Eastern Shock Cavalry & Giving ground

[Grizz]

A unit of Eastern Shock Cavalry (ESC) beat, but fail to break an enemy cavalry unit - who cannot Give Ground. Becuase of the presence of enemy infantry near their flank the ESC decides to Give Ground and moves back 10" - taking them out to the way of the pesky infantry.

The next turn is the enemies and they declare a charge against the ESC (with the unit that just held the previous turn).

Can the ESC declare a Counter Charge as it's charge reaction?

[Grizz]

OK found my answer -

With the exception of striking first counterchargers count as charging for all purposes, so based on that - they cannot countercharge on the turn after they give ground.