The Energy Regulation and Markets Review: Germany


The German energy sector continues to evolve dynamically. As Germany is likely to miss its 2020 carbon dioxide emission reduction goals, the government continues its efforts to pursue the reform of the German energy market (i.e., the transition of electricity generation from fossil to renewable sources, a substantial reduction of carbon dioxide emissions and the phasing out of nuclear energy). In particular, the share of renewable energy sources in the power generation mix shall be increased to 65 per cent by 2030. However, the side-effects of these ambitious targets have resulted in rising costs for the support of renewable energies, the need for considerable network expansion and unintended effects on the viability of conventional generation capacities. At the same time, the large German utilities are adapting their business models to the changing market conditions.


i The regulators

The responsibility for the energy transition, including climate change, is mainly concentrated at the Federal Ministry for Economic Affairs and Energy (BMWi). The main national regulatory authority is the Federal Network Agency for Electricity, Gas, Telecommunications, Post and Railway (BNetzA) under the authority of BMWi. BNetzA is responsible for the regulation of gas and electricity networks with at least 100,000 grid customers or networks that extend beyond the territory of an individual state. BNetzA also plays a key part in planning and approving large energy network extension measures according to the Grid Extension Acceleration Act. At regional level, the regulatory authorities of the 16 German states are in charge of the regulation of the smaller networks, in particular distribution networks. The regulatory authorities monitor the compliance of network operators with applicable law and determine the general market rules for transport of electricity and gas. Their duties include the supervision of non-discriminatory network access and determination of the grid operators' individual revenue caps. They also ensure that grid operators comply with unbundling rules and with their system security obligations.

The Federal Cartel Office (BKartA) has jurisdiction to apply competition law to the non-network-related parts of the energy supply chain, and is in charge of merger control.

Both the regulatory authorities and BKartA have wide-ranging powers of enforcement, such as refusal of permits, issue of prohibition orders and imposition of fines.

A market transparency unit at BKartA oversees and publishes fuel prices to increase transparency and competition in these markets. A parallel market transparency unit at BNetzA supervises the wholesale trade in electricity and gas markets.

Sources of law

The key source of legislation is the Energy Industry Act, which sets out the main regulation of the German energy market including unbundling requirements, grid operation, energy supply, grid concessions, regulators and legal protection. A number of ordinances set out further details, such as the Incentive Regulation Ordinance and the Electricity and Gas Grid Fee and Grid Access Ordinances. The Renewable Energies Act (EEG) sets out the priority network access and remuneration for the generation of electricity from renewable sources; since 2017 it is supplemented by the Offshore Wind Energy Act. The support for cogeneration power plants is regulated in the Cogeneration Act.

Another important source of law are the administrative decisions of BNetzA, addressed to individual parties or to groups of network operators. BNetzA also issues general guidelines addressed to the general public and interpreting energy sector legislation. The guidelines are not legally binding. However, market participants usually respect them as they form the basis of BNetzA's decision-making.

ii Regulated activities

Network operation

Operators of distribution and transmission networks for power and gas must obtain a grid operation permit confirming their personal, technical and economic capability and reliability to ensure the long-term operation of the network.

In addition, transmission system operators (TSOs) require certification by BNetzA confirming their compliance with unbundling regulation. Before making a final decision, BNetzA has to submit its draft decision to the European Commission and must take utmost account of the Commission's statement.

When using public roads, operators of gas and electricity networks must enter into concession agreements with the municipality owning the roads. These concession agreements have to be tendered by the municipalities every 20 years in a non-discriminatory procedure without the possibility of unduly favouring their own utilities.

Generation and supply

The construction of power generation facilities requires a permit under the Federal Immission Control Act. As the German government made a decision to phase out nuclear energy by 2022, commercial nuclear power plants will no longer be authorised. In January 2020, the government introduced a coal-exit bill with the aim of gradually phasing out electricity generation from coal by 2038. Also, no new coal-fired power plants are to be authorised.

Besides, operators of power generation facilities with a capacity of 10MW or more have to inform the responsible TSO and BNetzA of their intention to shut down a facility at least 12 months before the planned decommissioning. Facilities with a capacity of 50MW or more may not be decommissioned for a maximum period of 24 months if the facility has been designated by the responsible TSO and BNetzA as relevant for system security. In this case, the operator is entitled to reasonable compensation for the necessary maintenance expenses.

