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Page 1: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

TRACE, Inc. 151 West Street Annapolis, MD 21401

[email protected] +1 410.990.0076

TRACEcertification Due Diligence Report

Due Diligence Report

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Contents Due Diligence Report

TRACEcertification Due Diligence Summary

Questionnaire

Literature

Registrations

Resumes/CVs

Financials

Business References

Reputational Screening

Training

Code of Conduct

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TRACEcertification  Due Diligence Summary 

 

Agent Name:        

Certification Date:                                                                                  Issues arising in the course of the due diligence review:  

None  

Previous bankruptcy, negative reference, or qualified auditor's statement                                             

Unusual corporate structure                           

Apparent lack of qualifications for industry indicated                           

Requests payment outside the territory                          

  Ownership by government entity 

                          

Ownership by government official                           

Family member of key personnel is a government official                           

Answered “yes” to enforcement questions in Section E or H                           

Disclosed intention to work with an unvetted third party intermediary                          

  Negative Reputational Screening coverage  

                          

Other                               

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         Questionnaire   

The  TRACE  due  diligence  review  of  commercial  agents  is  thorough.  The review  may  nevertheless  fail  to  uncover  information  which,  if  available, would  have  discouraged  or  prevented  companies  from  entering  into  a business  relationship  with  the  agent.  Companies  requesting  TRACE  Reports agree  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  any omission  or misrepresentation  by  an  agent reviewed by TRACE. 

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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: [email protected]

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

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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 company’s 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

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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

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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

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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

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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

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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 Limitedd) Pinnacle Air Private Limited

There is no main company in the group.

Agent confirmed that this group is not referred to as Pinnacle Group.

5.) Will any of the individuals or entities listed above be involved in transactions for, or provide services to, your clients / vendors / suppliers?:

Yes

Questionnaire

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If Yes, please provide their FULL LEGAL NAMES and describe their involvement:

Agent confirmed that only Silverline Aviation Private Limited and Pinnacle Air Private Limited currently provide services to Shaurya Aeronautics customers.

Silverline Aviation Private Limited provides Flight Hiring & Flight Handling services.

Pinnacle Air Private Limited provides Consultancy, Flight Hiring, and Flying of Aircraft Services.

6.) EXTERNAL PERSONNEL: Will your company engage any third parties, intermediaries, or other persons or entities NOT previously mentioned to be involved in transactions for, or provide services to, your clients/vendors/suppliers?:

Yes

If Yes, please provide their FULL LEGAL NAMES and describe their involvement:

Global Supply Systems :

Global Supply Systems is a British all-cargo carrier who provides cargo services to Shaurya Aeronautics Private Limited’s customers.

SECTION D: Ownership Information:

1.) Is your company publicly traded? [If you answered "No", please provide ownership information in response to Question #2 below]:

No

If Yes, on which stock exchange is your company traded?:

Questionnaire

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PUBLICLY TRADED Ownership information:

If your company is traded on a stock exchange as indicated above, please list the FULL LEGAL NAMES, job titles, citizenships and ownership interest of all shareholders who have more than a 5% ownership interest in your company.

If any of the owners are entities, please email the ownership structure of that entity to [email protected] or describe in full detail below. One hundred percent of ownership should be attributed to individuals. Please provide a clear picture of each tier of your company's full ownership structure:

2.) PRIVATELY OWNED Ownership information:

If your company is privately owned please list the FULL LEGAL NAMES, job titles, citizenships and ownership percentage of all individuals who have an ownership interest in your company.

If any of the owners are entities, please email the ownership structure of that entity to [email protected] or describe it in full detail below. One hundred percent of ownership should be attributed to individuals. Please provide a clear picture of all of the tiers of your company's full ownership structure:

1. Full Legal Name : Nidhi Narula Job Title : Director Citizenship : Indian Ownership Percentage : 94% 2. Full Legal Name : Denzil Keelor Job Title : Director Citizenship : Indian Ownership Percentage : 6%

SECTION E: Board of Directors Information:

Does your business have a Board of Directors?: Yes

If Yes, please provide the FULL LEGAL NAMES of the members of the board, their titles and citizenships:

1. Full Legal Name : Nidhi Narula Title : Director Citizenship : Indian

2. Full Legal Name : Denzil Keelor Title : Director Citizenship : Indian

SECTION F: Personnel Information:

1.) What is your total number of personnel (including owners, managers and directors)?:

25

Questionnaire

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2.) Does your company have personnel (including owners and members of the board listed above)who are authorized to make binding decisions for your company and/or enter into contracts with clients?:

Yes

If Yes, please provide the FULL LEGAL NAMES of the employee(s), title and citizenship:

1. Full Legal Name: Nidhi Narula Title: Director Citizenship: Indian

2. Full legal Name: Bhavna Sheel Title: Executive Operations Citizenship: Indian

3.) Does your company have personnel (including owners and members of the board listed above) who market or sell any products/services to customers?:

Yes

If Yes, please provide the FULL LEGAL NAMES of the employee(s), title, and citizenship:

1. Full legal Name: Sandeep Saraf Title: Director- Operations Citizenship: Indian

2. Full legal Name: Purushottam Chabri Title: CEO Citizenship: Indian

3.Full legal Name: Pankaj Mishra Title: Logistics Manager Citizenship: Indian

4. Full legal Name: Bhavna Sheel Title: G.M. Operations Citizenship: Indian

5. Full legal Name: Amit Bhardwaj Title: Operations Manager Citizenship: Indian

Questionnaire

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4.) Does your company have personnel (including owners and members of the board listed above) who may interact with a government official?

