India Proxy Season 2012 Analysis - India's first proxy ... · PDF fileIndia Proxy Season 2012...

India Proxy Season 2012 Analysis

November 2012

InGovern Research ServicesShriram Subramanian

Founder and Managing Director

Contents

2

2012 AGMs –Proposals Analysis

Corporate Governance

Structure of Top 100 Companies

Key Developments for Investor

Protection in 2012

New Companies Bill – Key Provisions

About Us

2012 AGMs – Post Meeting Analysis

Contents

3





Protection in 2012


About Us


InGovern - Company Snapshot

First Proxy Advisory company in India

Fostering institutional shareholder activism in India

Featured on:

Advisory panel of corporate governance experts

Sale and distribution of InGovern vote recommendations

on ProxyEdge, Broadridge’s proprietary platform

4

About Us

InGovern - Vote Recommendations

5

Coverage for S&P CNX 500 and BSE 500: Universe of 588 cos. (over 95% of marcap)

Meeting Types: AGMs, EGMs, Postal Ballots, Court Convened Meetings

Vote recommendations done on the basis of detailed Policy Guidelines

Each resolution analysed with Reco to vote FOR, FOR* or AGAINST

FOR*: Shareholders advised to seek clarifications from the company

Don’t recommend ABSTAIN unless data insufficient or lack clarity to arrive at judgment

Recommendations sent to Company prior to meeting

About Us

InGovern - “Governance Radar” Policy

•Appointments, Compensation, Meetings, Remuneration, Responsibilities, Chairperson, Code of Conduct, Company Secretary, Independent Directors etc.

Board

•Audit, Nomination, Shareholders, Risk, Remuneration Committees

•Composition, Meetings, Powers, ResponsibilitiesBoard

Committees

•Code of Conduct, Remuneration Policies, Risk Management, Whistleblower Policies

Management & Operations

•Audit & Accounts, Auditor Independence, Ethical Standards for AuditAudit &

Accounts

•Related Party Transactions, Shareholders Meetings & Voting, Other RightsShareholders

Rights

•Audit & Accounts, Board (Appointments, Composition, Remuneration, Meetings), Board Committees, Independent Directors, Management & Operations, Ownership, Shareholder Meetings, Whistle Blower Policies, etc

