iv. Offering circular dated November 14, 2019 for the U.S.$500 mn Senior Secured Notes issued by Adani Transmission Limited (page 32 and 182) The relevant excerpts from the above documents are annexed hereto in Annexure 2. The relevant orders are appended in Annexure 6 and Annexure 8. Further, the statement made by us in the pre-IPO prospectus in 2009 is absolutely correct. It may also be noted that the over-invoicing allegations for power imports pertains to the period between April 2010 till August 2014, during which period Mr. Vinod Adani was not even a director in any of the relevant Adani entities against whom such investigations were initiated and had no role in their day to day affairs. 6/ (Allegation #27) Our findings indicate that SEBI has investigated and prosecuted more than 70 entities and individuals, including Adani promoters, for manipulating Adani stock between 1999 to 2005. How does Adani respond? There are no ongoing proceedings against the Adani promoters before SEBI in relation to this issue and all past cases before SEBI have been closed. These have also been duly disclosed by us and our stakeholders are already aware of the same. See for instance, p. 51 of the APSEZ Institutional Private Placement Prospectus dated June 2013, the relevant excerpt of which is annexed hereto as Annexure 2. We are neither aware of, nor are we required to be, aware of any proceedings against these other “entities and individuals”, who are not Adani promoters. 7/ (Allegation #28) A SEBI ruling determined that Adani promoters aided and abetted Ketan Parekh in the manipulation of shares of Adani Exports (now Adani Enterprises), showing that 14 Adani private companies transferred shares to entities controlled by Parekh. How does Adani explain this coordinated, systematic stock manipulation in its shares, together with one of India’s most notorious convicted stock fraudsters? 8/ (Allegation #29) In its defense, Adani Group claimed it had dealt with Parekh and his stock manipulation efforts to finance operations at the Mundra port. Does Adani view extraction of capital through stock manipulation as a legitimate method of financing? 9/ (Allegation #30) Individuals close to Ketan Parekh have told us that he continues to work on transactions with his old clients, including Adani. What was and is the full extent of the relationship between Parekh and the Adani roup, including either entity’s relationship with inod Adani? Common Response - The allegation in relation to Ketan Parekh working with Adani companies are incorrect. This matter has been disposed of by SEBI on 17th April 2008 and has also been duly disclosed by us in the public domain. 10/ (Allegation #31) Given that Adani Group promoters pledge shares as collateral for loans, wouldn’t stock manipulation artificially inflate the collateral and borrowing base for such loans, posing a significant risk for the promoters’ counterparties and, by proxy, Adani shareholders who would suffer at the hands of a collateral call or deleveraging via equity sale? 29
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