CELEX: 32021M10164
Language: en
Date: 2021-04-29 00:00:00
Title: Commission Decision of 29/04/2021 declaring a concentration to be compatible with the common market (Case No COMP/M.10164 - CVC / STARK GROUP) according to Council Regulation (EC) No 139/2004 (Only the English text is authentic)

EUROPEAN COMMISSION
                                                                Brussels, 29.4.2021
                                                                C(2021) 3189 final
                                                                                  PUBLIC VERSION
                                                                 In the published version of this decision,
                                                                 some information has been omitted
                                                                 pursuant to Article 17(2) of Council
                                                                 Regulation (EC) No 139/2004 concerning
                                                                 non-disclosure of business secrets and other
                                                                 confidential information. The omissions are
                                                                 shown thus […]. Where possible the
                                                                 information omitted has been replaced by
                                                                 ranges of figures or a general description.
                                                                CVC Capital Partners SICAV-FIS S.A.
                                                                20 Avenue Monterey
                                                                L-2163 Luxembourg
                                                                Luxembourg
Subject:            Case M.10164 – CVC/Stark Group
                    Commission decision pursuant to Article 6(1)(b) of Council Regulation
                    No 139/20041 and Article 57 of the Agreement on the European Economic
                    Area2
Dear Sir or Madam,
(1)       On 23 March 2021, the European Commission received notification of a proposed
          concentration pursuant to Article 4 of the Merger Regulation by which CVC Capital
          Partners SICAV-FIS S.A. ('CVC', Luxembourg) intends to acquire within the
          meaning of Article 3(1)(b) of the Merger Regulation sole control of STARK Group
          A/S ('Stark', Denmark) (the 'Transaction').3 CVC and Stark are designated
          hereinafter as the 'Parties'.
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 (the '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 113, 31.3.2021, p. 12.
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.
 ---pagebreak--- 1.      THE PARTIES
(2)     CVC and its subsidiaries manage investment funds and platforms. In particular,
        CVC owns Ahlsell AB ('Ahlsell'), which is active as a retailer and distributor of
        installation products for heating, ventilation and air-conditioning ('HVAC'),
        electrical equipment, tools and supplies, as well as building materials. Ahlsell has an
        approximate turnover of EUR [2 500 - 3 000] million. Ahlsell is active in Denmark,
        Finland, Norway and Sweden ('the 'Nordics').
(3)     Stark is mainly active as a retailer and distributor of heavy building materials, such
        as timber products, bricks, insulation, plasterboards, doors, windows and cement.
        Stark also offers a limited range of installation products and tools and supplies. Stark
        is active in the Nordics and in Germany.
2.      THE CONCENTRATION
(4)     On 8 January 2021, CVC agreed to acquire Stark via certain, indirectly wholly
        owned, special purpose vehicles under a sale and purchase agreement. Following the
        Transaction, Stark would be fully owned and solely controlled by CVC.
(5)     As a result, the Transaction constitutes a concentration within the meaning of
        Article 3(1)(b) of the Merger Regulation.
3.      UNION DIMENSION
(6)     The undertakings concerned have a combined aggregate world-wide turnover of
        more than EUR 5 000 million4 (CVC: EUR […] million (2019); Stark: EUR […]
        million (2019)). Each of them has a Union-wide turnover in excess of EUR 250
        million (CVC: EUR […] million (2019); Stark: EUR […] million (2019)), and they
        do not achieve more than two thirds of their aggregate Union-wide turnover within
        one and the same Member State.
(7)     The Transaction therefore has a Union dimension within the meaning of Article 1(2)
        of the Merger Regulation.
4.      MARKET DEFINITION
(8)     The Parties are both active in the distribution of building materials. Whereas Ahlsell
        is a specialist builder's merchant, Stark is a generalist builder's merchant. Ahlsell
        specialises in the distribution of installation products in the segments HVAC and
        electrical, as well as tools and supplies. Stark is active as distributor of general
        building materials. Ahsell is present both at wholesale and retail levels whereas
        Stark is only present at the retail level.
4   Turnover calculated in accordance with Article 5 of the Merger Regulation.
                                                          2
 ---pagebreak--- 4.1.    Relevant Product Market
4.1.1. The Commission's Previous Decisions
(9)     Within the overall market of distribution of building materials, the Commission has
        previously defined a market for the distribution of building products in general, but it
        has left open whether this market can be further divided into: (i) wholesale to
        retailers, (ii) retail sale to professional customers, and (iii) retail sale to consumers
        ('non-professional customers') primarily through (DIY) stores.5
(10)    In respect to (i), wholesale to retailers, the Commission has further considered
        a distinction by product category.
(11)    In respect to (ii) and (iii), retail sale to professional customers and consumers, the
        Commission has also noted that a distinction may exist between generalist builder's
        merchants and specialist builder's merchants6. Within specialist builder's merchants,
        the Commission also considered whether separate product markets exist for the
        distribution of individual product categories, for example insulation, installation
        products.7 However, such potential segmentations have been ultimately left open.
(12)    Against this matrix whereby the markets for the distribution of building materials are
        defined by sales channel, distinction between generalist and specialist merchants,
        and product categories, the Commission has considered that the distribution of
        (i) installation products8 and (ii) tools and supplies9 to constitute separate markets
        from the market for the distribution of building materials.
(13)    In relation to the distribution of installation products, the Commission has
        considered a distinction between the following sales channels: (i) wholesale to
        retailers, (ii) retail sale to professional customers, and (iii) retail sale to non-
        professional customers.10 The Commission has also considered further
        segmentations by individual product categories, in particular it has considered (i) the
        wholesale distribution of heating, ventilation, air conditioning (HVAC) and (ii) the
        wholesale or retail distribution of electrical products.11 These further segmentations
        have been ultimately left open.
(14)    Similarly in regard to the distribution of tools and supplies, the Commission has
        previously considered a distinction by sales channel: (i) wholesale to retailers,
        (ii) retail sale to professional customers, and (iii) retail sale to non-professional
        customers. The Commission also considered a further segmentation by product
        category whereby, the distribution of workwear and personal protective equipment
5   See, for example, Case COMP/M.7703 – PontMeyer/DBS, paragraphs 11–12; Case COMP/M.3407 –
    Saint Gobain/Dahl, paragraphs 12 and 16; Case COMP/M.3142 – CVC/Danske Traelast, paragraphs 11–
    13; Case M.8733 – Lone Star/Stark, paragraph 25; and Case COMP/M.9406 – Lone Star - Stark Group /
    Saint Gobain BDD, paragraph 19
6   Case COMP/M.3943 – Saint-Gobain/BPB, paragraph 15. Case COMP/M. 9790 – Blackstone/KP1,
    paragraph 22 and 23.
7   Case COMP/M.3407 – Saint Gobain/Dahl, paragraph 15 and Case COMP/M.3943 – Saint-Gobain/BPB,
    paragraphs 17-19. Case COMP/M.4050 – Goldman Sachs/Cinven/Ahlsell, paragraphs 8–13
8   Case M.7910 – Kesko/Onninen, paragraph 21
9   Case COMP/M.9644 – Nordstjernan/Momentum Group, paragraphs 13-21.
10 Case COMP/M.4050 – Goldman Sachs/Cinven/Ahlsell, paragraphs 8–13.
11 Case COMP/M.7457 – CVC/Paroc, paragraphs 23-25.
                                                       3
 ---pagebreak---         would constitute a separate market.12 However, the Commission '' but it ultimately
        left this issue open.13
4.1.2. The Parties' Arguments
(15)    The Parties agree with the segmentation by sales channels. At the wholesale level,
        the Parties agree with the distinction of installation products and tools and supplies
        but argue that a further distinction by product category is not necessary as the
        majority of suppliers offer a broad portfolio within each of these two categories. At
        the retail level, the Parties agree with the distinction between generalist and
        specialist merchant markets and with the further segmentation of specialists'
        merchant markets by the broader categories regarding installation products and tools
        and supplies. However, they argue that each of these two markets should not be
        further segmented by product category.
(16)    In conclusion, the Parties submit that at the wholesale level there are two relevant
        product markets: the wholesale market for the distribution of installation products
        and for the wholesale market for the distribution of tools and supplies. At the retail
        level, the Parties submit there is a generalist market for building materials, which can
        be further segmented by type of customer (professional and non-professional), and
        two specialist markets: one for installation products and another for tools of supplies
        further segmented by type of customer but not by product category.
4.1.3. Assessment
(17)    In respect to the wholesale markets, the majority of the respondents to the market
        investigation confirmed that there are two distinct markets: one for the wholesale of
        installation products; and another for the wholesale distribution of tools and supplies.
        However, the majority of respondents that expressed a view do not agree with
        a further segmentation of each of these two markets by product categories.14
(18)    The alternative segmentation of the wholesale installation products into HVAC in
        one hand, and electrical products, on the other does not affect the outcome of the
        competitive assessment of the Transaction, therefore the Commission concludes that
        exact product definition of the wholesale installation product market maybe left
        open.
(19)    Similarly, the further distinction of workwear and PPE from the overall tools and
        supplies market does not affect the outcome of the competitive assessment of the
        Transaction, therefore the Commission concludes that exact product definition of the
        wholesale market for tools and supplies maybe left open.
(20)    In respect to the retail markets, the majority of the respondents have also confirmed
        that the following are distinct markets: (i) generalist building materials, (ii) retail
        distribution for installation products, as well as (iii) retail distribution for tools and
        supplies. The majority of respondents that expressed a view also agree with a further
        segmentation of each of these three markets by customer type, and into retail sales to
12  Case COMP/M.9644 – Nordstjernan/Momentum Group, paragraphs 13-21.
13  Case COMP/M.9644 – Nordstjernan/Momentum Group, paragraphs 13-21.
14 Responses to Q1 – Questionnaire to customers, question 8; and Q2 – Questionnaire to competitors,
    question 6.
                                                    4
 ---pagebreak---        professionals and retail sales to non-professionals.15 However, the majority of
       respondents do not consider it necessary to further segment the retail market for
       installation products into HVAC products and electrical products. The majority of
       respondents that expressed a view also do not consider it necessary to further
       distinguish the workwear and PPE from the tools and supplies market.16.
(21)   The alternative segmentation of the retail buildings materials market by customer
       type, into retail sales to professionals and retail sales to non-professionals does not
       affect the outcome of the competitive assessment of the Transaction, therefore the
       Commission concludes that exact product definition of the retail markets for
       building materials may be left open.
(22)   The alternative sub-segmentation by product category of the retail markets for
       installation products into HVAC products and electrical products does not affect the
       outcome of the competitive assessment of the Transaction. Similarly the alternative
       sub-segmentation by customer type, into retail sales to professionals and retail sales
       to non-professionals also does not affect the competitive assessment of the
       Transaction, therefore the Commission concludes that exact product definition of the
       retail markets for installation products may be left open.
(23)   The alternative sub-segmentation by product category of the retail markets for tools
       and supplies into work-wear and PPE does not affect the outcome of the competitive
       assessment of the Transaction. Similarly, the alternative segmentation by customer
       type, into retail sales to professionals and retail sales to non-professionals also does
       not affect the competitive assessment of the Transaction, therefore the Commission
       concludes that exact product definition of the retail markets for tools and supplies
       may be left open.
(24)   Based on the above, for the purpose of assessment of the Transaction the
       Commission will consider the following markets and segmentations:
       (a)     Wholesale market of installation products with a possible segmentation by
               product categories into HVAC products and electrical products.
       (b)     Wholesale market of tools and supplies with a possible distinction of
               workwear and PPE products.
       (c)     Retail distribution market for building materials with a possible segmentation
               by customer type into professional and non-professional customers, and
               between generalist builder's merchants and specialist builder's merchants.
