Settlement Agreement between Eurotunnel and Dresdner Bank

Dresdner Bank and Eurotunnel put an end to the various pending Court proceedings started by Dresdner Bank in Paris relating to the adoption and implementation of Eurotunnel’s sauvegarde plan, as approved by the Paris Commercial Court on 15 January 2007.

Accordingly, Dresdner Bank has formally and irrevocably withdrawn and abandoned all pending claims and waived all rights of action in respect of such proceedings. Eurotunnel, as well as the representatives appointed by the Court under the sauvegarde proceedings, have unconditionally accepted such withdrawal.