Common use of STIPULATION AND AGREEMENT OF SETTLEMENT Clause in Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT. This Stipulation and Agreement of Settlement, dated as of May 8, 2023 (the “Stipulation”) is entered into between (a) Lead Plaintiffs Handelsbanken Fonder AB (“Handelsbanken”); Public Employees’ Retirement System of Mississippi (“Mississippi”); State of Rhode Island, Office of the General Treasurer (“Rhode Island”); and Louisiana Sheriffs’ Pension & Relief Fund (“Louisiana Sheriffs”) on behalf of themselves and the other members of the Settlement Class (as defined in paragraph 1(pp) below); and (b) defendants Xxxxx Fargo & Company (“Xxxxx Fargo” or the “Company”), Xxxxxxx X. Xxxxx, Xxxx X. Xxxxxxxxxxx, X. Xxxxx Xxxxxx, and Xxxxxxxxx “Xxxxx” Xxxx (collectively, the “Individual Defendants” and, with Xxxxx Fargo, “Defendants”), by and through their respective undersigned counsel, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”). Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice all claims that were or could have been asserted in the Action against Defendants.

STIPULATION AND AGREEMENT OF SETTLEMENT. This Stipulation and Agreement of Settlement, dated as of May 8, 2023 Settlement (the “Stipulation” or “Settlement Agreement”) is made and entered into by and between (a) Lead Plaintiffs Handelsbanken Fonder AB (“Handelsbanken”); Plaintiff Public Employees’ Retirement System of Mississippi (“MississippiMissPERS” or “Lead Plaintiff”) and additionally named Plaintiff Monroe County Employees’ Retirement System (“Monroe,” and with MissPERS, “Plaintiffs”); State of Rhode Island, Office of the General Treasurer (“Rhode Island”); and Louisiana Sheriffs’ Pension & Relief Fund (“Louisiana Sheriffs”) on behalf of themselves and the all other members of the proposed Settlement Class (as defined in paragraph 1(pp) below); , on the one hand, and (b) defendants Xxxxx Fargo & Company Defendants Xxxxxxx Holdings plc (“Xxxxx FargoNielsen” or the “Company”), Xxxxxxx X. XxxxxXxxxxx Xxxxxxxx Barns, Xxxx X. Xxxxxxxxxxx, X. Xxxxx XxxxxxXxxxxxxx, and Xxxxxxxxx “Xxxxx” Xxxx Xxxxxx Xxxxxxx (collectively, the “Individual Defendants,” and, and together with Xxxxx Fargo, Nielsen the “Defendants,” and together with both Nielsen and Plaintiffs the “Parties”), on the other, by and through their respective undersigned counselcounsel of record in the above-captioned litigation pending in the United States District Court for the Southern District of New York (the “Court”). This Stipulation is intended by the Parties to fully, finally, and embodies forever resolve, discharge, and settle the Released Claims as against the Released Defendant Parties and the Released Defendants’ Claims as against the Released Plaintiff Parties (each of these terms as defined below), upon and subject to the terms and conditions of the settlement of the above-captioned action (the “Action”). Subject hereof and subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice all claims that were or could have been asserted in the Action against DefendantsCourt’s approval.