the measure would be appropriate and proportionate in relation to the threat, ESMA has analysed how and the degree to which sharp price declines pose a risk to the orderly functioning, integrity and stability of the Italian market as a whole, looking not only at the range of shares affected by the latest market developments but also at the build-up of net short positions on the Restricted Shares. 31. From the analysis of the shares impacted by these sharp price declines, it becomes evident that the downfall spiral spreads across the Italian markets and across different sectors, including systemically important institutions. Such widespread impact is consistent with the global nature of the outbreak of a global pandemic (COVID-19), as announced by the World Health Organisation2 , that has proven to be very serious in Italy. 32. From that perspective, ESMA understands that limiting the scope of its measure to one or several sectors or to a subset of the issuers may not achieve the desired outcome. Without the broad scope applied by this measure CONSOB may have to adopt additional restrictive measures in the near future at a time when their effectiveness may be limited. 33. As also indicated by the data submitted to ESMA by CONSOB, the latest developments in relation to COVID-19, have put an extremely wide range of Italian shares in a situation of vulnerability. In case short-selling strategies start targeting those shares, the prices may drop further potentially triggering downward spirals and further ‘runs’ on the market. 34. ESMA considers that suspending the capacity of market participants in the Italian market to enter into short sales or into transactions with equivalent effect in relation to shares admitted to trading on regulated markets would not have a detrimental effect on the efficiency of financial markets or on investors that is disproportionate to its benefits. ESMA rather deems this measure suitable and adequate to provide an appropriate and uniform level of protection to all Italian issuers and investors and the wider Italian market as a whole. 35. ESMA considers that the measure is less stringent than other more intrusive measures that could adequately address the threat to confidence in the Italian market. A further temporary restriction on short selling according to Article 23 of the Regulation (EU) No 236/2012 would not address the threat to market confidence as it would remain 2 https://www.who.int/docs/default-source/coronaviruse/situation-reports/20200310-sitrep-50-covid-19.pdf?sfvrsn=55e904fb_2

7 applicable for a few days only and would be limited to short selling without covering any opening or increasing of net short positions. 36. Additionally, ESMA notes that the proposed measure does not extend the prohibition to index-related instruments or baskets of financial instruments composed by less than 20% of shares, to market making activity and to short positions entered into to hedge positions on convertible bonds or subscription rights. This is with a view to limit the measure to the strictly necessary scope and not to be overly restrictive to trading strategies of market participants, with particular reference to those ones that provide an important service in terms of increasing liquidity and reducing volatility, particularly relevant in the current situation. ESMA agrees that the appropriateness and proportionality of the measure will be safeguarded by CONSOB’ undertaking to re-evaluate these exemptions depending on market circumstances and to potentially amend the measure accordingly if the circumstances so require. 37. For the above reasons, ESMA considers that the emergency measure proposed by CONSOB under Article 20(2)(a) and (b) of Regulation (EU) No 236/2012 as further specified by Article 24(1)(c) of Commission Delegated Regulation (EU) No 918/2012 in relation to the Restricted Shares is appropriate and proportionate to address the existing threat to market confidence in the Italian market. On the duration of the measure 38. In terms of duration of the measure, ESMA considers that maintaining the prohibition for three months is justified considering the information publicly available at the moment. While CONSOB expressed its intention to lift the ban as soon as the evolution of the situation allows, it does not discard the possibility of extending the measure if the situation so requires. Conclusion: on the necessity of the measure 39. Having considered the adverse situation linked to the COVID-19, the appropriateness, proportionality and justified duration, ESMA considers as necessary the emergency measure proposed by CONSOB under Article 20(2)(a) and (b) of Regulation (EU) No 236/2012 as further specified in Article 24(1)(c) of Commission Delegated Regulation (EU) No 918/2012 in relation to Italian shares. This opinion will be published on ESMA’s website. Done at Paris, 17 March 2020 For the Board of Supervisors

8 Steven Maijoor Chair

9 ANNEX I Restricted Shares ISIN ISSUER IT0001008876 A.S. ROMA IT0001233417 A2A IT0001207098 ACEA IT0001469953 ACOTEL GROUP IT0001382024 ACSM-AGAM IT0005350449 AEDES IT0001384590 AEFFE IT0001006128 AEROPORTO GUGLIELMO MARCONI DI BOLOGNA IT0005216533 AGATOS IT0004720733 ALERION IT0004359037 ALGOWATT IT0005314635 ALKEMY IT0001042297 AMBIENTHESIS IT0004056880 AMPLIFON IT0004998065 ANIMA HOLDING IT0005241192 AQUAFIL IT0004093263 ASCOPIAVE IT0003261069 ASTALDI IT0000084027 ASTM IT0003506190 ATLANTIA IT0001137345 AUTOGRILL SPA IT0000084043 AUTOSTRADE MERID IT0005119810 AVIO IT0003261697 AZIMUT IT0001268561 B&C SPEAKERS IT0005187460 B.F. IT0005244402 BANCA FARMAFACTORING IT0001031084 BANCA GENERALI IT0003188064 BANCA IFIS IT0000074077 BANCA INTERMOBILIARE IT0004776628 BANCA MEDIOLANUM IT0003173629 BANCA SISTEMA IT0005218380 BANCO BPM IT0001033700 BASICNET

