MIRA INFORM REPORT

Report Date :

07.02.2014

IDENTIFICATION DETAILS

Name :	P.T. SOUTH PACIFIC VISCOSE

Registered Office :	Sampoerna Strategic Square South Tower, 22^nd Floor, Jl. Jend. Sudirman Kav. 45-46, Jakarta 12910

Country :	Indonesia

Financials (as on) :	31.12.2010

Date of Incorporation :	14.01.1978

Com. Reg. No.:	No. AHU-AH.01.10-03706

Legal Form :	Limited Liability Company

Line of Business :	Viscose Fibre, Sulphuric Acid, Carbon Bisulphide, and Sodium Sulphate Manufacturing

No. of Employees :	1,695 persons

RATING & COMMENTS

MIRA’s Rating :

RATING		STATUS	PROPOSED CREDIT LINE
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory

Status :	Satisfactory

Payment Behaviour :	Slow but Correct

Litigation :	Clear

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 – March, 31^st,2013

Country Name

Previous Rating

(31.12.2012)

Current Rating

(31.03.2013)

Indonesia

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

INDONESIA - ECONOMIC OVERVIEW

Indonesia, a vast polyglot nation, grew more than 6% annually in 2010-12. The government made economic advances under the first administration of President YUDHOYONO (2004-09), introducing significant reforms in the financial sector, including tax and customs reforms, the use of Treasury bills, and capital market development and supervision. During the global financial crisis, Indonesia outperformed its regional neighbors and joined China and India as the only G20 members posting growth in 2009. The government has promoted fiscally conservative policies, resulting in a debt-to-GDP ratio of less than 25%, a fiscal deficit below 3%, and historically low rates of inflation. Fitch and Moody's upgraded Indonesia's credit rating to investment grade in December 2011. Indonesia still struggles with poverty and unemployment, inadequate infrastructure, corruption, a complex regulatory environment, and unequal resource distribution among regions. The government in 2013 faces the ongoing challenge of improving Indonesia''s insufficient infrastructure to remove impediments to economic growth, labor unrest over wages, and reducing its fuel subsidy program in the face of high oil prices.

Source : CIA

BASIC SEARCH

Name of Company :

P.T. SOUTH PACIFIC VISCOSE

Address :

Head Office

Sampoerna Strategic Square South Tower, 22^nd Floor

Jl. Jend. Sudirman Kav. 45-46

Jakarta 12910

Indonesia

Phones - (021) 5771630 (hunting)

Fax. - (021) 5771640

Email - spv-jkt@cbn.net.id

Website - http://www.pt-spv.com

Building Area - 33 storey

Office Space - 1400 sq. meters

Region - Commercial

Status - Rent

Factory

Desa Cicadas, Cilangkap

Purwakarta, West Java

Indonesia

Phones - (0264) 8229752, 200636-7, 201414

Fax. - (0264) 202563, 200738

P.O. Box - 11 PWK

Land Area - 12.0 hectares

Building Space - 4.8 hectares

Region - Industrial Zone

Status - Owned

Date of Incorporation :

14 January 1978

Legal Form :

P.T. (Perseroan Terbatas) or Limited Liability Company

Company Reg. No. :

The Ministry of Law and Human Rights

a. No. C-19924.HT.01.04.TH.2004

Dated 06 August 2004

b. No. AHU-AH.01.10-15693

Dated 20 June 2008

c. No. AHU-00109.AH.01.02.Tahun 2009

Dated 05 January 2009

d. No. AHU-AH.01.10-08722

Dated 25 June 2009

e. No. AHU-AH.01.10-03706

Dated 08 February 2013

Company Status :

Foreign Investment Company (PMA)