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state subsidized:

Yes

If Yes, please provide:The FULL LEGAL NAMES of the employee(s), their title, and citizenship. :

1. Full legal Name: Sandeep Saraf Title: Director- Operations Citizenship: Indian

2. Purushottam Chabri Title: CEO Citizenship: Indian

3. Full legal Name: Amit Bhardwaj Title: Operations Manager Citizenship: Indian

4. Full legal Name: Bhavna Sheel Title: G.M. Operations Citizenship: Indian

5.) EXTERNAL PERSONNEL: Does any person, entity, government or government agency (not listed above) have any management right or financial interest in your business?

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state-subsidized:

No

If Yes, please provide:The FULL LEGAL NAMES of the individuals or entitiesCitizenship or country of that individual or entityDescribe the management right or financial interest:

SECTION G: Conflicts Information:

Questionnaire

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1.) Will your company market to a government or government agency, including the military?

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state-subsidized:

Yes

If Yes, identify the government agency: Airport Authority of India, Directorate of Civil Aviation, Rajasthan Government, Haryana Government, Government of Uttar Pradesh, Government of Madhya Pradesh, Hindustan Aeronautics Limited

2A.) Does your company have any service or other contracts directly with a government or a government-controlled entity?

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state-subsidized:

Yes

If Yes, please provide - the type of services/products to be performed, - the government agency for whom you are providing the services/products and - whether or not a conflict exists:

Annual Maintenance Contract For Beechcraft Aircraft-- Rajasthan state government of India - no conflict

Annual Maintenance Contract For Beechcraft Aircraft- Haryana state government of India , no conflict.

2B.) Does any individual listed in this questionnaire have any service or other contracts directly with a government or a government-controlled entity?

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state-subsidized:

No

Questionnaire

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If Yes, please provide - the FULL LEGAL NAME of the individual who holds the contract, - type of services/products to be performed, - the government agency for whom the individual is providing the services/products and - whether or not a conflict exists:

3.) Does any person listed in this questionnaire maintain additional directorships, ownership interests or employment outside of your business? :

Yes

If Yes, please provide - the FULL LEGAL NAME of the individual, - the type of external interest/employment, - the name of the external entity, and - a description of the responsibilities/duties of that interest :

Nidhi Narula A. Aviation India - DirectorPinnacle Air Pvt. Ltd- Director & OwnerShaurya Flight Sim Services Pvt. Ltd.- Director & OwnerUltrashine Aviaiton Pvt Ltd- Director & OwnerHelitek International Pvt Ltd- Director& OwnerA Aviation Technical Services Pvt Ltd- Director & OwnerFriendly Aviation Services Pvt Ltd- Director & OwnerRealog Aviation Services Pvt Ltd- Director & OwnerSaraf Seva Sadan- Director

Denzil Keelor Pinnacle Air Pvt. Ltd.-DirectorShaurya Flight Sim Services Pvt. Ltd-DirectorUltrashine Aviaiton Pvt Ltd-DirectorA Aviation Technical Services Pvt Ltd-DirectorRealog Aviation Services Pvt Ltd-DirectorSpecial Olympics Bharat- Chair Man

Sandeep SarafSilverline Aviation Pvt.Ltd- DirectorSamarth Aviation India Pvt. Ltd- DirectorShaurya Jb Mines Pvt. Ltd- DirectorHelijet Air Pvt Ltd - DirectorStar Universal Resources Infrastructure Ltd-

Questionnaire

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Director Emgee Airways Pvt Ltd- DirectorSas Jets India Pvt Ltd - DirectorSaraf Seva Sadan - DirectorOpen Unbound Trading And Consultants Pvt Ltd - DirectorOrange Air Pvt. Ltd- DirectorOis Aerospace Pvt Ltd- DirectorSilverline Avaition Pvt Ltd-Owner

Purushottam ChabriHimshikhar Aviation Services Pvt Ltd- Director & Owner

Dharminder Chawla Pinnacle Oil And Gas Pvt Ltd - DirectorPinnacle Renewable Energy Pvt. Ltd. - DirectorPinnacle Real Infrastructure Pvt. Ltd.- DirectorPinnacle Total Security Services Pvt Ltd- Director

Amit Bhardwaj Pinnacle Oil And Gas Pvt Ltd- DirectorPinnacle Renewable Energy Pvt. Ltd.- DirectorPinnacle Real Infrastructure Pvt. Ltd.- DirectorPinnacle Total Security Services Pvt Ltd- DirectorSilverline Aviation Pvt Ltd- Director

4.) Has any person listed in this questionnaire ever held or worked in a government position (non-military)?

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state-subsidized:

No

Questionnaire

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If Yes, please provide - the FULL LEGAL NAME of the individual - the position - start & end dates - whether they had or have procurement authority - name of the government office - the country in which they served - whether that country imposed any laws, rules, regulations or restrictions after government/military service:

5.) Has any person listed in this questionnaire ever been in the military, including compulsory military service?:

Yes

If Yes, please provide - the FULL LEGAL NAME of the individual - his/her rank- start & end dates - whether he/she had or has procurement authority - name of the military branch - the country of service- whether that country imposed any laws, rules, regulations or restrictions after military service- whether this military service compulsory:

Denzil KellorAir MarshalStart: 1953 End: 1991No procurement authorityIndian Air ForceIndiaNo restrictionsMilitary service was not compulsory

Purushottam ChabriFlying OfficerStart:1992 End: 2002No procurement authority Indian Air ForceIndia No restrictions

6.) Does any individual listed in this questionnaire currently hold any position with or have any duties for any political party or political campaign?:

No

If Yes, please provide- the FULL LEGAL NAME of the individual(s), - the position(s), - the duty/duties of that position(s) and - whether or not a conflict exists:

7.) Is any individual listed in this questionnaire a candidate for any political office?:

No

Questionnaire

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If Yes, please provide - the FULL LEGAL NAME of the individual(s), - the name of the political office, - the duties of that office, and - whether or not a conflict exists:

8.) Are any family members of any individual listed in this questionnaire (check all that apply):