       (d)     Retail distribution market for installation products, as a possible segment of
               the retail specialist building materials market, with a possible further
               segmentation by customer type into professional and non-professional
               customers, as well as by product category into HVAC products and electrical
               products
15 Responses to Q1 – Questionnaire to customers, question 6; and Q2 – Questionnaire to competitors,
   question 4.
16 Responses to Q1 – Questionnaire to customers, question 9; and Q2 – Questionnaire to competitors,
   question 7.
                                                   5
 ---pagebreak---         (e)     Retail of tools and supplies, as a possible segment of the retail specialist
                building materials market, with a possible further segmentation by customer
                type into professional and non-professional customers, as well as with
                a possible distinction of the product category workwear and PPE.
4.2.    Relevant Geographic Market
4.2.1. The Commission's Previous Decisions
(25)    In relation to wholesale markets for installation materials, including the alternative
        segmentations into HVAC and electrical products, the Commission has considered
        the relevant geographic market to be at least national but ultimately left the exact
        definition open. 17 Similarly, the Commission also considered the wholesale markets
        of tools and supplies, including the workwear and PPE to be at least national but
        ultimately left the exact market definition open18
(26)    In relation to the retail distribution markets for building materials, installation
        products (including further product segmentations), tools and supplies (including
        workwear and PPE) the Commission has previously found the relevant geographic
        markets to be national or potentially narrower (local). The question has been
        ultimately been left open.19 The alternative of national or local markets applies to
        both retail sales to professional customers and retail to professional customers.
(27)    The retail local markets have been defined by catchment areas of 30 km radius from
        generalist builder's merchant stores and by catchment areas of 50 km from specialist
        builder's merchant stores, which includes the installation products and the tools and
        supplies products.20
4.2.2. The Parties' Arguments
(28)    The Parties submit that each wholesale market for installation products (including
        the HVAC and electrical products segmentations), as well as the wholesale market
        for tools and supplies (including workwear and PPE segment) are national in scope.
(29)    The Parties submit that each of the retail markets for distribution of building
        materials, installation products and tools and supplies are national in scope because
        all of their main competitors operate at the national level and their price lists are set
        nationally. Moreover, the Parties argue that customers also order online and by
        phone and have their purchases delivered directly to them either from the retailers'
        warehouses, or from the manufacturers' sites. For example, […]. Nonetheless, the
        Parties have provided data for catchment areas within a 30 km radius of Stark's
        stores and for catchment areas within a 50 km radius of Ahlsell's stores.
17  Case COMP/M.7457 – CVC/ Paroc, paragraphs 26-28.
18  Case COMP/M.9644 – Nordstjernan/Momentum Group, paragraph 16.
19 Case COMP/M.3142 – CVC/Danske Traelast, paragraphs 14-16.
20 Case COMP/M.7703 - Pontmeyer/DBS, paragraph 21; Case COMP/M.7107 – Cordes & Graefe Case
    COMP/M.3184 - Wolseley / Pinault Bois & Materiaux, paragraphs 19–22.
                                                     6
 ---pagebreak--- 4.2.3. Assessment
(30)    The majority of respondents to the market definition considers that the retail markets
        of (i) building materials, (ii) installation products and (iii) tools and supplies are
        local (i.e. based on catchment areas within a 30 km radius from the store for
        generalist builder’s stores or 50 km radius from the store for specialist builder’s
        stores) whereas wholesale markets for installation products and tools and supplies
        are national.21
(31)    In line with past decisional practice, the Commission considers the wholesale
        markets for (i) installation products and (ii) tools and supplies are at least national in
        scope for the purposes of this Decision.
(32)    In respect to the retail markets of building materials, installation products (including
        HVAC and electrical products), tools and supplies (including workwear and PPE)
        the geographic relevant markets are national or local. The exact geographic market
        definition can be left open, as the outcome of the competitive assessment does not
        change under either of these two alternatives.
5.      COMPETITIVE ASSESSMENT
5.1.    Analytical framework
(33)    Under Article 2(2) and (3) of the Merger Regulation,22 the Commission must assess
        whether a proposed concentration would significantly impede effective competition
        in the internal market or in a substantial part of it, in particular through the creation
        or strengthening of a dominant position. Depending on the position of the parties in
        the supply chain, a concentration may entail horizontal and/or non-horizontal effects.
(34)    Horizontal effects arise when the parties to a concentration are actual or potential
        competitors in one or more of the relevant markets concerned. The Commission
        appraises horizontal effects in accordance with the guidance set out in the Horizontal
        Merger Guidelines.23
(35)    Non-horizontal effects arise when the parties to a concentration operate in different
        levels of the supply chain in certain relevant markets (vertical effects). The
        Commission appraises non-horizontal effects in accordance with the guidance set out
        in the Non-Horizontal Merger Guidelines.24
(36)    Both the Horizontal and Non-Horizontal Merger Guidelines distinguish between two
        main ways in which mergers between actual or potential competitors on the same
        relevant market may significantly impede effective competition, namely
        non-coordinated and coordinated effects.
21  Responses to Q1 – Questionnaire to customers, question 10; and Q2 – Questionnaire to competitors,
    questions 8 and 9.
22 As regards the assessment in relation to the EEA, see also Annex XIV to the EEA Agreement.
23 Guidelines on the assessment of horizontal mergers under the Council Regulation on the control of
    concentrations between undertakings (OJ C 31, 5.2,2014, p. 5).
24 Guidelines on the assessment of non-horizontal mergers under the Council Regulation on the control of
    concentrations between undertakings (OJ C 265, 18.10.2008, p. 6).
                                                         7
 ---pagebreak--- (37)    In horizontal mergers, non-coordinated effects may significantly impede effective
        competition by eliminating the competitive constraint imposed by each party to the
        merger on the other, as a result of which the merged entity would have increased
        market power, without resorting to coordinated behaviour. In that regard, the
        Horizontal Merger Guidelines consider not only the direct loss of competition
        between the merging firms, but also the reduction in competitive pressure on non-
        merging firms in the same market that could be brought about by the merger.25
(38)    The Horizontal Merger Guidelines list a number of factors, which may influence
        whether or not significant non-coordinated effects are likely to result from a merger.
        In particular, the Horizontal Merger Guidelines refer the large market shares of the
        merging firms, the fact that the merging firms are close competitors, the limited
        possibilities for customers to switch suppliers or the fact that the merger would
        eliminate an important competitive force.26 Not all these factors need to be present
        for significant non-coordinated effects to be likely. The list of factors is also not
        exhaustive.
(39)    In non-horizontal mergers, non-coordinated effects may arise when the concentration
        gives rise to foreclosure. In vertical mergers, foreclosure can take the form of input
        foreclosure, where the merger is likely to raise costs of downstream rivals by
        restricting their access to an important input; and/or the form of customer
        foreclosure, where the merger is likely to foreclose upstream rivals by restricting
        their access to a sufficient customer base.27
(40)    In assessing the likelihood of an anticompetitive foreclosure scenario, the
        Commission examines whether the merged entity would have post-transaction the
        ability to foreclose access to either inputs or customers, whether the merged entity
        would have the incentives to do so and whether such foreclosure strategy would have
        a detrimental effect on competition.28
5.2.    Horizontally affected markets
(41)    Both Parties are active in the Nordics. Sweden is the largest market for Ahlsell
        where approximately [60-70]% of its revenue is generated, followed by Norway with
        [10-20]%, Finland with [10-20]% and Denmark with [0-5]%. Denmark is the largest
        market in Nordics for Stark. Approximately [50-60]% of the Stark's revenue is
        generated in the Nordics (the remaining [40-50]% in Germany). Stark's sales in the
        Nordics are split between Denmark ([40-50]%), Sweden ([20-30]%), Finland
        ([20-30]%) and Norway ([5-10]%).
(42)    The Parties' activities overlap in the retail markets for building materials in Sweden,
        Finland and Norway. The Parties' activities also overlap in the retail of installation
        products, including in the HVAC and electrical products segments in these countries
        and in Denmark as regards HVAC segment. Finally, the Parties' activities overlap in
        the retail of tools and supplies, including in work wear and PPE in Sweden, Norway
        and Finland. Although Ahlsell almost exclusively serves professional customers,
25  Horizontal Merger Guidelines, paragraph 24.
26 Horizontal Merger Guidelines, paragraph 26 .
27 Non-Horizontal Merger Guidelines, para 30
28 Non-Horizontal Merger Guidelines, para 30
                                                    8
 ---pagebreak---        there is an overlap in both sales channels to professional and non-professional
       customers in respect to each of the retail markets: for building materials, installation
       products and the HVAC and electrical products segments, tools and supplies,
       including workwear and PPE.
(43)   While not all overlaps give rise to affected markets, the Transaction gives rise to the
       following horizontally affected markets (on the basis of value market shares) under
       all plausible market segmentations in terms of product and geography (national or
       local pursuant to catchment areas with 30 km or 50 km):
       (a)     Retail sale of building materials to professional customers at national level in
               Finland and at local level in Finland, Sweden and Norway;
       (b)     Retail sale of installation products to professional customers at national level
               in Sweden and at local level in Finland, Sweden and Norway;
       (c)     Retail sales of HVAC to professional customers at national level in Sweden
               and at local level in Finland, Sweden and Norway;
       (d)     Retail sale of electrical products to professional customers at national level in
               Sweden and at local level in Sweden and Norway;
       (e)     Retail sale of tools and supplies to professional customers at national level
               and at local level in Sweden;
       (f)     Retail sale of professional work wear and PPE to professional customers at
               national level in Finland and Sweden and at local level in Sweden.
5.2.1. Retail sale of building materials to professional customers
(44)   As mentioned in paragraph (8), Stark is a general builders merchant. It therefore has
       a larger offering of building products than Ahlsell who specialises in the distribution
       of installation products and tools and supplies. In fact, an analysis of the Parties’
       internal documents shows that they do not see each other as competitors. This is
       reflected in the market positions that each Party has in the retail markets for building
       materials, both at national and local levels. Within all possible affected markets,
       Stark's highest market share is at [30-40]% (at local level in Sweden), whereas
       Ahlsell's highest market share is at [0-5]% (at local level in Sweden).
(45)   At national level, one affected market arises in the retail distribution of building
       materials to professional customers in Finland. The Parties have a combined market
       share of [20-30]% and the increment brought about by the Transaction is negligible.
       Stark has a market share of [20-30]% whereas that of Ahlsell is merely [0-5]%. This
       is consistent with Stark being primarily focused on building materials while Ahlsell
       is only present in this market to a limited extent. In addition, there are several other
       competitors present at a national level, such as Kesko, Hartman, RTV, and
       Puumerkki. Kesko, which is considered by respondents to the market investigation
       to be a very close competitor to Stark, has a market share of [20-30]%. Hartman,
       RTV, and Puumerkki have market shares of [5-10]%, [5-10]% and [5-10]%,
       respectively.