Permit by the Government Department :

a. The Department of Finance

NPWP No. 01.000.573.4-052.000

b. The President of the Republic of Indonesia

No. B-40/Pres/11/1977

Dated 28 November 1977

c. The Capital Investment Coordinating Board

- No. 113/VI/PMA/1980

Dated 21 November 1980

- No. 470/III/PMA/1991

Dated 30 July 1991

- No. 741/II/PMA/1994

Dated 6 May 1994

- No.89/II/PMA/1999

Dated 18 May 1999

- No.673/II/PMA/2001

Dated 05 June 2001

d. The Department of Industry

No. 267/DJAI/IUT/III/PMA/VII/88

Dated 12 July 1988

Related/Affiliated Companies :

a. LENZING A.G. (Industrial Chemical Manufacturing)

b. ZENITH Steel Pipes and Industries Ltd. (Steel Making)

c. AVIT Investment Ltd. (Investment Holding)

d. PENIQUE S.A. (Investment Holding)

e. TUNGABHADRA Industries Ltd. (Textile Milling)

f. P.T. PURA GOLDEN LION (Trading)

g. P.T. INDO BHARAT RAYON (Viscose Industry)

CAPITAL AND OWNERSHIP

Capital Structure :

Authorized Capital - Rp. 290,000,000,000.-

Issued Capital - Rp. 72,500,000,000.-

Paid up Capital - Rp. 72,500,000,000.-

Shareholders/Owners :

a. LENZING A.G. of Austria - Rp 30,435,265,000.- (41.98%)

b. AVIT INVESTMENT Ltd. of Turks

& Caicos Islands British West India - Rp 23,086,012,000.- (31.84%)

c. PENIQUE SA of Panama - Rp 8,678,356,000.- (11.97%)

d. P.T. PURA GOLDEN LION of Indonesia - Rp 8,643,664,000.- (11.92%)

e. Mr. Bakti Santoso Luddin of Indonesia - Rp 1,656,703,000.- ( 2.29%)

BUSINESS ACTIVITIES

Lines of Business :

Viscose Fibre, Sulphuric Acid, Carbon Bisulphide, and Sodium Sulphate Manufacturing

Production Capacity :

Initial Units

a. Viscose Rayon Staple Fibres - 125,000 tons p.a.

b. Anhydrous Sodium Sulphates - 70,000 tons p.a.

c. Carbon Bisulphites - 18,150 tons p.a.

d. Sulphuric Acids - 71,800 tons p.a.

e. Filament Yarns - 15,000 tons p.a.

Expansion Units

a. Viscose Rayon Staple Fibres - 15,000 tons p.a.

b. Sodium Sulphate - 10,500 tons p.a.

c. Sulphuric Acid (H2SO4) - 13,500 tons p.a.

Total Investment :

Initial Units

a. Equity Capital - US$ 36.2 million

b. Reinvested Profit - US$ 27.0 million

c. Loan Capital - US$ 188.8 million

d. Total Investment - US$ 252.0 million

Expansion Units

a. Equity Capital - ---

b. Loan Capital - US$ 30.0 million

c. Total Investment - US$ 30.0 million

Started Operation :

1982

Brand Name :

SPV

Technical Assistance :

LENZING A.G., of Austria

Number of Employee :

1,695 persons

Marketing Area :

Domestic (Local) - 70%

Export - 30%

Main Customers :

a. Textile Industry such as P.T. HADTEX, P.T. PUJITEX, P.T. TRISULATEX, P.T. SANDRATEX,

P.T. PANASIA INDO SYNTEX, etc.

b. Overseas Buyers in China, Vietnam, Bangladesh, Srilanka, Malaysia, Australia, etc.

Market Situation :

Very Competitive

Main Competitors :

a. P.T. INDO BHARAT RAYON

b. P.T. TOBA PULP LESTARI Tbk

c. Etc.

Business Trend :

Growing

BANKER, AUDITOR & LITIGATION

Bankers :

a. STATE BANK OF INDIA, Singapore

10-01 DBS Building, 6 Shenton Way

Singapore 0106

b. American Express Banking Corp.

Hong Kong Branch

28/F Connaught Centre

Central Hongkong

c. American Express Banking Corp.