10 IT0004412497 BASTOGI SPA IT0005108763 BCA CARIGE IT0000088853 BCA FINNAT IT0005218752 BCA MPS IT0000784196 BCA POP SONDRIO IT0001073045 BCA PROFILO IT0001041000 BCO DESIO BRIANZA IT0001005070 BCO SARDEGNA RISP IT0001479523 BE IT0001223277 BEGHELLI IT0004222102 BIALETTI INDUSTRIE IT0004095888 BIANCAMANO IT0003097257 BIESSE IT0005387995 BIOERA IT0003217335 BORGOSESIA IT0000066123 BPER BANCA IT0005252728 BREMBO IT0000066180 BRIOSCHI IT0004764699 BRUNELLO CUCINELLI IT0001347308 BUZZI UNICEM IT0004329733 CAIRO COMMUNICATION IT0003025019 CALEFFI IT0003127930 CALTAGIRONE IT0001472171 CALTAGIRONE EDIT IT0005252207 CAMPARI IT0005331019 CAREL INDUSTRIES IT0001046553 CARRARO IT0000784154 CATTOLICA ASS IT0005244618 CELLULARLINE IT0001128047 CEMBRE NL0013995087 CEMENTIR HOLDING IT0003023980 CENTRALE DEL LATTE D'ITALIA IT0005010423 CERVED GROUP IT0001446613 CHL IT0003389522 CIA IT0000070786 CIR IT0005117848 CLASS EDITORI NL0010545661 CNH INDUSTRIAL IT0005136681 COIMA RES IT0004105653 CONAFI

11 IT0004991490 COSE BELLE D'ITALIA IT0003121677 CREDEM IT0005319444 CREDITO VALTELLINESE IT0001127874 CSP INT IND CALZE LU0290697514 D'AMICO IT0000076502 DANIELI & C IT0004053440 DATALOGIC IT0001431805 DEA CAPITAL IT0003115950 DE'LONGHI IT0003492391 DIASORIN IT0001469995 DIGITAL BROS IT0001044996 DOVALUE IT0003372205 EDISON R IT0001498234 EEMS IT0005188336 EL.EN. IT0005373417 ELES IT0003404214 ELICA IT0001237053 EMAK IT0005176406 ENAV IT0003128367 ENEL IT0004356751 ENERVIT IT0003132476 ENI IT0005084717 EPRICE IT0005312027 EQUITA GROUP IT0001157020 ERG IT0003850929 ESPRINET IT0004818297 EUKEDOS IT0003895668 EUROTECH NL0012059018 EXOR IT0001477402 EXPRIVIA IT0003198790 FALCK RENEWABLES NL0011585146 FERRARI NL0010877643 FIAT CHRYSLER AUTOMOBILES IT0001498481 FIDIA IT0003365613 FIERA MILANO IT0004967292 FILA IT0001415246 FINCANTIERI IT0000072170 FINECOBANK IT0000060886 FNM IT0001487047 FULLSIX

12 IT0005023038 GABETTI IT0005345233 GAROFALO HEALTH CARE IT0004098510 GAS PLUS IT0001398541 GEDI GRUPPO EDITORIALE IT0003203947 GEFRAN IT0000062072 GENERALI ASS IT0003697080 GEOX IT0004942915 GEQUITY IT0005122400 GIGLIO GROUP IT0005221517 GPI IT0005311821 GUALA CLOSURES IT0001250932 HERA IT0005108219 I GRANDI VIAGGI IT0001049623 I.M.A. IT0005322612 IGD IT0005283111 IL SOLE 24 ORE IT0005359192 ILLIMITY BANK IT0001413837 IMMSI IT0005245508 INDEL B IT0004552359 INTEK GROUP IT0001078911 INTERPUMP GROUP IT0000072618 INTESA SANPAOLO IT0005090300 INWIT IT0001077780 IRCE IT0003027817 IREN IT0001069902 ISAGRO IT0003057624 IT WAY IT0005211237 ITALGAS IT0003411417 ITALIAN EXHIBITION GROUP IT0005253205 ITALMOBILIARE LU0556041001 IVS GROUP IT0000336518 JUVENTUS FC IT0001055521 LA DORIA IT0004210289 LANDI RENZO IT0003856405 LEONARDO IT0005107492 LUVE IT0005013013 LVENTURE GROUP IT0004931058 MAIRE TECNIMONT IT0003428445 MARR IT0005042467 MASSIMO ZANETTI BEVERAGE

