1. Disclosed, discredited and disproven allegations: Allegations no. 1, 2, 3, 27, 28, 29, 30, 31, 72, 73, 74, 75, 76, 77, 78, 79, 80 present no new findings and only dredge up allegations (in some cases from a decade ago) which have been judicially determined in our favour and have also been disclosed by us to our investors and the regulators. By way of an example, there are multiple false narratives being created in relation to certain allegations concerning diamond exports, which matters have all been closed by the Appellate Tribunal (CESTAT) in our favour. This decision has been further confirmed by the Supreme Court itself twice over, a fact which has been deliberately ignored and concealed in the Hindenburg report (which contemptuously raises questions on the competence of the Appellate Tribunal with baseless claims that it has ignored evidence). 2. Baseless allegations around transactions which are in fact, compliant with law, fully disclosed and on proper commercial terms: Allegation no. 9, 15, 19, 24, 25, 32, 33, 35, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 53, 54, 55, 56, 57, 58, 59, 60, 61, 81, 82 & 83 are again a selective regurgitation of disclosures from the financial statements of Adani entities to paint a biased picture. These disclosures have already been approved by third parties who are qualified and competent to review these (rather than an unknown overseas shortseller) and are in line with applicable accounting standards and applicable law. In another instance (allegation 41 of the Hindenburg Report), they have falsely claimed that Emerging Market Investment DMCC gave a loan of USD 1 billion to Mahan Energen. The simple fact of the matter is that Emerging Market acquired the USD 1 billion “unsustainable debt” of Mahan Energen from its lenders for USD 100 as part of a resolution plant duly approved by the National Company Law Tribunal under the Indian Bankruptcy Code. These are mala fide attempts to question bona fide transactions, the details of which are fully disclosed and available in the public domain, to create doubt in the minds of our stakeholders and the public. In fact, the mala fide intent of Hindenburg can be clearly seen from it suggesting structures that would not be in compliance with corporate governance. By way of example, a fully disclosed transaction (see allegation 61 of the Hindenburg Report) of Adani Enterprises Limited’s subsidiary with NQXT to pay a standard security deposit (a common feature under long term take or pay contracts) for use of terminals has been questioned. Hindenburg seems to suggest that NQXT (a corporate entity in its own right and subject to its own regulations) should provide Adani Enterprises long term terminals for no charges at all – a transaction that would amount to providing a benefit to a related party without arm’s length terms. 3. Misleading claims around offshore entities being allegedly “related parties” without regard for applicable law and standards: Allegation no. 4, 36, 37, 38, and 39 from the report are in reference to offshore entities. The queries make reckless statements without any evidence whatsoever and purely on unsubstantiated speculations without any understanding of the Indian laws around related parties and related party transactions. 5
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