Disclosures

6

Approximately 400 criteria evolved

About Us

Contents

7





Protection in 2012

About Us



Month-wise Breakup of Resolutions

8

2012 AGMs

Nifty 11 0 24 0 7 61 95 92 182 9 0 0

Junior Nifty 0 0 6 20 0 33 143 104 78 0 0 0

Other S&P 500 13 19 31 150 60 154 640 704 1050 41 9 0

Other BSE 500 0 14 6 21 37 19 80 97 261 0 0 0

Total 24 33 67 191 104 267 958 997 1571 50 9 0

0

250

500

750

1,000

1,250

1,500

1,750

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Nu

mb

er o

f Res

olu

tio

ns

Index Wise Monthly Resolutions

89%

11%

Management Shareholder

87%

13%

Ordinary Special

Number of Resolutions Tabled

9

4,271 Resolutions Proposed in 2012 AGMs

2012 AGMs

Type of Resolution Resolutions Proposed By

Shareholder Resolutions

460 resolutions proposed; most were friendly resolutions

458 resolutions were for Appointment of Directors

2 resolutions were for Appointment of Auditors

10

2012 AGMs

Shareholder Proposals By Index Shareholder Proposals by Type

23%

9%

58%

10%

Nifty

Junior Nifty

Other S&P 500

Other BSE 50099.6%

0.4%

Appointment of Directors

Appointment of Auditors

Shareholder Resolutions – Few Examples

11

2012 AGMs

Company Resolutions Proposed

HCC Appointment of Dr. Ila Patnaik as a Director

Kansai Nerolac Paints Appointment of Mr. H. Nishibayashi as a Director

IDFC Appointment of Mr. S. S. Kohli as a Director

HDFC Appointment of Dr. J. J. Irani as a Director

Exide Industries Appointment of Auditors and fixing of remuneration

Torrent Power Appointment of Shri D. J. Pandian as a Director

Finolex Industries Appointment of Mr. Sanjay Asher as a Director

GMR Infrastructure Appointment of Mr. N. C. Sarabeswaran as a Director

D B Realty Appointment of Mr. Shahid Balwa as a Director

United Spirits Appointment of Mr. Ghyanendra Nath Bajpai as a Director

Slate Resolutions

26 slate resolutions proposed in 2012

InGovern recommends voting AGAINST slate resolutions

For Appointment of Directors InGovern recommends one resolution per Director

12

2012 AGMs

Slate Resolutions By Index Slate Resolutions by Type

19%

4%

8%69%

Nifty

Junior Nifty

Other S&P 500

Other BSE 500

65%

8%

12%

12%4%

Director Appointments

Dividend Declaration

ESOP Schemes

Appointment of Auditors

Other Slate Resolutions

Slate Resolutions – Few Examples

13

2012 AGMs

Company Type of Resolution Proposed

Hindustan Unilever

Re-appointment of Directors: (a) Mr. Harish Manwani, (b) Mr. Sridhar Ramamurthy, (c) Mr. A. Narayan, (d) Mr. S. Ramadorai, (e) Dr. R. A. Mashelkar, (f) Mr. Pradeep Banerjee

MTNLRe-appointment of Director: (a) Dr. Rajan Saxena, (b) Shri Kumar Sanjay Bariar

NMDC

Re-appointment of Directors: (i) Shri N.K. Nanda, (ii) Shri S. Thiagarajan, (iii) Shri S. Bose, (iv) Lt. Gen. (Retd.) Arvind Mahajan, (v) Shri R.N. Aga, (vi) Smt. Parminder Hira Mathur, (vii) Shri D. Rath

BoschRe-appointment of Directors: (i) Mrs. Renu S. Karnad, (ii) Mr. Prasad Chandran and (iii) Mr. V. K. Viswanathan

Bata India Re-appointment of Directors: (a) Mr. J. Carbajal, (b) Mr. J. Clemons

UnitechAppointment of (a) Statutory Auditors, (b) Branch Auditors and fixing of remuneration

Note: Although InGovern recommends AGAINST slate resolutions, separate recommendations are also given to shareholders for each of the sub agenda proposed under these slate resolutions.

Non-Routine Resolutions

14

2012 AGMs

Type of Resolutions Proposed# of Resolutions

Proposed

Authorization of CMD to set and revise Executive Directors’ remuneration 1

Continuation of Whole-time Directors in spite of attaining Retirement Age 1

Re-utilization of IPO issue proceeds 3

Change of status of directors not liable to retire by rotation 3

Approval to make donations and contributions to charitable funds 5

Alteration in Articles of Association to provide for share buybacks for PSUs 8

Waiver of excess remuneration to whole-time directors 10

Non-Routine Resolutions – Few Examples

15

2012 AGMs

Company Resolutions Proposed

Standard Chartered Authority to make donations to political parties and incur political expenditure

Coal India Alteration in Articles of Association to provide for share buybacks

Adani Enterprises Approval to contribute to charitable funds

Ranbaxy LaboratoriesPayment of remuneration of Rs. 54.78 million made to CEO & MD and waiver

of excess remuneration

Adani PowerWaiver of recovery of excess remuneration paid to Mr. Ravi Sharma Whole-

Time Director

Mahindra Holidays &

ResortsModify or extend the period of utilization of the IPO proceeds

Godrej Properties Amend the schedule of deployment and utilization of the IPO proceeds

Jindal Steel & Power Authorization of CMD to set and revise Executive Directors’ remuneration

Bajaj Finance Change of status of Rahul Bajaj as a director not liable to retire by rotation

PSLContinuation of Mr. R. K. Bahri as whole-time director in spite of his attaining

the age of 70 years

16

2012 AGMs

Other Resolutions on Major Corporate Actions

Type of Resolution Proposed

# of

Resolutions

Proposed

Few Examples of Companies

that Proposed the Resolution

Alteration to MoA/ AoA 87

Coal India, SAIL, NTPC, NMDC, Escorts, IDFC, Eicher,

Mastek, Wipro, Gammon Infra, MRPL, Aventis Pharma,Essar Ports

Issue of Securities 70

Ashok Leyland, Jindal Stainless, Jet Airways, Cox & Kings,

Gulf Oil Corp., Essar Ports, Jain Irrigation Systems, ReliancePower, Adani Enterprises, GTL Infrastructure, Yes Bank

