Green bonds – building optionality for issuers into programme documentation

White & Case LLP

White & Case LLP

Since their introduction in 2007, green bonds issuances have exponentially increased in volume and have become a necessary product for bond issuers to offer their investor base. In view of this, bond issuers are increasingly building optionality into existing MTN and GMTN Programme documentation to enable them to issue green bonds and meet investor demands.

Market Guidelines, Rules and Regulations

Green characteristics

There is no market standard definition of a "green bond" however, there are a few internationally accepted sets of criteria that set out key characteristics of what makes a bond "green" as opposed to a conventional bond. Chief among them are the Green Bond Principles ("GBP"). The GBP were developed by the International Capital Markets Association ("ICMA") in 2014, as updated in June 2017, in order to strengthen the integrity of the green bond market, which focuses on financing environmentally friendly and low carbon assets. The GBP are voluntary market guidelines that set out transparency, reporting and disclosure recommendations. The GBP: (i) provide issuers with guidance on the key components involved in launching a green bond; (ii) aid investors by ensuring availability of information necessary to evaluate the environmental impact of their green bond investments; and (iii) assist dealers/managers by standardising disclosure to facilitate transaction comparisons. Disclosure of "green" Use of Proceeds is the cornerstone of a green bond however the GBP do not have prescriptive formula for it. The "Use of Proceeds" section of a typical green bond prospectus1 is flexible enough to describe the project the issuer desires to use the proceeds for while enabling investors to assess whether the level of "green use" is compatible with their investment needs.

Benefits of going green

Whether an issuer opts to use the GBP as the basis of the green bond issuances or builds a more bespoke framework, their first foray into the green bond market is likely to be off their existing MTN programme, in particular in case of frequent issuers.

There are a number of advantages to building green bond capability into an MTN or GMTN Programme. From the issuer's perspective, a green bond results in the diversification of its investor pool (e.g., greater numbers of asset managers and insurance or pension funds, regional shift of investor groups), and contributes to "green" investor relations and corporate social responsibility initiatives. From a dealer/manager’s perspective, green bonds can be marketed as premium products to their clients as many investors are increasingly required to invest in social and sustainable products in order to meet their social and sustainability guidelines or criteria in their investment strategies. Hence, green bonds are considered as an asset class of its own. For investors, it provides much needed supply to the market.

"Green" Terms in Programme Documentation

As a practical matter an issuer will designate a "green" Use of Proceeds in the EMTN or GMTN base prospectus or other disclosure documentation and then provide summarised information about: (i) the "green" (eligible) projects it expects to finance, (ii) any reporting obligations it may have and (iii) the provision of second party opinions (if any). These rather simple amendments and others outlined below are the key changes that can be made to existing EMTN and GMTN Programme documentation in order to build in optionality for issuers to issue green bonds.

Key "green" terms

The GBP provide recommendations on process and disclosure that issuers, investors, underwriters, placement agents, rating agencies and other market participants may use to understand the characteristics of a particular green bond. The key sections in an EMTN and GMTN base prospectus or similar disclosure document are:

  • the "Use of Proceeds" section;
  • the applicable "Final Terms" or "Pricing Supplement"; and
  • the "Risk Factors" section.

When updating an existing MTN or GMTN base prospectus, the following few changes could enable issuers to raise funds for new and existing projects with environmental benefits through green bonds. Alternatively, issuers could include some of these in a supplemental or drawdown Prospectus to issue green bonds without completing a programme update:

  • Use of Proceeds is universally included in green bond documentation and remains the single most consistent identifier for a green bond. An issuer wishing to issue green bonds using its existing EMTN or GMTN programme documentation could include wording similar to the following in the "Use of Proceeds" section of its EMTN or GMTN base prospectus:
    • The net proceeds from each issue of Notes will be used by the issuer for general corporate purposes, unless otherwise specified in the applicable Final Terms or, in the case of Exempt Notes, the applicable Pricing Supplement.
    •  In particular, if so specified in the applicable Final Terms or, in the case of Exempt Notes, the applicable Pricing Supplement, the Issuer will apply the net proceeds from an offer of Notes specifically for projects and activities that promote climate-friendly and other environmental or sustainable purposes ("Green Projects")2.
  • "Green" Risk Factors are often included in an EMTN or GMTN base prospectus in order to describe the specific "green" risks which come along with an investment in green bonds. Such risks need to be set out on base prospectus level and cannot be added in the relevant Final Terms. If risk factors are not included in a current EMTN or GMTN base prospectus they can be introduced by way of supplement to the relevant base prospectus. Once the Prospectus Regulation3 becomes directly applicable (i.e. post 21 July 2019), risk factors will be categorised according to type of risk and listed in order of materiality. In addition, the assessment of the risk materialising (low, medium or high) may be disclosed but unlikely that issuers choose to do so due to an increase of liability. An issuer would therefore have to consider the specific risks related to issuing a green bond in comparison to more general risks about its business and the environment in which it operates and categorise them accordingly.

Final Terms or Pricing Supplement: issuers can include the following in "Part B" of their Final Terms or Pricing Supplements to facilitate green bond issues:

Reasons for the offer


Reasons for the offer:

[●] / [Not Applicable]

(See "Use of Proceeds" wording in the Prospectus – if reasons for the offer are different from general corporate purposes, include those reasons here, including if the Issuer intends to apply the net proceeds for Green Projects.)

This allows the Issuer to outline details of the specific eligible project or structure that the proceeds of the green bond issuance will be used for in the applicable Final Terms or Pricing Supplement. Although many stock exchanges accept such amendments to the form of Final Terms and/or Pricing Supplement, some may not. In these cases, we would work together with the listing venue team to find alternative solutions that work for that particular exchange and still allow issuer to incorporate relevant Use of Proceeds disclosure in the offering document.

