CHORUS LIMITED — Investor Presentation 2021

Nov 11, 2021

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Chorus Limited Level 10, 1 Willis Street P O Box 632 Wellington New Zealand

Email: company.secretary@chorus.co.nz

STOCK EXCHANGE ANNOUNCEMENT

12 November 2021

Investor presentation - UBS Australasia Conference

The attached Chorus presentation will be referenced at the UBS Australasia Conference next week.

Authorised by:

David Collins Chief Financial Officer

ENDS

For further information:

Brett Jackson

Investor Relations Manager Phone: +64 4 896 4039 Mobile: +64 (27) 488 7808 Email: Brett.Jackson@chorus.co.nz

Steve Pettigrew Head of External Communications Mobile +64 (27) 258 6257 Email: Steve.Pettigrew@chorus.co.nz

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Fibre infrastructure comes of age
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UBS AUSTRALASIA CONFERENCE

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15 November 2021

Our network infrastructure

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2

New Zealand market structure

Chorus structurally separated from Telecom NZ (retail) in 2011 for fibre PPP

3

Fibre PPP rollout 96% complete

10-year rollout programme coming to an end

> <50k premises remaining to pass by December 2022

• ~1.3m customers now able to connect in Chorus fibre rollout areas

• Chorus’ fibre footprint covers 300+ cities and small communities, from Auckland to Franz Josef on the South Island’s West Coast

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Auckland : home to 1/3 NZ population and
growing rapidly, with 76% fibre uptake to date.
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> 87% of NZ population will have access to fibre

• Chorus share of government PPP footprint equates to ~75%

• the other 25% is served by three other local fibre companies (~450k end customers in Chorus’ existing copper network areas)

Franz Josef : fibre was recently made available to the ~100 premises

4

COVID-19: reliable broadband is essential

On track for our target of 1 million fibre connections in 2022

• First four months of FY22 have delivered positive net monthly broadband connections

• fibre broadband connections up 23k in Q1, despite COVID 19 impact on installation activity

• COVID lockdowns helping drive migration from copper to fibre and upgrades to 1Gbps plans

> Reached 900,000 fibre connections in October (GPON+P2P)

• 858,000 connections in fibre PPP areas (at 30 Sept) out of ~1.3m able to connect

• uptake in UFB1 areas grew to 71% in Q1, up from 69%

• uptake in UFB2 areas grew to 44% in Q1, up from 42%

• Auckland uptake at 76%

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• strong growth in greenfields fibre demand outside fibre PPP areas

5

Data demand accelerates

Record 621GB average monthly usage per fibre connection in September

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700
COVID-19
lockdowns
Downstream Upstream
600
500
Gigabytes
400
per month
300
200
100
0
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Note: upstream traffic only shown from June 2020 onwards following COVID-19 effects on daytime usage trends

6

Working from home creates upstream need

Upstream traffic

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7

Fibre for speed, capacity, low latency

New code to address telco marketing practices

• Commerce Commission quarterly monitoring shows fibre outperforms other technologies on key measures (e.g. peak time speed, latency - see chart)

• industry-led code to be introduced following Commission concerns about marketing of alternative services during copper withdrawal. Proposed requirements include:

• consumers should provide express consent for a change in telco service

• at least 4 months’ notice should be provided by retailers where a copper service is being withdrawn

• service performance measures to be clear, accurate and up-to-date, with reporting of actual likely peak time broadband speed

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Source: Commerce Commission , Measuring Broadband New Zealand, Winter Report (August 2021)

8

Demand for higher data and speed will keep growing

We forecast 1,000GB average monthly usage in 2024

• adoption of streaming services has been accelerated by lockdowns, with more services expected to launch (e.g. Discovery+) and retailers bundling streaming services with broadband

• our pre-lockdown consumer research showed about a third of households expected their data usage to increase due to increased streaming, more devices and more use (e.g. working from home, older children)

• 38% of households would like more content in 4K quality

• smart home devices (e.g. AI digital assistants, CCTV) add to bandwidth demand and need for reliable broadband

• cloud-based gaming, 8KTV expected to drive future bandwidth requirements

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9

1 Gigabit plans now 22% of mass market

• 1Gbps connections are growing strongly, up from 20% (30 Sept) to 22% of GPON connections in October ▪ reflects consumer-led demand for upgrades, migrations from the 200Mbps plan, in-market Chorus incentives and retailer offers