Energy supply companies delivering energy to household customers must notify the regulatory authority of the commencement and of the discontinuance of their supply activities, including proof of sufficient resources and reliability.

iii Ownership and market access restrictions

If a TSO or its owner is controlled by one or more persons from a country that is not a member of the European Union (EU) or of the European Economic Area (EEA), the grid operator will only be certified by BNetzA if, in addition to compliance with the unbundling rules, BMWi confirms that the certification does not endanger the security of the electricity and gas supply of Germany or of the EU.

Under general foreign investment rules, BMWi may prohibit on the grounds of public policy or national security the acquisition by a non-EU or non-EEA investor of 25 per cent or more of the voting rights in a German company or asset. For certain critical infrastructures, the threshold is 10 per cent. In the energy sector, this relates among other things, to infrastructures that supply 500,000 persons or more with electricity, gas, fuel, heating oil, or district heating or generation assets with more than 420MW installed capacity. The rules will be further tightened during summer 2020, to reflect recent EU legislation.

iv Transfers of control and assignments

The transfer of regulated assets (i.e., network assets) is not subject to any sector-specific restrictions. However, network operators have to inform the regulatory authority about transfers, mergers or the splitting of grid assets. In the case of a transfer of network assets, part of the revenue cap is transferred with the assets.

The acquirer of transmission assets must comply with the unbundling rules. TSOs have to inform BNetzA of any intended transactions that may require a reassessment of their certification, particularly in the case of a planned takeover or participation by an investor from outside the EU or EEA.

Any transfer of control or decisive influence must be notified for merger clearance to BKartA or to the European Commission if certain thresholds are exceeded. A merger will be cleared if it does not significantly impede effective competition, in particular by creating or strengthening a dominant position. BKartA decides within one month of notification or, if an in-depth investigation is initiated, within an additional four months. The European Commission has a maximum of 135 working days in which to carry out an in-depth investigation to review a merger (or a maximum of 160 working days if remedies are offered).

Transmission/transportation and distribution services

i Vertical integration and unbundling

The Energy Industry Act provides for different unbundling regimes for TSOs and distribution system operators (DSOs).


As of 3 September 2009, the German transmission networks were all owned by vertically integrated energy supply undertakings (VIUs). The TSOs could choose between three unbundling models: ownership unbundling, the independent system operator model (ISO) or the independent transmission operator model (ITO).

Most of the TSOs have opted for the ITO model and some for ownership unbundling. Following several competition law procedures initiated by the European Commission, and owing to the increased regulation of grid assets, three of the four major German VIUs (E.ON, RWE and Vattenfall) divested their electricity and gas TSOs. This resulted in foreign TSOs and financial investors, such as infrastructure funds, entering the German transmission market.

Regarding the ITO model, the German definition of a VIU in the view of the European Commission excludes activities outside the EU. Furthermore, the independence of the ITO's staff and management was not sufficiently guaranteed. The European Commission has therefore filed a complaint with the European Court of Justice (C-718/18).

With respect to the ownership unbundling model, German law allows a person controlling electricity or gas production, generation or supply activities to hold a minority participation in a TSO of up to 25 per cent at the same time, provided that this participation does not confer significant minority rights. Each case is evaluated on its merits.

The European Commission has in the meantime recognised that a TSO may be certified as ownership unbundled despite having a shareholder with a participation in generation, production or supply activities if it can prove that no conflict of interest exists. This will be examined case by case, taking into account in particular the geographical location of the transmission activities and the generation, production or supply activities concerned, the value and the nature of the participations in these activities, as well as their size and market share.

DSOs and gas storage operators

Unbundling requirements for DSOs are less strict. DSOs with at least 100,000 grid customers and gas storage system operators must be legally and operationally unbundled from the VIU. DSOs are required to ensure that their communication and branding do not create confusion with regard to the supply branch of the VIU.

At the level of the DSOs, there remains a large degree of vertical integration. DSOs typically belong to municipal utilities or to one of the incumbent energy suppliers.

ii Transmission/transportation and distribution access

Connection to networks and network access is regulated. Network operators have to ensure a reasonable, non-discriminatory and transparent connection and access to their grids for all third parties, including extension of the network if required and reasonable (regulated third-party access). By way of exception, priority will be given to network connection and access of operators of renewable energy facilities.

