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3.2
One consequence of the above changes is that, to a much greater extent than in past years, the target company may need (and perhaps would be expected) to engage professional advisers, consultants and experts (e.g. lawyers, accountants, financial advisers, analysts, public relations experts, market sector experts, etc) to assist it throughout the takeover process. As a result it should be recognised that target companies in the modern takeover environment may properly incur costs that would not have been incurred, or may not have been seen as properly incurred, at the time Canterbury Frozen Meat was decided.

3.3
This environment means that companies subject to takeovers suffer from not only a significant diversion of resources when a bid occurs, but also very real cost which, in some cases, can be quite disproportionate to the size or assets of the target company. Takeover offers can be hostile and in any event do not require the agreement of the target company to be made. Therefore it is important that rule 49(2) is applied in a manner which reflects the realities of a modern takeover and enables all properly incurred expenses to be recovered.

4.
Applying Canterbury Frozen Meat to rule 49(2)

4.1
The Panel considers that Canterbury Frozen Meat should be applied to rule 49(2) as set out below.

Category 1 (expenses related to notices and target company statement obligations)

4.2
In broad terms, this category is directed to the regulatory obligations of target company boards in responding to takeover offers. The manner in which the category is expressed by the Court reflects the limited regulatory requirements of both the Companies Amendment Act 1963 and the law generally in 1972. Applying the principle to which this category is directed in the light of today's takeover environment, the Panel recognises two parts to this general category:

The line between complaints about matters which affect target company shareholders and complaints designed to frustrate the course of the bid can be a fine one. Bidders should not be expected to pay for relentless target company actions regarding legal compliance.

4.3
Expenses which are incidental to the above should also be recoverable. It is recognised that there may be some overlap between Part 1 and Part 2.

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