MIRA INFORM REPORT

Report Date :

13.02.2013

IDENTIFICATION DETAILS

Name :	VENKATESWARA WIRES PRIVATE LIMITED
Registered Office :	302 Navjeevan Chamber, Vinoba Marg, RG C-Scheme, Jaipur – 302001, Rajasthan
Country :	India
Financials (as on) :	31.03.2012
Date of Incorporation :	16.05.1988
Com. Reg. No.:	17-004446
Capital Investment / Paid-up Capital :	Rs.5.758 Millions
CIN No.: [Company Identification No.]	U31300RJ1988PTC004446
TAN No.: [Tax Deduction & Collection Account No.]	JPRV02011C
PAN No.: [Permanent Account No.]	AAACV5085F
Legal Form :	Private Limited Liability Company
Line of Business :	The Company is engaged in manufacturing of high quality ACSR (Aluminum Conductor Steel Reinforced), AAAC (All Aluminum Alloy Conductor), AAC (All Aluminum Conductor) and LT Aerial Bunched cables.
No. of Employees :	Not Available

RATING & COMMENTS

MIRA’s Rating :

B (36)

RATING		STATUS	PROPOSED CREDIT LINE
26-40	B	Capability to overcome financial difficulties seems comparatively below average.	Small

Maximum Credit Limit :	USD 580000
Status :	Moderate
Payment Behaviour :	Slow but correct
Litigation :	Clear
Comments :	Subject is an established company having a moderate track record. The company has recorded moderate scale of operation and there appears declined in its profitability and weal debt coverage. However, the networth of the company appears to be strong. Trade relations are reported to be fair. Business is active. Payments are reported to be slow but correct. The company can be considered for business dealings with slight caution

NOTES:

Any query related to this report can be made on e-mail: infodept@mirainform.com while quoting report number, name and date.

ECGC Country Risk Classification List – June 30, 2012

Country Name	Previous Rating (31.03.2012)	Current Rating (30.06.2012)
India	A1	A1

Risk Category	ECGC Classification
Insignificant	A1
Low	A2
Moderate	B1
High	B2
Very High	C1
Restricted	C2
Off-credit	D

INDIAN ECONOMIC OVERVIEW

India is developing into an open-market economy, yet traces of its past autarkic policies remain. Economic liberalization, including industrial deregulation, privatization of state-owned enterprises, and reduced controls on foreign trade and investment, began in the early 1990s and has served to accelerate the country's growth, which has averaged more than 7% per year since 1997. India's diverse economy encompasses traditional village farming, modern agriculture, handicrafts, a wide range of modern industries, and a multitude of services. Slightly more than half of the work force is in agriculture, but services are the major source of economic growth, accounting for more than half of India's output, with only one-third of its labor force. India has capitalized on its large educated English-speaking population to become a major exporter of information technology services and software workers. In 2010, the Indian economy rebounded robustly from the global financial crisis - in large part because of strong domestic demand - and growth exceeded 8% year-on-year in real terms. However, India's economic growth in 2011 slowed because of persistently high inflation and interest rates and little progress on economic reforms. High international crude prices have exacerbated the government's fuel subsidy expenditures contributing to a higher fiscal deficit, and a worsening current account deficit. Little economic reform took place in 2011 largely due to corruption scandals that have slowed legislative work. India's medium-term growth outlook is positive due to a young population and corresponding low dependency ratio, healthy savings and investment rates, and increasing integration into the global economy. India has many long-term challenges that it has not yet fully addressed, including widespread poverty, inadequate physical and social infrastructure, limited non-agricultural employment opportunities, scarce access to quality basic and higher education, and accommodating rural-to-urban migration.

Source : CIA

EXTERNAL AGENCY RATING

Rating Agency Name	CARE
Rating	Short Tern Bank Facilities: A4
Rating Explanation	Having minimal degree of safety regarding timely payment of financial obligation, it carry very high credit risk and are susceptible to default.
Date	September, 2012

RBI DEFAULTERS’ LIST STATUS

Subject’s name is not enlisted as a defaulter in the publicly available RBI Defaulters’ list.

EPF (Employee Provident Fund) DEFAULTERS’ LIST STATUS

Subject’s name is not enlisted as a defaulter in the publicly available EPF (Employee Provident Fund) Defaulters’ list as of 31-03-2012.

