Hayward Holdings, Inc.

The filed complaint alleges that Hayward Holdings, Inc. made materially false and/or misleading statements and/or failed to disclose that:

(a) Hayward and its management had engaged in a channel-stuffing scheme designed to artificially boost Hayward’s short-term sales and earnings; (b) Hayward had flooded its channel partners with inventory that they did not want or need at a level that far outpaced then-existing consumer demand; (c) Hayward’s channel partners were suffering from an inventory glut as a result of the channel-stuffing scheme that would require a massive destocking in the second half of 2022; (d) Hayward’s channel-stuffing scheme had cannibalized future sales, materially impairing the Company’s ability to sell to its customers; (e) the demand for pool equipment had slowed down, which, combined with flooding channel partners with more inventory, led to an inventory glut and the need for these channel partners to reduce inventory levels; and (f) as a result of (a)-(e) above, Hayward’s projected 2022 financial results were not achievable and lacked a reasonable basis in fact.