> CPI changes to pricing:

• 1.52% applied to selected fibre services from 1 October: residential 50Mbps $44.22 and 100Mbps $47.87 $51.20+

• ▪ $43.56 4.93% to apply to copper services from mid December: baseband $33.73; broadband $45.09

Chorus mass market connections by plan type (as at 30 Sept)

Copper connections: 435,000

Residential fibre (GPON): 802,000

Business fibre (GPON): 81,000

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Unbundled lines Baseband lines
ADSL VDSL
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$47.15
$56.38+
$65+
$56
1Gbps 200-300Mbps 100Mbps
1Gbps 200Mbps 100Mbps
50Mbps Voice <100Mbps Voice
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Note: business plan pricing shown is indicative entry level option for each speed tier

10

Refining our product proposition

Boosting NZ into global top 10 for average speed

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• retailers can choose to apply our plan upgrades:

• consumer 100/20 300/100

• business evolve 100/100 300/300

• small business 100/100 500/500

• currently consulting with retailers on possible introduction of entry level consumer plan:

• 40/10 speed at $44.22 per month

• price could reduce to $39 per month where retail pricing is $63 or less (incl GST)

• note : plan introduction and make-up is subject to Chorus assessment of industry feedback

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11

Active wholesaler programme lifting fibre uptake

Targeted advertising, incentive and installation programme continues

> 270,000 addresses have fibre at their gate

• ~12k of 30k installations in Q1 were via our managed migration programme

• ~140,000 addresses have fibre installed but not activated

• ~7k activations in Q1 with ~3k from offnet addresses

• direct marketing: $100 Prezzy Card incentive

Managed migration programme

18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0

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Q1 FY21Q2 FY21Q3 FY21Q4 FY21Q1 FY22

Installations Connections

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12

New ‘broadband bundlers’ growing market share

Retail broadband competition growing with energy and pay TV bundlers

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600,000
500,000
No. of
customer 400,000
connections
300,000
200,000
100,000
0
Contact Mercury TrustPower Nova Vocus Sky TV
Energy Energy
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> Energy and pay TV ‘broadband entrants’ serve ~1.7m customers on their core services

• Contact Energy entered the broadband market in late 2017. Their connections increased 96% in FY21.

• Mercury NZ is in the process of purchasing Trustpower with a focus on bundling services. Trustpower is NZ’s 5[th] largest broadband retailer, while Mercury has not previously provided broadband services.

• Sky TV entered the broadband market in March 2021 with a focus on its large base of Sky Box customers.

• Nova Energy entered the broadband market in late 2018. Broadband connections aren’t publicly reported.

• ▪ Vocus NZ acquired power retailer Switch in late 2016.

Electricity/TV connections Broadband customers (reported)

Note: Electricity customer numbers reflect Electricity Authority ICP data as at 30 Sept 2021. Broadband customer numbers reflect publicly reported data where available.

13

Growing retail diversity

Lift in retail competition as new entrants grow share

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NZ broadband market share by
retailer (Q2 2021 vs Q1 2013) %
15
1 [10]
6 37
12
7 48
Q1 2021 Q1 2013
29
12.5
22.5
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Source: IDC market data

14

Home building growth supports fibre demand

New homes consented in Auckland up 29% to year ended Sept 2021

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Source:
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Chorus new property connection pipeline (all NZ)

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30,000
25,000
20,000
15,000
10,000
5,000
0
FY19 FY20 FY21
New property orders Completed
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15

Connection changes by Zone (indicative)