LOCATIONS

Registered/ Corporate Office :	302 Navjeevan Chamber, Vinoba Marg, RG C-Scheme, Jaipur – 302001, Rajasthan, India
Tel. No.:	91-141-2371394/ 5107094/ 2330078
Fax No.:	91-141-2366854
E-Mail :	s_hirawat51@hotmail.com venwire@yahoo.com
Website :	http://www.venwires.com

DIRECTORS

(AS ON 23.07.2012)

Name :	Mr. Rohit Kumar Saboo
Designation :	Director
Address :	14-A, Sangram Colony, C-Scheme, Jaipur-302001, Rajasthan, India
Date of Birth/Age :	01.02.1967
Date of Appointment :	16.05.1988
DIN No.:	00086846

Other Directorship:

S.No.	CIN	Name of the Company	Current designation of the director	Date of appointment at current designation	Original date of appointment	Date of cessation	Company Status	Defaulting status
1	U31300RJ1988PTC004446	VENKATESWARA WIRES PRIVATE LIMITED	Director	16-05-88	16-05-88	-	Active	NO
2	U14101RJ1992PTC006940	MLS EXPORTS AND TRADING PRIVATE LIMITED	Director	08-09-92	08-09-92	-	Active	NO
3	U74899DL1961PLC003394	INDIAN ROCKWOOL COMPANY LIMITED	Director	18-12-00	18-12-00	17-08-07	Active	NO
4	U31300RJ2004PTC019802	ROYAL CON-CAB PRIVATE LIMITED	Director	24-11-04	24-11-04	-	Active	NO
5	U51101RJ1948PLC000752	UNIVERSAL TRADING COMPANY LIMITED	Director	20-07-09	17-06-08	-	Active	NO
6	U67120RJ1943PTC000137	JAIPUR FINANCE AND DIARY PRODUCTS PRIVATE LIMITED	Director	04-08-08	04-08-08	-	Active	NO
7	U34300DL2005PTC140968	NTN NEI MANUFACTURING INDIA PRIVATE LIMITED	Director	25-08-08	25-08-08	-	Active	NO
8	U14219RJ1949PLC000700	RAJASTHAN INDUSTRIES LIMITED.	Director	20-07-09	05-09-08	-	Active	NO
9	U72900DL2010PLC197773	BIRLA SOFT LIMITED	Director	07-01-10	07-01-10	-	Active	NO

Name :	Mr. Abhay Kumar Bohra
Designation :	Director
Address :	C-128, Malyiya Nagar, Jaipur-302017, Rajasthan, India
Date of Birth/Age :	12.01.1948
Date of Appointment :	21.04.1998
DIN No.:	00420120

Other Directorship:

S.No.	CIN	Name of the Company	Current designation of the director	Date of appointment at current designation	Original date of appointment	Company Status	Defaulting status
1	U31300RJ1987PTC004236	ADINATH ELECTRICALS PRIVATE LIMITED	Director	20-04-98	20-04-98	Active	NO
2	U31300RJ1988PTC004446	VENKATESWARA WIRES PRIVATE LIMITED	Director	21-04-98	21-04-98	Active	NO

Name :	Mr. Sanjay Kumar Saboo
Designation :	Director
Address :	14, Ashok Niwas, Mahaveer Marg, C-Scheme, Jaipur-302001 , Rajasthan, India
Date of Birth/Age :	29.11.1960
Date of Appointment :	16.05.1988
DIN No.:	00633771

Other Directorship:

