A Statement of Defence (SoD) was recently filed against the Joint Petition to have the two Settlement
Agreements with SCOR and ZFS declared binding. The SoD was filed by ten institutional investors
allegedly representing less than 1% of the total damages of the class of non-US investors eligible to
participate in these settlements. The parties to the joint Petition (Stichting Converium Securities
Compensation Foundation, SCOR Holding (Switzerland) AG, Zurich Financial Services Ltd and Vereninging
VEB NCVB) remain of the opinion that the two Settlements described in the Joint Petition are reasonable
in all respects, are in the best interests of all non-US shareholders, and fully satisfy the requirements
under Dutch law for approval of the Amsterdam Court of Appeal. The Parties to the Joint Petition will
refute the arguments set forth in the SoD at the oral hearing which will take place on 3 (and if necessary
on 4) October 2011.