Costs for network connection are in general borne by the network customer, except for offshore wind farms, of which the connection costs are socialised. Operators of LNG terminals shall bear only 10 per cent of their connection costs.

Access to electricity networks is granted on the basis of standardised network access agreements concluded between the grid operator and the grid customer or, in the case of electricity suppliers, on the basis of supplier framework access agreements. The access agreement grants nationwide access to all electricity networks. The agreements are based on a model network access agreement developed by BNetzA.

Access to gas networks is based on capacity bookings in a two-contract entry-exit system: one contract is concluded between the grid customer and the grid operator for the feed-in of gas, and a second contract is concluded between the grid customer and the grid operator for the offtake of gas. Gas can be transported and traded without physical restrictions across networks, including on virtual trading points, within each of two gas market areas in Germany (GASPOOL and NetConnect Germany).

Transmission and distribution networks are closely interlinked and operators are obliged to cooperate. Contracts for network access and general terms and conditions are standardised and approved by BNetzA. BNetzA has the competence to set detailed rules on network access applicable to all network operators, for example in relation to balancing energy and capacity management. However, the European Commission holds the view that BNetzA does not enjoy sufficient discretion in the setting of network tariffs and other terms and conditions for access to networks and balancing services. It has therefore filed a complaint with the European Court of Justice (C-718/18).

The increase in generation of electricity from renewable energy sources and the phasing out of nuclear energy is leading to a shift of generation to northern Germany, resulting in bottlenecks on the north–south transmission lines. Network operators may restrict network access to maintain system security. They must use non-discriminatory and market-based measures to prevent or eliminate bottlenecks. However, generators of electricity from renewable sources may only be curtailed on a subordinate basis.

Costs for redispatch measures of TSOs to relieve bottlenecks are socialised to all grid customers. Hence construction of additional electricity transmission lines is one of the key priorities of German energy policy. In addition, the installation of new onshore wind capacity in northern Germany has been limited to 902MW per year.

TSOs have to establish 10-year network development plans for electricity, gas and for connection of offshore wind farms every two years. The development plans set out the required grid expansion measures. BNetzA reviews the development plans and may request modifications. The necessity of all listed projects is then legally determined by the federal government. BNetzA is responsible for planning approval of projects that cross the borders between German states.

iii Rates

As of 2009, grid fees are subject to revenue cap incentive regulation. Two years prior to the beginning of each five-year regulatory period, the competent regulatory authority determines a grid operator's allowed cost and asset base by analysing its costs of the preceding financial year (photo year). The cost and asset base in the photo year is the basis for the network operator's allowed revenues in the next regulatory period. The regulatory authority sets the grid operator's individual annual revenue cap for each year of the five-year regulatory period, taking into account individual and sector-specific efficiency targets and an allowed rate of return on equity set by BNetzA. For the third regulatory period (gas: 2018–2022, electricity: 2019–2023), BNetzA has set the allowed rates of return on equity to 6.91 per cent before tax for new assets and to 5.12 per cent before tax for old assets. During the regulatory period, the annual revenue cap will be adjusted only in a few cases, such as when the consumer retail price index or the grid operator's permanently non-controllable costs change. As a result, the grid operator has an incentive to outperform its efficiency targets before the revenue cap is reset for the next regulatory period. Based on their fixed revenue caps, the grid operators charge the corresponding access fees to their grid customers.

As of 2016, capital costs for network investments made after the photo year are recognised in DSOs' revenue caps without delay. Very efficient DSOs may receive an efficiency bonus.

Grid customers with atypical grid use or with continuous and very high consumption (at least 7,000 hours and more than 10GWh per year) have a right to individual network fees below the regulated tariffs. These individually agreed fees have to be notified to the competent regulatory authority.

iv Security and technology restrictions

There are no specific restrictions on technology transfer for the energy sector.

Based on a report from the TSOs, every two years BNetzA reviews whether the disruption or destruction of transmission assets in Germany could have a material effect on at least two EU Member States. BNetzA can declare these assets to be critical European infrastructure. TSOs have to develop specific security plans for these assets, including access control, security of IT systems and emergency protocols. In 2015, an IT Security Act was adopted that shall tighten IT security requirements and extend their scope to all assets required for secure network operation.