ARTHALOKA Building

Jalan M.H. Thamrin No. 2

Jakarta Pusat

d. DEUTCHE BANK LTD.

Jakarta Branch

Jalan Imam Bonjol No. 80

Jakarta Pusat

Auditor :

Purwantono, Sarwoko and Sandjaja, a public accountant

Litigation :

No litigation record in our database

FINANCIAL FIGURE

Annual Sales :

2008 – Rp. 3,258.9 billion

2009 – Rp. 3,195.6 billion

2010 – Rp. 4,562.8 billion

2011 – Rp. 5,110.0 billion (estimated)

2012 – Rp. 5,490.0 billion (estimated)

2013 – Rp. 3,016.0 billion (January – June) - estimated

Net Profit :

2008 – Rp. 110.2 billion

2009 – Rp. 354.4 billion

2010 – Rp. 636.6 billion

2011 – Rp. 712.0 billion (estimated)

2012 – Rp. 765.0 billion (estimated)

2013 – Rp. 420.0 billion (January – June) - estimated

Payment Manner :

Average

Financial Comments :

Satisfactory

KEY EXECUTIVES

Board of Management :

President Director - Mr. Wolfram Reinhard Kalt AKA Wolfram Kalt

Directors - a. Mr. Ian Arthur Colley

b. Mr. Gerhard Danninger

c. Mr. Sutarto Budi

d. Mr. Darmawan Alim

e. Mr. Venkatachalam Sundararajan

Board of Commissioner :

President Commissioner - Mr. Peter Untersperger

Commissioners - a. Mr. Kunrat Hadi Tanubrata

c. Mr. Friedrich Weninger

d. Mr. Wolfgang Plasser

e. Mr. Thomas Georg Winkler

f. Mr. Guenther Krohn

Signatories :

President Director (Mr. Wolfram Reinhard Kalt) or one of the Directors (Mr. Ian Arthur Colley, Mr. Gerhard Danninger, Mr. Sutarto Budi, Mr. Darmawan Alim or Mr. Venkatachalam Sundararajan) which must be approved by Board of Commissioners.

CAPABILITIES

Management Capability :

Good

Business Morality :

Good

Credit Risk :

Below average

Credit Recommendation :

Credit can be proceeded normally

Proposed Credit Limit :

Moderate amount

OVERALL PERFORMANCE

The company was established in Jakarta in 1978 with an authorized capital of US$ 6,500,000.- issued capital of US$ 1,300,000.- of which US$ 130,000.- was paid-up. Founders and original shareholders of P.T. SOUTH PACIFIC VISCOSE (P.T. SPV) were TUNGABHADRA Industries Ltd., of India, SNIA Viscose SPA of Italy, INTERNATIONAL Textile Corporation Ltd., of Hong Kong and the late Mr. Ali Noor Luddin, an indigenous businessman. In 1984, the authorized capital was increased to US$ 11,500,000.- wholly issued and paid-up. On the same occasion SNIA Viscose SPA and INTERNATIONAL Textile Corporation Ltd., pulled-out and replaced by CHEMIE FASSER LENZING AG., of Austria, ZENITH Steel Pipes Industries Ltd., of India, AVIT Investment Ltd of Turks & Caicos Islands British West India. Meanwhile, the local partner has been replaced by P.T. PURA GOLDEN LION. In 1991, its capital has been converted into rupiah and the authorized capital was set-up at Rp. 90,000,000,000.- issued capital of Rp. 58,614,968,000.- wholly paid-up.

On August 2004, its issued and paid up capital was increased to Rp. 72,500,000,000.- It seems that 41.98% shares of P.T. SPV is controlled by LENZING AG., a member of the LENZING AG Group, a major business group of Austria, 31.18% is controlled by AVIT INVESTMENT Ltd., of Turks & Caicos Islands British West India and the rest by PENIQUE SA., of Panama (11.97%), two shareholders of Indonesia namely P.T. PURA GOLDEN LION (11.92%) and Mrs. Saparsih Noor Luddin (2.29%) and GODAVARI Corp., Ltd., of India (0.66%).