Quarterly change (‘000s) by zone**

-15 -5 5 15

Q1 FY22 Q4 FY21 Q3 FY21 Q2 FY21 Q1 FY21	-2 -2 -3 -2
					Other fi compan zone	bre y (LFC)	Broadband connections	42,000	Disconnections continue due to Local Fibre Company and fixed wireless provider activity, with some slowdown due to COVID-19 restrictions.
		-9
		-6
							Copper line (no broadband)	25,000
		-6
		-5
							TOTAL	67,000
		-3 -3
Q1 FY22 Q4 FY21 Q3 FY21 Q2 FY21 Q1 FY21		-1 -1 -2 -2 -1 -2 -1 -1 -1			Non-UF	B zone	Broadband connections	149,000	Some expansion of wireless broadband footprint through Government backed programme. New housing outside of UFB zone driving fibre premises growth.
							Copper line (no broadband)	34,000
							TOTAL	183,000
7 5 6 -4 -2 -8 -10 -8 -7 -8 Q1 FY22 Q4 FY21 Q3 FY21 Q2 FY21 Q1 FY21 Broadband connections C (n bdbnd) nntin					Chorus UFB zone*		Broadband connections	992,000	Continued broadband growth driven by Chorus incentives and migration campaigns. Copper voice disconnections reflect migration to fibre and targeted fixed wireless activities. COVID-19 restrictions slowed market activity in Q1 and broadband growth has been constrained by COVID-19 limits on net migration.
		-2
		-4					Copper line (no broadband)	76,000
		-8	6
		0	5				TOTAL	1,068,000
		-8	7
opper o roaa coecos

• Includes planned Chorus UFB1, 2 and 2+ coverage

**Excludes 10k partly subsidised education connections and 13k fibre premium and data services (copper) connections

16

Fibre enables sustainability

> inaugural Sustainability Report in 2021

• sustainability strategy focused on: thriving environment, champion digital futures, thriving people

• aligning our reporting with GRESB communications infrastructure framework

> targeting 80% emissions reduction (scope 1&2) from FY12 level by 2030

• electricity consumption expected to reduce 30-40% as customers migrate to fibre

• assisted by NZ electricity decarbonistation: grid typically ~80% renewable with Climate Change Commission recommended target of 95% to 98% by 2030

• broadband underpins significant emissions reduction by enabling activities such as working from home, telemedicine and reduced travel

> Diversity and inclusion

• Chorus Board: 43% women, 57% men

• targeting 40:40:20 people leader gender ratio: 36% women, 64% men in FY21

• objective of 0% gender career level pay gap by 2022

• employee engagement: 8.5/10 in FY20 and FY21

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17

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Financial highlights and
regulatory framework
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UBS AUSTRALASIA CONFERENCE

15 November 2021

Financial snapshot

Revenue

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1000
800
600
$m
400
200
0
FY18 FY19 FY20 FY21
Guidance
EBITDA
$640 - $660m
700
600
500
400
$m
300
200
100
0
FY18 FY19 FY20 FY21 FY22
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Revenue has reduced due to:

>

• copper line loss in areas where Chorus is not the Government’s chosen fibre network provider

• fixed wireless competition

> Revenue loss partially offset by:

• strong fibre uptake at higher ARPU than copper

• consumers upgrading to higher speed plans (e.g. 1Gbps)

Objective of modest EBITDA growth:

• expect continued fibre ARPU growth

• ongoing focus on cost reduction as fibre rollout ends and transition to operational mode

• New accounting standards IFRS 9, 15 and 16 were adopted from FY18

19

Capex & Leverage

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Guidance
900 $550 - $590m 4.5
800 4
700 3.5 Net Debt
/EBITDA
600 3
$m
500 2.5
400 2
300 1.5
200 1
100 0.5
0 0
FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22
Capex Net senior debt/EBITDA
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• Chorus’ Board considers that a ‘ BBB ’ credit rating or equivalent credit rating is appropriate for a company such as Chorus.

• 4.24x ND/EBITDA at 30 June

• total net debt $2,748m at 30 June

• ratings agencies expected to review current thresholds to reflect new regulatory regime and growth in free cashflow

• S&P: 4.25x ND/EBITDA on a sustained basis

• Moody’s: 4.2x ND/EBITDA on a sustained basis

• financial covenants require senior debt ratio to be no greater than 4.75 times

• member of GLIO infrastructure index from Sept 2021

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*based on S&P and bank covenant methodologies

20

Free cash flow grows as fibre rollout ends

• significant downward trajectory for capex:

• communal fibre spend ends in FY23 as rollout ends; installation capex slows as uptake is maximised

• installation demand is the bulk of expected RP1 capex (see chart)

  • Chorus’ RP1 proposal forecasts ~$1 billion of capex for 2022 to 2024 (calendar)

• copper capex will reduce as fibre migration migration enables copper withdrawal

