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BEFORE THE ADJUDICATING OFFICER

SECURITIES AND EXCHANGE BOARD OF INDIA


[ADJUDICATION ORDER NO. CFD/EIL/AO/DRK-VB/EAD3/710-713/35-38/2015]

__________________________________________________
UNDER SECTION 15 I OF SECURITIES AND EXCHANGE BOARD OF INDIA
ACT, 1992 READ WITH RULE 5(1) OF SECURITIES AND EXCHANGE
BOARD OF INDIA (PROCEDURE FOR HOLDING INQUIRY AND IMPOSING
PENALTIES BY ADJUDICATING OFFICER) RULES, 1995
In respect of:
1. Shri Anil Monga,

2. Shri Rajesh Monga,

Chariman & Managing Director,

Whole Time Director,

Emmsons International Ltd,

Emmsons International Ltd.

Khasra No.230/232

184, Kohat Enclave,

Westend Marg, Saidulajab

Pitampura,

New Delhi-110030

Delhi-110034

3. Ms. Renu Monga

4. Shri B.B Gandhi

Khasra No.230/232

2/75, Punjabi Bagh west,

Westend Marg,Saidulajab

New Delhi-110026

New Delhi-110030

FACTS IN BRIEF
1.

Securities and Exchange Board of India (hereinafter referred to as SEBI) while


examining the Letter of Offer filed by Shri. Anil Monga, Shri Rajesh Monga, Ms.
Renu Monga, Ms. Manya Monga, Ms. Rashi Monga, Shri Shivaz Monga, Ms.
Poonam Monga, Shri B.B Gandhi, Shri Jagroop Singh and Emmpac Holdings
Pvt. Ltd to acquire shares of the Emmsons International Limited (hereinafter
referred to as "EIL / the company") observed certain non compliances with
regard to SEBI (Substantial Acquisition of Shares and Takeovers) Regulations,
1997 (hereinafter referred to as SAST Regulations,1997) and SEBI
(Substantial

Acquisition

of

Shares

and

Takeovers)

Regulations,

2011

(hereinafter referred to as SAST Regulations, 2011).


APPOINTMENT OF ADJUDICATING OFFICER
2.

I was appointed as Adjudicating Officer under Section 15 I of the Securities and


Exchange Board of India Act, 1992 (hereinafter referred to as SEBI Act), read

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with Rule 3 of Securities and Exchange Board of India (Procedure for Holding
Inquiry and Imposing Penalties by Adjudicating Officer) Rules, 1995 (hereinafter
referred to as Adjudication Rules) to inquire into and adjudge under Section
15A (b) and Section 15H (ii) of the SEBI Act for the violations of Regulation 11
(1) read with Regulation 14 (1) of the SAST Regulations,1997 and Regulations
13(2)(c)

read

with

Regulation

13

(1),Regulation 29(2) of the SAST

Regulations,2011 alleged to have been committed by Shri. Anil Monga, Shri


Rajesh Monga, Ms. Renu Monga and Shri B.B Gandhi (hereinafter referred to
as 'Promoter / Promoter group / noticees') and the same was communicated
vide proceedings of the Whole Time Member appointing Adjudicating Officer
dated April 26,2013.
SHOW CAUSE NOTICE, REPLY AND HEARING
3.

A common Show Cause Notice No. A&E/EAD3/DRK-DS/22165/2013 dated


August 30,2013 (herein after referred to as SCN) was served on all the
noticees by Speed Post Acknowledgement Due (herein after referred to as
'SPAD') requiring the noticees to show cause as to why an inquiry should not be
held against the noticees and why penalty, if any, should not be imposed on the
noticees under Section 15A(b) and Section 15H (ii) of the SEBI Act.

4.

In the said SCN, it was alleged that pursuant to forfeiture of 7,89,100 equity
shares of the company, the shareholding of noticees along with other promoters
namely Shri Sanjeev Monga, Shri Madan Lal Monga, Shri Anil Aggarwal and
their PAC namely Emmpac Holdings Pvt. Ltd., increased by 7.66% on August
05, 2005. However, the noticees did not make public announcement as required
under Regulation 11(1) read with Regulation 14(1) of the SAST Regulations,
1997.