S.No.	CIN	Name of the Company	Current designation of the director	Date of appointment at current designation	Original date of appointment	Date of cessation	Company Status	Defaulting status
1	U51101RJ1983PTC002682	VENKATESHWARA TRADING AND INVESTMENTS COMPANY PRIVATE LIMITED	Director	26-03-83	26-03-83	-	Active	NO
2	U31300RJ1988PTC004446	VENKATESWARA WIRES PRIVATE LIMITED	Director	16-05-88	16-05-88	-	Active	NO
3	U65993RJ1991PLC005870	MOONLIGHT INVESTMENT AND MARKETING COMPANY LIMITED	Director	15-03-91	15-03-91	-	Active	NO
4	U31300RJ1987PTC004236	ADINATH ELECTRICALS PRIVATE LIMITED	Director	08-02-93	08-02-93	-	Active	NO
5	U14101RJ1992PTC006940	MLS EXPORTS AND TRADING PVT. LTD	Director	20-10-94	20-10-94	-	Active	NO
6	U36911RJ1997PTC014313	PELIKAN SOLITAIRES PRIVATE LIMITED	Director	09-10-97	09-10-97	-	Active	NO
7	U67120RJ1997PTC014430	PEARL SHARE BROKER PRIVATE LIMITED	Director	13-11-97	13-11-97	-	Active	NO
8	U31300RJ2004PTC019802	ROYAL CON-CAB PRIVATE LIMITED	Director	24-11-04	24-11-04	-	Active	NO
9	U29299RJ2006PTC023319	SHUBH SUMANGAL ENGINEERS PRIVATE LIMITED	Director	14-11-06	14-11-06	04-07-11	Active	NO

MAJOR SHAREHOLDERS / SHAREHOLDING PATTERN

(AS ON 23.07.2012)

Shareholding details file attached.

(AS ON 30.09.2012)

Equity Shares Break – up

Category	Percentage
Bodies corporate	12.35
Directors or relatives of directors	87.60
Other top fifty shareholders	0.05
Total 4	100.00

BUSINESS DETAILS

Line of Business :

The Company is engaged in manufacturing of high quality ACSR (Aluminum Conductor Steel Reinforced), AAAC (All Aluminum Alloy Conductor), AAC (All Aluminum Conductor) and LT Aerial Bunched cables.

Products :

Products Description	Item Code No.
Conductor Wire	760500

PRODUCTION STATUS (AS ON 31.03.2011)

Particulars	Unit	Installed Capacity	Actual Production
AAC, ACSR, AAAC, Multisrand Conductor and XLPE Cable	K.M.	40000	19394.723
Aluminum and Compacted Wire	MT	--	2025.496

GENERAL INFORMATION

No. of Employees :

Not Available

Bankers :

· The Bank of Rajasthan Limited

V K I Area Branch, Road No.5, Jaipur – 302013, Rajasthan, India

· ICICI Bank Limited

Shreeji Tower C-99, C-Scheme, Ahinda Circle, Jaipur-302001, Rajasthan, India

Facilities :

Secured Loans	31.03.2012	31.03.2011
	(Rs. In Millions)
Term Loans
From ICICI Banks
On Wind Mill Power Project, Jaiselmer	4.193	6.747
Wind Mill Power Project, Barmer	13.318	14.634
On VWPLII Plant and Machinery	5.046	3.737
Term loan from ICICI Bank Limited for wind power project is secured against the equitable mortgage of Land and Building and Hypothecation of New P and M and other Fixed Assets of Wind Power Mill situated at Jaiselmer District of Rajasthan, Dhalgaon District of Sangli and Barmer district of Rajasthan and are repayable in 6 years. Loan From ICICI Bar* Limited for VWPL-II P&M is secured against the equitable mortgage of Land and Building of Royal Concab Private Limited. (Associated Concern) situated at Plot No. 55, Road No. 5, VKIA, Jaipur and is repayable in 5 years.
Loans repayable on demand from ICICI BANK:
Cash Credit Limit	91.328	75.928
Channel financing for supplies from BALCO	45.965	59.214
Cash credit book debt, and Adhoc limits from ICICI Bank Ltd are secured against hypothecation of raw materials, goods in processes, finished goods of conductor and personally guaranteed by two directors of company and repayable on Loan from ICICI Bank Balco loan Secured against hypothecation of material in transit. (Of the above, Rs.137.294 Millions is guaranteed by two Directors)
Total	159.850	160.260
Unsecured Loans	31.03.2012	31.03.2011
	(Rs. In Millions)
Others Loans
From related Parties	15.351	13.558
From shareholders	9.639	9.486
Unsecured and carry forward loans as per directions of lenders have been classified as long term borrowings
Loans repayable on demand from HDFC Bank	2.779	0.000
Total	27.769	23.044