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▪
other ongoing discretionary capex subject to
market drivers and regulatory incentives
300
250
200
$m
150
100
50
Communal spend
Installation & layer 2 spend
0
FY20 FY21 FY22 FY23 FY24
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*based on midpoint of FY22 guidance and regulatory proposals

Source: Chorus proposed fibre capex, Our Fibre Plans 2020 Chorus CI = confidential information

21

Transition to new dividend policy underway

• we expect to provide further detail on dividend outlook, including expected pay-out range, in February 2022, following finalisation of key regulatory outputs

• policy based on a majority pay-out range of free cashflow (net cash flows from operating activities minus sustaining capex)

• sustaining capex was $180m in FY21 and expected to be ~$200m (midpoint within a range) in future

• dividend levels through the transition period will reflect the maintenance of a BBB credit rating and non-sustaining capex demands (fibre rollout and connections)

• we expect the April 2022 interim dividend will be fully imputed, followed by unimputed dividends for the short to medium term

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Initial
guidance of
Dividend 26cps
30
25
20
15
10
5
0
FY17 FY18 FY19 FY20 FY21 FY22
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22

Regulatory process

Final RAB and MAR decisions due December

> 2022-2024 parameters confirmed so far :

• vanilla WACC: 4.72%

• post tax WACC: 4.52%

• CPI forecast: 1.63% (2022), 2.03% (2023), 2.17% (2024)

> regulatory framework provides allowance for inflation :

• RAB will be indexed by actual inflation over the regulatory period (reflected in RAB at start of second regulatory period)

• forecast inflation is applied to the RAB to set the initial MAR, with the MAR reduced by the value of the revaluation - there is no adjustment for actual inflation in the period

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Source: Commerce Commission, stylised key building blocks equations

23

Regulatory asset base (RAB)

Draft Commission decision (19 August) suggested 1 Jan 2022 RAB of $5.4bn

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Core fibre Financial loss
assets asset
$3,980m $1,446m
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• Chorus’ conservative initial valuation of $5.5 billion was based on extensive modelling work undertaken by Analysys Mason

• the Commission’s draft $5.4bn RAB doesn’t reflect Chorus’ business operations, particularly allocation of technology costs, duct sharing and exchange space

• the draft RAB amounts exclude ~$1.3bn assets: copper assets (including shared assets currently allocated to copper), non-regulated fibre assets (e.g. fibre in local fibre company areas) and fibre assets part or wholly funded with third party capital contributions (e.g. government subsidised Rural Broadband Initiative network, greenfields developers).

24

Maximum allowable revenue (MAR)

Draft Commission decision (27 May)

• Table X3 (right) summarises key MAR components but doesn’t reflect potential final decision changes for:

• Commission draft RAB of $5,427m in August vs Commission’s use of Chorus initial valuation of $5,507m in May

• changes in risk free rates reflected in final WACC (increased from .43% to .51%)

• updated indexation forecasts following May quarter

• Chorus’ submissions noting fundamental issues with the Commission’s proposed reductions to capex ($158m or 16.2% reduction) and opex ($52m or 10.6% reduction)

• treatment of depreciation for the financial loss asset (Commission draft MAR decision proposed diminishing value of 14.3%)

The Commission noted on 19 August: “If all other aspects of our draft PQ decision remained unchanged, our indicative estimate of the combined impact of these decisions would lead to a 2%-2.5% reduction in allowable revenue over the PQP1 period.”

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Source: Commerce Commission

25

Looking ahead…

• We expect MAR for the second regulatory period to reflect:

• future risk-free rate

• inclusion of tax building block once tax loss of ~$280m (tax effected) is used up

• ~$250m (current value) of existing shared assets that should be eligible to enter the RAB over time

• partial repayments of Crown financing (regulator only allows ~2% return on funded assets)

• we estimate that $158m (53%) of FY21 expenditure was regulated FFLAS, up from 47% in FY20, vs 59% of FY21 total revenue*

• cost allocators remain consistent with the initial RAB unless there is a justifiable reason to change

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• based on Chorus’ March Initial Asset Value and May Expenditure proposals ** based on Input Methodologies

26

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Appendices
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UBS AUSTRALASIA CONFERENCE

15 November 2021

FY22 strategy

28

Capital allocation framework driven by shareholder value

Net cash flow from operating activities

• Transition from FY22 to dividend distribution based on payout range of free cash flow to reflect :

