Commission européenne, DG COMP MERGER REGISTRY, 1049 Bruxelles, BELGIQUE  
Europese Commissie, DG COMP MERGER REGISTRY, 1049 Brussel,   BELGIË  
 
Tel: +32 229- 91111. Fax: +32 229 -64301. E -mail: COMP -MERGER -REGISTRY@ec.europa.eu.  
  EUROPEAN COMMISSION  
Brussels, 27.09.2019  
C(2019)  7107 final  
PUBLIC VERSION 
To the notifying parties  
Subject : Case M.9465 – PRIMUS  SHAREHOLDERS / PRUDENTIAL / REAL 
ESTATE  
Commission decision pursuant to Article 6(1)(b) of Council Regulation 
(EC) No  139/20041 and Article 57 of the Agreement on the European 
Economic Area2  
Dear Sir or Madam,  
1. On 4 September 2019, the European Commission received notification of a proposed 
concentration pursuant to Article 4 of the Merger  Regulation by which K Plus BV; 
Givin BV, Muhak BV and 3K Investment BV (“the Primus Shareholders”, 
Netherlands) and  Pramerica Real Estate Capital VI S.à.r.l. (“PRECap”, Luxembourg),  
(indirectly) managed by PGIM Fund Management Limited  and ultimately  controlled 
by Prudential Financial In c. (“PFI”, USA) , acquire within the meaning of 
Article  3(1)(b) of the Merger Regulation joint control over a real estate property 
located in Berlin (“ the Real Estate Asset ”) by way of  purchase of assets .3 
2. The business activities of the undertakings concerned are:  
− for the Primus Shareholders : investment vehicles, held by certain members of 
the Sabancı -family, who also have holdings in the affiliated entity Esas Holding 
A.S. (“Esas”), which is active (with offices in Istanbul and London) in the 
investm ent business globally investing in various asset classes including private 
equity, real estate, venture capital and liquid assets.  
− for PreCAP: the provision of capital to assist with the acquisition and refinancing 
of commercial real estate assets predominantly located in the United Kingdom 
and Germany. PRECap is ultimately controlled by Prudential Financial Inc, a 
financial services institution providing insurance, investment management, and 
                                                 
1 OJ L 24, 29.1.2004, p. 1 ( the ‘Merger Regulation ’). With effect from 1 December 2009,  the Treaty on 
the Functioning of the European Union ( ‘TFEU ’) has introduced certain changes, such as the 
replacement of ‘Community ’ by ‘Union’  and ‘common market ’ by ‘internal market ’. The terminology 
of the TFEU will be used throughout this decision.  
2  OJ L 1, 3.1.1994, p.  3 (the ‘EEA Agreement ’). 
3  Publication in the Official Journal of the European Union No C 307, 11.9.2019, p. 9. 

 
2 other financial products and services to both retail and institutional customers 
throughout the United States and in over 40 other countries.  
− for the Real Estate Asset : a real estate property located at Groninger Straße 25, 
27, Liebenwalder Straße 21, Oudenarder Straße 16, 13347 Berlin, which is 
mainly used for office purposes and to a minor extent also for retail, 
manufacturing and logistic purposes.  
3. After examination of the notification, the European Commission has concluded that 
the notified operation falls within the scope of the Merger  Regulation and of 
paragraph 5(c) of the Commission Notice on a simplified procedure for treatment of 
certain concentrations  under Council Regulation (EC) No  139/2004.4 
4. For the reasons set out in the Notice on a simplified procedure, the European 
Commission has decided not to oppose the notified operation and to declare it 
compatible with the internal market and with the EEA Agreement. This decision is 
adopted in application of Article 6(1)(b) of the Merger  Regulation  and Article 57 of 
the EEA Agre ement . 
For the Commission 
 
 
(Signed)  
Cecilio MADERO VILLAREJO  
Acting Director -General  
                                                 
4  OJ C 366, 14.12.2013, p. 5.