5.

It was further alleged that noticees along with other promoters namely Ms.
Manya Monga, Ms. Rashi Monga, Shri Shivaz Monga, Ms. Poonam Monga, Shri
Jagroop Singh and their PAC namely Emmpac Holdings Pvt. Ltd acquired voting
rights pursuant to the conversion of 8,50,000 warrants on February 29, 2012
which increased the shareholding of promoter group in the company by 7.95%.
However, noticees had delayed making public announcement resulting in non
compliance with Regulation 13(2)(c) read with Regulation 13(1) of the SAST
Regulations, 2011.

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Regulation

Due

Date

compliance
Regulation 13(2)(c) read 27.02.2012

of Actual Date of Delay


Compliance

(No of days)

22.05.2012

85

with Regulation 13(1)

6.

It was also alleged that noticees had made delayed disclosures which were not
in compliance with Regulation 29(2) of the SAST Regulations, 2011.

7.

Sr.

Name

of

the Regulation Due Date of Actual Date of Delay

No

Promoter

1.

Shri. Anil Monga

2.

Compliance

Compliance

(No of days)

29(2)

02.03.2012

19.05.2012

78

Ms. Renu Monga

29(2)

02.03.2012

19.05.2012

78

3.

Shri. B.B. Gandhi

29(2)

02.03.2012

19.05.2012

78

4.

Shri Rajesh Monga

29(2)

02.03.2012

05.03.2012

In response to the SCN, Noticees vide their letter dated September 17, 2013
submitted a common reply to the SCN as follows:
a) The noticees submitted that as on August 23, 2005, the Company had
forfeited 7,89,100 equity shares and pursuant to this, the total paid up capital
of the Target Company was reduced from 51,48,020 equity shares to
43,58,920 equity shares, thereby reducing the total shareholding of the
promoter group from 22,12,975 equity shares to 22,07,475 equity shares
(5500 shares). Thus there was no increase in shareholding or the Promoters
have not acquired any shares. Due to decrease in total outstanding paid up
capital, merely the percentage shareholding of the promoter group had
increased by 7.66% i.e. from 42.99% to 50.64%. In this regard, the following
submissions were made:

There was no actual acquisition. Since no single share was actually


acquired, it is pertinent to mention that noticees, in this case cannot be
treated as 'Acquirer' within the meaning of the SAST Regulations 1997
as there was no actual acquisition by the Promoters. In support of their
submission the noticee submitted the Order of Hon'ble SAT dated
November 21,2011 in the matter of Raghu Hari Dalmia and others vs
SEBI.
Since there was no increase in number of shares held, there had also
been no change in the voting rights. The promoter continues to
exercise same rights as before forfeiture since the shares which were
forfeited had no voting rights at all the provisions of Regulation 11(1)
cannot be said to be attracted.
The Forfeiture of shares is the act of the Company, the power in
respect to which it derives from the provisions of the Companies Act,
1956 and its Articles of Associations (AOA).
The percentage increase in the voting rights of the promoters holding
in the Company was not by reason of any act of theirs but was
incidental to the legally vested right of the Target Company. Moreover

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there was no actual increase in the number of shares held by them and
no increase in the voting rights exercised by them pre and post
forfeiture.
Under the new SAST Regulations 2011, an automatic exemption is
given for any change in holding subsequent to the Buy Back of
securities which is a corporate action of the Company and may result
in passive increase in the shareholders voting rights. Likewise, even in
case of forfeiture, any change is Passive in nature without any act on
part of the Promoters.