• a focus on providing shareholders with dividend predictability, stability and sustainable growth

Sustaining capital Dividend expenditure distribution

• comparable Australasian infrastructure and utility-like businesses that pay out the majority of FCF

• robust management of sustaining capital expenditure

• Transition driven by reductions in non-sustaining capex, mainly UFB build & installations

Surplus capital

• dividend levels & surplus capital temporarily constrained by credit rating thresholds

• Future surplus capital after dividend to be allocated based on maximising shareholder value, and guided by :

• debt levels consistent with existing credit rating, noting potential re-gearing from any relaxation of rating thresholds

• discretionary capex will only be pursued where:

Share buy Additional Discretionary backs dividends capex *

• greater shareholder value is created compared to share buy backs and/or additional dividends; and

• regulatory incentives are appropriate (e.g. regulatory WACC vs Chorus WACC)

*Examples include fibre footprint expansion, greenfield connections & customer retention spend

29

Sustaining capex

• $180m sustaining capex in FY21 vs FY20:$186m (see table on right)

• chart (below) shows proposed regulated fibre capex for RP1 (calendar years) as per our general definition of sustaining vs non-sustaining:

• see 17 December 2020 presentation slide 12 for more detail on regulatory categories

• is net of capital contributions, excludes FFLAS in LFC areas and includes regulatory inflation

• actual RP1 spend subject to regulatory outcomes

Proposed regulatory fibre capex

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400
Sustaining Non-sustaining
350
300
250
200
$m
150
100
50
0
2022 2023 2024
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Fibre capex: sustaining	FY21 $m	FY20 $m
Layer 2	31	31
Fibre products & systems	11	14
Other fibre	11	12
Fibre sustain	11	8
Customer retention costs*	11	7
Subtotal	75	72
Copper capex: sustaining	FY21 $m	FY20 $m
Network sustain	29	31
Copper connections	1	1
Copper layer 2	4	7
Customer retention costs*	11	15
Subtotal	45	54
Common capex: sustaining	FY21 $m	FY20 $m
Information technology	46	43
Building & engineering services	14	17
Subtotal	60	60

*Relates to provisioning, systems and service desk costs

30

Crown financing and debt profile

> At 30 June, debt of $2,339m comprised:

• Long term bank facilities of $350m ($140m drawn)

• up to $1.33 billion CIP financing available by 2023 (57:43 equity/debt)

• $1,189m drawn at 30 June 2021

• NZ bonds: $400m and $500m

• Euro Medium Term Notes $1,299m (NZ$ equivalent at hedged rates)

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CIP debt securities available
Face value of CIP debt securities issued
800
EUR EMTN
700
NZ Bond
600
500
NZ
400 785
$M
20
300
514 500 86 46
200 39
100 200 200
163
128
85
0
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drawn undrawn
NZ 41
$M
462 462
265
105
UFB1 UFB1 DEBT UFB2/2+ UFB2/2+
EQUITY EQUITY DEBT
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31

Crown financing

▪ CIP equity securities

• unique class of security with no right to vote at shareholder meetings, but entitle the holder to a right to repayment preference on liquidation

• an increasing portion of the securities will attract dividend payments from 30 June 2025 onwards

• the dividend rate is based on 180 day NZ bank bill rate, plus 6% p.a. margin

• may be redeemed at any time by cash payment of total issue price or the issue of Chorus shares (at a 5% discount to the 20-day VWAP for Chorus shares)

Equity securities subject to paying dividends 30 June 30 June 30 June 30 June (cumulative) 2025 2030 2033 2036 TOTAL UFB1 & 2 $85.3m $197.1m $377.7m $766.4m $766.4m

▪ CIP debt securities

• unsecured, non-interest bearing and carry no voting rights at shareholder meetings

• Chorus is required to redeem the securities in tranches from 30 June 2025 to 2036 by repaying the issue price to the holder

Debt securities maturity 30 June 30 June 30 June 30 June profile 2025 2030 2033 2036 TOTAL UFB1 & 2 $85.3m $104.7m $166.7m $210.2m $566.9m