On June 2008, GODAVARI Corp., Ltd., of India pulled-out and its shares sold to AVIT INVESTMENT LTD., of Turks & Caicos Islands British West India. At time, the shareholders of P.T. SPV are LENZING AG., (41.98%), AVIT INVESTMENT Ltd., (31.84%), PENIQUE SA., (11.97%), P.T. PURA GOLDEN LION (11.92%) and Mrs. Saparsih Noor Luddin (2.29%). The amendment notary deed of the company was approved by the Ministry of Law and Human Right in its Decision Letter No. AHU-AH.01.10-15693, dated 20 June 2008.

On June 2009, Mr. Thomas Michael Fahnemann resigned from a position as President Commissioner and his position replaced by Mr. Peter Untersperger. Concurrently, Mr. Wolfram Reinhard Kalt entered into P.T. SPV as a new president director. Latest, on December 2012, Mrs. Saparsih Noor Luddin pulled out and the whole shares are sold to Mr. Bakti Santoso Luddin. Concurently, Mr. Venkatachalam Sundarajan entered into P.T. SPV as a new director. The amendment notary deed of the company was approved by the Ministry of Law and Human Right in its Decision Letter No. AHU-AH.01.10-03706, dated February 8, 2013. No changes have been effected in term of its shareholding composition and capital structures to date.

P.T. SPV is a Foreign Capital Investment (PMA) corporation engaged in viscose fibre manufacturing. Its plant is located at Desa Cicadas, Cilangkap, Purwakarta, West Java, has been operating commercially since 1982 and running well as yet. Besides, P.T. SPV has also produced by-products like sulphurid acid (H2SO4), carbon bisulphide (CS2) and anhydrous sodium sulphate, all for own needs. P.T. SPV operates 3 production lines producing 300 tons per day on the average. Its export volume comes to about 2,500 to 2,600 tons per month.

Mr. Cacuk Martakusuma, a senior marketing staff of P.T. SPV disclosed that before economic crisis, domestic market was a potential one, but since October 1997 it concentrated to overseas market and now some 30% of the products exported to P.R. China, Vietnam, Bangladesh, Srilangka, Malaysia, the Philippines, Australia, Switzerland, the USA, Argentine, Africa, Egypt, South Africa and Asia, while the rest 70% remains for local textile industries in the HADTEX Group, the PUJITEX Group, the TRISULATEX Group, the SANDRATEX Group, the PANASIA Group, etc. We observed that P.T. SPV is the medium-sized company in the country at present in viscose fibre industry of which the operation has been growing slowly in the last five years.

Generally, demand for textile and textile product including cotton yarn, polyester textured yarn, finished fabrics, viscose fiber, garment, textile chemicals and raw materials has been fluctuating in the last five years. According to the Central Bureau of Statistics (BPS) the Indonesian garments export in 2002 amounted to 333,100 tons (US$ 3,887.2 million) to 339,000 tons (US$ 4,037.9 million) in 2003 to 327.300 tons (US$ 4,351.9 million) in 2004 to 369.500 tons (US$ 4,967.0 million) in 2005 to 399,600 tons (US$ 5,608.1 million) in 2006, to 399,800 tons (US$ 5,712.9 million) in 2007 to 417,600 tons (US$ 6,092.2 million) in 2008 declined to 393,400 tons (US$ 5,735.6 million) in 2009 and rose again to 445,200 tons (US$ 6,598.0 million) in 2010 to 450,900 tons (US$ 7,801.5 million) in 2011 and dropped to 450,200 tons (US$ 7,304.8 million) in 2012.

