21/ (Allegation #40) A Vinod Adani-controlled Mauritius entity now called Krunal Trade & Investment lent INR 11.71 billion (U.S. ~$253 million) to a private Adani entity without disclosure of it being a related party loan. How does Adani explain this? 22/ (Allegation #42) A Vinod Adani-controlled Cyprus entity called Vakoder Investments has no signs of employees, no substantive online presence, and no clear operations. It had an investment of U.S. ~$85 million in an Adani private entity without disclosure that it was a related party. How does Adani explain this? 23/ (Allegation #43) What was the source of the Vakoder funds? 24/ (Allegation #46) We found that a “silver bar” merchant based at a residence with no website and no obvious signs of operations, run by a current and former Adani director, lent INR 15 billion (U.S. $202 million) to private Adani Infra with no disclosure of it being a related party transaction. What is the explanation for the lack of required disclosure? 25/ (Allegation #48) Gardenia Trade and Investments is a Mauritius-based entity with no website, no employees on LinkedIn, no social media presence, and no apparent web presence. One of its directors is Subir Mittra, the head of the Adani private family office. The entity lent INR 51.4 billion (U.S. $692.5 million) to private Adani Infra with no disclosure of it being a related party loan. What is the explanation for the lack of required disclosure? 26/ (Allegation #47) What was the purpose of the loan, and what was the original source of the “silver bar” merchant’s funds? 27/ (Allegation #49) What was the purpose of the loan, and what was the original source of the Gardenia Trade and Investments funds? 28/ (Allegation #50) Milestone Tradelinks, another claimed silver and gold merchant also run by a longstanding employee of the Adani Group and a former director of Adani companies, invested INR 7.5 billion (U.S. $101 million) into Adani Infra. Once again there was no disclosure of it being a related party loan. What is the explanation for the lack of required disclosure? 29/ (Allegation #51) What was the purpose of the loan, and what was the original source of the Milestone Tradelinks funds? Common Response - The above cited transactions with Krunal Trade & Investment, Vakoder, Rehvar Infrastructure, Milestone Tradelink, ardenia Trade and Investment and the ‘private Adani entities’ are not ‘related party transactions’ under laws of Indian or accounting standards. Consequently, we are neither aware nor required to be aware of their ‘source of funds’. All transactions cited above between the Adani listed entities and the “private Adani entities”, i.e., Adani Estates Private Limited, Sunbourne Developers Private Limited are related party transactions, which have been undertaken on arm’s length terms and in compliance with applicable Indian laws and standard, and have also been fully disclosed as related party transactions. 30/ (Allegation #41) A Vinod Adani-controlled UAE entity called Emerging Market Investment DMCC lists no employees on LinkedIn, has no substantive online presence, has announced no clients or 35