- Employed or otherwise engaged in any capacity by any government entity, including the military- Employed by or have duties for any political party or political campaign- Candidates for political office

GOVERNMENT DEFINITION: Any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state-subsidized.:

None of the Above

If Yes, please provide the following information for ALL family members to which the question above applies:- FULL LEGAL NAME of the individual listed in this questionnaire who has a relative associated with the government or a political party - FULL LEGAL NAME of the relative - Relationship - Relative's Position - Whether the Relative has Procurement Authority - an explanation of what that Procurement Authority entails (if applicable) :

SECTION H: Compliance Information:

1.) Does your company currently have a written policy addressing bribery? :

Yes

Questionnaire

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2.) Has your company (or any person or entity listed in this questionnaire) ever been convicted of violating any rules or regulations governing the purchase or sale of goods or services to or by any government?:

No

3.) Has your company (or any person or entity listed in this questionnaire) ever been interviewed, deposed or subpoenaed in connection with any litigation or investigation involving any government regulations?:

No

4.) Has your company (or any person or entity listed in this questionnaire) ever been found guilty of violating any law governing donations, contributions, honoraria or any other form of remuneration to any government official?:

No

5.) Has your company (or any person or entity listed in this questionnaire) ever been interviewed, deposed or subpoenaed in connection with any litigation or investigation involving any law governing donations, contributions, honoraria or any other form of remuneration to any government official?:

No

6.) Has your company (or any person or entity listed in this questionnaire) ever been interviewed, subpoenaed or asked to testify before any legislative body concerning fraud or abuse with regard to any governmental procurements?:

No

7.) Has your company (or any person or entity listed in this questionnaire) ever been found guilty of any violations of securities or commodities trading laws?:

No

8.) Has your company (or any person or entity listed in this questionnaire) ever been interviewed, deposed or subpoenaed in connection with any litigation or investigation involving any violations of securities or commodities trading laws?:

No

9.) Has your company (or any person or entity listed in this questionnaire) ever been found guilty of any violation of any laws governing the regulation of antitrust practices?:

No

Questionnaire

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10.) Has your company (or any person or entity listed in this questionnaire) ever been the subject of or mentioned by name in any newspaper or magazine article in an adverse manner?:

No

11.) Has your company (or any person or entity listed in this questionnaire) ever been charged, interviewed or found guilty concerning income tax evasion?:

No

12.) Has your company (or any person or entity listed in this questionnaire) ever been convicted of a felony or other criminal act for any matter not listed above?:

No

13.) Excluding traffic charges, has any person listed in this questionnaire ever been arrested, charged, cited or held by law enforcement authorities regardless of whether the charge was dropped, dismissed or a verdict of not guilty was entered?:

No

14.) Has your company (or any corporation, partnership, or other entity in which your company owns more than a 5% interest) ever been debarred from competing for World Bank contracts?:

No

15.) Has your company (or any person or entity listed in this questionnaire) ever been debarred from competing for government contracts in any country?:

No

16.) Has your company (or any person or entity listed in this questionnaire) ever had a security clearance denied or revoked?:

No

17.) Has any person listed in this questionnaire ever been discharged from any Armed Forces with other than an honorable discharge?:

No

18.) Has your company (or any corporation, partnership or other entity in which the Candidate has more than a 5% interest) or has an owner, partner, officer, director or key employee been the subject of any voluntary or involuntary bankruptcy or other similar proceeding?:

No

Questionnaire

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19.) Is your company (or any person or entity listed in this questionnaire) named on any of the following lists (check all that apply):- The Specially Designated Nationals List- The Specially Designated Global Terrorists List- The Specially Designated Narcotics Traffickers List- The Specially Designated Narcotics Traffickers/Kingpins List- The U.S. Department of Treasury Office of Foreign Assets Control List of Foreign Terrorist Organization- The U.S. Department of Commerce Denied Parties List- The U.S. Department of State ODTC Debarred List:

None of the Above

If Yes, please provide the FULL LEGAL NAME of the individual(s) or entity(s) and the name of the list on which they named:

20.) If you answered YES to any of the above questions (except question #1), please provide an explanation :

SECTION I: Additional Information:

Please provide any additional information that will be useful and relevant for your file. You may also use this section to clarify your responses to any of the questions in the preceding sections.:

Website clarifications:

The Shaurya website states that the company was established in 1997. The questionnaire states it was established on 05/12/2000. Agent confirmed that the company was incorporated and registered with the Registrar of Companies on the 5th of December 2000. The company started work as a proprietorship in 1997 and converted the proprietorship to a company on 05/12/2000.

Agent confirmed that Shaurya conducts all their business in the name of Shaurya Aeronautics Private Limited. (This name was abbreviated on the website.)

The website mentioned that Shaurya Aeronautics Pvt. Ltd. provides services in

Questionnaire

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Nepal. Agent confirmed that Shaurya Aeronautics Pvt. Ltd. does not have any current operations in Nepal but are trying to establish themselves there in the near future.

Agent confirmed that Shaurya Aeronautics Pvt. Ltd. does not have current operations in Western Europe but are trying to establish themselves there in the near future. The website mentioned that Shaurya Aeronautics Pvt. Ltd. provides services in this region.

Agent confirmed that Monarch Airlines aircraft does not provide any services to Shaurya Aeronautics Pvt. Ltd. The website mentions that Shaurya Aeronautics works with Monarch Airlines.

The website states that Shaurya Aeronautics Pvt. Ltd has complete coordination with the Airport Authority of India, the DGCA and Indian Ministry of Defense. Agent confirmed that these organizations are prime government regulatory organizations for the aviation sector in India. Agent confirmed that the statement "by complete coordination" means that all of Shaurya's operations and activities are carried out as per the regulatory guidelines of these organizations . Shaurya takes proper care to ensure complete compliance of these organization's rules and regulations.

