On February 21 and 22, 2017, SEBI forwarded to the Company two anonymous complaints dated February 12, 2017 and February 19, 2017 (“Anonymous Complaints”) making allegations relating to the Company. The details of the allegations made in the Anonymous Complaints were also reported by the press.
The Anonymous Complaints were placed before the Audit Committee. The Audit Committee approved a comprehensive investigation into the Anonymous Complaints for which Gibson Dunn & Crutcher, LLP, an international law firm recognized for its expertise in conducting internal investigations, and Control Risks, a global risk consultancy specializing in expert analysis and in-depth investigations, were retained to conduct the investigation (the “Independent Investigation”). Neither firm performs other work for the Company.
The Indian law firm, Khaitan & Company was appointed to provide legal counsel on Indian law matters associated with the Anonymous Complaint, Independent Investigation and related matters.
The auditors of the Company performed select procedures related to the independent investigation as part the audit for the year ended March 31, 2017.
Gibson Dunn and Control Risks have now completed their detailed and extensive Independent Investigation and as they have described in the attached document, they did not find any evidence whatsoever of wrongdoing.
The Company has also fully cooperated with all requests for information from SEBI regarding the Anonymous Complaints.
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