(46)   Based on a local market definition, additional affected markets arise in catchment
       areas in Finland, Norway and Sweden. In Finland, there are 20 affected catchment
                                                   9
 ---pagebreak---         areas with a 30 km radius from Stark's stores ('Stark catchment areas) and nine
        catchment areas with a 50 km radius from Ahlsell's stores ('Ahlsell catchment
        areas'). The Parties' combined shares are in the range of 20-30% and the increment
        brought about by Ahlsell is consistently below [0-5]%.29 In Norway, […]* two
        affected catchment areas, one with a 30 km radius from a Stark' store and another of
        50 km from Ahlsell's store, where the Parties have a combined share of [20-30]%
        and [20-30]% and the increment brought about by Ahlsell is up to [0-5]%.30 In
        Sweden there are 18 affected catchment areas with a 30 […]** radius from Stark
        stores and catchment areas with a 50 km radius from Ahlsell […]***. In these
        catchment areas the Parties' combined market shares range from 20-39%; however
        the increment brought about by the Transaction is consistently low, within a range
        from [0-5]%.31With regard to building materials, the Parties do not appear to be
        close competitors. The Parties have argued and the market investigation confirmed32
        that Ahlsell focuses on light products (e.g. plumbing, electrical products) whereas
        Stark focuses on heavy products (e.g. timber, bricks). While, light and heavy
        products form part of the same overall retail building materials market, as there is
        some overlap between what can be described as a light and a heavy product, and in
        particular since suppliers tend to stock both types of products to some extent; the
        market is nevertheless very differentiated as the suppliers offer a wide range of
        products. Ahlsell's sales of light building materials are in fact peripheral to its
        installation business and Ahlsell only sells heavy building materials in a few
        locations in Sweden.33 On its end, Stark as a generalist builder offers both light and
        heavy materials but with an emphasis on the so-called heavy materials. Indeed, for
        the most part, the Parties' portfolios of products are not in direct competition but
        rather complement one another. In the market investigation, the majority of
        respondents that expressed a view consider that the Parties have mainly
        complementary offerings.34
(47)    The Parties also target different customer groups. Whereas Ahlsell focuses on
        installers, in particular, plumbers and electricians, Stark focuses on builders, in
        particular masons and carpenters. In fact, the majority of customers and competitors
        that expressed a view consider that Parties target the same customers to a limited
        extent. Moreover, considering the limited product overlap between the Parties, the
        same type of customer does not necessarily look for the same item in Ahlsell's and
        Stark's offerings.
(48)    The majority of respondents that expressed a view does not consider Ahlsell and
        Stark to be very close or close competitors. The majority of respondents that
        expressed a view consider Dahl to be a very close competitor to Ahlsell, followed by
* Should read “there are”
** Should read “km”
*** Should read “stores”
29 See Annex I, section A.1.
30 See Annex I, section B.1.
31 S Annex I, section C.1.
32 Responses to Q1 – Questionnaire to customers, question 12; and Q2 – Questionnaire to competitors,
    question 11.
33 Form CO, paragraph 71 and Parties' response to RFI no.3, question 1.
34 Responses to Q1 – Questionnaire to customers, question 11; and Q2 – Questionnaire to competitors,
    question 10.
                                                      10
 ---pagebreak---         Onninen and Rexel. Similarly, the majority of respondents that expressed a view
        consider Kesko and XL Bygg to be very close competitors to Stark.
(49)    The majority of respondents that expressed a view also consider that the Transaction
        will have no impact on prices, quality and choice in the markets for retail of building
        materials to professional customers.35
(50)    In light of the above, particularly in view of the results of the market investigation,
        the Commission concludes that the Transaction does not raise serious doubts as to its
        compatibility with the internal market or the functioning of the EEA Agreement in
        relation the retail distribution of building materials to professional customers, both at
        national and local levels.
5.2.2. Retail sale of installation products to professional customers
(51)    In the retail sale of installation products, Ahlsell, as a specialist builder merchant,
        has a stronger position than Stark.
(52)    At the national level, one affected market arises in the retail sale of installation
        products to professional customers in Sweden. The Parties have a combined share of
        [30-40]% and the increment brought about by the Transaction is below [0-5]%, as
        Stark has a very small presence on this market and its possible segments. Once
        again, these shares reflect the different focus and nature of the Parties product
        portfolios. Other suppliers in Sweden are Dahl with [10-20]% market share,
        followed by Sonepar with [10-20]%, Rexel with [10-20]% and Solar with [5-10]%.
(53)    If a narrower market definition were adopted, the Transaction would also give rise to
        two other nationally affected markets in Sweden: the retail sale of HVAC products to
        professional customers and the retail sale of electrical products to professional
        customers. Similarly to the overall installation products market, the increment
        brought about by the Transaction is very limited and below [0-5]% as the Target
        does not have a significant presence for the retail distribution of these products. In
        the retail sale of HVAC, the Parties have a combined share of [30-40]%. The market
        leader is Dahl ([30-40]% share); other suppliers are Solar ([5-10]%),
        Lundagrossisten ([5-10]% share). In the retail sale of electrical products, the Parties
        have a combined market share of [20-30]%. Other suppliers are Sonepar ([20-30]%
        share), Rexel ([20-30]% share), and Solar ([10-20]% share).
(54)    The market investigation suggests that the Parties are not close competitors in
        relation to installation products. A majority of customers and competitors that
        expressed a view consider that the Parties have a different or very different product
        assortment regarding HVAC, one of the categories of installation products where
        they overlap. The majority of respondents to the market investigation that expressed
        a view also consider that the Parties' electrical product assortments are different.
        Only in relation to work wear and PPE, the majority of the respondents that
        expressed a view consider the product assortment to be similar. However, Ahlsell's
        workwear and PPE is ancillary to its installation business, while Stark's is ancillary
        to its heavy building materials business and thus they target different customer
        groups.
35  Responses to Q1 – Questionnaire to customers, question 22; and Q2 – Questionnaire to competitors,
    question 29.
                                                    11
 ---pagebreak--- (55)   The majority of respondents that expressed a view also consider that the Transaction
       will have no impact on prices, quality and choice in the national markets for retail of
       installation products to professional customers, nor in the narrower markets of
       HVAC and electrical products at national level.36
(56)   At the local level, there are a several affected catchment areas not only in Sweden,
       but also in Norway and Finland.
(57)   In Sweden in respect to the retail sales of installation products there are 37 affected
       Stark catchment areas and 64 affected Ahlsell catchment areas. In the vast majority
       of these catchment areas the Parties’ combined market shares in the installation
       markets are between 20-30% with an increment of up to [0-5]%. There are also a
       number of catchment areas where the Parties have a combined share between
       30-50% and the increment is up to [0-5]%. Finally, there are a few areas where the
       combined share is between 50-80% where the increment is up to [5-10]% and two
       catchment areas where the Parties have a combined share between [80-90]% and the
       increment is up to [0-5]%.37 The catchment areas where the Parties have combined
       market share of [50-60]% and above are further discussed in paragraph (66).
(58)   In respect to narrow market of HVAC there are 31 affected Stark catchment areas
       and 65 affected Ahlsell catchment areas in Sweden. In the majority of these areas the
       Parties have a combined market share between 20-30% with an increment of up
       to [0-5]%.There are also a number of areas where the Parties have a combined
       market share between 30-50% with an increment up to [0-5]%. However, there are a
       few areas where the combined share is between 50-80% and where the increment is
       up to [5-10]%; and two catchment areas where the Parties have a combined share
       between 80-89% and the increment is up to [0-5]%.38 The catchment areas where the
       Parties have a combined share below [40-50]% do not appear to raise concerns given
       that the increment is below [0-5]% and given the lack of closeness of the Parties.
       The catchment areas where the Parties have combined market share of [50-60]% and
       above will be further discussed in paragraph (66) below.
(59)   In respect to the narrow local markets of electrical products, there are 32 affected
       Stark catchment areas and 55 affected Ahlsell catchment areas in Sweden. In the
       majority of these areas the Parties have a combined market share between 20-30%
       with an increment of up to [0-5]%.There are also a number of areas where the Parties
       have a combined market share between 30-50% with an increment up to [0-5]%.
       Finally, there are a few areas where the combined share is between 50-70% with an
       increment is up to [5-10]%; three catchment areas where the combined market share
       is between 70-80% and the increment up to [0-5]% and two catchment areas where
       the Parties have a combined share between [80-90]% and the increment is up to
       [0-5]%.39 The catchment areas where the Parties have a combined share below
       [40-50]% do not appear to raise concerns given that the increment is only up to
       [0-5]% and given the lack of closeness of the Parties. The catchment areas where
       the Parties have combined market share of [50-60]% and above are further discussed
       in paragraph (66).
36 Responses to Q1 Responses to Q1 – Questionnaire to customers, question 22; and Q2 – Questionnaire to
   competitors, question 29.
37 See Annex I, sections C.2.1 and C.2.2.
38 See Annex I, sections C.3.1 and C.3.2.
39 See Annex I, sections C.4.1 and C.4.2.
                                                    12
 ---pagebreak--- (60)   In Norway, there are five affected Stark catchment areas and four affected Ahlsell
       catchment areas in respect to the installation products market. Except for one
       catchment area where the Parties have a combined share of [70-80]% and an
       increment of [5-10]%, in all other catchment areas the Parties have a combined share
       between [20-30]% with an increment below [0-5]%.40 Given the low combined
       shares and increment of less than [0-5]%, the vast majority of catchment areas do not
       appear to raise concerns. The catchment area where the Parties have a combined
       share of [70-80]% is further discussed in paragraph (66).
(61)   In respect to the HVAC products segment, there are six affected Stark catchment
       areas and five affected Ahlsell catchment areas in Norway. Except for one catchment
       area where the Parties have a combined share of [70-80]% and an increment of
       [0-5]%, in all other catchment areas the Parties have a combined share between
       20-30% with an increment below [0-5]%.41 Given the low combined shares and
       increment of less than [0-5]%, the vast majority of catchment areas do not appear to
       raise concerns. The catchment area where the Parties have a combined share of
       [70-80]% is further discussed in paragraph (66).
(62)   In respect to the electrical products segment, there are eight affected Stark catchment
       areas and three affected Ahlsell catchment areas in Norway. The Parties have
       combined shares between 20-30% with an increment below [0-5]% in all areas
       except for one where the combined share is [30-40]% and the increment [0-5]%, and
       another where the combined share is [60-70]% and the increment [5-10]%.42 Given
       the low combined shares and increment of less than [0-5]%, the vast majority of
       catchment areas do not appear to raise concerns. The catchment area where the
       combined share is [60-70]% and the increment [5-10]% is further discussed in
       paragraph (66).
(63)   In Finland there are three affected Stark catchment areas and two affected Ahlsell
       catchment areas in respect to the retail sale of installation products. In these
       catchment areas the Parties' combined market share range between [20-30]% and the
       increment is below [0-5]%.43
(64)   In respect to the HVAC segment, there are 24 affected Stark catchment areas and 24
       affected Ahlsell catchment areas in Finland. In the vast majority of catchment areas
       the Parties have a combined share of 20-30% with an increment below [0-5]%.
       There are few catchment areas where the Parties have a combined share of 30-40%
       with an increment up to [0-5]%. There is one catchment area where the Parties'
       combined share is [40-50]% and the increment below [0-5].44 The catchment areas
       where the Parties have a combined share below [40-50]% do not appear to raise
       concerns given that the increment is below [0-5]% and the Parties’ lack of closeness.
       The catchment areas where the Parties have a combined share of [40-50]% is further
       discussed in paragraph (66).
40 See Annex I, section B.2.
41 See Annex I, section B.3.
42 See Annex I, section B.4.
43 See Annex I, section A.2.
44 See Annex I, section A.3.
                                                 13
 ---pagebreak---  ---pagebreak---         increase or a quality or choice decreased as a result of the Transaction at local level,
        in particular in the catchment areas identified in Table 1.46
(67)    In light of the above, particularly in view of the results of the market investigation,
        the Commission concludes that the Transaction does not raise serious doubts as to its
        compatibility with the internal market or the functioning of the EEA Agreement in
        relation to the retail distribution of installation products to professional customers,
        both at national and local levels.