b) The aforesaid increase in percentage holding subsequent to forfeiture is


disclosed in the offer document dated August 30, 2012. The offer price was
given due effect taking August 23, 2005 as the trigger date and including the
interest (calculated @10%p.a.) for the period 24.08.2005 to 22.05.2012. The
offer price came to be Rs. 34.51/- each share as per SAST Regulation 1997
and an interest amount of Rs. 26.739/- was added bringing total offer price to
be Rs. 61.25/- .However, since the offer price considering the February 27,
2012 as the trigger date along with interest works out to be at Rs. 123/-, the
offer was made at said price.
c) Subsequent to aforesaid conversion of 8,50,000 warrants on February 29,
2012, the promoter shareholding increased by 7.95% and as per the
provisions of SEBI SAST Regulations 2011, an offer was required to be made
to the public shareholders on second working day preceding the scheduled
date of conversion of the warrants i.e. on February 27, 2012 .However, the
offer was made on May 22, 2012. It was submitted that the delay was for 85
days for the reason of non-availability of adequate professional expertise and
advice within the Company and Promoter Group and also due to lack of
immediate availability of funds as was required to make public
announcement.
d) At the time of making the offer, the delay of 85 days in making the offer was
duly disclosed in the offer document dated August 30, 2012,. The offer price
taking February 27, 2012 as offer trigger date came to be Rs. 120/- per share
and in furtherance to this, the due effect was given to the delay by adding the
interest @10% p.a. to the offer price for the period from February 28, 2012 till
May 22, 2012 which came to be Rs. 3/- per share. Thus offer was made at
the total price of Rs. 123/- per share.
e) With regard to delay in making the disclosures under Regulations 29(2) of the
SEBI SAST Regulations 2011, noticees submitted that the delay had been
on account of non-availability of the adequate professional expertise within
the Company and with the Promoter Group and non-intentional. The delay
had been merely technical in nature and had no adverse effect on any
shareholder and due disclosure was made in the offer document and they
submitted that the delay may be pardoned.
8.

As requested, noticees were granted an opportunity of personal hearing vide


hearing notices dated October 31,2013 to appear for personal hearing on
November 07,2013 at 11:00 am at SEBI Northern Regional Office, New Delhi.

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The hearing notices were sent by SPAD. The Noticees did not avail the
opportunity of the said hearing without providing any reason. Thereafter, vide
common hearing notice dated August 08, 2014 the noticees were granted the
final opportunity of personal hearing on August 27, 2014 at 11:00 am at SEBI
Bhavan, Mumbai. Accordingly, the said hearing was attended by Ms Deepika
Sawhney, Advocate and Shri Vinay Gujral, Company Secretary, (hereinafter
referred to as 'ARs') and made the following submissions:
a) The ARs have reiterated the submissions made vide reply dated
September 17, 2013 and submitted that there was no acquisition of
shares and voting rights by the noticees pursuant to forfeiture of 7,89,100
shares in 2005.
b) With respect to the delay in making public offer, the ARs submitted that
the noticees paid 10% interest on the offer price pursuant to the delay of
85 days.
c) The ARs admitted that there had been a delay on part of the noticees in
making disclosures under Regulation 29(2) of the SAST Regulations
2011.
d) The ARs have undertaken to provide the history/ details of forfeiture of
shares within one week from the date of hearing. The hearing is
concluded and no further hearing is required by the AR

9.

Subsequently, the noticees vide letter dated September 03,2014 submitted the
history with respect to the forfeiture of shares

CONSIDERATION OF EVIDENCE AND FINDINGS


10. I have taken into consideration the facts and circumstances of the case and the
material made available on record.

Alleged Violation of SAST Regulations, 1997


11. Regulation 11 of the SAST Regulations 1997 deals with consolidation of
holdings. Regulation 11 (1) of the SAST Regulations 1997 states that

"No acquirer who, together with persons acting in concert with him, had
acquired, in accordance with the provisions of law, 15 per cent or more but
less than fifty five per cent (55%) of the shares or voting rights in a
company, shall acquire, either by himself or through or with persons acting
in concert with him, additional shares or voting rights entitling him to
exercise more than 5% of the voting rights, in any financial year ending on
31st March unless such acquirer makes a public announcement to acquire
shares in accordance with the regulations."
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Regulation 14 (1) of the SAST Regulations 1997 states that

"The public announcement referred to in regulation 10 or regulation 11


shall be made by the merchant banker not later than four working days of
entering into an agreement for acquisition of shares or voting rights or
deciding to acquire shares or voting rights exceeding the respective
percentage specified therein.......".

