Supplier, Country of Origin Certificate (Form A1), Bill of Entry, Bill of Lading etc. In compliance with the DRI directions, we have already submitted the necessary documents to the regulator. No show cause notice has been issued to us till date. B. Baseless allegations around transactions which are in fact, compliant with law, fully disclosed and on proper commercial terms 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. The Indian legislations (Companies Act, Listing Regulations, Accounting Standards etc) have one of the most robust and well-defined framework to identify and determine “related parties”. Adani roup’s Indian entities follow and comply with these legislations at all times. Further, all related party transactions are at arm’s length, properly disclosed and reviewed/audited by statutory independent auditors, of relevant entities periodically. In a similar manner, overseas entities, follow the law of land, of their respective jurisdiction. The assumption that the entities, as stated in the Report, are related to Adani listed entities, is imaginary, vague and unsubstantiated and flows only from a lack of understanding by Hindenburg of the Indian laws, regulations and accounting standards. The Audit Committee of each of the listed companies that reviews and approves these related party transactions is composed of 100% of Independent Directors and chaired by Independent Director. The Statutory Auditors are appointed only upon recommendation by the Audit Committee to the Board of Directors. Adani Portfolio companies follow a stated policy of having global Big 6 or regional leaders as Statutory Auditors. Further Adani Portfolio also has a policy to conduct an independent review of disclosure and notes by one of the Big 6 across all portfolio companies and the last review carried out for FY 20 and FY 21 was undertaken by Grant Thornton. Indian regulations have high standards of corporate governance which we have consistently complied with. Hindenburg Research does not appear to have any understanding on matters of Indian law or accounting standards and yet makes claims of entities being undisclosed “related parties” with no understanding of what constitutes a related party. In several instances, the report makes unsubstantiated statements of “close relationships” and “conflicts of interest” as “related party”. Any mere close or business relationship of any promoter entity or their relatives does not make a transaction a related party transaction. 18/ (Allegation #35) We found at least 38 Mauritius-based entities associated with Vinod Adani and Subir Mittra (the head of the Adani private family office). We also found Vinod Adani associated entities in other tax haven jurisdictions like Cyprus, the UAE, Singapore, and various Caribbean islands. Several of these entities have transacted with Adani entities without disclosing the related party nature of the dealings, seemingly in violation of the law, as evidenced throughout our report. What is the explanation for this? 32
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