5.2.3. Retail sale of tools and supplies to professional customers
(68)    At the national level, the Transaction gives rise to an affected market in the retail
        sale of tools and supplies to professional customers in Sweden, where the Parties
        have a combined share of [30-40]%. The increment brought about by the Transaction
        is minimal at [0-5]%. Ahlsell has a share of [30-40]% whereas Stark has a share of
        [0-5]%. This is consistent with Ahlsell's activities primarily being focused on
        installation products and tools and supplies; whereas Stark is more focused on
        building materials. There are a number of alternative suppliers such as Momentum
        ([10-20]% market share), Procurator ([5-10]% market share), and Würth ([5-10]%
        market share).
(69)    If a narrower market definition is adopted where workwear and PPE are a part of a
        separate market from other tools and supplies, the Transaction would give rise to
        affected national markets in Sweden and in Finland. In Sweden, the Parties have
        a combined market share of [20-30]%. However, the increment is low ([0-5]%).
        Ahlsell has a [20-30]% share and Stark has a [0-5]% share. Ahlsell's main
        competitors in the segment are Momentum ([10-20]% share), Procurator ([5-10]%
        share) and Würth ([5-10]% market share). In Finland, the Parties have a combined
        market share of [20-30]%. However, the increment is small and just over [0-5]%:
        Ahlsell has a [20-30]% share and Stark has a [0-5]% share. Ahlsell's main
        competitors in the segment are Würth ([20-30]% share), Etra ([10-20]% share), IHK
        ([10-20]% share) and Linström ([5-10]% share) amongst others.
(70)    At the local level, additional affected markets arise for the retail to professional
        customers of tools and supplies, and for workwear and PEE in Sweden.
(71)    The Transaction gives rise to 14 affected Stark catchment areas and 15 affected
        Ahlsell catchment areas for the market for tools and supplies (excluding
        PPE/workwear) in Sweden. In the vast majority of these affected catchment areas,
        the Parties' combined market shares in these locally affected markets are in the
        region of 20-30%. There are two Stark catchment areas and three Ahlsell catchment
        areas where the market shares are between 30-40% and there a small number of
        areas where the combined market share is above [40-50]% (detailed in Table 2
        below). In all affected catchment areas, the increments brought about by the
        Transaction range from [0-20]%.47
(72)    In relation to workwear/PPE, the Transaction gives rise to 10 affected Stark
        catchment areas and 11 affected Ahlsell catchment areas in Sweden. In the majority
46  Responses to Q1 Responses to Q1 – Questionnaire to customers, questions 23.1 and 23.2; and Q2 –
    Questionnaire to competitors, questions 29.3 and 29.4
47 See Annex I, sections C.5.1 and C.5.2
                                                         15
 ---pagebreak---  ---pagebreak--- 5.3.   Vertically affected markets
(77)   As Ahlsell is active in the wholesale of installation products, as well as the
       wholesale of tools and supplies in all Nordic countries, and Stark is active in the
       wholesale of building materials in Finland, the Transaction also creates vertical links
       with the Parties' retail distribution businesses. Not all vertical links give however rise
       to vertically affected markets. Mainly due to the Parties' positions in the retail
       markets the following vertically affected markets arise (on the basis of value market
       shares):
       (a)      Wholesale of installation products (national) and retail of these products to
                professional customers at national and local levels in Sweden and at local
                level in Norway and Finland.
       (b)      Wholesale of HVAC products (national) and retail of these products to
                professional customers at national and local levels in Sweden and at local
                level in Norway and Finland.
       (c)      Wholesale of electrical products (national) and retail of these products to
                professional customers at local level in Sweden, Norway.
       (d)      Wholesale of tools and supplies and retail of these products to professional
                customers at national and local levels in Sweden.
5.3.1. Wholesale and retail distribution of installation products
(78)   Ahlsell is active in the wholesale of installation products in Sweden, Finland and
       Norway however, its presence is relatively limited, since it has a market share up to
       [5-10]% in Sweden, up to [5-10]% in Finland and up to [0-5]% in Norway, including
       in the HVAC and electrical products segments. The wholesale markets are vertical
       affected markets, due to the Parties' position in the retail markets for these products,
       in particular Ahlsell's position.
(79)   At the national level, the Transaction gives rise to affected markets in Sweden for the
       retail (downstream) and wholesale distribution (upstream) of installation products. If
       a narrower market definition is adopted, the wholesale and retail markets for HVAC
       products are also affected. In the wholesale markets, Ahlsell has a market share of
       [5-10]% in the overall installation products market and of [0-5]% in the HVAC
       products market. In the respective retail markets, Parties have a combined share of
       [30-40]% in the overall installation product and [30-40]% in the HVAC products
       market. Stark brings an increment of less than [0-5]% in both installation products
       and in the HVAC sub-segment.
(80)   At the local level, there are a several vertically affected catchment areas in Sweden
       not only regarding the downstream retail sale of installation products and the HVAC
       segment and the respective upstream national wholesale markets, but also regarding
       the downstream retail sale of electrical products market and the respective upstream
       national wholesale market. In Sweden, Ahlsell has also a market share of [5-10]% in
       the wholesale of electrical products.
(81)   Likewise, in Norway the Transaction gives rise to vertically affected markets in the
       upstream wholesale and the downstream retail of installation products, HVAC and
       electrical products due to the Parties' combined position in downstream markets. The
                                                   17
 ---pagebreak---        position of Ahlsell at the upstream wholesale is however limited ([0-5]% market
       share).
(82)   Similarly, due to the Parties' position at the downstream retail local markets, in
       particular Ahlsell's, the Transaction gives raise to vertically affected markets for the
       upstream wholesale and downstream retail of HVAC products in Finland. In
       Finland, Ahlsell has a small share of [5-10]% in the upstream wholesale of HVAC
       products.
(83)   Both looking at the national and local markets in the three countries, the merged
       entity will have no ability to adopt an input foreclosure strategy. First, as explained
       above Ahlsell has a very limited presence in the upstream wholesale markets and
       therefore lacks the necessary degree of market power. There are a number of
       competitors active at the wholesale level in each country, which provide alternative
       sources of supply to builders merchants. Second, Ahlsell's supplies are not
       sufficiently important inputs for Stark and other general builder's merchants as their
       focus is the distribution of building materials. Third, Ahlsell is already present in the
       downstream retail installation product markets and the increment brought by the
       Transaction is small.
(84)   In addition, the merged entity will also not have the incentive to adopt an input
       foreclosure strategy, First, Ahlsell's main wholesale customers are not close
       competitors of Stark, therefore it would not compensate to lose sales at the wholesale
       level, by refusing to sell or increase the wholesale prices, when these losses cannot
       be compensated for at the retail level, by selling more retail products via Stark.
       Second, Ahlsell is already making some wholesale sales to Stark, while it is also
       present at the retail level, which means that the sales to Stark are not a threat to its
       retail business for the companies do not directly compete. Supplying only to Stark
       would also not be profitable, as Stark cannot absorb all the wholesale supplies of
       Ahlsell.
(85)   Similarly, the merged entity would not have the ability to adopt a customer
       foreclosure strategy. First Ahlsell is already vertically integrated in the installation
       markets and the increment brought at the retail level is small. Second, Stark has a
       small share of the retail markets for HVAC products in Sweden, Finland and
       Norway, both at national (below [0-5]%) and local levels (up to [5-10]%). Stark is
       therefore not an important customer of HVAC wholesale distributors. Third, there
       are sufficient alternatives to Stark to whom Ahlsell's wholesale competitors can sell
       their output.
(86)   In addition, the merged entity will also have no incentives to adopt a customer
       foreclosure strategy. Stark has a small presence in the retail markets of HVAC
       products, therefore the possibility to enjoy increased margins downstream by virtue
       of a price increase at the wholesale level is very unlikely.
(87)   Indeed, the majority of competitors that expressed a view considers that the
       Transaction will have no impact on their ability to source, installation products, nor
       on their ability to access retailers.50
50 Responses to Q2 – Questionnaire to competitors, questions 22 and 23.
                                                      18
 ---pagebreak--- (88)    In light of above, and in view of the results of the market investigation, the
        Commission concludes that the Transaction does not raise serious doubts as to its
        compatibility with the internal market in relation to the vertical link between the
        wholesale and the retail distribution of installation products.
5.3.2. Wholesale and retail distribution of tools and supplies
(89)    Ahlsell is a wholesale supplier of tools and supplies in Sweden, but it has a very
        limited presence with a less than [0-5]% market share. Due to the Parties' presence in
        the retail markets, in particular Ahlsell's, the Transaction gives rise to vertical
        affected markets both at the national level (combined share of [30-40]%) and local
        level (combined shares between 30-60%).
(90)    The merged entity will have no ability to adopt an input foreclosure strategy. First,
        Ahlsell has less than [0-5]% share of the wholesale market. Second, Ahsell supplies
        are not significant inputs for Stark and its close competitors, as they focus on
        building materials. The merged entity will also have no incentive to adopt such
        strategy. Being already present today in the retail market, where the increment
        brought by the Transaction is small, the merged entity will have no ability to adopt
        an input foreclosure strategy both at the national and local levels. Likewise, the
        arguments made regarding the relevance of Ahlsell supplies and the relevance of
        Stark as a wholesale customer for the installation markets also apply to tool and
        supplies markets.
(91)    Indeed, the majority of competitors that expressed a view considers that the
        Transaction will have no impact on their ability to source, tools and supplies, nor on
        their ability to access retailers.51
(92)    In light of above, and in view of the results of the market investigation, the
        Commission concludes that the Transaction does not raise serious doubts as to its
        compatibility with the internal market or the functioning of the EEA Agreement in
        relation to the vertical link between the wholesale and the retail distribution of tools
        and supplies.
(93)    The Commission therefore concludes that the Transaction does not give rise to
        serious doubts as to its compatibility with the internal market or the functioning of
        the EEA Agreement in relation to any vertical links.
51  Responses to Q2 – Questionnaire to competitors, questions 22 and 23.
                                                       19
 ---pagebreak--- 6.   CONCLUSION
(94) For the above reasons, the European Commission decides not to oppose the
     Transaction 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 Agreement.