The Indonesia textile products export in 2002 amounted to 1,425.9 tons (US$ 3,075.9 million) to 1,307.5 tons (US$ 3,064.6 million) in 2003 to 1,300.4 tons (US$ 3,354.6 million) in 2004 to 1,427.3 tons (US$ 3,704.0 million) in 2005 to 1,477.800 tons (US$ 3,908.6 million) in 2006 to 1,473.6 tons (US$ 4,178.0 million) in 2007 declined to 1,312,200 tons (US$ 4,127.9 million) in 2008 to 1,369,600 tons (US$ 3,602.8 million) in 2009 to 1,525,900 tons (US$ 4,721.8 million) in 2010 declined to 1,493,3000 tons (US$ 5,563.3 million) in 2011 and rose again to 1,508,500 tons (US$ 5,278.1 million) in 2012. The export volume and value of the national TPT products in 2002 to 2012 are pictured on the following table.

Year

Garment

Textile Products

(Thousand Ton)

(US$ Million)

(Thousand Ton)

(US$ Million)

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

333.1

339.9

327.3

369.5

399.6

399.8

417.6

393.4

445.2

450.9

450.2

3,887.2

4,037.9

4,351.9

4,967.0

5,608.1

5,712.9

6,092.2

5,735.6

6,598.0

7,801.5

7,304.8

1,425.9

1,307.5

1,300.4

1,427.3

1,477.8

1,473.6

1,312.2

1,369.6

1,525.9

1,493.3

1,508.5

3,075.9

3,064.6

3,354.6

3,704.0

3,908.6

4,178.0

4,127.9

3,602.8

4,721.8

5,563.3

5,278.1

Source: Central Bureau of Statistic

According to the financial statement of the company (source: the Department of Trade and Industry), the total income/revenue of P.T. SPV in 2008 amounted to Rp. 3,258.9 billion with a net profit of Rp. 110.2 billion declined to Rp. 3,195.6 billion with a net profit of Rp. 354.4 billion in 2009 and rose again to Rp. 4,562.8 billion with a net profit of Rp. 636.6 billion in 2010. Up to present, we have yet to gain the statement of income of P.T. SPV in 2011 and 2012. However, we estimated that net income of the company in 2011 rose to Rp. 5,110.0 billion with a net profit of Rp. 712.0 billion and rose again to Rp. 5,490.0 billion with a net profit of Rp. 765.0 billion in 2012. It is forecasted that total sales turnover of the company will increase at least 8% in 2013. So far we did not hear that the P.T. SPV has been black listed by Bank Indonesia (Central Bank) or having detrimental cases being settled in local district court. The company usually pays its debts punctually to suppliers.

Since January 2010, the management of P.T. SPV has been headed by Mr. Wolfram Reinhard Kalt AKA Wolfram Kalt (51) replacing Mr. Guenther Krohn (55) as the president director. Mr. Kalt is a professional manager from Austria, with more than 21 years experience in LENZING Group with various positions. In his daily activities, he is assisted by five directors namely Mr. Ian Arthur Colley (50), Mr. Gerhard Danninger (56), Mr. Sutarto Budi (67), Mr. Darmawan Alim (59) and Mr. Venkatachalam Sundararajan (54) of India. The management has a good reputation in industry and trading of viscose rayon staple fibre and other textile raw materials. The management also has wide relation with private businessmen of home and overseas as well as with the government sectors. So far, we did not hear that the management of the company has involved in fraudulent business dealing.

P.T. SOUTH PACIFIC VISCOSE is sufficiently fairly good for business transaction. However, in view of the economic condition in the country is still unstable, we recommend to treat prudently in extending any new loan to the company.