Grant of ESOPs/ Modification

to existing ESOP schemes46

ICICI Bank, Hindustan Unilever, OnMobile Global, India

Infoline, Fortis Healthcare, Zensar Technologies, EssarPorts, Godrej Industries, Dr. Reddy's Laboratories

Increase in borrowing limits 25

Indiabulls Financial Services, Kotak Mahindra Bank, BASF

India, Power Grid Corporation, REC, United Breweries, Cox& Kings,

Creation of mortgage/charges

on assets of the Company31

Shriram Transport Finance, HEG, Kesoram Industries,

IL&FS Transportation Networks, Ashok Leyland, REC,Power Grid Corporation, Hindalco Industries, Jain

Irrigation Systems, India Cements

Other Resolutions on Major Corporate Actions

17

2012 AGMs

Type of Resolution Proposed

# of

Resolutions

Proposed

Few Examples of Companies

that Proposed the Resolution

Increase / Sub-division of

Authorized Share Capital13

Religare Enterprises, Reliance Communications, Amara

Raja Batteries, Oberoi Realty, GTL Infrastructure, MagmaFincorp, India Glycols,

Change in place of keeping

Company Records9

Sterlite Industries, Agro Tech Foods, Gulf Oil Corporation,

Wyeth, NCC, Educomp Solutions, Taj GVK Hotels &Resorts

Intercorporate investments/

Providing guarantees8

Bajaj Finserv, Jet Airways, JBF Industries, Zuari Global

Limited

Increase in the FII holding

limits5

Gujarat Pipavav Port, HDFC, Kotak Mahindra Bank, AIA

Engineering, ENIL

Issue of bonus shares 1 Motherson Sumi Systems

Delisting of Securities 1 Mahanagar Telephone Nigam Limited

Contents

18





Protection in 2012

About Us



Board Size

19

InGovern recommends: 7 to 16 Directors

CG Structure of Top 100 Companies

“10% of companies have board sizes of either more than 16 directors or less than 7 directors”

0

15

30

45

60

75

Less than 10 Directors

Between 10 and 15 Directors

More than 15 Directors

Company Directors

Jaiprakash Associates 20

Larsen & Toubro 17

NTPC 17

Bharat Electronics 17

Sesa Goa 6

IDBI Bank 6

Reliance Capital 6

Zee Entertainment Enterprises 6

Reliance Communications 5

Reliance Power 5

Classification by Board Size

Average Board Size: 11

Board Composition

20

* IDs: 1/3 if Chairman is independent; 1/2 otherwise


“9% of companies were non compliant with Clause 49; with <50% IDs and no Independent Chairman”

Company % of IDs

Power Grid Corporation of India 25%

Container Corporation of India 30%

Hindustan Petroleum Corporation 33%

Adani Enterprises 40%

Bharat Petroleum Corporation 40%

Bharat Heavy Electricals 43%

Union Bank of India 45%

Tata Power Company 46%

NTPC 47%

The percentage of IDs on Top 100 Indiancompanies is approximately 54%

9 companies did not have an IndependentChairman and had more than 50% IDs andhence were not Clause 49 compliant

Ambuja Cements, HDFC Bank, Infosys,Kotak Mahindra, Siemens and FederalBank had the ideal board compositionfrom a corporate governance perspectivewith more than 50% IndependentDirectors and an Independent Chairman

Sesa Goa: No chairman as of Mar 31, 2012

Contribution at Board Meetings

21


Company Director RoleBoard Meeting

Attendance*

Bajaj Auto Mr. J. N. Godrej ID 0%

Jaiprakash Associates Mr. Pankaj Gaur MD 0%

Hero MotoCorp Mr. Analjit Singh ID 0%

IDFC Mr. Bimal Julka NED 0%

United Phosphorus Mr. K. Banerjee ED 0%

Hindalco Mr. Ram Charan ID 14%

Maruti Suzuki Ms. Pallavi Shroff ID 17%

Hero MotoCorp Dr. Anand Burman ID 20%

Jaiprakash Associates Mr. Ranvijay Singh ED 20%

ITC Mr. Dinesh Mehrotra ID 29%

Cipla Mr. VC Kotwal ID 33%

“One in Five Directors attend less than 75% of Board Meetings”

*Note: Attendance is calculated only for Board Meetings held in FY 2012 for the respective companies, however InGovern recommends shareholders to also take into consideration the attendance for AGM and committee meetings prior to their voting.