                                                  For the Commission
                                                  (Signed)
                                                  Margrethe VESTAGER
                                                  Executive Vice-President
                                             20
 ---pagebreak---                                                                      ANNEX I
A - FINLAND
A. 1. Finland Building Materials
           Catchment Areas from Stark Stores                Catchment Areas from Stark stores              Catchment Areas from Ahlsell stores
                           (30Km)                                        (30KM)                                         (50KM)
        Vantaa Petikko      Stark        [20-30]%       Tampere            Stark          [20-30]%       Vantaa         Ahlsell            [0-5]%
                            Ahlsell        [0-5]%       Hankkio            Ahlsell          [0-5]%                      Stark           [10-20]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [10-20]%
        Vantaa              Stark        [20-30]%       Tampere Nekala     Stark          [20-30]%       Hyvinkää       Ahlsell            [0-5]%
        Martinlaakso        Ahlsell        [0-5]%                          Ahlsell          [0-5]%                      Stark           [20-30]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [20-30]%
        Helsinki            Stark        [20-30]%       Tampere Lielahti   Stark          [20-30]%       Helsinki       Ahlsell            [0-5]%
        Suutarila           Ahlsell        [0-5]%                          Ahlsell          [0-5]%                      Stark           [20-30]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [20-30]%
        Helsinki            Stark        [20-30]%       Lahti Mukkula      Stark          [20-30]%       Helsinki,      Ahlsell            [0-5]%
        Herttoniemi         Ahlsell        [0-5]%                          Ahlsell          [0-5]%       Herttoniemi    Stark           [10-20]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [10-20]%
        Kotka               Stark        [20-30]%       Lahti Laune        Stark          [20-30]%       Espoo          Ahlsell            [0-5]%
                            Ahlsell        [0-5]%                          Ahlsell          [0-5]%                      Stark           [20-30]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [20-30]%
        Espoo               Stark        [30-40]%       Pori               Stark          [20-30]%       Espoo Olari,   Stark           [20-30]%
        Kivenlahti          Ahlsell        [0-5]%                          Ahlsell          [0-5]%                      Ahlsell            [0-5]%
                            Combined     [30-40]%                          Combined       [20-30]%                      Combined        [20-30]%
        Joensuu             Stark        [20-30]%       Mikkeli            Stark          [20-30]%       Joensuu        Ahlsell            [0-5]%
                            Ahlsell        [0-5]%                          Ahlsell          [0-5]%                      Stark           [20-30]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [20-30]%
        Lohja               Stark        [10-20]%       Kotka              Stark          [20-30]%       Lohja          Ahlsell            [0-5]%
                            Ahlsell        [0-5]%                          Ahlsell          [0-5]%                      Stark           [20-30]%
                            Combined     [10-20]%                          Combined       [20-30]%                      Combined        [20-30]%
        Turku Skanssi       Stark        [20-30]%       Hämeenlinna        Stark          [20-30]%       Turku,         Ahlsell            [0-5]%
                            Ahlsell        [0-5]%                          Ahlsell          [0-5]%       Satakunnantie  Stark           [20-30]%
                            Combined     [20-30]%                          Combined       [20-30]%                      Combined        [20-30]%
        Turku               Stark        [20-30]%       Lappeenranta       Stark          [20-30]%
        Artukainen          Ahlsell        [0-5]%                          Ahlsell          [0-5]%
                            Combined     [20-30]%                          Combined       [20-30]%
A. 2. Finland Installation Products
                 Catchment Areas From Stark Stores (30km)                                  Catchment Areas From Ahlsell Stores (50km)
        Tampere, Lielahti       Stark                       [0-5]%                 Oulu, Oritkari        Ahlsell                     [20-30]%
                                Ahlsell                  [10-20]%                                        Stark                          [0-5]%
                                Combined                 [10-20]%                                        Combined                    [20-30]%
        Oulu                    Stark                       [0-5]%                 Oulu, Rusko           Ahlsell                     [20-30]%
                                Ahlsell                  [20-30]%                                        Stark                          [0-5]%
                                Combined                 [20-30]%                                        Combined                    [20-30]%
        Lappeenranta            Stark                       [0-5]%
                                Ahlsell                  [20-30]%
                                Combined                 [20-30]%
A. 3. Finland Hvac Products
                Catchment Areas From Stark Stores (30km)                                     Catchment Areas From Ahlsell Stores (50km)
        Vantaa Petikko          Stark                     [0-5]%                   Vantaa                Ahlsell                       [20-30]%
                                Ahlsell                [20-30]%                                          Stark                            [0-5]%
                                Combined               [20-30]%                                          Combined                      [20-30]%
        Vantaa                  Stark                     [0-5]%                   Hyvinkää              Ahlsell                       [10-20]%
        Martinlaakso            Ahlsell                [20-30]%                                          Stark                            [0-5]%
                                Combined               [20-30]%                                          Combined                      [20-30]%
        Helsinki Suutarila      Stark                     [0-5]%                   Helsinki              Ahlsell                       [20-30]%
                                Ahlsell                [20-30]%                                          Stark                            [0-5]%
                                Combined               [20-30]%                                          Combined                      [20-30]%
        Helsinki                Stark                     [0-5]%                   Helsinki,             Ahlsell                       [20-30]%
 ---pagebreak---         Catchment Areas From Stark Stores (30km)                 Catchment Areas From Ahlsell Stores (50km)
Herttoniemi         Ahlsell                    [20-30]% Herttoniemi          Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Espoo Kivenlahti    Stark                        [0-5]% Espoo                Ahlsell                       [20-30]%
                    Ahlsell                    [10-20]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Tampere Hankkio     Stark                        [0-5]% Kerava               Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Tampere Nekala      Stark                        [0-5]% Tampere, Vihiojtie   Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Tampere Lielahti    Stark                        [0-5]% Tampere,             Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]% Turvesuonkatu        Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Turku Artukainen    Stark                        [0-5]% Turku,               Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]% Satakunnantie        Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Turku Skanssi       Stark                        [0-5]% Turku, Skanssi       Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Oulu                Stark                        [0-5]% Oulu, Oritkari       Ahlsell                       [30-40]%
                    Ahlsell                    [30-40]%                      Stark                           [0-5]%
                    Combined                   [30-40]%                      Combined                      [30-40]%
Lahti Laune         Stark                        [0-5]% Oulu, Rusko          Ahlsell                       [30-40]%
                    Ahlsell                    [30-40]%                      Stark                           [0-5]%
                    Combined                   [30-40]%                      Combined                      [30-40]%
Lahti Mukkula       Stark                        [0-5]% Rauma                Ahlsell                       [30-40]%
                    Ahlsell                    [30-40]%                      Stark                           [0-5]%
                    Combined                   [30-40]%                      Combined                      [30-40]%
Lohja               Stark                        [0-5]% Lohja                Ahlsell                       [10-20]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [10-20]%
Kuopio              Stark                        [0-5]% Kuopio               Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Jyväskylä           Stark                        [0-5]% Jyväskylä            Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Seinäjoki           Stark                        [0-5]% Seinäjoki            Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Pori                Stark                        [0-5]% Pori                 Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Vaasa               Stark                        [0-5]% Vaasa                Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Mikkeli             Stark                        [0-5]% Mikkeli              Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [20-30]%                      Combined                      [20-30]%
Kotka               Stark                        [0-5]% Bay                  Ahlsell                       [20-30]%
                    Ahlsell                    [40-50]%                      Stark                           [0-5]%
                    Combined                   [40-50]%                      Combined                      [20-30]%
Joensuu             Stark                        [0-5]% Joensuu              Ahlsell                       [20-30]%
                    Ahlsell                    [20-30]%                      Stark                           [0-5]%
                    Combined                   [30-40]%                      Combined                      [30-40]%
Hämeenlinna         Stark                        [0-5]% Kouvola              Ahlsell                       [30-40]%
                    Ahlsell                    [30-40]%                      Stark                           [0-5]%
 ---pagebreak---                Catchment Areas From Stark Stores (30km)                   Catchment Areas From Ahlsell Stores (50km)
                              Combined                  [30-40]%                       Combined                      [30-40]%
       Lappeenranta           Stark                        [0-5]% Eagle                Ahlsell                       [30-40]%
                              Ahlsell                   [30-40]%                       Stark                           [0-5]%
                              Combined                  [30-40]%                       Combined                      [30-40]%
B - NORWAY
B.1 Norway Building Materials
              Catchment Areas from Ahlsell stores (50KM)                 Catchment Areas from Stark Stores (30Km)
       Tromsø                 Ahlsell                      [0-5]% Tromsø               Stark                     [20-30]%
                              Stark                     [20-30]%                       Ahlsell                     [0-5]%
                              Combined                  [20-30]%                       Combined                  [20-30]%
B.2 Norway Installation Products
              Catchment Areas from Ahlsell stores (50KM)                 Catchment Areas from Stark Stores (30Km)
       Bergen Fana            Ahlsell                   [20-30]%  Bergen Midtun        Stark                       [0-5]%
                              Stark                        [0-5]%                      Ahlsell                   [20-30]%
                              Combined                  [20-30]%                       Combined                  [20-30]%
       Bergen                 Ahlsell                   [20-30]%  Bergen Sandviken     Stark                       [0-5]%
       Fabrikkgaten           Stark                        [0-5]%                      Ahlsell                   [20-30]%
                              Combined                  [20-30]%                       Combined                  [20-30]%
       Bergen Åsane           Ahlsell                   [20-30]%  Førde                Stark                       [0-5]%
                              Stark                        [0-5]%                      Ahlsell                   [20-30]%
                              Combined                  [20-30]%                       Combined                  [20-30]%
       Bergen Godvik          Ahlsell                   [20-30]%  Mandal               Stark                       [0-5]%
                              Stark                        [0-5]%                      Ahlsell                   [70-80]%
                              Combined                  [20-30]%                       Combined                  [70-80]%
       Førde                  Ahlsell                   [20-30]%
                              Stark                        [0-5]%
                              Combined                  [20-30]%
B.3 Norway HVAC Products
              Catchment Areas from Ahlsell stores (50KM)                 Catchment Areas from Stark Stores (30Km)
       Bergen Fana            Ahlsell                  [20-30]%   Bergen Midtun        Stark                       [0-5]%
                              Stark                       [0-5]%                       Ahlsell                   [20-30]%
                              Combined                 [20-30]%                        Combined                  [20-30]%
       Bergen                 Ahlsell                  [20-30]%   Bergen Sandviken     Stark                       [0-5]%
       Fabrikkgaten           Stark                       [0-5]%                       Ahlsell                   [20-30]%
                              Combined                 [20-30]%                        Combined                  [20-30]%
       Bergen Åsane           Ahlsell                  [20-30]%   Bryne                Stark                       [0-5]%
                              Stark                       [0-5]%                       Ahlsell                   [10-20]%
                              Combined                 [20-30]%                        Combined                  [20-30]%
       Bergen Godvik          Ahlsell                  [20-30]%   Mandal               Stark                       [0-5]%
                              Stark                       [0-5]%                       Ahlsell                   [70-80]%
                              Combined                 [20-30]%                        Combined                  [70-80]%
       Førde                  Ahlsell                  [20-30]%   Førde                Stark                       [0-5]%
                              Stark                       [0-5]%                       Ahlsell                   [20-30]%
                              Combined                 [20-30]%                        Combined                  [30-40]%
       Sortland               Ahlsell                  [20-30]%
