TRACE, Inc. 151 West Street Annapolis, MD 21401

info@TRACEinternational.org +1 410.990.0076

TRACEcertification Due Diligence Report

Due Diligence Report

Contents Due Diligence Report

TRACEcertification Due Diligence Summary

Questionnaire

Literature

Registrations

Resumes/CVs

Financials

Business References

Reputational Screening

Training

Code of Conduct

TRACEcertificationDueDiligenceSummary

AgentName:

CertificationDate: Issuesarisinginthecourseoftheduediligencereview:

None

Previousbankruptcy,negativereference,orqualifiedauditor'sstatement

Unusualcorporatestructure

Apparentlackofqualificationsforindustryindicated

Requestspaymentoutsidetheterritory

Ownershipbygovernmententity

Ownershipbygovernmentofficial

Familymemberofkeypersonnelisagovernmentofficial

AnsweredyestoenforcementquestionsinSectionEorH

Disclosedintentiontoworkwithanunvettedthirdpartyintermediary

NegativeReputationalScreeningcoverage

Other

Questionnaire

The TRACE due diligence review of commercial agents is thorough. Thereview may nevertheless fail to uncover information which, if available,would have discouraged or prevented companies from entering into abusiness relationship with the agent. Companies requesting TRACE Reportsagree that in no event shall TRACE be liable for any damages incurred as a result of relying on TRACE Reports or as a result of anyomission ormisrepresentation by an agentreviewedbyTRACE.

SECTION A: Business information:

Specify Intermediary Type: Corporation

COMPANY'S FULL LEGAL NAME: SHAURYA AERONAUTICS PRIVATE LIMITED

Doing Business As Name or Trade/Marketing Name (if applicable):

None

STREET ADDRESS: T-15, 2ND FLOOR, GREEN PARK MAIN

CITY: NEW DELHI

STATE/PROVINCE: DELHI

POSTAL CODE: 110016

Specify Country: India

TELEPHONE: +91-1126527051

FACSIMILE: 011-26510376

WEBSITE ADDRESS(if you do not have a website, please indicate "none" in this field):

www.sapl.us

FULL LEGAL NAME FOR CONTACT PERSON: CAPT. NIDHI NARULA

E-MAIL ADDRESS OF CONTACT: carahulsangal@gmail.com

Specify Industry: Aviation

Specify Type of Services: Other

In which country/countries do you provide products/services?:

INDIA, UK

In what country/countries do you ask to be paid, and where do you make payments from (i.e. In which country/countries is the bank or financial institution that will host these financial transactions located)?:

INDIA

Please indicate the method(s) by which you prefer to receive payments (check all that apply):- Check- Wire Transfer- Other:

Wire Transfer

Questionnaire

Please provide a three (3) to five (5) sentence description of the types of products/services that you provide:

Sales (Fixed Wing & Rt Ring)Fbo and Aircraft MaintenanceRepair & Maintenance of Aircrafts and HelicoptersDomestic / International flight HandlingAir Charter ServiceFlight Operation/DispatchAircraft/Ramp HandlingLegal Advisory & Consultancy

If "Other" was provided as a response to any of the questions above, please clarify the meaning of "other" here:

We at Shaurya Aeronautics provide maintenance, repair and overhaul of aircrafts services, domestic and international flights handling, air charter services, flight/ramp handling and aviation related management consultancy services.

SECTION B: Business Registration Information:

1.) What is the date that your business was established?:

12/05/2000

2.) If the date that your company was established differs from the dates on any registration documents, please clarify here:

Agent confirmed that Shaurya has been registered with the government of India since 05/12/2000.

The tax registration was obtained four years after the companys establishment. Agent confirmed that according to the Taxation Laws of India, there is no requirement for a Tax registration until a company reaches a certain turnover amount. When Shaurya's company turnover increased, the company obtained the Tax Registration.

