Instead, Hindenburg seems to suggest, in flagrant violation of standard governance requirements for related party transactions, that simply because two parties are related, NQXT (which is a separate corporate entity and subject to the regulations of Australian Securities & Investment Commission) should have provided long term access to the terminal for no security deposit or charges at all rather than a contract on arm’s length basis. 34/ (Allegation #60) Why have listed Adani companies paid private Adani entity “Adani Infrastructure Management Services” INR 21.1 billion (U.S. $260 million) over the past 5 years, given that the listed companies’ business is also managing infrastructure? This allegation stems from a complete lack of understanding the manner in which businesses are carried out by large companies in these sectors, with suggestions that merely because they manage infrastructure business, they cannot outsource parts work or enter into contracts for obtaining these services from other related parties who specialize in providing such services. It further flows from a complete lack of understanding of these complex businesses which require specialized services and management which cannot at all times be housed in the same corporate entity. Adani Infrastructure Management Services Limited (AIMSL) is such a specialized service provider for the Adani companies. AIMSL is a pioneer in operation and maintenance of key assets in India’s power sector with all required manpower and qualifications to be able to provide such services to the Adani companies on arms’ length terms. Currently, AIMSL is operating AGEL, ATL & APL assets spread across multiple states such as Rajasthan, Karnataka, Maharashtra, Gujarat, M.P, Haryana etc. and is being managed by experienced resources. Annexure 11 sets out further details about AIMSL and their credentials. 35/ (Allegation #9) What is the extent of the Adani Group Companies, and any Vinod Adani related entities’ dealings with Jatin Mehta? There are no business relationships or business dealings with Mr. Jatin Mehta. 36/ (Allegation #15) Adani has worked extensively with international incorporation firm Amicorp, which has established at least 7 of its promoter entities, at least 17 offshore shells and entities associated with Vinod Adani, and at least 3 Mauritius-based offshore shareholders of Adani stock. Amicorp played a key role in the 1MDB international fraud scandal, according to the book Billion Dollar Whale and U.S. legal case files, along with files from the Malaysian anti-corruption commission. Why has Adani continued to work closely with Amicorp despite its proximity to a major international fraud and money laundering scandal? Amicorp is a recognized firm that provides secretarial services to various entities and corporate groups from across the globe and not just the Adani portfolio entities. More details for Amicorp and its portfolio are available at: https://www.amicorp.com/. We are not concerned with these completely unrelated “scandals” that you refer to in a blatant attempt to build a false narrative around our group. Hindenburg can write to Amicorp to seek their response if it so wishes about any scandal they believe Amicorp is involved in. 37/ (Allegation #19) Trustlink’s CEO touts its close relationship with Adani. The same Trustlink CEO was previously alleged by the DRI to have been involved in a fraud using shell companies with Adani. 37

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