                              Stark                       [0-5]%
                              Combined                 [20-30]%
B.4 Norway Electrical Products
              Catchment Areas from Ahlsell stores (50KM)                   Catchment Areas from Stark Stores (30Km)
       Bergen Fana      Ahlsell                       [20-30]%        Bergen Midtun      Stark                     [0-5]%
                        Stark                            [0-5]%                          Ahlsell                 [20-30]%
                        Combined                      [20-30]%                           Combined                [20-30]%
       Bergen           Ahlsell                       [20-30]%        Bergen Sandviken   Stark                     [0-5]%
       Fabrikkgaten     Stark                            [0-5]%                          Ahlsell                 [20-30]%
 ---pagebreak---               Catchment Areas from Ahlsell stores (50KM)                                   Catchment Areas from Stark Stores (30Km)
                      Combined                         [20-30]%                                         Combined                  [20-30]%
       Bergen Åsane   Ahlsell                          [20-30]%                      Førde              Stark                       [0-5]%
                      Stark                              [0-5]%                                         Ahlsell                   [20-30]%
                      Combined                         [20-30]%                                         Combined                  [20-30]%
       Bergen         Ahlsell                          [20-30]%                      Mandal             Stark                      [5-10]%
       Godvik         Stark                              [0-5]%                                         Ahlsell                   [60-70]%
                      Combined                         [20-30]%                                         Combined                  [60-70]%
       Stord          Ahlsell                          [20-30]%
                      Stark                              [0-5]%
                      Combined                         [20-30]%
       Haugesund      Ahlsell                          [20-30]%
                      Stark                              [0-5]%
                      Combined                         [20-30]%
       Arendal        Ahlsell                          [30-40]%
                      Stark                              [0-5]%
                      Combined                         [30-40]%
       Førde          Ahlsell                          [10-20]%
                      Stark                              [0-5]%
                      Combined                         [10-20]%
C - SWEDEN
C.1 Sweden Building Materials
        Catchment Areas from Stark Stores                 Catchment Areas from Stark Stores                  Catchment Areas from Ahlsell stores
                     (30Km)                                           (30Km)                                              (50KM)
       Malmö          Stark        [10-20]%           Hörby         Stark             [20-30]%            Ystad              Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                         Ahlsell             [0-5]%                               Stark         [20-30]%
                      Combined     [20-30]%                         Combined          [20-30]%                               Combined      [20-30]%
       Sjöbo          Stark        [20-30]%           Karlskoga     Stark             [20-30]%            Luleå              Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                         Ahlsell             [0-5]%                               Stark         [20-30]%
                      Combined     [20-30]%                         Combined          [20-30]%                               Combined      [20-30]%
       Kalmar         Stark        [20-30]%           Kristinehamn  Stark             [20-30]%            Kalmar             Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                         Ahlsell             [0-5]%                               Stark         [20-30]%
                      Combined     [20-30]%                         Combined          [20-30]%                               Combined      [20-30]%
       Söderhamn      Stark        [20-30]%           Värnamo       Stark             [20-30]%            Söderhamn          Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                         Ahlsell             [0-5]%                               Stark         [20-30]%
                      Combined     [20-30]%                         Combined          [20-30]%                               Combined      [20-30]%
       Hudiksvall     Stark        [30-40]%           Alingsås      Stark             [20-30]%            Hudiksvall         Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                         Ahlsell             [0-5]%                               Stark         [30-40]%
                      Combined     [30-40]%                         Combined          [20-30]%                               Combined      [30-40]%
       Kiruna         Stark        [30-40]%           Arvika        Stark             [20-30]%            Kiruna             Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                         Ahlsell             [0-5]%                               Stark         [30-40]%
                      Combined     [30-40]%                         Combined          [20-30]%                               Combined      [30-40]%
       Gällivare      Stark        [30-40]%                                                               Gällivare          Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                                                                                  Stark         [30-40]%
                      Combined     [30-40]%                                                                                  Combined      [30-40]%
       Bollnäs        Stark        [30-40]%                                                               Bollnäs            Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                                                                                  Stark         [20-30]%
                      Combined     [30-40]%                                                                                  Combined      [20-30]%
       Piteå          Stark        [30-40]%                                                               Piteå              Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                                                                                  Stark         [20-30]%
                      Combined     [30-40]%                                                                                  Combined      [20-30]%
       Gislaved       Stark        [20-30]%                                                               Gislaved           Ahlsell         [0-5]%
                      Ahlsell        [0-5]%                                                                                  Stark         [20-30]%
                      Combined     [20-30]%                                                                                  Combined      [20-30]%
       Färjestaden    Stark        [30-40]%                                                               Västervik          Stark         [20-30]%
                      Ahlsell        [0-5]%                                                                                  Ahlsell         [0-5]%
                      Combined     [30-40]%                                                                                  Combined      [20-30]%
       Boden          Stark        [20-30]%                                                               Örnsköldsvik       Stark         [20-30]%
 ---pagebreak---          Catchment Areas from Stark Stores                Catchment Areas from Stark Stores                 Catchment Areas from Ahlsell stores
                        (30Km)                                          (30Km)                                            (50KM)
                         Ahlsell        [0-5]%                                                                              Ahlsell         [0-5]%
                         Combined    [20-30]%                                                                               Combined      [20-30]%
C.2 Sweden Installation Products:
C.2.1 Catchment Areas from Stark Stores
         Catchment Areas from Stark Stores           Catchment Areas from Stark stores (30KM)         Catchment Areas from Stark stores
                        (30Km)                                                                                      (30KM)
       Hisings Backa      Stark          [0-5]%     Västerås             Stark            [0-5]%     Värnamo         Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [20-30]%                     Ahlsell       [70-80]%
                          Combined    [20-30]%                           Combined       [20-30]%                     Combined      [70-80]%
       Mölnlycke          Stark          [0-5]%     Skara                Stark            [0-5]%     Strängnäs       Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [30-40]%                     Ahlsell       [40-50]%
                          Combined    [20-30]%                           Combined       [30-40]%                     Combined      [40-50]%
       Mölndal            Stark          [0-5]%     Sölvesborg           Stark            [0-5]%     Alingså         Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [10-20]%                     Ahlsell       [40-50]%
                          Combined    [20-30]%                           Combined       [10-20]%                     Combined      [40-50]%
       Lerum              Stark          [0-5]%     Uppsala              Stark            [0-5]%     Arvika          Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [20-30]%                     Ahlsell       [30-40]%
                          Combined    [20-30]%                           Combined       [20-30]%                     Combined      [30-40]%
       Södra Sandby       Stark          [0-5]%     Sjöbo                Stark            [0-5]%     Piteå           Stark           [0-5]%
                          Ahlsell     [10-20]%                           Ahlsell        [30-40]%                     Ahlsell       [20-30]%
                          Combined    [20-30]%                           Combined       [30-40]%                     Combined      [20-30]%
       Arlöv              Stark          [0-5]%     Stenungsund          Stark            [0-5]%     Örnsköldsvik    Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [40-50]%                     Ahlsell       [20-30]%
                          Combined    [20-30]%                           Combined       [40-50]%                     Combined      [20-30]%
       Lund               Stark          [0-5]%     Karlshamn            Stark            [0-5]%     Västervik       Stark           [0-5]%
                          Ahlsell     [10-20]%                           Ahlsell        [20-30]%                     Ahlsell       [30-40]%
                          Combined    [10-20]%                           Combined       [20-30]%                     Combined      [30-40]%
       Kungsbacka         Stark          [0-5]%     Tomelilla            Stark            [0-5]%     Söderhamn       Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [30-40]%                     Ahlsell       [20-30]%
                          Combined    [20-30]%                           Combined       [30-40]%                     Combined      [30-40]%
       Märsta             Stark          [0-5]%     Gislaved             Stark            [0-5]%     Hudiksvall      Stark           [0-5]%
                          Ahlsell     [10-20]%                           Ahlsell        [80-90]%                     Ahlsell       [20-30]%
                          Combined    [10-20]%                           Combined       [80-90]%                     Combined      [20-30]%
       Malmö              Stark          [0-5]%     Karlskrona           Stark            [0-5]%     Kiruna          Stark           [0-5]%
                          Ahlsell     [10-20]%                           Ahlsell        [10-20]%                     Ahlsell       [20-30]%
                          Combined    [20-30]%                           Combined       [10-20]%                     Combined      [20-30]%
       Älvängen           Stark          [0-5]%     Hörby                Stark           [5-10]%     Gällivare       Stark           [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [50-60]%                     Ahlsell       [30-40]%
                          Combined    [20-30]%                           Combined       [60-70]%                     Combined      [30-40]%
       Bollnäs            Stark          [0-5]%     Karlskoga            Stark            [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [20-30]%
                          Combined    [30-40]%                           Combined       [20-30]%
       Eskilstuna         Stark          [0-5]%     Kristinehamn         Stark            [0-5]%
                          Ahlsell     [20-30]%                           Ahlsell        [20-30]%
                          Combined    [20-30]%                           Combined       [20-30]%
C.2.2 Sweden Installation Products: Catchment Areas from Ahlsell Stores
         Catchment Areas from Ahlsell Stores           Catchment Areas from Ahlsell stores          Catchment Areas from Ahlsell stores
                        (50Km)                                       (50KM)                                       (50KM)
       Alingsås          Ahlsell      [20-30]%      Skövde              Ahlsell    [30-40]%      Malmö - Fosie     Ahlsell         [20-30]%
                         Stark           [0-5]%                         Stark         [0-5]%                       Stark             [0-5]%
                         Combined     [20-30]%                          Combined   [30-40]%                        Combined        [20-30]%
       Stenungsund       Ahlsell      [20-30]%      Ystad               Ahlsell    [30-40]%      Strängnäs         Ahlsell         [20-30]%
                         Stark           [0-5]%                         Stark         [0-5]%                       Stark             [0-5]%
                         Combined     [20-30]%                          Combined   [30-40]%                        Combined        [20-30]%
       Eslöv             Ahlsell      [10-20]%      Borås               Ahlsell    [20-30]%      Helsingborg       Ahlsell         [20-30]%
                         Stark           [0-5]%                         Stark         [0-5]%                       Stark             [0-5]%
                         Combined     [10-20]%                          Combined   [20-30]%                        Combined        [20-30]%
 ---pagebreak---  Catchment Areas from Ahlsell Stores    Catchment Areas from Ahlsell stores     Catchment Areas from Ahlsell stores
              (50Km)                                  (50KM)                                (50KM)
Lund           Ahlsell      [10-20]%  Katrineholm        Ahlsell    [20-30]%  Trelleborg     Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [10-20]%                     Combined   [20-30]%                 Combined       [20-30]%
Landskrona     Ahlsell      [10-20]%  Sala               Ahlsell    [20-30]%  Uppsala        Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [10-20]%                     Combined   [20-30]%                 Combined       [20-30]%
Lund           Ahlsell      [20-30]%  Lidköping          Ahlsell    [30-40]%  Trollhättan    Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [30-40]%                 Combined       [20-30]%
Kungälv        Ahlsell      [20-30]%  Norrtälje          Ahlsell    [20-30]%  Eskilstuna     Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Göteborg       Ahlsell      [20-30]%  Nässjö             Ahlsell    [20-30]%  Uddevalla      Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Göteborg -     Ahlsell      [20-30]%  Mjölby             Ahlsell    [20-30]%  Västerås       Ahlsell        [20-30]%