List Not Exhaustive

22


List Not Exhaustive

Independent Directors – Outside Directorships

InGovern recommends AGAINST IDs with > 10 Public Directorships and/or >20 Private Directorships

“9% of Independent Directors have outside directorships in more than 10 public companies”

Company Independent Director# of Outside

Directorships

Siemens Mr. Deepak S. Parekh 16

Biocon Mr. Suresh N. Talwar 15

Asian Paints Mr. S. Ramadorai 14

Colgate Palmolive India Mr. R. A. Shah 14

HDFC Mr. B. S. Mehta 14

Hindalco Mr. C. M. Maniar 14

Ambuja Cements Mr. Nasser Munjee 13

Ambuja Cements Mr. Shailesh Haribhakti 13

ITC Mr. Sunil Behari Mathur 13

23


List Not Exhaustive

Independent Directors – Tenure

InGovern recommends AGAINST IDs > 9 years on Board

“22% of IDs have served on the Board for more than 9 years”

Company Independent Director Tenure of IDs (years)

Cummins India Mr. B. H. Reporter 50

Exide Industries Mr. Bhaskar Mitter 46

BASF India Mr. R. A. Shah 44

Zuari Industries Mr. D. B. Engineer 42

HDFC Mr. Keshub Mahindra 35

Colgate Palmolive India Mr. J. K. Setna 34

Tata Steel Mr. Nusli N. Wadia 33

Hindalco Industries Mr. C. M. Maniar 30

Cipla Dr. H.R. Manchanda 29

Ambuja Cements Mr. M. L. Bhakta 27

Titan Industries Mr. T. K. Balaji 26

Audit and Remuneration Committee

24


InGovern recommends AGAINST Adoption of Accounts when Chairman of Audit Committee is not Independent

“Only 45 companies had Audit Committees

comprising only of IDs”

“13 companies have not constituted a Remuneration

Committee”

The average number of audit committeemembers was approximately four.

Only 45 companies had Audit Committeescomprising only of IDs

Companies such as Coal India, Cipla, DLF,Adani Enterprises, Lupin, HPCL, BharatElectronics, Cummins India, etc. haveexecutive directors as part of their Auditcommittee, which is not a good corporategovernance practice.

Clause 49 (Annexure 1D) of the ListingAgreement has a non mandatory requirementfor setting up of a remuneration committeecomprising of at least three directors, all ofwhom should be non-executive directors, theChairman of committee being an independentdirector.

However, as a corporate governance bestpractice, it is recommended that theremuneration committee be comprised only ofindependent directors

25


List Not Exhaustive

Tenure of Audit Firm and Audit Partner

InGovern recommends AGAINST re-appointment of Audit Firm if tenure of Audit Firm >5 years and Audit Partner >3 years

“53 companies have had the same Auditors for >5 years”

Company Auditor Tenure Partner Tenure

Reliance Industries Chaturvedi & Shah 35 D. Chaturvedi 35

Aditya Birla Nuvo Khimji Kunverji & Co >16 Shivji K. Vikamsey 13

Hindalco Industries Singhi & Co 16 Mr. Rajiv Singhi 13

Ashok Leyland M.S. Krishnaswami & Rajan 16 M. K. Rajan 11

Crompton Greaves Sharp & Tannan >16 L Vaidyanathan >9

Sterlite Industries Chaturvedi & Shah 16 R. Koria 6

Tata Power Co. Deloitte Haskins & Sells 16 N. Venkatram 4

DLF Walker, Chandiok & Co 14 David Jones 5

Bajaj Auto Dalal & Shah 13 Mr. Anish P. Amin 12

Remuneration of Auditors

26


InGovern recommends AGAINST re-appointment of Audit Firm if Other Fees* as percentage of Total Fees is very high

List Not Exhaustive

Company AuditorOther Fees as

% of Total Fees

Sterlite Industries Chaturvedi & Shah; Deloitte Haskins & Sells 67%

Ultratech Cement Deloitte Haskins & Sells; G. P. Kapadia & Co 55%

Larsen & Toubro Sharp & Tannan 52%

Sesa Goa Deloitte Haskins & Sells 48%

Tata Consultancy Services Deloitte Haskins & Sells 44%

IDFC Deloitte Haskins & Sells 41%

Mahindra & Mahindra Deloitte Haskins & Sells 40%

Other Observations from CG Perspective

Nominee Directors of Financial Institutions as IDs

Chairman and CEO same

No Chairman

Equal commission to all NEDs

Related Party Transactions

Accounts of Subsidiary/ JV/ Associates consolidated without being audited

Details of components of Audit Fees not disclosed in schedules

No performance criteria or role of Directors mentioned in letter of appointment

No limit on perquisites paid to Directors

Relatives of Promoters appointed as ID (E.g. Shapoor Mistry in Indian Hotels)