Energy markets

i Development of energy markets

Gross energy consumption in 2019 decreased by 2.3 per cent compared to 2018; gross electricity consumption decreased by 1.8 per cent. In 2019, primary energy consumption was composed of oil (35.3 per cent), natural gas (25 per cent), hard coal (8.8 per cent), lignite (9.1 per cent), nuclear (6.4 per cent) and renewable sources (14.7 per cent).

Gross electricity generation in 2019 was composed of lignite (19 per cent), hard coal (9 per cent), nuclear (12 per cent), natural gas (15 per cent), mineral oil (1 per cent), others (4 per cent) and renewable sources (40 per cent), the latter mainly consisting of wind power (21 per cent), hydropower (3 per cent), biomass (7 per cent), photovoltaic (7 per cent) and waste (1 per cent). These figures illustrate that despite an increased share of renewable energy sources, conventional energy sources are still the backbone of the German energy supply.

As of 1 October 2021, the two separate dual-quality (high caloric and low caloric gas) gas market areas NCG and GASPOOL will merge into one gas market area. Already, gas can be traded without capacity restrictions between the gas market areas at virtual trading hubs through matching buy and sell orders between two balancing groups. Owing to the decreasing production of low caloric gas in Germany and the Netherlands, until 2030 all grids and customer units will consecutively be transferred to comply with high caloric standards.

The European Energy Exchange AG (EEX) in Leipzig operates organised markets for trading in electricity, natural gas, oil, coal and carbon dioxide emission allowances. EEX offers trading of electricity futures for delivery in the German market area and trading of gas futures and short-term gas contracts for delivery in the GASPOOL and NCG areas. The electricity spot market is operated by EPEX SPOT SE in Paris.

Prices on the spot and futures markets are based on bids by generators and customers. The order of the bids is determined by the short-run marginal costs of the power plants (merit order). Owing to the statutory priority of feed-in of renewable energies ('produce and forget'), electricity from renewable sources is always first in line in the merit order, usually followed by nuclear energy and coal-fired power plants. The prices on the spot and forward markets are the benchmark for wholesale prices and over-the-counter (OTC) trades.

The spot and futures markets are energy-only markets (i.e., there are no capacity payments). The increase in generation from renewable energies has led to a decrease in wholesale prices and has pushed conventional generation capacity out of the merit order, in particular flexible gas-fired power plants.

To guarantee security of supply, the Electricity Market Act of 2016 implemented several capacity mechanisms, but without introducing a real capacity market. The network reserve is composed of 'system relevant' power plants, mainly in southern Germany, that would otherwise be decommissioned, providing additional redispatch potential if necessary. The capacity reserve shall be provided by power plants outside the energy market being remunerated for the provision of capacity via a tendering process. Until 2023, the function of the capacity reserve will be served mainly by lignite-fired power plants that are being transferred to security standby mode before being decommissioned four years later.

ii Energy market rules and regulation

The energy market operated by EEX is subject to the Exchange Act. Under the authority of the State Ministry of Economy, Labour and Transport in the German state of Saxony, an independent market surveillance body continuously supervises trading activities to prevent market manipulation.

Under the EU Regulation on wholesale energy market integrity and transparency (REMIT), market participants are required to publish inside information in an effective and timely manner. REMIT also prohibits market abuse in wholesale energy markets in the form of market manipulation and insider trading. As of 2015, market participants have to register with BNetzA and report details of wholesale energy transactions executed at organised market places to the European Agency for the Cooperation of Energy Regulators.

As of 2014, all EU-based entities that enter into derivatives transactions are required to report details of these transactions to a trade repository under the European Marketing Infrastructure Regulation (EMIR). There is also an obligation to report certain existing and historical derivatives transactions, although deadlines for this vary. Furthermore, EMIR established a central clearing obligation for certain OTC derivatives and the application of risk mitigation techniques for non-centrally cleared OTC derivatives.

iii Contracts for sale of energy

In principle, there are no regulatory limitations on the entering of individual contracts for the sale of energy, either at wholesale or retail level. However, household customers have a right to be supplied at standard (but not regulated) tariffs by the local supplier with the most household customers within a network area (supplier of last resort). Energy supply contracts with household customers also have to comply with certain transparency and information requirements.