32

Fibre comprises 67% of Chorus connections

	30 Sept	31 Dec	31 March	30 June	30 Sept
Unbundled copper	2020 14,000	2020 13,000	2021 11,000	2021 10,000	2021 8,000	1,400,000	Baseband copper
(no broadband) Baseband copper	169,000	159,000	150,000	137,000	127,000	1,200,000	Unbundled copper
(no broadband)							Copper ADSL
Copper ADSL	218,000	197,000	180,000	163,000	152,000	1,000,000
(includes naked)							VDSL
VDSL	202,000	184,000	170,000	157,000	148,000	800,000
(includes naked)
Fibre broadband (GPON)	773,000	802,000	831,000	860,000	883,000	600,000	Fibre (GPON)
Data services (copper)	3,000	3,000	3,000	2,000	2,000	400,000
Fibre premium	11,000	11,000	11,000	11,000	11,000
(P2P) Total connections	1,390,000	1,369,000	1,356,000	1,340,000	1,331,000	200,000
						0	~~Business premium~~
						30-Sep-20 31-Dec-20			31-Mar-21		30-Jun-21		30-Sep-21

> 1,183,000 broadband connections comprises:

▪ 883,000 fibre (GPON) connections

• 300,000 VDSL/ADSL (copper) connections

Note : 10,000 partly subsidised education connections are excluded from this data

33

Connection and market trends

Broadband uptake by retailer (all technology)

NZ broadband market – by technology

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2,000,000
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
200,000
-
Spark Vodafone Orcon Vocus 2degrees Trustpower ROM
Q1 2013 Q2 2013 Q3 2013 Q4 2013 Q1 2014 Q2 2014 Q3 2014 Q4 2014 Q1 2015 Q2 2015 Q3 2015 Q4 2015 Q1 2016 Q2 2016 Q3 2016 Q4 2016 Q1 2017 Q2 2017 Q3 2017 Q4 2017 Q1 2018 Q2 2018 Q3 2018 Q4 2018 Q1 2019 Q2 2019 Q3 2019 Q4 2019 Q1 2020 Q2 2020 Q3 2020 Q4 2020 Q1 2021
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2,000,000
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
200,000
-
Chorus xDSL Chorus mass market fibre Chorus premium fibre
Local fibre companies (UFB) Other fibre networks Other xDSL
Vodafone cable Fixed (mobile) wireless Legacy fixed wireless, satellite
Source: IDC
Q1 2013 Q2 2013 Q3 2013 Q4 2013 Q1 2014 Q2 2014 Q3 2014 Q4 2014 Q1 2015 Q2 2015 Q3 2015 Q4 2015 Q1 2016 Q2 2016 Q3 2016 Q4 2016 Q1 2017 Q2 2017 Q3 2017 Q4 2017 Q1 2018 Q2 2018 Q3 2018 Q4 2018 Q1 2019 Q2 2019 Q3 2019 Q4 2019 Q1 2020 Q2 2020 Q3 2020 Q4 2020 Q1 2021
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Source: IDC

34

Disclaimer

This presentation:

• Is provided for general information purposes and does not constitute investment advice or an offer of or invitation to purchase Chorus securities.

• Includes forward-looking statements. These statements are not guarantees or predictions of future performance. They involve known and unknown risks, uncertainties and other factors, many of which are beyond Chorus’ control, and which may cause actual results to differ materially from those contained in this presentation.

• Includes statements relating to past performance which should not be regarded as reliable indicators of future performance.

• Is current at the date of this presentation, unless otherwise stated. Except as required by law or the NZX Main Board and ASX listing rules, Chorus is not under any obligation to update this presentation, whether as a result of new information, future events or otherwise.

• Should be read in conjunction with Chorus’ audited consolidated financial statements for the year to 30 June 2021 and NZX and ASX market releases.

• Includes non-GAAP financial measures such as "EBITDA”. These measures do not have a standardised meaning prescribed by GAAP and therefore may not be comparable to similar financial information presented by other entities. They should not be used in substitution for, or isolation of, Chorus' audited consolidated financial statements. We monitor EBITDA as a key performance indicator and we believe it assists investors in assessing the performance of the core operations of our business.

• Has been prepared with due care and attention. However, Chorus and its directors and employees accept no liability for any errors or omissions.

• Contains information from third parties Chorus believes reliable. However, no representations or warranties (express or implied) are made as to the accuracy or completeness of such information.

35