Banking Relations :	--
Auditors :
Name :	H. S. Darda and Company Chartered Accountant
Address :	36-A, Suraj Nagar East, Civil Lines, Jaipur – 302006, Rajasthan, India
PAN No.: :	AACFM0580E
Associates :	· MLS Export and Trading Private Limited CIN No.:- U14101RJ1992PTC006940 · Moonlight Investment and Trading Limited CIN No.:- U65993RJ1991PLC005870 · Venkateshwar Trading and Investment Private Limited CIN No.:- U51101RJ1983PTC002682 · Adinath Electricals Private Limited CIN No.:- U31300RJ1987PTC004236 · Royal Concab Private Limited CIN No.:- U31300RJ2004PTC019802

CAPITAL STRUCTURE

(AS ON 31.03.2012)

Authorised Capital :

No. of Shares	Type	Value	Amount
75000	Equity Shares	Rs.100/- each	Rs. 7.500 Millions

Issued, Subscribed & Paid-up Capital :

No. of Shares	Type	Value	Amount
57575	Equity Shares	Rs.100/- each	Rs. 5.758 Millions

FINANCIAL DATA

[all figures are in Rupees Millions]

ABRIDGED BALANCE SHEET

SOURCES OF FUNDS		31.03.2012	31.03.2011	31.03.2010
SHAREHOLDERS FUNDS
1] Share Capital		5.758	5.758	5.758
2] Share Application Money		0.000	0.000	0.000
3] Reserves & Surplus		139.546	138.557	128.146
4] (Accumulated Losses)		0.000	0.000	0.000
NETWORTH		145.304	144.315	133.904
LOAN FUNDS
1] Secured Loans		159.850	160.260	184.031
2] Unsecured Loans		27.769	23.044	26.981
TOTAL BORROWING		187.619	183.304	211.012
DEFERRED TAX LIABILITIES		29.460	21.362	21.362
TOTAL		362.383	348.981	366.278
APPLICATION OF FUNDS
FIXED ASSETS [Net Block]		124.602	116.395	121.195
Capital work-in-progress		0.000	9.715	0.000
INVESTMENT		1.944	1.945	1.945
DEFERREX TAX ASSETS		0.000	0.000	0.000
CURRENT ASSETS, LOANS & ADVANCES
	Inventories	11.342	38.579	28.702
	Sundry Debtors	309.963	256.810	271.360
	Cash & Bank Balances	38.615	43.255	33.175
	Other Current Assets	13.043	14.800	0.000
	Loans & Advances	37.989	22.168	27.761
Total Current Assets		410.952	375.612	360.998
Less : CURRENT LIABILITIES & PROVISIONS
	Sundry Creditor	159.354	125.012	112.742
	Other Current Liabilities	14.809	26.562	0.000
	Provisions	0.952	3.112	5.159
Total Current Liabilities		175.115	154.686	117.901
Net Current Assets		235.837	220.926	243.097
MISCELLANEOUS EXPENSES		0.000	0.000	0.041
TOTAL		362.383	348.981	366.278

PROFIT & LOSS ACCOUNT

	PARTICULARS		31.03.2012	31.03.2011	31.03.2010
	SALES
		Revenue from Operations	1142.110	995.322	1032.756
		Other Income	6.061	4.098	NA
		TOTAL (A)	1148.171	999.420	NA
Less	EXPENSES
		Cost of Materials Consumed	1031.036	896.586	NA
		Changes in inventories of finished goods work in progress and stock in trade	0.488	0.077	NA
		Employee Benefits Expenses	6.193	5.592	NA
		Other expenses	51.251	42.143	NA
		TOTAL (B)	1088.968	944.398	NA
Less	PROFIT BEFORE INTEREST, TAX, DEPRECIATION AND AMORTISATION (A-B) (C)		59.203	55.022	NA
Less	FINANCIAL EXPENSES (D)		49.236	35.930	NA
	PROFIT BEFORE TAX, DEPRECIATION AND AMORTISATION (C-D) (E)		9.967	19.092	37.810
Less/ Add	DEPRECIATION/ AMORTISATION (F)		7.173	6.664	5.867
	PROFIT BEFORE TAX (E-F) (G)		2.794	12.428	31.943
Less	TAX (H)		1.789	2.000	7.425
	PROFIT AFTER TAX (G-H) (I)		1.005	10.428	24.518
Add	PREVIOUS YEARS’ BALANCE BROUGHT FORWARD		94.035	83.607	61.589
Less	APPROPRIATIONS
		Transfer to General Reserve	0.000	0.000	2.500
	BALANCE CARRIED TO THE B/S		95.040	94.035	83.607
	Earnings Per Share (Rs.)		17.46	181.12	459.27