Partille       Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Göteborg -     Ahlsell      [20-30]%  Falkenberg         Ahlsell    [20-30]%  Hallstahammar  Ahlsell        [20-30]%
Almedal        Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Göteborg -     Ahlsell      [20-30]%  Emmaboda           Ahlsell    [20-30]%  Köping         Ahlsell        [20-30]%
Biskopsgården  Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Hisings Backa  Ahlsell      [20-30]%  Motala             Ahlsell    [20-30]%  Karlshamn      Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Mölndal        Ahlsell      [20-30]%  Jönköping          Ahlsell    [20-30]%  Hässleholm     Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [20-30]%
Kungsbacka     Ahlsell      [20-30]%  Sävsjö             Ahlsell    [50-60]%  Varberg        Ahlsell        [30-40]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [50-60]%                 Combined       [30-40]%
Enköping,      Ahlsell      [20-30]%  Mariestad          Ahlsell    [20-30]%  Karlskrona     Ahlsell        [30-40]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [30-40]%                 Combined       [30-40]%
Malmö-Arlöv    Ahlsell      [20-30]%  Kristianstad       Ahlsell    [20-30]%  Ljungby        Ahlsell        [70-80]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [20-30]%                 Combined       [70-80]%
Malmö -        Ahlsell      [20-30]%  Värnamo            Ahlsell    [80-90]%  Kalmar         Ahlsell        [20-30]%
Bulltofta      Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [80-90]%                 Combined       [20-30]%
Söderhamn      Ahlsell      [20-30]%  Sunne              Ahlsell    [40-50]%  Oskarshamn     Ahlsell        [40-50]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [20-30]%                     Combined   [40-50]%                 Combined       [40-50]%
Gislaved       Ahlsell      [70-80]%  Bollnäs            Ahlsell    [20-30]%  Kiruna         Ahlsell        [20-30]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [80-90]%                     Combined   [30-40]%                 Combined       [20-30]%
Vimmerby       Ahlsell      [30-40]%  Västervik          Ahlsell    [30-40]%  Gällivare      Ahlsell        [30-40]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [30-40]%                     Combined   [30-40]%                 Combined       [30-40]%
Arvika         Ahlsell      [40-50]%  41 Örnsköldsvik    Ahlsell    [20-30]%  Falköping      Ahlsell        [30-40]%
               Stark           [0-5]%                    Stark         [0-5]%                Stark             [0-5]%
               Combined     [40-50]%                     Combined   [20-30]%                 Combined       [30-40]%
Hudiksvall     Ahlsell      [20-30]%
               Stark           [0-5]%
               Combined     [20-30]%
 ---pagebreak--- C.3 Sweden HVAC Products
C.3.1 Catchment Areas from Stark Stores
          Catchment Areas from Stark Stores              Catchment Areas from Stark stores       Catchment Areas from Stark stores
                        (30Km)                                       (30KM)                                  (30KM)
       Hisings Backa     Stark           [0-5]%    Stenungsund         Stark           [0-5]% Arvika        Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [70-80]%               Ahlsell        [20-30]%
                         Combined      [20-30]%                        Combined      [70-80]%               Combined       [20-30]%
       Mölnlycke         Stark           [0-5]%    Karlshamn           Stark           [0-5]% Piteå         Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [20-30]%               Ahlsell        [30-40]%
                         Combined      [20-30]%                        Combined      [20-30]%               Combined       [30-40]%
       Mölndal           Stark           [0-5]%    Tomelilla           Stark           [0-5]% Örnsköldsvik  Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [20-30]%               Ahlsell        [30-40]%
                         Combined      [20-30]%                        Combined      [20-30]%               Combined       [30-40]%
       Lerum             Stark           [0-5]%    Gislaved            Stark           [0-5]% Västervik     Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [80-90]%               Ahlsell        [20-30]%
                         Combined      [20-30]%                        Combined      [80-90]%               Combined       [20-30]%
       Kungsbacka        Stark           [0-5]%    Skellefteå          Stark           [0-5]% Söderhamn     Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [20-30]%               Ahlsell        [20-30]%
                         Combined      [20-30]%                        Combined      [20-30]%               Combined       [20-30]%
       Märsta            Stark           [0-5]%    Hörby               Stark           [0-5]% Hudiksvall    Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [50-60]%               Ahlsell        [20-30]%
                         Combined      [20-30]%                        Combined      [60-70]%               Combined       [20-30]%
       Älvängen          Stark           [0-5]%    Karlskoga           Stark           [0-5]% Kiruna        Stark             [0-5]%
                         Ahlsell       [30-40]%                        Ahlsell       [50-60]%               Ahlsell        [30-40]%
                         Combined      [30-40]%                        Combined      [60-70]%               Combined       [30-40]%
       Eskilstuna        Stark           [0-5]%    Kristinehamn        Stark           [0-5]% Gällivare     Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [50-60]%               Ahlsell        [50-60]%
                         Combined      [20-30]%                        Combined      [60-70]%               Combined       [50-60]%
       Västerås          Stark           [0-5]%    Värnamo             Stark           [0-5]% Strängnäs     Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [70-80]%               Ahlsell        [30-40]%
                         Combined      [20-30]%                        Combined      [80-90]%               Combined       [30-40]%
       Uppsala           Stark           [0-5]%    Alingsås            Stark          [5-10]% Bollnäs       Stark             [0-5]%
                         Ahlsell       [20-30]%                        Ahlsell       [70-80]%               Ahlsell        [30-40]%
                         Combined      [20-30]%                        Combined      [70-80]%               Combined       [30-40]%
       Östersund         Stark           [0-5]%
                         Ahlsell       [20-30]%
                         Combined      [20-30]%
C.3.2 Sweden HVAC Products: Catchment Areas from Ahlsell Stores
          Catchment Areas from Ahlsell Stores           Catchment Areas from Ahlsell stores    Catchment Areas from Ahlsell stores
                        (50Km)                                        (50KM)                                (50KM)
       Alingsås         Ahlsell        [20-30]%      Malmö - Fosie     Ahlsell       [20-30]% Borås          Ahlsell      [20-30]%
                        Stark            [0-5]%                        Stark           [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                        Combined      [20-30]%                Combined     [20-30]%
       Stenungsund      Ahlsell        [20-30]%      Strängnäs         Ahlsell       [10-20]% Falköping      Ahlsell      [30-40]%
                        Stark            [0-5]%                        Stark           [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                        Combined      [10-20]%                Combined     [30-40]%
       Lund             Ahlsell        [20-30]%      Helsingborg       Ahlsell       [10-20]% Skövde         Ahlsell      [30-40]%
                        Stark            [0-5]%                        Stark           [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                        Combined      [20-30]%                Combined     [30-40]%
       Kungälv          Ahlsell        [20-30]%      Uppsala Söder     Ahlsell       [20-30]% Ystad          Ahlsell      [30-40]%
                        Stark            [0-5]%                        Stark           [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                        Combined      [20-30]%                Combined     [30-40]%
       Göteborg -       Ahlsell        [20-30]%      Uppsala Norr      Ahlsell       [20-30]% Hallsberg      Ahlsell      [20-30]%
       Partille         Stark            [0-5]%                        Stark           [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                        Combined      [20-30]%                Combined     [20-30]%
       Göteborg -       Ahlsell        [20-30]%      Trollhättan       Ahlsell       [20-30]% Katrineholm    Ahlsell      [20-30]%
       Marieholm        Stark            [0-5]%                        Stark           [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                        Combined      [30-40]%                Combined     [20-30]%
 ---pagebreak---           Catchment Areas from Ahlsell Stores         Catchment Areas from Ahlsell stores    Catchment Areas from Ahlsell stores
                        (50Km)                                    (50KM)                                  (50KM)
       Göteborg -       Ahlsell        [20-30]%    Eskilstuna      Ahlsell         [20-30]% Sala           Ahlsell       [20-30]%
       Hisings Backa    Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Göteborg -       Ahlsell        [20-30]%    Uddevalla       Ahlsell         [20-30]% Lidköping      Ahlsell       [40-50]%
       Almedal          Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [40-50]%
       Göteborg -       Ahlsell        [20-30]%    Västerås        Ahlsell         [20-30]% Norrtälje      Ahlsell       [20-30]%
       Biskopsgården    Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Mölndal          Ahlsell        [20-30]%    Hallstahammar   Ahlsell         [20-30]% Nässjö         Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Arlöv            Ahlsell        [20-30]%    Köping          Ahlsell         [20-30]% Falkenberg     Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Kungsbacka       Ahlsell        [20-30]%    Karlskoga       Ahlsell         [20-30]% Emmaboda       Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Enköping         Ahlsell        [20-30]%    Örebro          Ahlsell         [20-30]% Motala         Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Malmö -          Ahlsell        [20-30]%    Kristianstad    Ahlsell         [10-20]% Jönköping      Ahlsell       [20-30]%
       Bulltofta        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Sävsjö           Ahlsell        [50-60]%    Söderhamn       Ahlsell         [20-30]% Skellefteå     Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [50-60]%                    Combined        [20-30]%                Combined      [20-30]%
       Mariestad        Ahlsell        [30-40]%    Gislaved        Ahlsell         [80-90]% Västervik      Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [30-40]%                    Combined        [80-90]%                Combined      [20-30]%
       Luleå            Ahlsell        [10-20]%    Vimmerby        Ahlsell         [20-30]% Östersund      Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [20-30]%                Combined      [20-30]%
       Värnamo          Ahlsell        [80-90]%    Arvika          Ahlsell         [30-40]% Örnsköldsvik   Ahlsell       [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [80-90]%                    Combined        [30-40]%                Combined      [20-30]%
       Varberg          Ahlsell        [30-40]%    Hudiksvall      Ahlsell         [20-30]% Oskarshamn     Ahlsell       [80-90]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [30-40]%                    Combined        [20-30]%                Combined      [80-90]%
       Piteå            Ahlsell        [20-30]%    Sunne           Ahlsell         [30-40]% Kiruna         Ahlsell       [30-40]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [20-30]%                    Combined        [30-40]%                Combined      [30-40]%
       Karlskrona       Ahlsell        [30-40]%    Bollnäs         Ahlsell         [30-40]% Gällivare      Ahlsell       [50-60]%
                        Stark            [0-5]%                    Stark             [0-5]%                Stark           [0-5]%
                        Combined       [30-40]%                    Combined        [30-40]%                Combined      [50-60]%
       Ljungby          Ahlsell        [80-90]%    Kalmar          Ahlsell         [20-30]%
                        Stark            [0-5]%                    Stark             [0-5]%
                        Combined       [80-90]%                    Combined        [20-30]%
C.4 Sweden Electrical Products:
C.4.1 Catchment Areas from Stark Stores
        Catchment Areas from Stark Stores (30Km)      Catchment Areas from Stark stores     Catchment Areas from Stark stores (30KM)
                                                                  (30KM)
       Hisings Backa       Stark            [0-5]% Älvängen      Stark               [0-5]% Värnamo       Stark                 [0-5]%
                           Ahlsell       [20-30]%                Ahlsell          [20-30]%                Ahlsell            [60-70]%
                           Combined      [20-30]%                Combined         [20-30]%                Combined           [70-80]%
       Mölnlycke           Stark            [0-5]% Västerås      Stark               [0-5]% Alingså       Stark                 [0-5]%
                           Ahlsell       [20-30]%                Ahlsell          [10-20]%                Ahlsell            [20-30]%
 ---pagebreak---         Catchment Areas from Stark Stores (30Km)            Catchment Areas from Stark stores        Catchment Areas from Stark stores (30KM)
                                                                         (30KM)
                           Combined       [20-30]%                      Combined        [20-30]%                     Combined         [30-40]%
       Mölndal             Stark            [0-5]%      Skara           Stark             [0-5]%     Arvika          Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [30-40]%                     Ahlsell          [50-60]%
                           Combined       [20-30]%                      Combined        [30-40]%                     Combined         [50-60]%
       Lerum               Stark            [0-5]%      Sölvesborg      Stark             [0-5]%     Örnsköldsvik    Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [20-30]%                     Ahlsell          [10-20]%
                           Combined       [20-30]%                      Combined        [20-30]%                     Combined         [20-30]%
       Södra Sandby        Stark            [0-5]%      Sjöbo           Stark            [5-10]%     Västervik       Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [40-50]%                     Ahlsell          [60-70]%
                           Combined       [20-30]%                      Combined        [50-60]%                     Combined         [60-70]%
       Arlöv               Stark            [0-5]%      Stenungsund     Stark             [0-5]%     Söderhamn       Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [20-30]%                     Ahlsell          [30-40]%
                           Combined       [20-30]%                      Combined        [20-30]%                     Combined         [30-40]%
       Lund                Stark            [0-5]%      Karlshamn       Stark             [0-5]%     Hudiksvall      Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [20-30]%                     Ahlsell          [30-40]%
                           Combined       [20-30]%                      Combined        [20-30]%                     Combined         [30-40]%