27


Contents

28





Protection in 2012

About Us



Current Voting Practices in India

29

Voting by show of hands. Proxies cannot vote by show of hands. But Proxy can demand a Poll.

Poll allowed if member demands it: (a) 1/10th of total voting power, or

(b) Rs.50,000 of shares

Proxy not allowed to speak in meeting

Member’s resolution: (a) 1/10th of total voting power , or

(b) 100 members and holding paid-up capital of Rs.1,00,000 or more

Notice should be released 21 days prior to meeting date

Post Meeting Analysis


30


72% of the resolutions proposed in the proxy season were passedunanimously with the remaining passed with requisite majority

Most of the resolutions proposed were passed through show of handswith only two of the resolutions put for voting by poll

In many AGMs, shareholders didn’t ask queries on any resolution

Company Resolution Proposed

Jindal Steel & PowerAppointment of Shri Manohar Lal Gupta as Wholetime Director and

fixing of remuneration

Jindal Steel & Power Revision in the remuneration of Wholetime Directors

Voting by Poll

Withdrawal of Resolutions

31


Company Resolutions Withdrawn/Amended

Sterlite Industries (India) Change in place of keeping the registers and records

Dabur India Re-appointment of Director: Mr. Analjit Singh

IFCI Re-appointment of Director: Mr. Prakash P. Mallya

Titan Industries Re-appointment of Director: Mr. R. Poornalingam

Reliance Infrastructure Appointment of Shri C P Jain as a Director

Oil & Natural Gas Corporation Appointment of Mr. Bimal Julka as a Director

Six resolutions were withdrawn/ amended by companies at their annual shareholder meetings

Contents

32





Protection in 2012

About Us



33


New Companies Bill

Key Provisions Details

Concept of independent

directors introduced

The concept of Independent Director (ID) has been introduced for the first time requiring all listedcompanies and such other public companies as may be prescribed by the Government to appoint IDs.The provisions require companies to at least have 1/3rd of the Board to comprise of IDs. The IDs shall

hold office upto two consecutive terms, each term of upto 5 consecutive years and will be eligible forappointment after cooling period of 3 years. Nominee directors appointed by any institution orGovernment to represent its shareholding shall not be deemed as an ID. IDs will not get stock optionsbut may get payment of fee and commissions subject to limits specified in the Bill/Rules.

Code for Independent Directors

IDs shall abide by a code provided in Schedule IV to the Bill, which lists down guidelines for

important aspects like professional conduct, role and functions, duties, manner of appointment andreappointment, resignation or removal, separate meeting, evaluation mechanism. Important points tobe noted include, appointment of IDs to be independent of management, reappointment to be basedon performance evaluation, holding of at-least one meeting a year without the attendance of non IDs,

performance appraisal to be done by entire board (except the ID being evaluated), etc.

Audit Committee

The Audit committee shall consist of a minimum of three directors with IDs forming a majority,provided that majority of members including its chairperson shall be persons with ability to read andunderstand the financial statements.

Remuneration and Nomination

Committee

Besides the Audit Committee, the constitution of Nomination and Remuneration Committee has alsobeen made mandatory in the case of listed companies and such other class or description of companiesas may be prescribed. The Nomination and Remuneration Committee shall consist of three or morenon-executive director(s) out of which not less than one half shall be IDs.

Stakeholders relationship

committee

Where the combined membership of the shareholders, debenture holders, deposit holders and othersecurity holders is >1,000 at any time during the financial year, the company shall constitute a

Stakeholders’ Relationship Committee. The Chairman of the Committee shall be a non-ED.

