According to the Complaint, NMC Health Plc, together with its subsidiaries, purports to provide healthcare services in the United Arab Emirates, the United Kingdom, Spain, and internationally. The Company purports to own and manage approximately 200 healthcare facilities, including hospitals, medical centers, long term care facilities, day surgery centers, fertility clinics, and home health services providers. The Company purports to offer medical services as well as research and medical services in the field of gynecology, obstetrics, and human reproduction; and management services to hospitals, as well as retail pharmaceutical goods.

The Complaint alleges that Defendants throughout the Class Period made false and/or misleading statements and/or failed to disclose that: (1) the Company lacked effective internal controls and risk management; (2) the Company engaged in undisclosed and extensive related party and de facto related party transactions; (3) NMC's debts were significantly understated and obfuscated; (4) NMC's cash-on-hand figures were overstated; (5) NMC's principal shareholders were not accurately reporting or accounting their interests or stakes in the Company; (6) NMC did not review or know their principal shareholders interests or stakes in the Company; (7) consequently, the Company was not enforcing its Relationship Agreement with the principal shareholders; and (8) as a result, Defendants' statements about its business, operations, and prospects, were materially false and misleading and/or lacked a reasonable basis at all relevant times.