3.) Please provide a business tax identification number (for sole proprietors, please provide an individual tax identification number):

AAFCS3675P

4.) Do you have any mandatory business registrations, licenses and/or certifications?:

Yes

Questionnaire

If Yes, please list the name of the registration, the registration date, the expiration date, & the office, city and country where registered:

1. Number: AAFCS3675PName Of Registration : Service Tax RegistrationRegistration Date : 05/25/2004Expiration Date : Not ApplicableOffice, City, Country : Office Of The Deputy Commissioner Service Tax Division - Ii, Range -Xv, New Delhi, India

2. Number: 057980481213Name Of Registration : DVAT RegistrationRegistration Date : 01/09/2013Expiration Date : Not ApplicableOffice, City, Country : Department Of Trade & Taxes, New Delhi, India

3. Number: 0507079035Name Of Registration : Importer -Exporter Code Registration Date : 01/29/2008Expiration Date : Not ApplicableOffice, City, Country : Ministry Of Commerce, New Delhi, India

4. Number: U62200DL2000PTC108725Name of Registration: Certificate of Incorporation Registration Date: 12/05/2000Expiration Date: N/AOffice, City, Country: N/A, N/A, India

5.) Are you required by law to be registered with any other Government Agencies based on the type of services that you provide, or the industry that you primarily work in (i.e. if you engage in the promotion or distribution of military equipment, are there special registration requirements in your home territory or the territory in which you conduct the activity)?:

Yes

Questionnaire

If Yes, please list the name of the registration, the registration date, the expiration date, & the office, city and country where registered:

1. Number: SAPL/F-APP71182Name of Registration: The Director General of Civil Aviation Registration Date: 10/12/07Expiration Date: 12/31/2013 Office, City, Country: N/A, N/A, India.

2. Number: COM/931/1.3/2009/VOL-XL/1618Name of Registration: The Airport Authority of IndiaRegistration Date: 09/22/2010Expiration Date: N/AOffice, City, Country: Airport Authority of India, New Delhi, India.

3. Number: CAS-7 (23)/2010-Div-1 (Shaurya)Name of Registration: Bureau of Civil Aviation SecurityRegistration Date: 09/27/2010Expiration Date: N/AOffice, City, Country: Ministry of Civil Aviation, New Delhi, India

6.) Are you registered with any other organizations or associations?:

No

If Yes, please list the name of the registration, the registration date, the expiration date, & the office, city and country where registered:

Questionnaire

7.) Please add any additional or clarifying information here regarding your Business Registrations:

Agent confirmed that the date mentioned on the Service Tax Registration (10/18/2004) is the date that the Service Tax Department notified Shaurya of the registration. However, the registration applies from the date of Shaurya's application (05/25/2004.)

Agent confirmed that Shaurya' has an ongoing registration with the Department of Tourism. The registration was not provided to TRACE.

The registrations mention the following names:VK AroraLaxmi Narayan Ravi Krishna Agent confirmed that the above names are all Govt. Officials, who are authorized to issue Registration Certificates. These people are not the part of Shaurya Aeronautics Pvt. Ltd.

Agent confirmed that the original versions of these registrations are in English:

Service Tax RegistrationDVAT RegistrationImporter -Exporter CodeCertificate ofIncorporation

SECTION C: Associated Offices and Entities Information:

1.) Do you have any Subsidiary Organizations?: No

If Yes, please provide the name and address of the Subsidiary/Subsidiaries, and the FULL LEGAL NAMES of all owners and percentages of all ownership interests.:

Questionnaire

2.) Do you have any Joint Ventures?: No

If Yes, please provide the name and address of the Joint Venture(s), and the FULL LEGAL NAMES of all owners and percentages of all ownership interests:

3.) Do you have any Branch Offices?: Yes

If Yes, please provide the FULL LEGAL NAMES and address of the Branch Office(s):

SHAURYA AERONAUTICS PRIVATE LIMITED KOLKATAHanger No. 20,Room No. 4,NSCBI AirportKolkata-52West Bengal

SHAURYA AERONAUTICS PRIVATE LIMITED JAIPUR67/133, Sector-6,Pratap Nagar,Sanganer,Jaipur-302033Rajasthan

SHAURYA AERONAUTICS PRIVATE LIMITED DEHRADUNJolly Grant Airport,Airport Authority of IndiaDehradunUttarakhand

4.) Are you part of a Group of companies or affiliated companies?:

Yes

Questionnaire

If Yes, please provide the FULL LEGAL NAME and address of the Group, your relationship with the group, and whether the Group is a legal entity or marketing name:

Agent confirmed that the following companies are all managed by the same management and thus are considered to belong to the same group. Agent confirmed that the following companies share an address with Shaurya Aeronautics at T-15, 2nd Floor, Green Park Main, New Delhi-110016. The following are legal entities and not marketing names:

a) Pinnacle Oil And Gas Private Limitedb) Pinnacle Renewable Energy Private Limitedc) Pinnacle Real Infrastructure Private Limitedd) Pinnacle Total Security Services Private Limitede) Silverline Aviation Private Limit