Although there is no ex ante price regulation of wholesale or retail energy prices, regulated network charges, taxes and surcharges (such as the surcharge for renewable energies) account for more than half of the final energy prices for electricity and for between 25 and 30 per cent for gas. Competition authorities may review energy prices (except the regulated components) and prohibit dominant suppliers from charging prices that unreasonably exceed costs or that are lower than on comparable markets.

In recent years, price increases for final customers based on the passing-on of input costs (e.g., increase in fuel cost for electricity generation) have repeatedly been annulled by the courts, arguing that these were not justified or that provisions in energy supply contracts enabling such price increases were not sufficiently transparent. Following landmark decisions of the European Court of Justice and the German Federal Court in 2013 and 2014, according to which a standard clause for price adjustments that was widely used in supply agreements is invalid, utility companies have to provide information on the scope, reasons and preconditions for the adjustment.

iv Market developments

The large German utilities are increasingly adapting their business to the changing market environment by divesting or consolidating their conventional power generation facilities and investing in renewable energy sources, grids and new forms of energy supply and customer solutions. In 2016, RWE transferred its renewables, grids and supply business to its subsidiary, innogy, while E.ON spun off its conventional generation and trading business into a new listed company (Uniper). In January 2018, E.ON sold its shares in Uniper to the Finnish energy supplier Fortum, and in March 2018, E.ON began the acquisition process of RWE's majority stake in innogy, which was completed in September 2019. In return, E.ON transferred its renewables business to RWE and will also transfer innogy's renewables business back to RWE. As a consequence of this asset swap, RWE will focus on conventional and renewable energy generation while E.ON will concentrate on energy networks and customer solutions.

In line with the government's climate protection plans, utilities have also started to divest their coal-fired generation units.

Renewable energy and conservation

i Development of renewable energy

In 2017, a major reform of the EEG, the law governing the development of renewable energy sources, introduced auctions as the basic mechanism to determine the remuneration for electricity from onshore and offshore wind power, photovoltaic power and biomass, subject to a number of exemptions; for example, for smaller facilities, for which remuneration remains fixed by law. Auctions for other renewable energy sources, such as geothermal energy, may be introduced at a later stage. The technology-specific auction volumes are limited to:

  1. 4,100MW in 2020, 4,250MW in 2021 and 2,900MW per year as of 2022 for onshore wind;
  2. 1,800MW in 2020, 1,950MW in 2021 and 600MW per year as of 2022 for solar;
  3. 200MW per year as of 2020 for biomass; and
  4. 15GW until 2030 for offshore wind.

Finally, the EEG foresees so-called innovation tenders that shall take place on 1 September and have a volume of 400MW in 2020 and 500MW in 2021. Each tender volume increases according to volume not having been awarded in the corresponding previous tender year.

Since December 2017, BNetzA also conducts two auctions for electricity from co-generation per year. In addition, BNetzA carried out technology neutral auctions for onshore wind and solar power together in the amount of 400MW per year from 2018 to 2020.

In addition to the EEG 2017, the Offshore Wind Farm Act sets out rules for the planning, tendering and approval of offshore wind farms (OWFs). It applies to OWFs in the German exclusive economic zone that commission as from 1 January 2021. The main aim of the law is to better harmonise the construction of OWFs and their grid connections to the onshore grid. As a main feature, the Federal Maritime and Hydrographic Agency, instead of the developers in a central planning model, identifies suitable areas for the construction of OWFs, which then are put to tender.

ii Energy efficiency and conservation

Germany is going miss its goal to reduce its emissions by 40 per cent in 2020 compared to 1990. Germany will also miss its goal to reduce gross energy consumption by 20 per cent in 2020 compared to 2008: in 2019, the decline was only 9.6 per cent as compared to 2008. The German government reacted to that by formulating a cross-sector energy efficiency strategy based on the 'efficiency first' principle. The Commission for Growth, Structural Transformation and Employment implemented by the German government in January 2019 proposed a gradual phasing out of lignite-fired and coal-fired power plants by 2038. The government introduced its Coal Exit Bill one year later, in January 2020. Furthermore, the government has introduced the Federal Climate Protection Act setting out a sector-specific trajectory regarding energy and emission savings.

iii Technological developments

Driven by the need to store the surplus electricity from renewable energy sources, the installation of power storage facilities, at both household level and commercial level, is developing very dynamically. Storage facilities are based on a large variety of technologies, such as battery storage, power-to-gas, power-to-heat or power-to-liquid. In particular, the deployment of hydrogen (from renewable and other sources) has become a focus for government and economic actors recently. Currently, the federal government is developing its hydrogen strategy, which will outline whether and how hydrogen is to be promoted and integrated in the regulatory system.