In the present matter it is observed from the material made available on record
that on August 23, 2005 Promoter group's shareholding had increased from
42.99% to 50.64%. i.e., an increase of 7.66% due to forfeiture of shares and the
total paid up capital of the Company was reduced from 51,48,020 equity shares
to 43,58,920 equity shares. Further, it is also observed that the total
shareholding of the promoter / promoter group had reduced from 22,12,975
equity shares to 22,07,475 equity shares due to said forfeiture of shares (5500
shares belonging to promoter group entity namely Ratan lal Monga (1000) and
Divya sood (4500)).

12. The noticees had submitted that since no single share was actually acquired
they cannot be treated as 'Acquirer' within the meaning of the SAST Regulations
1997. They further submitted that the percentage increase in the voting rights of
the promoters holding in the Company was not due to their act but was
incidental to the legally vested right of the Company. Noticees also submitted
that the change in the shareholding is passive in nature without any act on part
of the Promoters.

13. At this juncture, It may be added that forfeiture of shares is not a passive
acquisition like buyback of shares since forfeiture of shares is orchestrated by
the management / promoters of the company and can be made only by the
Board of Directors by passing resolution. It is noted that Hon'ble SAT in its Order
dated November 21,2011 in the matter of Raghu Hari Dalmia and others vs
SEBI had held that:-

"...An increase in percentage shareholding of a non-promoter pursuant to


a buy back scheme or forfeiture of shares of other shareholders would
lead to a situation where a non-promoter may not know as to when the
takeover code gets triggered as non-promoters have no access to the
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records of a company regarding the number of shares tendered from time


to time...."

From the above, it is seen that Hon'ble SAT had categorically referred to
increase in percentage shareholding of a "non-promoter" pursuant to buyback or
forfeiture of shares wherein it was held that a non-promoter may not be aware of
such an increase. However, in the instant case, percentage of shareholding of
the promoter / promoter group's voting rights had increased pursuant to
forfeiture of shares. Apart from this, it is also observed that even 5500 shares of
the promoter / promoter group was also forfeited and the management /
promoters were very well aware of the forfeiture proceedings since they have
access to the records of the company. Further, it may also be added that two of
noticees namely Shri Anil Monga and Shri Rajesh Monga are Chariman &
Managing Director and Whole Time Director of the company respectively.

14. The noticees had contended that they continue to exercise same rights as
before forfeiture, since the shares which were forfeited had no voting rights at
all, the provisions of Regulation 11(1) of SAST Regulations 1997 cannot be said
to be attracted. In this regard, I would like to quote the order of Hon'ble SAT
dated March 20, 2002 in the matter of Luxury Foams Ltd & others vs SEBI
wherein it was observed / held that partly paid shares carry voting rights and
therefore should be included for calculation of voting rights. Relevant extract of
the order is reproduced below : -

"In the light of the legal position regarding voting rights attached to the partly paid
shares in terms section 181 and 87 of the Companies Act, it is difficult to subscribe to
the Appellants version that 440 lakh X equity shares of Rs.10 each issued but partly
paid, have no voting rights and as such should be excluded for the purpose of
computing the percentages prescribed in regulation 10 etc., is not tenable."

In the instant case also, the shares forfeited were partly paid shares. Therefore,
the contention of the noticees do not hold good / are not acceptable

15. Further, I would like to quote the order of the Honble Supreme Court of India in
Swedish Match AB & Anr. Vs SEBI dated 25.08.2004 wherein it was held as
follows:
..Indisputably, the purport and object of which a regulation is made must
be duly fulfilled. Public announcement is at the base of Regulations 10, 11
and 12. Except in a situation which would bring the case within one or the
other 'exception clause', the requirement of complying with the mandatory
requirements to make public announcement cannot be dispensed with..."
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16. In light of above discussions / observations, it can be concluded that noticees


had failed to make a public announcement in compliance with Regulation 11(1)
read with Regulation 14(1) of the SAST Regulations, 1997 pursuant to increase
in percentage shareholding of the promoters / increase in percentage of voting
rights due to forfeiture of shares.

