Raising financing against shares as collateral is a common practice globally. These loans are given by large reputed financial institutions and banks on the back of thorough credit analysis of the underlying assets in the listed company as well as detailed assessment of liquidity of the company stock pledged as collateral. Further, there is a robust disclosure system in place in India wherein listed companies need to disclose their overall pledge position of shares to stock exchanges from time to time. Consequently, Hindenburg’s narrative of alleged stock manipulation on account of pledge of shares has no basis and stems from ignorance of the securities laws in India. Please refer chart below for promoter pledge position across Adani portfolio listed companies. This clearly shows a significant reduction in the pledge position across all the listed companies. Promoter Gross Pledge position Source: Bombay Stock Exchange (BSE) website. 11/ (Allegation #74) In 2011, the parliamentary Ombudsman for the Karnataka state issued a 466- page report describing Adani as the “anchor point” for a massive INR 600 billion (U.S. $12 billion) scam involving the illegal importation of iron ore, alleging that Adani had bribed all levels of the government in facilitation of the scheme. What is Adani’s response to the investigation and the extensive evidence presented as part of these findings? The proceeding has been closed in July 2017 in our favour. However, in the interest of governance and transparency to all of our stakeholders, the following are details of the matter. The Special Investigation Team (SIT) formed by Karnataka Lokayukta had lodged an FIR against AEL and others. The same was publicly disclosed by AEL vide stock exchange disclosure dated July 30, 2011 (link: https://www.bseindia.com/xml- data/corpfiling/CorpAttachment/2011/7/Adani_Enterprises_Ltd_300711.pdf). The SIT and after a detailed investigation, determined the allegations were false and filed a closure report stating that AEL was not involved in such alleged illegal gratification. This has been accepted by the designated Lokayukta court at Bangalore. 12/ (Allegation #75) In 2014, the DRI once again accused Adani of using intermediary UAE-based shell entities controlled by Vinod Adani to siphon funds, in this case through the over-invoicing of 30

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