experience, nor does it name a single individual associated with the company. Why did Adani Group select such a small firm for coal supply? What was the due-diligence process that went into its selection? The transaction with Pan Asia has been clearly disclosed in the financials and hence the attempts to suggest that these transactions need to be brought to light are absurd when all relevant stakeholders have had access to this information for almost 4 years. In any event, the tenders floated by Adani portfolio entities have well laid out technical and financial qualification criteria for all prospective bidders and any prospective bidder who meets the aforementioned conditions is eligible to participate in the tenders. 48/ (Allegation #82) Corporate records show that a former Adani Group company director was a director and shareholder of Pan Asia. Why didn’t Adani roup disclose the potential conflict of interest in the transaction? This allegation stems from a complete misunderstanding by Hindenburg of the facts and what amounts to conflict of interest in bid documents. Hence to clarify, no Adani company director was a director or a shareholder in Pan Asia at the time of, or even close to the time of, when the said bidding process was carried out. Hence, there was no conflict of interest, potential or otherwise, while dealing with Pan Asia for this tender. 49/ (Allegation #83) In the same year as winning the coal deal in 2019, Pan Asia Coal Trading lent U.S. $30 million to a private entity of Adani Group, per Singaporean corporate records. Why did a private company of the Adani family take money from a small single shareholder entity in Singapore at the same time its listed company was awarding a coal supply deal to it? This loan transaction has no link to the tender. We have been informed that the loan transaction has been carried out in compliance with applicable laws by the relevant parties. C. Misleading claims around offshore entities being allegedly “related parties” without regard for applicable law and standards 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. 50/ (Allegation #4) What has been the full extent of inod Adani’s role in the Adani Group to date, including all roles on deals and entities that have transacted with the Adani Group? 51/ (Allegation #36) How many entities is Vinod Adani associated with as either director, shareholder, or beneficial owner? What are the names and jurisdictions of these entities? 52/ (Allegation #37) What are the full details of the Vinod Adani-associated entities’ dealings with private and listed entities in the Adani empire? 40
Adani Response Page 39 Page 41