  • Other potential amendments: issuers can include further features in the EMTN or GMTN base prospectus such as including details of the process for project evaluation and selection, management of proceeds and reporting in relation to the proceeds of any green bond issuances and appropriate disclaimers. These are not mandatory but may help raise interest from certain "dark green" investors.

Key "green" terms – Contractual Documents

Undertaking or representation on Use of Proceeds

"Green" provisions are not typically included in contractual documents, although the inclusion of an undertaking regarding Use of Proceeds in the Dealer and/or Subscription Agreement is sometimes requested by underwriters.

However, we do see a representation on the use of proceeds in the context of sanction representations, e.g. "The Issuer will only use the proceeds of the issue of the Notes, or lend, contribute or otherwise make available such proceeds to any person or entity for the purposes as disclosed in the Prospectus."

Issuers should ensure that such an undertaking or representation does not create an obligation of liability for ongoing monitoring or enforcement.

"Green" undertakings

Issuers are reluctant to include "green" undertakings as a breach may trigger an event of default under bond documentation, which could result in cross-defaults of other agreements. However, in green project bonds and "green" structured finance there has been a willingness to include such undertakings. There does not currently appear to be much demand from investors to move toward an undertaking–style approach but this may change in a changing market environment.

Prospectus liability

In many jurisdictions, prospectus liability (either criminal or civil) may be imposed if there is a material inaccuracy in, or omission of information from, the prospectus or other offering document, which causes investors to suffer loss as a result. If the issuer discloses in the "Use of Proceeds" section, for example, that it would use the proceeds of the issuance for certain eligible projects, and did not, in some jurisdictions prospectus liability may arise if the result of such incorrect or incomplete disclosure is a loss. The same may apply if the disclosure in the prospectus or offering document sets out a mechanism to credit the proceeds of the green bond into a specific sub-account or otherwise track them by a formal internal process.

Green bond listing venues

There are a growing number of dedicated green bond markets and indices that exist to promote "green" finance, such as the green bond segment of the London Stock Exchange, the Frankfurt Stock Exchange, the Luxembourg Green Exchange, the Shanghai Stock Exchange Social Responsibility Index and the FTSE4GOOD Index Series. Green bonds must comply with the listing rules of the dedicated green bond segment of the relevant Stock Exchange on which they are listed. These rules or criteria apply in addition to conventional regulatory listing requirements or rules for bonds and include, inter alia, disclosure on the Use of Proceeds, external review and ex-post reporting. There are a number of green bond exchanges that have similar listing requirements for green bonds.

Market Precedents

Example "green" Programmes

We have advised several issuers on updating their Programme documentation in order to allow them to issue green bonds. Here is a sample of different approaches that issuers can take. However, there are many options available to make MTN programmes green bond ready.

Investment Grade Financial Institutions: Svenksa Handelsbanken AB (publ) completed their Programme update in June 2017. Although the bank amended its ‘Use of Proceeds’ wording and Final Terms/Pricing Supplement in its updated Prospectus, it opted to omit a green bonds risk factor, preferring instead to issue a Supplementary Prospectus for any future green bond issuance.

Crédit Agricole Corporate & Investment Bank ("CACIB") issued Premium Green PLC Series 2017-2 Balance Sheet Notes due 2029 pursuant to the PREMIUM Multi Issuer Asset Backed Medium Term Note Programme. The transaction was a landmark US$3 billion synthetic securitisation of project finance, asset finance and infrastructure loans, a first-of-its-kind "Green Capital Note" that blends best practice from capital management and the objectives of socially responsible investing.

Landesbank Baden-Württemberg (LBBW) completed their Programme update in April 2017. The bank amended its ‘Use of Proceeds’ wording on base prospectus level in order to set out relevant Use of Proceeds wording in the relevant Final Terms for the first senior unsecured green bond issue by LBBW in December 2017.

Corporates: a number of corporates have updated their Programme documentation to include optionality to issue green bonds. Stora Enso, a leading provider of renewable solutions in packaging, biomaterials, wood and paper has issued green bonds under their programme and included a market setting "green" risk factor.

SNCF Réseau, the French railway infrastructure manager issued a debut green bond of €900 million 1.00%. Notes due 2032 with a follow up issue in March 2017 of €1bn 1.875%. Notes due 2034, both were admitted to trading on the regulated market of Euronext Paris. SNCF Réseau is the first railway infrastructure manager in the world and the first European transportation entity to issue a green bond. The proceeds of these issues will be allocated in priority to maintenance and upgrades of the railway network and to development of new projects and the strengthening of the strategy of SNCF Réseau dedicated to biodiversity and protection of natural resources.

Unibail-Rodamco: we represented Bank of America Merrill Lynch International and Crédit Agricole CIB as Global Coordinators on the issue of €750 million 2.5% Notes due 2024 under the €11 billion Guaranteed Euro Medium Term Note Programme. This transaction represents the first green bond issuance for a real estate business in the European market.

Sovereigns: we represented the Ministry of Finance of the Republic of Poland on the offering of a five year €750 million denominated green bond with a maturity of 2021 under its EMTN Programme. Republic of Poland green bond was the first sovereign green bond.

Click here to download PDF.

1 Prospectus is used as a general term to represent offering memorandum and other debt securities offering documentation and the terms can be used interchangeably in this regard.
2 This is a generic example only, specific terms may vary.
3 Regulation (EU) 2017/1129.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© White & Case LLP | Attorney Advertising

Written by:

White & Case LLP

White & Case LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.