       Kungsbacka          Stark            [0-5]%      Tomelilla       Stark             [0-5]%     Gällivare       Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [50-60]%                     Ahlsell          [10-20]%
                           Combined       [20-30]%                      Combined        [50-60]%                     Combined         [20-30]%
       Malmö               Stark            [0-5]%      Gislaved        Stark             [0-5]%     Strängnäs       Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [70-80]%                     Ahlsell          [70-80]%
                           Combined       [20-30]%                      Combined        [80-90]%                     Combined         [70-80]%
       Trelleborg          Stark            [0-5]%      Karlskrona      Stark             [0-5]%     Bollnäs         Stark               [0-5]%
                           Ahlsell        [20-30]%                      Ahlsell         [20-30]%                     Ahlsell          [20-30]%
                           Combined       [20-30]%                      Combined        [20-30]%                     Combined         [20-30]%
       Eskilstuna          Stark            [0-5]%      Hörby           Stark            [5-10]%
                           Ahlsell        [20-30]%                      Ahlsell         [60-70]%
                           Combined       [20-30]%                      Combined        [60-70]%
C.4.2 Catchment Areas from Ahlsell Stores
         Catchment Areas from Ahlsell Stores          Catchment Areas from Ahlsell stores           Catchment Areas from Ahlsell stores
                      (50Km)                                        (50KM)                                        (50KM)
       Lund             Ahlsell      [30-40]%      Kungsbacka        Ahlsell       [20-30]%      Västerås         Ahlsell         [20-30]%
                        Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [30-40]%                        Combined      [20-30]%                       Combined        [20-30]%
       Kungälv          Ahlsell      [20-30]%      Enköping          Ahlsell       [20-30]%      Hallstahammar    Ahlsell         [20-30]%
                        Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [20-30]%                       Combined        [20-30]%
       Göteborg -       Ahlsell      [20-30]%      Malmö -           Ahlsell       [20-30]%      Hässleholm       Ahlsell         [40-50]%
       Partille         Stark          [0-5]%      Bulltofta         Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [20-30]%                       Combined        [40-50]%
       Göteborg -       Ahlsell      [20-30]%      Malmö - Fosie     Ahlsell       [20-30]%      Kristianstad     Ahlsell         [20-30]%
       Marieholm        Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [20-30]%                       Combined        [20-30]%
       Göteborg -       Ahlsell      [20-30]%      Strängnäs         Ahlsell       [20-30]%      Karlshamn        Ahlsell         [20-30]%
       Hisings Backa    Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [20-30]%                       Combined        [20-30]%
       Göteborg -       Ahlsell      [20-30]%      Helsingborg       Ahlsell       [20-30]%      Halmstad         Ahlsell         [20-30]%
       Almedal          Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [20-30]%                       Combined        [20-30]%
       Göteborg -       Ahlsell      [20-30]%      Uppsala Söder     Ahlsell       [10-20]%      Borås            Ahlsell         [20-30]%
       Biskopsgården    Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [10-20]%                       Combined        [20-30]%
       Mölndal          Ahlsell      [20-30]%      Trollhättan       Ahlsell       [20-30]%      Falköping        Ahlsell         [20-30]%
                        Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
                        Combined     [20-30]%                        Combined      [20-30]%                       Combined        [20-30]%
       Arlöv            Ahlsell      [20-30]%      Eskilstuna        Ahlsell       [20-30]%      Skövde           Ahlsell         [30-40]%
                        Stark          [0-5]%                        Stark           [0-5]%                       Stark             [0-5]%
 ---pagebreak---          Catchment Areas from Ahlsell Stores            Catchment Areas from Ahlsell stores               Catchment Areas from Ahlsell stores
                      (50Km)                                           (50KM)                                           (50KM)
                        Combined     [20-30]%                           Combined       [20-30]%                         Combined        [30-40]%
       Ystad            Ahlsell      [40-50]%        Sävsjö             Ahlsell        [50-60]%        Arvika           Ahlsell         [50-60]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [40-50]%                           Combined       [50-60]%                         Combined        [50-60]%
       Sala             Ahlsell      [20-30]%        Mariestad          Ahlsell        [20-30]%        Hudiksvall       Ahlsell         [30-40]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [20-30]%                           Combined       [20-30]%                         Combined        [30-40]%
       Lidköping        Ahlsell      [30-40]%        Värnamo            Ahlsell        [80-90]%        Sunne            Ahlsell         [60-70]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [30-40]%                           Combined       [80-90]%                         Combined        [60-70]%
       Norrtälje        Ahlsell      [10-20]%        Varberg            Ahlsell        [30-40]%        Bollnäs          Ahlsell         [20-30]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [20-30]%                           Combined       [30-40]%                         Combined        [20-30]%
       Nässjö           Ahlsell      [20-30]%        Karlskrona         Ahlsell        [30-40]%        Västervik        Ahlsell         [70-80]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [20-30]%                           Combined       [30-40]%                         Combined        [70-80]%
       Mjölby           Ahlsell      [20-30]%        Ljungby            Ahlsell        [70-80]%        Örnsköldsvik     Ahlsell         [10-20]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [20-30]%                           Combined       [70-80]%                         Combined        [20-30]%
       Falkenberg       Ahlsell      [10-20]%        Kalmar             Ahlsell        [20-30]%        Oskarshamn       Ahlsell         [20-30]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [10-20]%                           Combined       [20-30]%                         Combined        [20-30]%
       Emmaboda         Ahlsell      [20-30]%        Söderhamn          Ahlsell        [20-30]%        Gällivare        Ahlsell         [10-20]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [20-30]%                           Combined       [20-30]%                         Combined        [20-30]%
       Motala           Ahlsell      [20-30]%        Gislaved           Ahlsell        [70-80]%        Vimmerby         Ahlsell         [60-70]%
                        Stark          [0-5]%                           Stark            [0-5]%                         Stark             [0-5]%
                        Combined     [20-30]%                           Combined       [70-80]%                         Combined        [70-80]%
       Jönköping        Ahlsell      [20-30]%
                        Stark          [0-5]%
                        Combined     [20-30]%
C.5 Sweden Tools and Supplies:
C.5.1 Catchment Areas from Stark Stores
         Catchment Areas from Stark Stores (30Km)               Catchment Areas from Stark stores            Catchment Areas from Stark stores (30KM)
                                                                               (30KM)
       Sjöbo                Stark           [10-20]%        Hörby             Stark          [10-20]%       Söderhamn         Stark             [5-10]%
                            Ahlsell           [5-10]%                         Ahlsell        [10-20]%                         Ahlsell          [10-20]%
                            Combined        [20-30]%                          Combined       [20-30]%                         Combined         [20-30]%
       Stenungsund          Stark             [5-10]%       Norrtälje         Stark            [5-10]%      Hudiksvall        Stark             [5-10]%
                            Ahlsell         [10-20]%                          Ahlsell        [10-20]%                         Ahlsell          [10-20]%
                            Combined        [20-30]%                          Combined       [20-30]%                         Combined         [20-30]%
       Karlshamn            Stark             [5-10]%       Alingså           Stark          [10-20]%       Strängnäs         Stark             [5-10]%
                            Ahlsell         [10-20]%                          Ahlsell        [10-20]%                         Ahlsell          [30-40]%
                            Combined        [20-30]%                          Combined       [20-30]%                         Combined         [40-50]%
       Tomelilla            Stark             [5-10]%       Arvika            Stark            [5-10]%      Bollnäs           Stark            [10-20]%
                            Ahlsell         [10-20]%                          Ahlsell        [20-30]%                         Ahlsell          [40-50]%
                            Combined        [20-30]%                          Combined       [30-40]%                         Combined         [50-60]%
       Gislaved             Stark              [0-5]%       Västervik         Stark            [5-10]%
                            Ahlsell         [10-20]%                          Ahlsell        [20-30]%
                            Combined        [10-20]%                          Combined       [30-40]%
C.5.2 Sweden Tools & Supplies: Catchment Areas from Ahlsell Stores:
        Catchment Areas from Ahlsell Stores (50Km)             Catchment Areas from Ahlsell stores               Catchment Areas from Ahlsell stores
                                                                               (50KM)                                          (50KM)
       Ystad               Ahlsell         [10-20]%         Karlskrona        Ahlsell         [10-20]%       Hudiksvall      Ahlsell           [10-20]%
                           Stark             [5-10]%                          Stark             [0-5]%                       Stark              [5-10]%
                           Combined        [20-30]%                           Combined        [20-30]%                       Combined          [20-30]%
       Norrtälje           Ahlsell         [10-20]%         Söderhamn         Ahlsell         [20-30]%       Sunne           Ahlsell           [20-30]%
 ---pagebreak---         Catchment Areas from Ahlsell Stores (50Km)         Catchment Areas from Ahlsell stores         Catchment Areas from Ahlsell stores
                                                                        (50KM)                                      (50KM)
                           Stark               [0-5]%                  Stark             [5-10]%                  Stark                [0-5]%
                           Combined         [20-30]%                   Combined         [20-30]%                  Combined           [30-40]%
       Sävsjö              Ahlsell          [10-20]%    Gislaved       Ahlsell          [10-20]%   Bollnäs        Ahlsell            [20-30]%
                           Stark               [0-5]%                  Stark             [5-10]%                  Stark               [5-10]%
                           Combined         [20-30]%                   Combined         [10-20]%                  Combined           [30-40]%
       Värnamo             Ahlsell          [20-30]%    Vimmerby       Ahlsell          [20-30]%   Västervik      Ahlsell            [20-30]%
                           Stark               [0-5]%                  Stark               [0-5]%                 Stark                [0-5]%
                           Combined         [20-30]%                   Combined         [20-30]%                  Combined           [20-30]%
       Varberg             Ahlsell          [20-30]%    Arvika         Ahlsell          [20-30]%   Oskarshamn     Ahlsell            [30-40]%
                           Stark               [0-5]%                  Stark               [0-5]%                 Stark               [5-10]%
                           Combined         [20-30]%                   Combined         [20-30]%                  Combined           [30-40]%
C.6 Sweden Workwear and PPE
C.6.1 Catchment Areas from Stark Stores
        Catchment Areas from Stark Stores (30Km)      Catchment Areas from Stark stores (30KM)     Catchment Areas from Stark stores (30KM)
       Stenungsund          Stark            [0-5]%   Norrtälje       Stark              [5-10]%  Hudiksvall     Stark                 [0-5]%
                            Ahlsell      [10-20]%                     Ahlsell          [30-40]%                  Ahlsell             [10-20]%
                            Combined     [20-30]%                     Combined         [40-50]%                  Combined            [20-30]%
       Karlshamn            Stark          [5-10]%    Arvika          Stark              [5-10]%  Strängnäs      Stark                [5-10]%
                            Ahlsell      [20-30]%                     Ahlsell          [30-40]%                  Ahlsell             [40-50]%
                            Combined     [30-40]%                     Combined         [40-50]%                  Combined            [50-60]%
       Tomelilla            Stark          [5-10]%    Västervik       Stark              [5-10]%  Bollnäs        Stark                [5-10]%
                            Ahlsell      [20-30]%                     Ahlsell          [40-50]%                  Ahlsell             [40-50]%
                            Combined     [30-40]%                     Combined         [40-50]%                  Combined            [50-60]%
       Hörby                Stark        [10-20]%
                            Ahlsell      [30-40]%
                            Combined     [50-60]%
C.6.2 Sweden Workwear and PPE: Catchment Areas from Ahlsell Stores
           Catchment Areas from Ahlsell Stores            Catchment Areas from Ahlsell stores          Catchment Areas from Ahlsell stores
                         (50Km)                                        (50KM)                                       (50KM)
       Ystad            Ahlsell          [10-20]%     Söderhamn       Ahlsell           [20-30]%   Bollnäs        Ahlsell            [20-30]%
                        Stark             [5-10]%                     Stark                [0-5]%                 Stark                [0-5]%
                        Combined         [20-30]%                     Combined          [20-30]%                  Combined           [20-30]%
       Norrtälje        Ahlsell          [10-20]%     Vimmerby        Ahlsell           [20-30]%   Västervik      Ahlsell            [20-30]%
                        Stark               [0-5]%                    Stark                [0-5]%                 Stark                [0-5]%
                        Combined         [20-30]%                     Combined          [20-30]%                  Combined           [20-30]%
       Värnamo          Ahlsell          [20-30]%     Arvika          Ahlsell           [30-40]%   Oskarshamn     Ahlsell            [30-40]%
                        Stark               [0-5]%                    Stark                [0-5]%                 Stark               [5-10]%
                        Combined         [20-30]%                     Combined          [30-40]%                  Combined           [40-50]%
       Varberg          Ahlsell          [40-50]%     Sunne           Ahlsell           [30-40]%
                        Stark               [0-5]%                    Stark                [0-5]%
                        Combined         [40-50]%                     Combined          [40-50]%