Consent form:

Agent confirmed that the consent form was signed by Capt. Nidhi. Narula.

Trade Compliance Questions:

Has your company (or any business concern controlled by your company or, to your knowledge, any of your owners,

Questionnaire

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employees, officers or directors) ever admitted guilt for, been convicted of or currently under investigation for Trade Control violations (such as violations of export controls, sanctions, and anti-boycott laws or regulations)? NO

b) Has your company (or any business concern controlled by your company, or, to your knowledge, any of your owners, employees, officers or directors) ever been placed on any restricted parties’ lists (For example: United Nations Consolidated List, European Commission Terrorism List, U.S. Department of Commerce Denied Persons List, Unverified List or Entity List; U.S. Treasury Department's Specially Designated Nationals List, etc.) NO

c) Does your company (or any business concern controlled by your company or, to your knowledge, any of your owners, employees, officers or directors) have any offices or other operations in Myanmar, Cuba, Iran, North Korea, the Republic of Sudan or Syria? NO

d) Has your company (including any business concern controlled by your company or, to your knowledge, any of your officers, directors, employees, or owners), ever donated, sold, exported, re-exported or otherwise transferred, purchased or imported, directly or indirectly through third countries or parties, equipment, products, funds or services to or from Myanmar, Cuba, Iran, North Korea, the Republic of Sudan or Syria or otherwise serviced (or requested services in relation to) products located in these countries without the requisite license in place? NO

Certification:

Questionnaire

Page 27: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

Electronic Certification:

I certify the following information:

- The information provided is, to the best of my knowledge and belief, accurate, current and complete.

- I am authorized to certify that the foregoing is true and correct.

(Click the box if you agree):

True

On the following date, I have certified all of the foregoing information::

12/24/2013

Name of the person who has completed and certified to the foregoing information contained in this questionnaire::

CAPT. NIDHI NARULA

Questionnaire

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Name confirmation document for SHAURYA AERONAUTICS PRIVATELIMITED

Please provide all responses using the Roman or Latin alphabet.

Name provided to TRACE on the application

Full Legal Name (as it appears on passport or government identification)

Commonly Used Name(s) in business

Variations/Spellings of the Legal Name

(if applies)

Given/First Name

Middle Name(s) Family/ Last Name(s)

Example: Andrew Sloan Andrew Joseph Sloan Andrew Sloan, Andrew J. Sloan NA

Example: Maria Smith Maria Anna Smith Anna Smith NA Example: Jose Lopez Garcia Jose Ricardo Lopez Garcia JoseLopez, JoseLopez-Garcia NA

Example: Mohammed Karim Hassani Mohammed Karim Mustafa Al-Hassani Karim Al-Hassani Muhammed Karim Al-Hassani Example: Michael Xiaoming Wang Xiao Ming Wang Michael Wang Wang Xiaoming

Capt. Nidhi Narula Nidhi Narula Capt. Nidhi Narula NA Denzil Keelor Denzil Keelor Air Marshal (Retd.) Denzil Keelor NA

Sandeep Saraf Sandeep Saraf Capt. Sandeep Saraf NA P.K. Chabri, Purushottam Chabri Purushottam Kumar Chabri Capt. P.K. Chabri NA

Pankaj Mishra Pankaj Mishra Pankaj Mishra NA Dharminder Chawla Dharminder Chawla Dharminder Chawla NA

Amit Bhardwaj Amit Bhardwaj Amit Bhardwaj NA Mrs. Bhavna, Bhavna Sheel

Bhavna Sheel Bhavna Sheel NA

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Literature

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Aviation India

http://www.aviationindia.com/[11/15/2013 10:22:46 AM]

+91 9911177575 / 9971666878 E-mail : [email protected]

Home About Us Services Careers Contact Us

Non Scheduled Permit Form Special Offer Testimonials

International flight operator

Cargo Services

Passenger Services

Flight Operation

Air Charter services

Freight Management

Aircraft and ramp handling

Advisory and Consultancy

Aircraft maintenance & repairs

International flight operator

Air Management

Helipad Engineering

About Us :The company established in year 1997 by a committed pool of professional delivering world class services and

solutions and lead by the Aviation Veteran Air Marsh. (Retd.) Denzil Keelor.

The Company holds a strong team of highly experienced Licensed Aircraft Maintenance Engineers, Simulator

Engineers, Materials managers, Logistic Managers, IT Managers, and Trainers, Commercial pilots . Advisors

and consultants to handle liaison activities with government agencies and authorities.

Our Team :

Chairman

Director

CEO

VP - Operations

Manager - Operations

Asstt. Manager -Operations

Chairman

Director

CEO

VP - Operations

Manager - Operations

Asstt. Manager -Operations

Home About Us Services Careers Contact Us

Copyright © 2011 Aviation India Powered by The Web Conz Technologies

Charter Services Flight Services Helipad Engineering Simulator Facility Air Management Maintenance

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Registrations

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Page 34: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report
Page 35: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report
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Page 37: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

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Page 38: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

D

OFFICE O

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31-12-2007 sdt( sh. V.K, Arora.D4!)10-10'2007

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31-12-2009sd/'

( sh. V.K Ator..oA!ryL-01,01-200s

sdl{ Sh. V.K. ArorarDAW)01-01-201 31-12-2010

sdl'{ Sh. Latrnl Narayan'Cllyf01-01-201 31-12-2011

sdi-{ sh. Ravt Kdslna.oAw)c 1 -01 -201 31-12-2012

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NCSS

Page 39: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

IISatlon Nallle:

)Jcrcf..r SAPL / F-A

RATING

Aircr.aft

.t

APPROVAL SCHEDULEhaurya Aeronautics (P) Ltd

t11a2NEW DELHI

1 .2,3&4) "Mltenahce of Super King Air 8200

LIMITATIgNta.lntena, "e of Cissn-a C'tat'o ';'O xrSAircraft lilted wrth PW 5458 engrne and its

wiih P&W PT6A-21 Engines'

(upto 800 ts'rc l 24 Months ie Phase

Aircraft

,.1|l

X

/,

BAS- LINE

A1

MaintenanceAircraft fitted

of Cessna Citation CJ2+with Vvilliams Rolls FJ44

rcraft

Rtted with P&w PT6A-135A Enginats

iUpto a rnotuoing 800 Hrsl Phase lVinsPectlqn)

fitted with P&W PTOA42 Engines.

