GSM Investors

Globe Specialty Metals
AIM Rule 26 Disclosures

Details of Any Restrictions on the Transfer of Securities

For U.S. holders, the transfer of Shares and/or Warrants, and the exercise of Warrants, are subject to transfer and exercise requirements under the U.S. Securities Act of 1933 ("Securities Act"). This security was originally issued in a transaction exempt from registration under the Securities Act, and is a restricted security (as defined in Rule 144 under the Securities Act).

For U.S. holders, the Shares and Warrants are subject to the conditions listed under section 903(b)(3) or Category 3 of Regulation S of the Securities Act. Under Category 3, offering restrictions (as defined under Regulation S) had to be in place in connection with the offering and additional restrictions are imposed on resales of the securities. All Shares and Warrants are subject to these restrictions, regardless of whether the purchaser acquired the securities in a transaction pursuant to Rule 144A or in a transaction pursuant to Regulation S. This security cannot be offered, sold or otherwise transferred in the absence of registration or an applicable exemption therefrom.

Prior to permitting any transfer, the Company may request an opinion of counsel reasonably satisfactory to the Company that such transfer is to be effected in a transaction meeting the requirements of Regulation S under the Securities Act or is otherwise exempt from registration under the Securities Act.

There are otherwise no restrictions on the transfer of the Company's securities

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