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Graña y Montero Securities Settlement

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WELCOME TO THE GRAÑA Y MONTERO SECURITIES SETTLEMENT WEBSITE

Pursuant to the Court’s Order, dated December 3, 2020, the Fairness Hearing
scheduled for December 21, 2020, at 11:00 a.m. shall be conducted
telephonically. The Order is available here. All parties shall connect to the
call through dial-in number 888-557-8511 with access code 3152145.



This website has been established to provide general information related to the
proposed settlement of the case styled In re Graña y Montero S.A.A. Securities
Litigation, No. 2:17-cv-01105-LDH-ST (the "Litigation"), pending before the
United States District Court for the Eastern District of New York (the "Court").
The capitalized terms used on this website, and not otherwise defined, shall
have the same meanings ascribed to them in the Stipulation and Agreement of
Settlement (the "Stipulation") dated July 2, 2020, which can be found and
downloaded by clicking on the Case Documents tab above. Your rights may be
affected by the Settlement if you purchased or otherwise acquired American
Depository Shares ("ADS") of Graña y Montero S.A.A. ("Graña y Montero" or the
"Company") during the period from July 24, 2013 through February 24, 2017,
inclusive, and are not otherwise excluded from the Settlement Class. 

The law firms of Robbins Geller Rudman & Dowd LLP and Holzer & Holzer, LLC
represent you and other Settlement Class Members. You will not be charged for
these lawyers. They will be paid from the Settlement Fund to the extent the
Court approves their application for fees and expenses. If you want to be
represented by your own lawyer, you may hire one at your own expense.

WHAT IS THIS LAWSUIT ABOUT?

As more fully described in the Notice of Pendency and Proposed Settlement of
Class Action (the "Notice"), the Consolidated Amended Class Action Complaint for
Violations of the Federal Securities Laws was filed on May 29, 2018. 

On November 19, 2019, counsel for Graña y Montero, Monica Miloslavich Hart and
Plaintiffs participated in an in-person mediation session with Gregory
Lindstrom, Esq. of Phillips ADR Enterprises, an experienced mediator. The
mediation was preceded by submission of mediation statements by the mediating
parties. The Settling Parties engaged in arm’s-length negotiations during the
mediation session, and reached an agreement-in-principle to resolve the
Litigation, subject to insurer approval. The agreement included, among other
things, the Settling Parties’ agreement to settle the Litigation in return for a
cash payment of $20,000,000 for the benefit of the Settlement Class, subject to
the negotiation of the terms of a Stipulation of Settlement and approval by the
Court. The Stipulation (together with the Exhibits thereto) reflects the final
and binding agreement between the Settling Parties.

WHAT DOES THE SETTLEMENT PROVIDE?

The Settlement, if approved, will result in the creation of a cash settlement
fund of $20,000,000.00 (the “Settlement Amount”). The Settlement Amount, plus
accrued interest, is the Settlement Fund. The Settlement Fund minus the costs of
the Notice and all costs associated with the administration of the Settlement,
Taxes and Tax Expenses, attorneys’ fees and expenses, and any award to
Plaintiffs in connection with their representation of the Settlement Class, as
approved by the Court (the “Net Settlement Fund”), will be distributed to
eligible Settlement Class Members pursuant to the Plan of Allocation that is
described in the Notice.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not
replace the information contained in the Notice and Stipulation, both of which
can be found and downloaded by clicking on the Case Documents tab above. We
recommend that you read the Notice and other relevant case documents carefully.


YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

SUBMIT A PROOF OF CLAIM FORM The only way to be eligible to receive a payment
from the Settlement. Proof of Claim forms must be postmarked or submitted online
on or before January 13, 2021. EXCLUDE YOURSELF Get no payment. This is the only
option that potentially allows you to ever be part of any other lawsuit against
the Defendants or any other Released Persons about the legal claims being
resolved by this Settlement. Should you elect to exclude yourself from the
Settlement Class you should understand that Defendants and the other Released
Defendant Parties will have the right to assert any and all defenses they may
have to any claims that you may seek to assert, including, without limitation,
the defense that any such claims are untimely under applicable statutes of
limitations and statutes of repose. Exclusions must be postmarked on or before
November 10, 2020. OBJECT Write to the Court about why you do not like the
Settlement, the Plan of Allocation, and/or the request for attorneys’ fees and
expenses. You will still be a Member of the Settlement Class. Objections must be
received by the Court and counsel on or before November 10, 2020. If you submit
a written objection, you may (but do not have to) attend the hearing. GO TO THE
HEARING ON DECEMBER 21, 2020 AT 11:00 A.M. Ask to speak in Court about the
fairness of the Settlement. Requests to speak must be received by the Court and
counsel on or before November 10, 2020. DO NOTHING Receive no payment. You will,
however, still be a Member of the Settlement Class, which means that you give up
your right to ever be part of any other lawsuit against the Defendants or any
other Released Defendant Parties about the legal claims being resolved by this
Settlement and you will be bound by any judgments or orders entered by the Court
in the Litigation.





IMPORTANT DATES AND DEADLINES

Submit Proof of Claim: January 13, 2021 File Objection: November 10, 2020
Request Exclusion: November 10, 2020 File Notice of Intention to Appear:
November 10, 2020 Court Hearing on Fairness of Settlement: December 21, 2020, at
11:00 a.m.

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