Upto 800Hrs onths i.e. Phase 1 3&42

Enoines. iffivffinlt,ce ot Cessna Citation CJ2Aircraft

fitted with Williams Rolls FJ44-2C Engines

Uoto 1$0Hrs/check 1 engine lnspection

aircrait fltted with P&w canada PT6A-1144

en9lne.(Upto (! lncluding annual lrrspectron

schedule)

{l l2AircraflF,,(linesschedule

X

I l\4ai||te,' ., ol cessna Lll.iiL I

I fitteC '.; ri, '.'.'illiaois Rolls FJ44-"r

I (Upto 300Hrs/'l2 Monlh lnspectionIt_-

Page 40: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

Maintenxn,r i |i Ohetak SA316fl llr:rcoptcrfilted wrllr /',ri(,ustlc ll B/81 Enqin,l(Upto BLI(.)l ilril Yrs In9llqctroll :i l,,rlLr {))Maintenancc of tsell 206Blll Helirioptcf fitte.twith RR:/5rl rl20J I R4 Engine X

!p!9 120u Jrs In9p99!9!_99!9dL .

Nlaintenance of Bell407 Helicopter fltted withAllison /RR250-C478 Engine('1200 Hrs / 24 Months and 24 lvlonthslns on schedule.Maintenafice of Robinson R44fitted with lO-540 AE 1A5 Engine(Upto 100Hrs/ 12 MonthsScheduleMaintenance of AS350-83 helicopter fittedwith Turbomeca Arriel 281 engine & itsassociated system(Upto 100Hrs/12 N4onlhs inspectionSchedull\,taintenance of AS35GB3 helicopter flttedwith turbomeca Arriel 2D engine & its

Helicopter

Inspection

-rI

't

Aircraft

Components omer

than engineor APU

associated system(Upto 100Hrs/12 MonthsSchedulFunctional (esting of fuel manifolds &assy. installed on P&W PT6A-42fitted on Super King Air 8200 Aircraft.Funclional testing & Cleaning of fuet nozzte

nozzleEngine X

Engine (Primary & Secondary) assy With inletadapter bearing part no 3014704/31 06347-01 t301 1 1 52t301 47 05/31 06346-0 1 /301 1 1 54installed on P&W PTOA series.

X

KOLKATA

--- =r----

tMl LINE

Ma'ntenance of Beechjet 400A A ircraft-fitted w'ttr P&W JT15D-5 Engines

aircra.l rlried with P&W (,r.i[,i]ii pT6A

(Upto e lncluding 200 hrs/12 I roflh

Aircraft

Page 41: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

n

BEHALA, KOLKATA

BASE

. 6H6PAL

Mdinten4rce

and in the Ecope oi,fi&ttpproved maintenance dg€ifrs€tion exposition.

l';rUe l):] .,f 0-i

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DIRMTOR OF AIRTI4ORTH INESS 1'"IIPRTi{ERN REGOT{

1 X

Initial lssueRev.9Place

2-i 0-071-12-201P

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CLASSI:, 1

I r-ruridnnoru.l- -r --_---.,-. -- .--.rI lvlailtenance of Cessna 1524 Aircraft I

I tttfo 'al*rq,ooming

G235 N2C engine I

I (udto 1000 H6/5year Inspeclion IAircraft

Page 42: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report
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Resumes/CVs

Page 45: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

Name:

Title:

Email:

NIDHI NARULA

CAPT.

[email protected]

2. Basic Information:

1.) What is your full legal name?: NIDHI NARULA

2.) What is your citizenship(s):: INDIAN

3. Current Employment Information:

1.) What is the name of your the company that has asked you to complete this form?:

SHAURYA AERONAUTICS PRIVATE LIMITED

2.) Please select the type of position(s) you hold at this company::

Owner|Member of Board of Directors

3.) What is your title?: DIRECTOR

4.) What was your start date?: 05/12/2000

5.) What was your end date? (Indicate "none" if you are still employed with the company) :

NONE

6.) Are you involved in the day-to-day operations of this company? [If NO, you do not need to provide your 10 year work history; and you may proceed to External Affiliations and Government & Military Service Sections.]:

Yes

4. Work History:

Please explain any gaps (3 months or more) in employment or any overlapping employment::

If you are involved in the day to day operation of the company that has asked you to complete this form, please provide your work history for the past 10 years, including 1.) Name of Company 2.) Title 3.) Start Date 4.) End Date:

1.) SHAURYA AERONAUTICS PRIVATE LIMITED2.) Director/Owner3) 05/12/2004) Present

5. External Affiliations :

Employment History and Affiliations

Page 46: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

1.) Do you have any current external ownership interests?:

Yes

If Yes, please provide the name of the entity owned::

1. Pinnacle Air Private Limited2. Shaurya Flight Sim Private Limited3. Helitek International Private Limited4. Ultra Shine Aviation India Private Limited5. A Aviation Technical Services Private Limited6. Friendly Aviation Services Private Limited7. Realog Aviation India Private Limited

2.) Do you sit on the Board of Directors for any entity?:

Yes

If Yes, please provide the name of the entity/entities for which you are a member of the Board of Directors::

1. Shaurya Aeronautics Private Limited2. Pinnacle Air Private Limited3. Shaurya Flight Sim Private Limited4. Helitek International Private Limited5.. Ultra Shine Aviation India Private Limited6. A Aviation Technical Services Private Limited7. Friendly Aviation Services Private Limited8. Realog Aviation India Private Limited9. Saraf Seva Sadan

3.) Outside of your current employment, listed above, are you currently employed with any other entity?:

No

If Yes, please provide name of company/companies of additional employment and your position::

6. Government & Military Service:

1.) Do you have any current or past government service?

