Viceroy comment relating to report by Intellidex
12 July 2018 - So we can carry on writing our “prolific” research reports, here is Viceroy Research’s comment on
the Intellidex report:
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Viceroy expect our work to be treated with the same skepticism as that of any other party and have
continuously advocated for quality due diligence on the part of our readers. The quality of our research is
like any other, subjective, but our content is thoroughly back-tested. Intellidex’s report does not disprove
any of our published work.
Viceroy receives a significant amount of anonymous data relating to companies worldwide on a regular
basis. We incorporate independently verifiable data into our reports where appropriate and value-additive.
This was the case with Steinhoff, where substantial details of a further off-balance sheet entity were sent
to us and we incorporated this into our report where they could be second sourced and verified. We have
commented as such on every occasion where asked by numerous journalists locally. We have no business
relationship with any individuals or funds cited in Intellidex's report, and our work is funded internally.
Viceroy, like any short activist, has a network of industry consultants which are utilized on a case-by-case
basis under strict non-disclosure agreements. We have never shied away from this and the assertion that
this is somehow uncommon in the financial markets is ridiculous. There are many organizations that
specifically procure these specialist services for investment professionals. Again, the work of these
consultants is funded internally.
Viceroy itself is currently a key witness to regulators internationally. We have never shied away from
regulators and are actively assisting them in their pursuit of criminal prosecutions. It is ironic given these
circumstances that Intellidex – directly or indirectly – claim that we are somehow hiding away from
regulators. We are regulated, as is any other player in financial markets: any assertion otherwise is
ridiculous.
MiMedx served Viceroy weeks ago, and Viceroy have already filed a response to the complaint. We don’t
know how Intellidex have missed this given they have apparently counted every one of our tweets on a
company by company basis. We have widely discussed the lodgment of our response. Further, the CEO &
Chairman has been compelled to resign, internal investigations are taking place and prosecutions of
professionals are underway for receiving bribes and inducements from MiMedx.
Intellidex find it suspicious that we have used different valuation methodologies across different reports on
separate companies. We used an NPV for Syrah because it is a mine, and thus has a limited lifespan. We use
comparatives for companies like ProSieben because there are numerous variables that can’t feasibly be
reasonably priced in. We withhold valuations on any companies where we believe results have been
adulterated, and we will not try to blindly fabricate this data to justify a valuation. We price $0 valuations
where we do not see a viable future for the businesses. This is Finance 101.
Intellidex have interchanged the term “cabal” used to discredit short-sellers with “ecosystem”, and suggest
Viceroy are paid “semi-gratuitous” fees to promote hedge funds’ short positions. This is not the case, nor is
this a new conspiracy argument aimed at activist short sellers. Viceroy has no business relationships with
any of the individuals or funds cited in the Intellidex report, and all our research is funded internally. It
makes no financial sense for activist short sellers to disclose their work-in-progress or reporting timelines
to anyone, as this adversely affects our trading position. It is also illegal, referred to as “concert party”, and
we do not partake in this activity.

Viceroy encourages all parties to read our research at www.viceroyresearch.org, where they can make up their
own minds. We have also attached to this report the correspondence between Viceroy Research and Intellidex.
To avoid any dispute on our next piece on a South Africa Company, we have spent near 3 months back checking
our data and analysis and will publish only when we are satisfied of its accuracy and validity.
Yours faithfully

Viceroy Team

Viceroy Research Group

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