KEY RATIOS

PARTICULARS		31.03.2012	31.03.2011	31.03.2010
PAT / Total Income	(%)	0.09	1.04	NA
Net Profit Margin (PBT/Sales)	(%)	0.24	1.25	3.09
Return on Total Assets (PBT/Total Assets}	(%)	0.52	2.53	6.62
Return on Investment (ROI) (PBT/Networth)		0.02	0.09	0.24
Debt Equity Ratio (Total Debt/Networth)		1.29	1.27	1.58
Current Ratio (Current Asset/Current Liability)		2.35	2.43	3.06

LOCAL AGENCY FURTHER INFORMATION

Sr. No.	Check List by Info Agents	Available in Report (Yes / No)
1]	Year of Establishment	Yes
2]	Locality of the firm	Yes
3]	Constitutions of the firm	Yes
4]	Premises details	No
5]	Type of Business	Yes
6]	Line of Business	Yes
7]	Promoter's background	Yes
8]	No. of employees	No
9]	Name of person contacted	No
10]	Designation of contact person	No
11]	Turnover of firm for last three years	Yes
12]	Profitability for last three years	Yes
13]	Reasons for variation <> 20%	-----
14]	Estimation for coming financial year	No
15]	Capital in the business	Yes
16]	Details of sister concerns	Yes
17]	Major suppliers	No
18]	Major customers	No
19]	Payments terms	No
20]	Export / Import details (if applicable)	No
21]	Market information	-----
22]	Litigations that the firm / promoter involved in	-----
23]	Banking Details	Yes
24]	Banking facility details	Yes
25]	Conduct of the banking account	-----
26]	Buyer visit details	-----
27]	Financials, if provided	Yes
28]	Incorporation details, if applicable	Yes
29]	Last accounts filed at ROC	Yes
30]	Major Shareholders, if available	Yes
31]	Date of Birth of Proprietor/Partner/Director, if available	Yes
32]	PAN of Proprietor/Partner/Director, if available	No
33]	Voter ID No of Proprietor/Partner/Director, if available	No
34]	External Agency Rating, if available	Yes

PEFORMANCE AND BUSINESS

The company attained a sales turnover of Rs 1255.655 Millions (including Wind Power project sale of electricity of Rs. 13.397 Millions) against a turnover of Rs. 1095.941 Millions (including Wind Power project sale of electricity of Rs.12.305 Millions) in the financial year 2011-12. The year was most challenging for the company’s business. High Fluctuation in prices of Raw materials, lesser price realization coupled with tight liquidity position of electricity boards and quite delayed payments have severely squeezed the margins. The management worked hard to increase the turnover, however, due to very tight margins, just could afford to jeep the bottom line in black.

FIXED ASSETS

· Land

· Building

· Plant and Machinery

· Testing Equipment

· Electricity Installments

· Vehicles

· Furniture

· Office Equipments

CMT REPORT (Corruption, Money Laundering & Terrorism]

The Public Notice information has been collected from various sources including but not limited to: The Courts, India Prisons Service, Interpol, etc.

1] INFORMATION ON DESIGNATED PARTY

No exist designating subject or any of its beneficial owners, controlling shareholders or senior officers as terrorist or terrorist organization or whom notice had been received that all financial transactions involving their assets have been blocked or convicted, found guilty or against whom a judgement or order had been entered in a proceedings for violating money-laundering, anti-corruption or bribery or international economic or anti-terrorism sanction laws or whose assets were seized, blocked, frozen or ordered forfeited for violation of money laundering or international anti-terrorism laws.

2] Court Declaration :

No exist to suggest that subject is or was the subject of any formal or informal allegations, prosecutions or other official proceeding for making any prohibited payments or other improper payments to government officials for engaging in prohibited transactions or with designated parties.

3] Asset Declaration :

No records exist to suggest that the property or assets of the subject are derived from criminal conduct or a prohibited transaction.

4] Record on Financial Crime :

Charges or conviction registered against subject: None

5] Records on Violation of Anti-Corruption Laws :

Charges or investigation registered against subject: None

6] Records on Int’l Anti-Money Laundering Laws/Standards :

Charges or investigation registered against subject: None

7] Criminal Records

No available information exist that suggest that subject or any of its principals have been formally charged or convicted by a competent governmental authority for any financial crime or under any formal investigation by a competent government authority for any violation of anti-corruption laws or international anti-money laundering laws or standard.

