Adani response summary page 4
4. False suggestions based on malicious misrepresentation of the governance practices in
Adani portfolio : Allegation no. 34, 62, 63, 64, 65, 66, 67, 68, 69, 70, and 71 use selective
information to make insinuations, when in fact, the Adani portfolio has instituted various
corporate governance policies and committees including our Corporate Responsibility
Committee consisting solely of independent directors tasked with keeping the Board of
Directors informed about the ESG performance of businesses. Our ESG approach is based on
well-thought out goals, commitments and targets which are independently verified through
an assurance process.
An example of where the report exposes its motives is the question around “convoluted
structures” and multiplicity of subsidiaries, while failing to comprehend that in the
infrastructure business, especially in a sprawling geography like India, most large corporates
operate in a similar fashion because projects are housed in separate SPVs and these need to
be ring fenced from a lender perspective for limited recourse project finance and in many
cases on account of specific regulatory requirements. As an example, transmission projects
in India are awarded under tariff based competitive bidding, in such bidding the successful
bidder has to acquire the SPV which is undertaking the project. Hence, it is a regulatory
requirement as part of the Electricity Act, 2003 and the regulations of the Central Electricity
Regulatory Commission to execute projects in different SPVs
5. Manipulated narrative around unrelated third party entities: Allegation no. 5, 6, 7, 8, 10,
11, 12, 13, 14, 16, 17, 18, 20, 21, 22, 23, 26 and 52 from the report seek information on our
public shareholders. Shares of listed companies on Indian stock exchanges are traded on a
regular basis. The listed entity does not have control over who buys / sells / owns the publicly
traded shares in the company. A listed company does not have nor is it required to have
information on its public shareholders and investors.
Hindenburg deliberately ignores Indian legal processes and regulations in their insinuations
against us. For instance, they have raised several questions around the offer for sale
undertaken by Adani Green Energy Limited in 2019 while maliciously ignoring the fact that in
India the process for OFS is a regulated process implemented through an automated order
book matching process on the platform of the stock exchange. This is not a process which is
controlled by any entity and the purchasers are not visible to anyone of the platform.
6. Biased and unsubstantiated rhetoric: Allegation no. 84, 85, 86, 87, and 88 from the report
are inherently biased statements around our openness to address criticism with a windowdressing to garb them as questions. Criticism does not include the right to make false and
defamatory statement which could damage the interests of our stakeholders. We continue to
have the right to seek judicial remedy before Indian courts when such interests are
threatened, and in all cases, we have exercised these rights in due compliance with law and
the judicial process.
Hindenburg has sought to spotlight selective media reporting while deliberately ignoring
judicial findings. For instance, in another twisting of facts, Hindenburg questions why we
sought to have a “critical journalist” jailed. The fact of the matter is that he was never jailed
in connection with any proceedings related to us and in fact, a non-bailable warrant had been