Although from a low level, e-mobility is also picking up speed. In 2019, however, new registrations of electric vehicles increased by 75.5 per cent compared to 2018. In January 2020, 136,000 electric vehicles were registered in Germany. The government promotes this development by providing public funding beyond 2020 as it plans to have between 7 million and 10 million electric vehicles on the road and 1 million charging points available by 2030. Also, as from 2020, tenants and co-owners in condominiums have the right to instal charging points at their own expense. New or refurbished buildings are to be equipped with cabling infrastructure and, in some cases, charging points.

In relation to smart meters, the EU has set a non-binding target of rollout to 80 per cent of all consumers by 2020. The Act on the Operation of Measuring Points (MsbG), which entered into force in 2016, provides for the introduction of smart meters, including rules on data protection, data access, rollout and financing of the rollout. The rollout is expected to start in 2020. The MsbG establishes maximum price limits for the installation and servicing of the smart meters depending on individual consumption. Provided the maximum price limits are met, the installation of smart meters will be mandatory for consumers with a consumption above 6,000kWh per year. The installation of smart meters for consumers with an annual consumption below 6,000kWh per year is optional. The goal is to complete the smart meter rollout in 2032.

The year in review

Although auctions as the basic mechanism to determine the remuneration level for the support of power from renewable sources proved successful in countering a further cost increase when introduced in 2019, some of the tenders for onshore wind and solar had low to no competition during 2019 as it became harder for renewable projects to find available spaces and obtain permits for their projects.

Still, the increased share of intermittent renewable generation continued to put further pressure on the viability of conventional generation facilities. This induced the large German utilities to continue the restructuring and consolidation of their generation portfolios and business models, including the divestment of coal generation units, and, in view of the government plans, to phase out power generation from coal.

In response to the government's climate protection programme, published in October 2019, which emphasised, inter alia, a stronger role for e-mobility, energy storage and hydrogen, utilities sought collaborations with the market players that have recently entered the scene. These are start-ups promoting new technologies, such as blockchain or e-mobility, and companies from other sectors, such as IT and telecommunications, driving forward the digitalisation of the energy sector.

Conclusions and outlook

To ensure that Germany achieves its 2030 climate goals, the government needs to continue its course of climate protection.

The details of the gradual phasing out of power generation from coal are yet to be determined. In particular, the extent of compensation for the operators of hard coal-fired plants is still under debate.

The details of the planned reduction of energy bills for households and enterprises by lowering the EEG surcharge foreseen in the climate protection programme have not yet been implemented either.

Finally, the government will need to remove barriers hampering the deployment of new renewable energy generation. In this regard, the climate protection programme foresees lifting the limitation of solar installations to 52GW in total, increasing the goal for offshore wind capacity to 20GW and lifting barriers for new onshore wind projects (notwithstanding a new general ban on onshore wind projects being erected within less than 1,000 metres of residential buildings).

In the coming years, more and more renewable projects will reach the end of their 20-year remuneration period. For those projects remaining in the market, the sale of their electricity via corporate power purchase agreements (PPAs) may become more attractive. The German market has also begun to see new renewable projects selling their electricity via PPAs. However, this phenomenon is not yet very common as regulatory hurdles persist and prices on the wholesale market remain low.

As of 2021, Germany will introduce a national emission trading system within the transport and heating sector. This system obliges fuel suppliers to buy and surrender emission allowances for the fuels they sell. The details are to be set out in ordinances that have yet to be issued. For example, there must be a mechanism for enterprises that are already subject to the EU-wide emission trading system to ensure that they do not have to pay twice for their emissions.

Although the direct effects of the covid-19 pandemic on the energy landscape are not as obvious as for other areas of the economy, the sector has been affected by a reduction in energy demand and the need to keep the critical infrastructure running. We also expect delays to outstanding legislative projects. If, and to what extent, the government will adjust its climate protection ambitions as a reaction to the economic effects of the covid-19 crisis remains to be seen.


1 Thomas Schulz is a partner and Julia Sack and Ruth Losch are lawyers at Linklaters LLP.

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