The information contained on this website is only a summary of the information presented in more detail in the Notice of Pendency and Proposed Settlement of Unitholder Class Action, Settlement Hearing, and Right to Appear (the “Notice”), which you can access here. Because this website is just a summary, you should review the Notice for additional details.

This website relates to stockholder class and derivative action (the “Action”), pending in the Court of Chancery of the State of Delaware (the “Court”)

NOTICE OF SETTLEMENT: Please also be advised that (i) co-lead plaintiffs Massachusetts Laborers’ Pension Fund, Charles Waddell, and John Bicanich (collectively, “Co-Lead Plaintiffs”), on behalf of themselves and the Classes (defined in paragraph 29 below), (ii) Defendants Erhard Schoewel, Robert Singer, Sabine Chalmers, and Pierre Laubies (collectively, the “Director Defendants”), (iii) Defendants Joachim Faber, Olivier Goudet, Peter Harf, and Anna-Lena Kamenetzky (collectively, the “JAB Director Defendants”), (iv) Defendants JAB Holdings B.V., JAB Cosmetics B.V., and Cottage Holdco B.V. (collectively, the “JAB Entity Defendants,” and with the Director Defendants and JAB Director Defendants, the “Defendants”), and (v) Nominal Defendant Coty (collectively with Co-Lead Plaintiffs and Defendants, the “Parties”) have reached a proposed settlement for $35,000,000 in cash and the implementation of certain corporate governance terms described below (the “Settlement”). The full terms of the Settlement are set forth in a Stipulation and Agreement of Compromise and Settlement (the “Stipulation”) filed with the Court on March 29, 2023. The proposed Settlement, if approved, will resolve all claims against the Defendants in the Action, including claims brought derivatively on Coty’s behalf.

If you are a member of one or both of the Classes, you are a Class Member subject to the Settlement and may be eligible to receive a pro rata distribution from the Settlement proceeds.  The Classes certified by the Court consist of:

All record holders and beneficial owners of shares of Coty Inc. common stock issued and outstanding as of February 11, 2019 (the “Class Shares”), together with their heirs, assignees, transferees, and successors-in-interest, in each case in their capacity as holders of Class Shares, whose Class Shares (i) were accepted for purchase on April 30, 2019 (the “Tendering Class”); or (ii) remained outstanding after April 30, 2019 (the “Remaining Stockholder Class”). Excluded from the Classes are Defendants and their respective affiliates.

Members of the Tendering Class (“Eligible Class Members”) are eligible to receive a pro rata distribution from the Settlement proceeds, according to the Plan of Allocation described below. 

PLEASE NOTE:  The Classes are non-“opt-out” classes pursuant to Delaware Court of Chancery Rules 23(a), 23(b)(1), and 23(b)(2).  Accordingly, Class Members do not have the right to exclude themselves from either Class.

If you are a member of the Remaining Stockholder Class and/or a Current Stockholder, you may be impacted by the corporate governance benefits included in the Settlement.  The Settlement, if approved by the Court, will resolve claims that were asserted in the Action derivatively on behalf of Coty, and requires the implementation of the corporate governance benefits described in the Notice.

Eligible Class Members do not need to submit a claim form in order to receive a distribution from the Settlement. If you are eligible to receive a distribution from the Settlement, your distribution will be paid to you directly.

Please be patient. If the Settlement is approved by the Court, it will take some time to conduct the Settlement distribution.

PLEASE READ THE NOTICE CAREFULLY AND IN ITS ENTIRETY.  The Notice explains how Current Stockholders and Class Members will be affected by the Settlement.  The following table provides a brief summary of the rights you have as a Current Stockholder and/or Class Member and the relevant deadlines, which are described in more detail in the Notice.