13 IT0001063210 MEDIASET S.P.A IT0000062957 MEDIOBANCA IT0001447348 MITTEL IT0001080248 MOLMED IT0004965148 MONCLER IT0001469383 MONDADORI EDIT IT0001447785 MONDO TV IT0000066016 MONRIF IT0004195308 MUTUIONLINE IT0004819030 NETWEEK IT0005385213 NEWLAT FOOD IT0005366767 NEXI IT0005330516 NOVA RE IT0001350625 OLIDATA IT0003683528 OPENJOBMETIS IT0005138703 ORSERO IT0005043507 OVS IT0001467577 PANARIAGROUP IT0003073266 PIAGGIO IT0004007560 PIERREL IT0003056386 PININFARINA SPA IT0005337958 PIOVAN IT0004240443 PIQUADRO IT0005278236 PIRELLI & C IT0004997984 PITECO IT0005339160 PLC IT0001352217 POLIGRAF. S. F. IT0000086923 POLIGRAFICI EDIT IT0003796171 POSTE ITALIANE IT0003124663 PRIMA INDUSTRIE IT0004176001 PRYSMIAN IT0005054967 RAI WAY IT0004724107 RATTI IT0004931496 RCS MEDIAGROUP IT0003828271 RECORDATI ORD IT0001178299 RENO DE MEDICI IT0005282865 REPLY IT0005349052 RESTART IT0004370463 RETELIT IT0001402269 RISANAMENTO

14 IT0004297575 ROSSS IT0003621783 S.S. LAZIO IT0001042610 SABAF IT0001029492 SAES GETTERS IT0004604762 SAFILO GROUP IT0005252140 SAIPEM IT0003865570 SALINI IMPREGILO IT0004712375 SALVATORE FERRAGAMO IT0003549422 SANLORENZO IT0000433307 SARAS IT0005283640 SERI INDUSTRIAL IT0003814537 SERVIZI ITALIA IT0004729759 SESA IT0005262149 SIT IT0001206769 SOL IT0003153415 SNAM IT0000076536 SOGEFI IT0004607518 STEFANEL NL0000226223 STMICROELECTRONICS IT0003153621 TAMBURI IT0001424644 TAS IT0005331001 TECHEDGE IT0005162406 TECHNOGYM IT0003497168 TELECOM ITALIA LU0156801721 TENARIS IT0003242622 TERNA IT0004585243 TESMEC IT0005037210 TINEXTA IT0004513666 TISCALI IT0004659428 TITANMET IT0003007728 TOD'S IT0000214293 TOSCANA AEROPORTI IT0005390965 TREVI FIN IND IT0005001554 TRIBOO IT0001454435 TXT E -SOLUTIONS IT0003487029 UBI BANCA IT0005239881 UNIEURO IT0004810054 UNIPOL IT0004827447 UNIPOLSAI IT0005239360 UNICREDIT

15 IT0001018362 VALSOIA IT0003127898 VIANINI IT0004922826 WIIT IT0004171440 ZIGNAGO VETRO IT0005395071 ZUCCHI

16 ANNEX II FIGURE 1 – MAIN ITALIAN INDICES Index % daily variation between 6 and 9 March 2020 % daily variation between 6 and 12 March 2020 % daily variation between 13 and 16 March 2020 FTSE ITALIA CAP INDEX -7.47% -22.77% -5.71% FTSE Italia Star -7.76% -22.48% -4.26% FTSE ITALIA CAP INDEX -7.47% -22.77% -5.71% FTSE ITALIAN ALL-SHARE BASIC RES -21.20% -36.00% -6.37% FTSE ITALIAN ALL-SHARE CONS GOOD -8.32% -20.11% -5.64% FTSE ITALIAN CONS SERV -9.16% -26.38% -7.76% FTSE ALL-SHARE FIN -8.16% -24.51% -9.81% FTSE ALL SHARE HEALTH CARE -4.91% -21.74% -3.50% FTSE ALL SHARE INDUSTRIAL -10.15% -28.41% -5.53% FTSE ALL SHARE OIL & GAS -17.36% -33.16% -4.13% FTSE ALL SHARE TECH -9.76% -24.93% -8.42% FTSE ALL SHARE - TELEC -7.63% -26.20% -10.53% FTSE ALL SHARE UTIL -9.55% -31.94% -2.73% FTSE MIB -11.17% -28.39% -6.10% FIGURE 2 – TRADING VOLUME IN THE ITAILIAN MARKET FTSE MIB Date Trade Volume Daily var. % 06/03/2020

864,917,486 - 09/03/2020

1,272,046,596 47.07% 10/03/2020

1,096,966,366 -13.76% 11/03/2020

916,163,284 -16.48% 12/03/2020

1,535,614,359 67.61% 13/03/2020

1,267,823,870 -17.44%

17 16/03/2020

1,218,842,042 -3.86% 17/03/2020

261,191,815 -78.57%