Attachment

FINANCIAL STATEMENTS

Per 31 December 2007, 2008, 2009 and 2010

(In million Rupiah)

DECCRIPTION	31 December
DECCRIPTION	2010	2009	2008	2007
A. ASSETS
a. Current Assets
- Cash and cash equivalents	288,039.0	120,201.4	258,674.6	357,454.0
- Trade and other receivables - net	386,701.5	329,014.2	403,245.3	341,622.4
- Inventories - net	705,196.4	484,325.2	612,421.1	437,000.1
- Prepayments	7,358.1	6,058.3	1,827.0	2,707.4
- Claims for tax refund	210,183.5	161,132.7	101,652.9	55,415.2
Total Current Assets	1,597,478.5	1,100,731.8	1,377,820.9	1,194,199.2

b. Non-Current Assets
- Property, plant and equipment - net	2,172,167.1	1,812,667.6	721,099.6	559,237.1
- Intangible asset – net of accumulated	--	--	--	864.6
- Net deferred tax assets	17,625.5	24,397.9	36,112.3	16,572.1
- Receivables from employees	8,155.2	7,934.1	5,347.0	4,623.3
- Advances for purchase of property and plant	4,379.2	48,195.9	164,114.4	8,917.2
- Other non-current assets	3,256.3	3,382.3	2,804.6	2,893.7
Total Non-Current Assets	2,205,583.3	1,896,577.9	929,507.9	593,107.9
TOTAL ASSETS = TOTAL LIABILITIES & SHAREHOLDERS’ EQUITY	3,803,061.8	2,997,309.8	2,307,328.8	1,787,307.1

LIABILITIES
a. Current Liabilities
- Trade and other payables	510,591.2	389,020.5	581,629.1	375,880.4
- Dividends payable	51,800.9	--	--	23,602.2
- Taxes payable	113,672.3	51,164.4	39,696.3	114,747.5
- Accrued expenses and provisions	150,568.7	131,930.7	92,685.5	108,370.0
- Current portion	282,143.2	122,351.4	26,006.2	174,063.5
Total Current Liabilities	1,108,776.2	694,467.0	740,017.1	796,663.6

b. Non-Current Liabilities
- Long-term portion * Long-term debt * Subordinated loans	889,286.9 135,058.6	1,055,617.4 183,811.1	653,140.1 205,247.3	66,975.0 212,563.0
- Dividends payable	--	54,448.5	63,024.4	--
- Retirement benefits obligations	75,209.0	54,997.9	50,849.0	40,397.9
- Government Grants	8,680.6	4,545.5	--	--
Total Non-Current Liabilities	1,108,235.0	1,353,420.4	972,260.8	319,935.9

c. Shareholders’ Equity
- Share capital (Issued and Paid up capital)	72,500.0	72,500.0	72,500.0	72,500.0
- Revaluation increment in property and plant	--	--	--	0.1
- Retained earnings	1,513,550.6	876,922.4	522,550.9	598,207.5
Total Shareholders’ Equity	1,586,050.6	949,442.4	595,050.9	670,707.6

STATEMENTS OF INCOME
- Net Sales	4,562,813.9	3,195,630.1	3,258,886.5	3,016,457.3
- Cost of goods sold	(3,383,113.2)	(2,519,118.3)	(2,727,631.7)	(2,217,453.9)
- Gross Profit	1,179,680.7	676,511.8	531,254.9	799,003.4
- Operating Expenses	(372,163.7)	(286,533.2)	(273,527.4)	(240,761.5)
- Income from operations	807,517.0	389,978.6	257,727.5	558,241.9
- Other Income (Charges)	42,927.4	106,931.1	(92,522.8)	(41,159.5)
- Income before income tax	850,444.4	496,909.7	165,204.7	517,082.4
- Income tax expense - Net	(213,816.2)	(142,538.2)	(54,990.3)	(157,625.8)
NET PROFIT (Net Income)	636,628.2	354,371.5	110,214.4	359,456.6

Audited by Purwantono, Sarwoko & Sandjaja (a member of Ernst & Young)

FOREIGN EXCHANGE RATES

Currency	Unit	Indian Rupees
US Dollar	1	Rs.62.50
UK Pound	1	Rs.101.92
Euro	1	Rs.84.50

INFORMATION DETAILS

Report Prepared by :

NIS

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	----

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%)

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.