I propose to take Questions Nos. 510, 511 and 512 together.
The NTMA uses a network of primary dealers to sell Irish Government Bonds. There are currently fourteen primary dealers. Bond sales are mainly through two methods, bond syndications and bond auctions.
Bond syndications involve assembling a syndicate of primary dealers, usually six, from the full network of primary dealers. The syndicate works with the NTMA to launch new bonds or significant taps of existing bonds. The size of bond syndications is typically €3 billion and upwards. Bonds sold through a syndicate are sold to end investors who may choose to hold the bonds to maturity or trade them themselves. The primary dealers invite institutional and other investors to submit orders for the bonds and the prices which they are willing to pay for them. As such investors can include companies affiliated with a primary dealer or be a primary dealer itself; bonds would have been sold to Davy along with other primary dealers.
Bond auctions involve the sale of bonds to primary dealers in a competitive auction process on an electronic platform. Allocations to primary dealers by this method are made in accordance with the bid prices with the final price of each bond set at a cut-off level as determined by the NTMA. In the case of bond auctions all primary dealers including Davy were obliged to bid for bonds and a primary dealer such as Davy would have been allocated bonds if their bid was at or above the cut-off level.
Separately, Davy was appointed by the NTMA to sell corporate bonds held in ISIF (period checked 2014-2021). The contract contained selling restrictions, including a restriction on Davy offering or selling the bonds to Davy or any affiliate, partner, officer, director or employee of Davy.
No potential conflicts were declared in respect of the sale of the above bonds.
Financial services in connection with the sale of bonds are excluded from the scope of the EU (Award of Public Authority Contracts) Regulations 2016.