GOVERNMENT: any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state subsidized?:

No

If Yes, please provide: 1.) Name of Government Office 2.) Country 3.) Position/Title 4.) Start Date 5.) End Date :

2.) Do you have any current or past military service (including compulsory military service)?:

No

If Yes, please provide: 1.) Name of Military Branch 2.) Country 3.) Position/Rank 4.) Start Date 5.) End Date :

Employment History and Affiliations

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3.) Was your military service compulsory?: No

4.) Do you or did you have procurement authority?:

No

If you answered yes to any of the above government or military questions, please enter any additional clarifying information below::

Employment History and Affiliations

Page 48: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

Name:

Title:

Email:

DENZIL KELLOR

RETD. AIR MARSAL

[email protected]

2. Basic Information:

1.) What is your full legal name?: DENZIL KEELOR

2.) What is your citizenship(s):: INDIAN

3. Current Employment Information:

1.) What is the name of your the company that has asked you to complete this form?:

SHAURYA AERONAUTICS PRIVATE LIMITED

2.) Please select the type of position(s) you hold at this company::

Member of Board of Directors

3.) What is your title?: DIRECTOR

4.) What was your start date?: 12/05/2000

5.) What was your end date? (Indicate "none" if you are still employed with the company) :

NONE

6.) Are you involved in the day-to-day operations of this company? [If NO, you do not need to provide your 10 year work history; and you may proceed to External Affiliations and Government & Military Service Sections.]:

No

4. Work History:

Please explain any gaps (3 months or more) in employment or any overlapping employment::

If you are involved in the day to day operation of the company that has asked you to complete this form, please provide your work history for the past 10 years, including 1.) Name of Company 2.) Title 3.) Start Date 4.) End Date:

5. External Affiliations :

Employment History and Affiliations

Page 49: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

1.) Do you have any current external ownership interests?:

No

If Yes, please provide the name of the entity owned::

2.) Do you sit on the Board of Directors for any entity?:

Yes

If Yes, please provide the name of the entity/entities for which you are a member of the Board of Directors::

1. PINNACLE AIR PRIVATE LIMITED2. A AVIATION TECHNICAL SERVICES PRIVATE LIMITED3. SHAURYA FLIGHT SIM PRIVATE LIMITED4. ULTRA SHINE AVIATION INDIA PRIVATE LIMITED5. REALOG AVIATION INDIA PRIVATE LIMITED

3.) Outside of your current employment, listed above, are you currently employed with any other entity?:

Yes

If Yes, please provide name of company/companies of additional employment and your position::

CHAIRMAN- SPECIAL OLYMPICS BHARAT

6. Government & Military Service:

1.) Do you have any current or past government service?

GOVERNMENT: any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state subsidized?:

No

If Yes, please provide: 1.) Name of Government Office 2.) Country 3.) Position/Title 4.) Start Date 5.) End Date :

2.) Do you have any current or past military service (including compulsory military service)?:

Yes

If Yes, please provide: 1.) Name of Military Branch 2.) Country 3.) Position/Rank 4.) Start Date 5.) End Date :

1. INDIAN AIR FORCE2. INDIA3. AIR MARSHAL4. 19535. 1991

3.) Was your military service compulsory?: No

4.) Do you or did you have procurement authority?:

No

Employment History and Affiliations

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Employment History and Affiliations For Owners, Directors and Key Employees of Shaurya Aeronautics Pvt. Ltd

Full Legal Name: Citizenship: Are you involved in the day-to-day operation of Shaurya Aeronautics Pvt. Ltd?

SECTION I: Work History:

Work History for the previous 10 years:

Company Position Beginning Date Ending Date Shaurya Aeronautics Pvt. Ltd Executive Operations February 2009 Current

Explanation of gaps (3 months or more) in employment or any overlapping employment:

Agent confirmed that from 2003-2009 Bhavna Sheel was receiving an education.

SECTION II: External Affiliations:

Current outside Ownership positions: YES NO

Company

Current outside Director positions: YES NO

Company

Current outside Employment positions: YES NO

Company Position

Current or Past Government/Military Service: YES NO

Agency Country Position/Rank Start Date Termination Date

Compulsory Military Service?

If you have current or past government/military service:

• Does your country impose impose laws, rules, regulations or restrictions on individuals in your country after they leave public service, including the military?

• Do you have procurement authority? If yes to either of the above, please provide an explanation here.

BHAVNA SHEEL

Indian

Yes

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Employment History and Affiliations For Owners, Directors and Key Employees of Shaurya Aeronautics Pvt. Ltd

Full Legal Name: Citizenship: Are you involved in the day-to-day operation of Shaurya Aeronautics Pvt. Ltd?

SECTION I: Work History:

Work History for the previous 10 years:

Company Position Beginning Date Ending Date SHAURYA AERONAUTICS PVT. LTD Director-Operations December 2000 current

Explanation of gaps (3 months or more) in employment or any overlapping employment:

SECTION II: External Affiliations:

Current outside Ownership positions: YES NO

Company SILVERLINE AVIATION PVT. LTD.