34


New Companies Bill

Key Provisions Details

Rotation of Auditors

No listed company shall appoint or re-appoint (a) an individual as auditor for more than one term of 5

consecutive years; and (b) an audit firm as auditor for more than 2 terms of 5 consecutive years. Both,audit firms and individual auditors, shall not be eligible for re-appointment in the same company for 5years from the completion of their term. Further, as on the date of appointment no audit firm havingcommon partners to the other audit firm, whose tenure has expired in a company immediately

preceding the financial year, shall be appointed as auditor of the same company for a period of 5 years.

Exit option to share holders in

case of dissent to change in

object of public issue proceeds

Listed companies which has raised money from public through prospectus and still has any unutilizedamount out of the money so raised shall not change its objects for which it raised the money through

prospectus unless a special resolution is passed by the company. The dissenting shareholders shall begiven an opportunity to exit by the promoters and shareholders having control in accordance withregulations to be specified by SEBI.

Exit option to share holders in

case of Amalgamations

The NCLT Tribunal is being empowered to provide for exit offer to dissenting shareholders in case ofcompromises, arrangements and amalgamations.

Provision for Class Action Suit

Provisions for Class Action Suit have been included with revisions providing for minimum number ofpersons who may apply for such suits. Further, safeguards against misuse of these provisions have alsobeing included.

Constitution of Serious Fraud

Investigation Office (SFIO)

Central Government shall constitute a Serious Fraud Investigation Office (SFIO). It shall also appoint aDirector in the SFIO not below the rank of Joint Secretary and may also appoint such experts and other

officers as it considers necessary for efficient discharge of functions.

Right to Vote by Electronic

Means

The clause provides for members in the prescribed class of companies to exercise the right to vote byelectronic means.

Contents

35





Protection in 2012

About Us



36

Key Developments for Investors

Key Developments

Key Regulatory Developments in 2012

June 2012: E-voting made compulsoryby SEBI for Postal Ballots for top 500Indian companies

August 2012: Listed companies barredby SEBI from buying shares fromsecondary market through ESOP Trusts/ Employee Welfare Trusts

October 2012: Reforms introduced bySEBI in the IPO market viz. role ofmerchant banker, maximum limit of 25%of IPO proceeds towards generalcorporate purposes, etc

SEBI has decided to form a QualifiedAudit Report Review Committee whichwill scrutinize audit reports of listedcompanies with qualifications foraccounting irregularities

SEBI has proposed to introduce amandatory safety net mechanism forretail shareholders in IPOs in case of dropin share prices by more than 20% in firstthree months of listing of a company

Key Regulations Under Consideration

37

Key Developments for Investors

Key Developments

Shareholder Activism in 2012

February 2012: 23.15% of votes were againstthe merger of 3 Promoter controlled unlistedentities with Akzo Nobel India.

June 2012: >20% shareholders of Sesa Goavoted against the merger of Sesa Goa, Sterlite&other unlisted entities of the Vedanta Group.

June 2012: 60.36% of the non-institutionalshareholders voted against Satyam Computersand Mahindra Satyam merger.

August 2012: Certain shareholders havingaggregate voting rights of >5% in Halonixcomplained to SEBI/ED over its violations ofFEMA and misleading public shareholders

August 2012: UK hedge fund TCI filed a caseagainst Coal India’s Board for its rollback ofprice increase under government’s directives

Jindal Steel & Power: After concerns regardingabsence of certain committees arose, the Boardof the Company voluntarily made somechanges which included change in MD - fromPromoter to a Professional, and setting up aRemuneration & Nomination Committee.

ONGC: The Board of ONGC decided toevaluate performance of its IndependentDirectors

OnMobile Global: Parted ways with itserstwhile Chairman Arvind Rao over certaincorporate governance concerns

Voluntary CG Changes By Indian Cos.

Conclusions

Engagement on Corporate Governance between Institutional Shareholders and Companies is very poor

Routine CG matters are still ignored by companies

Tail Risk remains as CG role of Independent Directors and Investor Engagement isn’t taken seriously

Greater need exist for greater Institutional engagement and activism

38

Q&ATo ask questions, please raise your hand or chat

the question

You can also mail us at [email protected]

mailto:[email protected]

Thank YouShriram Subramanian

Founder and Managing Director

InGovern Research Services Pvt. Ltd.

[email protected]

Mobile: +91-9844244411

ConfidentialityThis document is confidential and may not be reproduced in any manner without the written permission of InGovern

Research Services Pvt. Ltd. (“InGovern”). It has been sent for limited circulation and should not be forwarded or shared.

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