8] Affiliation with Government :

No record exists to suggest that any director or indirect owners, controlling shareholders, director, officer or employee of the company is a government official or a family member or close business associate of a Government official.

9] Compensation Package :

Our market survey revealed that the amount of compensation sought by the subject is fair and reasonable and comparable to compensation paid to others for similar services.

10] Press Report :

No press reports / filings exists on the subject.

CORPORATE GOVERNANCE

MIRA INFORM as part of its Due Diligence do provide comments on Corporate Governance to identify management and governance. These factors often have been predictive and in some cases have created vulnerabilities to credit deterioration.

Our Governance Assessment focuses principally on the interactions between a company’s management, its Board of Directors, Shareholders and other financial stakeholders.

CONTRAVENTION

Subject is not known to have contravened any existing local laws, regulations or policies that prohibit, restrict or otherwise affect the terms and conditions that could be included in the agreement with the subject.

FOREIGN EXCHANGE RATES

Currency	Unit	Indian Rupees
US Dollar	1	Rs.53.96
UK Pound	1	Rs.84.49
Euro	1	Rs.72.23

INFORMATION DETAILS

Report Prepared by :

NIT

SCORE & RATING EXPLANATIONS

SCORE FACTORS	RANGE	POINTS
HISTORY	1~10	4
PAID-UP CAPITAL	1~10	4
OPERATING SCALE	1~10	4
FINANCIAL CONDITION
--BUSINESS SCALE	1~10	4
--PROFITABILIRY	1~10	4
--LIQUIDITY	1~10	4
--LEVERAGE	1~10	4
--RESERVES	1~10	4
--CREDIT LINES	1~10	4
--MARGINS	-5~5	--
DEMERIT POINTS
--BANK CHARGES	YES/NO	YES
--LITIGATION	YES/NO	NO
--OTHER ADVERSE INFORMATION	YES/NO	NO
MERIT POINTS
--SOLE DISTRIBUTORSHIP	YES/NO	NO
--EXPORT ACTIVITIES	YES/NO	NO
--AFFILIATION	YES/NO	YES
--LISTED	YES/NO	NO
--OTHER MERIT FACTORS	YES/NO	YES
TOTAL		36

This score serves as a reference to assess SC’s credit risk and to set the amount of credit to be extended. It is calculated from a composite of weighted scores obtained from each of the major sections of this report. The assessed factors and their relative weights (as indicated through %) are as follows:

Financial condition (40%) Ownership background (20%) Payment record (10%)

Credit history (10%) Market trend (10%) Operational size (10%)

RATING EXPLANATIONS

RATING		STATUS	PROPOSED CREDIT LINE
>86	Aaa	Possesses an extremely sound financial base with the strongest capability for timely payment of interest and principal sums	Unlimited
71-85	Aa	Possesses adequate working capital. No caution needed for credit transaction. It has above average (strong) capability for payment of interest and principal sums	Large
56-70	A	Financial & operational base are regarded healthy. General unfavourable factors will not cause fatal effect. Satisfactory capability for payment of interest and principal sums	Fairly Large
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory
26-40	B	Capability to overcome financial difficulties seems comparatively below average.	Small
11-25	Ca	Adverse factors are apparent. Repayment of interest and principal sums in default or expected to be in default upon maturity	Limited with full security
<10	C	Absolute credit risk exists. Caution needed to be exercised	Credit not recommended
-	NB	New Business	-

PRIVATE & CONFIDENTIAL : This information is provided to you at your request, you having employed MIPL for such purpose. You will use the information as aid only in determining the propriety of giving credit and generally as an aid to your business and for no other purpose. You will hold the information in strict confidence, and shall not reveal it or make it known to the subject persons, firms or corporations or to any other. MIPL does not warrant the correctness of the information as you hold it free of any liability whatsoever. You will be liable to and indemnify MIPL for any loss, damage or expense, occasioned by your breach or non observance of any one, or more of these conditions

This report is issued at your request without any risk and responsibility on the part of MIRA INFORM PRIVATE LIMITED (MIPL) or its officials.