Current outside Director positions: YES NO

Company SILVERLINE AVIATION PVT. LTD. SAMARTH AVIATION INDIA LIMITED SHAURYA JB MINES PRIVATE LIMITED HELIJET AIR PRIVATE LIMITED STAR UNIVERSAL RESOURCES INFRASTRUCTURE LIMITED EMGEE AIRWAYS PRIVATE LIMITED SAS JETS INDIA PRIVATE LIMITED SARAF SEVA SADAN OPEN UNBOUND TRADING AND CONSULTANTS PRIVATE LIMITED ORANGE AIR PRIVATE LIMITED OIS AEROSPACE PRIVATE LIMITED

Current outside Employment positions: YES NO

Company Position Beginning Date

SANDEEP SARAF

INDIAN

Yes

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Employment History and Affiliations For Owners, Directors and Key Employees of Shaurya Aeronautics Pvt. Ltd

Current or Past Government/Military Service: YES NO

Agency Country Position/Rank Start Date Termination Date

Compulsory Military Service?

If you have current or past government/military service:

• Does your country impose impose laws, rules, regulations or restrictions on individuals in your country after they leave public service, including the military?

• Do you have procurement authority? If yes to either of the above, please provide an explanation here.

Page 53: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

Employment History and Affiliations For Owners, Directors and Key Employees of Shaurya Aeronautics Pvt. Ltd

Full Legal Name: Citizenship: Are you involved in the day-to-day operation of Shaurya Aeronautics Pvt. Ltd?

SECTION I: Work History:

Work History for the previous 10 years:

Company Position Beginning Date Ending Date Indraprastha Gas LTD. Operator Septemeber 2002 November 2004 Prabhatam Aviation PVT. LTD. CEO November 2004 January 2012 Shaurya Aeronautics PVT.LTD. CEO January 2012 Current

Explanation of gaps (3 months or more) in employment or any overlapping employment:

SECTION II: External Affiliations:

Current outside Ownership positions: YES NO

Company Himshikhar Aviation Pvt. LTD

Current outside Director positions: YES NO

Company Himshikhar Aviation Pvt. LTD

Current outside Employment positions: YES NO

Company Position Beginning Date

Current or Past Government/Military Service: YES NO

Agency Country Position/Rank Start Date Termination Date

Compulsory Military Service?

Indian Air Force India Flying Officer 1992 2002

If you have current or past government/military service:

• Does your country impose impose laws, rules, regulations or restrictions on individuals in your country after they leave public service, including the military? No

• Do you have procurement authority? No If yes to either of the above, please provide an explanation here.

Purushottam Chabri

Indian

Yes

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Employment History and Affiliations For Owners, Directors and Key Employees of Shaurya Aeronautics Pvt. Ltd

Full Legal Name: Citizenship: Are you involved in the day-to-day operation of Shaurya Aeronautics Pvt. Ltd?

SECTION I: Work History:

Work History for the previous 10 years:

Company Position Beginning Date Ending Date Horizon Aircraft Maintenance Pvt. Ltd Store Officer August 2006 March 2012 Shauruya Aeronautics Pvt. Ltd Logistics Manager April 2012 current

Explanation of gaps (3 months or more) in employment or any overlapping employment:

Agent confirmed that before 2006 Pankaj Mishra was receiving an education.

SECTION II: External Affiliations:

Current outside Ownership positions: YES NO

Company

Current outside Director positions: YES NO

Company

Current outside Employment positions: YES NO

Company Position

Current or Past Government/Military Service: YES NO

Agency Country Position/Rank Start Date Termination Date

Compulsory Military Service?

If you have current or past government/military service:

• Does your country impose impose laws, rules, regulations or restrictions on individuals in your country after they leave public service, including the military?

• Do you have procurement authority? If yes to either of the above, please provide an explanation here.

Pankaj Mishra

Indian

Yes

Page 55: Due Diligence Report - Shaurya Aeronautics : Homeshaurya.org/TRACE_Certification_2014.pdf · TRACEcertification Due Diligence Report Due Diligence Report Contents Due Diligence Report

Name:

Title:

Email:

AMIT BHARDWAJ

MR.

[email protected]

2. Basic Information:

1.) What is your full legal name?: AMIT BHADWAJ

2.) What is your citizenship(s):: INDIAN

3. Current Employment Information:

1.) What is the name of your the company that has asked you to complete this form?:

SHAURYA AERONAUTICS PRIVATE LIMITED

2.) Please select the type of position(s) you hold at this company::

Employee - Leadership

3.) What is your title?: OPERATIONS MANAGER

4.) What was your start date?: 09/01/2007

5.) What was your end date? (Indicate "none" if you are still employed with the company) :

None

6.) Are you involved in the day-to-day operations of this company? [If NO, you do not need to provide your 10 year work history; and you may proceed to External Affiliations and Government & Military Service Sections.]:

Yes

4. Work History:

Please explain any gaps (3 months or more) in employment or any overlapping employment::

From 2003-2007 Amit Bhardwaj was receiving education.

If you are involved in the day to day operation of the company that has asked you to complete this form, please provide your work history for the past 10 years, including 1.) Name of Company 2.) Title 3.) Start Date 4.) End Date:

1) SHAURYA AERONAUTICS PRIVATE LIMITED2) OPERATIONS MANAGER3) 09/01/20074) PRESENT

5. External Affiliations :

Employment History and Affiliations

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1.) Do you have any current external ownership interests?:

Yes

If Yes, please provide the name of the entity owned::

1. Pinnacle Oil And Gas Private Limited.2. Pinnacle Real Infrastructure Private Limited3. Pinnacle Renewable Energy Private Limited4. Pinnacle Total Security Services Private Limited5. Silverline Aviation Private Limited

2.) Do you sit on the Board of Directors for any entity?:

Yes

If Yes, please provide the name of the entity/entities for which you are a member of the Board of Directors::

1. Pinnacle Oil And Gas Private Limited.2. Pinnacle Real Infrastructure Private Limited3. Pinnacle Renewable Energy Private Limited4. Pinnacle Total Security Services Private Limited5. Silverline Aviation Private Limited

3.) Outside of your current employment, listed above, are you currently employed with any other entity?:

No

If Yes, please provide name of company/companies of additional employment and your position::

6. Government & Military Service:

1.) Do you have any current or past government service?

GOVERNMENT: any government agency or office, political party organization, state-owned enterprise, public international organization, agency of a public international organization or schools, universities or hospitals that are state-owned or state subsidized?:

No

If Yes, please provide: 1.) Name of Government Office 2.) Country 3.) Position/Title 4.) Start Date 5.) End Date :

2.) Do you have any current or past military service (including compulsory military service)?:

No

If Yes, please provide: 1.) Name of Military Branch 2.) Country 3.) Position/Rank 4.) Start Date 5.) End Date :

3.) Was your military service compulsory?: Not applicable, I never served in the military

Employment History and Affiliations

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4.) Do you or did you have procurement authority?:

Not Applicable, I never served the government/military

If you answered yes to any of the above government or military questions, please enter any additional clarifying information below::

Employment History and Affiliations

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Financials

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Name:

Title:

Email:

AVIJIT SHRIVASTAVA

ICICI BANK LIMITED

[email protected]

2. Financial Reference Contact Information:

Your Full Legal Name:: AVIJIT SHRIVASTAVA

Name of Company/Institution/Bank:: ICICI BANK

Address:: S 26, 27, 28 Veera TowerNear Uphar CinemaGreen Park ExtensionNew Delhi 110016

Phone Number:: 011 46085800

Facsimile Number::

Email Address:: [email protected]

3. Financial Reference Questions:

How long has your firm had a business relationship with CANDIDATE?:

Seven years

Based on the information available to you, would you describe CANDIDATE as financially stable?:

Yes

Overall, how would you rate CANDIDATE'S business ethics and practices?:

EXCELLENT

TRACE welcomes additional comments on CANDIDATE::

4. Financial Reference Specific Questions:

Which of the following best describes you:: Bank

If you indicated that you are CANDIDATE's Accountant, please answer the following question: Based on the information available to you, would you agree that the books and records of CANDIDATE appear to be maintained in accordance with accepted accounting standards?:

Not Applicable, I am not an Accountant

Financial Statement

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If you indicated that you are CANDIDATE's Supplier, please answer the following question: Is CANDIDATE prompt in making payments?:

Not Applicable, I am not a supplier

6. FOR TRACE USE ONLY (Financial Reference Clarifications):

TRACEselect COMMENTS & CLARIFICATIONS (THIS SECTION IS FOR TRACEselect USE ONLY)::

Financial Statement

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Business References

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Anti-Bribery Compliance Solutions

Business Reference Contact Record for Shaurya Aeronautics Pvt. Ltd

Contact Name Company Phone Number Email Address Date

Received M.G. SINGH TATA STEEL LIMITED 9234511472 [email protected] 08/12/13 S.CHAKORBARTY

RP-SANJIV GOENKA GROUP 9874066006 [email protected] 08/12/13

ANIL THAKUR GVK 9930144192 [email protected]

m 08/12/13

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Reputational Screening

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Reputational Screening for

___________________________________________________________________

> Reputational Screening Search Parameters

> Reputational Screening Results Summaries

> Copies of Articles/Documents Pertaining to Results Summaries (if applicable)

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Reputational Screening Search Parameters 

Internet Based Search (Google) Entity name and name(s) of significant owners (single largest shareholder and others who hold 33% or greater ownership interest) are searched.  Entity names are searched as provided omitting any preface or ending (i.e. M/S, JSC, Inc).   Individual names are searched as confirmed in the Name Confirmation Document. Names are searched relative to the words: bribery, corruption, criminal, allegation, unethical.  TRACE reviews the first 20 results. Negative media is summarized and included in this report.   Denied Party/PEP Screening All entities and individuals that are found to be associated with the intermediary are searched.  Entity and individuals’ names are searched through a database of PEP (Politically Exposed Persons) lists and international  sanctions  and  enforcement  (Denied  Parties)  lists.    The  search  includes  Sanctions,  Law Enforcement, Regulatory Enforcement and Other Bodies lists. . TRACE reviews all results. Direct hits are summarized and included in this report.  Media Search (Westlaw) All entities and individuals that are found to be associated with the intermediary are searched.  Entity names are searched as provided omitting any preface or ending (i.e. M/S, JSC,  Inc).  Individual names are  searched  as  confirmed  in  the  Name  Confirmation  Document  including  variations  noted  in  the  file excluding confirmed misspellings.  Names are searched within 70 words of bribery, corruption, criminal, allegation, unethical and variations of those words  to allow  the broadest search possible.   The  initial search period covers 10 years.   The  renewal searches cover either a period  from  the  last search  to date or 10 years  if  the subject of  the search  is new.  Streamlined renewal searches include only names that have been added or removed from the report.  TRACE  reviews all  results.   However,  if we  receive excessive  results we will set  limiting parameters on  the search. Only negative media is summarized and included in this report. 

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Reputational Screening Results Summary

Shaurya Aeronautics Pvt. Ltd November 11, 2013

No adverse results were found.

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Training

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This is to certify that

has successfully completed the coursework

and the examination for the TRACE Anti-Bribery Course

and has thereby earned this certificate.

TRACE Anti-Bribery Course

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Code of Conduct

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15

OFFICES: 151 West Street Annapolis, MD 21401

419 Park Ave S. 2nd Floor New York, NY 10016

TEL: +1 410.990.0076 FAX: +1 410.990.0707

WEBSITE: www.TRACEinternational.org EMAIL: [email protected]

Unit 11P One Gateway Place Pioneer St. Cor. Robinsons Road Mandaluyong City, Metro Manila, Philippines 1552

TEL: +632 570.7189

703 B Wing, DSOA HQ Dubai Silicon Oasis Duabi, UAE

TEL: +971 56.657.2276