Alleged Violation of SAST Regulations, 2011


17. Due to conversion of 8,50,000 warrants on February 29, 2012 the promoter
shareholding increased by 7.95% and as per the provisions of SAST
Regulations 2011, the public announcement was required to be made to the
shareholders on February 27, 2012. However, the public announcement was
made only on May 22, 2012. In this regard, the noticees have admitted that the
delay of 85 days was due to non-availability of professional expertise and lack of
immediate availability of funds required to make public announcement. The
noticees further submitted that they had given due effect to the delay by adding
the interest @10% p.a. of ` 3/- for the period from February 28, 2012 till May 22,
2012 to the offer price of ` 120/-, amounting to the final offer price of ` 123/- per
share in terms of applicable provisions of SAST Regulations, 2011.

18. It is observed that the aforesaid delayed public announcement pertains to


increased promoter shareholding pursuant to the conversion of 8,50,000
warrants into equity shares. However, with respect to the forfeiture of shares
during the year 2005 as discussed in pre-pages, no public announcement was
made. The submission of the noticees to club both the independent triggers of
public announcement and making a single public announcement for the higher
price is purportedly erroneous. Both the events are independent of each other
and happened with wide time difference/gap. As seen from facts, the forfeiture
of shares happened during the year 2005 and conversion of warrants took place
during the year 2012 and the cause of action on both the events were different,
therefore, the public announcement had to be made on both the occasions.

19. In view of the above discussions, it can be concluded that the noticees had
failed to comply with Regulation 13(2)(c) read with Regulation 13(1)

of the

SAST Regulations, 2011. The relevant text of the aforesaid provisions are as
follows:

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SEBI (Substantial Acquisition of Shares and Takeovers) Regulations,


2011
Timing.
13(1) The public announcement referred to in regulation 3 and regulation 4
shall be made in accordance with regulation 14 and regulation 15, on the date
of agreeing to acquire shares or voting rights in, or control over the target
company.
(2) Such public announcement
..........
(c) pursuant to an acquirer acquiring shares or voting rights in, or control over
the target company upon conversion of convertible securities with a fixed date
of conversion shall be made on the second working day preceding the
scheduled date of conversion of such securities into shares of the target
company;
Delayed Disclosure under SAST Regulations, 2011

20. It is noted that the noticees were also required to make disclosures under
Regulation 29(2) of the SAST Regulations, 2011 due to increase in promoter
shareholding by 7.95% pursuant to the conversion of 8,50,000 warrants into
equity shares within two working days of the receipt of intimation of the
acquisition of shares or voting rights in the company. However, from the material
available on record, it is noted that the noticees had delayed in making the
disclosures as observed from para 6 above. Noticees had admitted that the said
delay had been on account of non-availability of the adequate professional
expertise. Since the noticees have themselves admitted the delay in making the
disclosures, it can be concluded that the noticees had failed to comply with
Regulation 29(2) of the SAST Regulations, 2011.The relevant text of the
aforesaid provisions are as follows:
SEBI (Substantial Acquisition of Shares and Takeovers) Regulations,
2011
Disclosure of acquisition and disposal.
29 (2) Any acquirer, who together with persons acting in concert with him,
holds shares or voting rights entitling them to five per cent or more of the
shares or voting rights in a target company, shall disclose every acquisition or
disposal of shares of such target company representing two per cent or more
of the shares or voting rights in such target company in such form as may be
specified.
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21. The aforesaid failures attract penalty under Section 15A(b) and Section 15H (ii)
of the SEBI Act. The text of the said provision is as follows:
SEBI Act
Penalty for failure to furnish information, return, etc.
15A. If any person, who is required under this Act or any rules or regulations
made thereunder,
(b) to file any return or furnish any information, books or other documents
within the time specified thereof in the regulations, fails to file return or furnish
the same within the time specified thereof in the regulations, he shall be liable
to a penalty of one lakh rupees for each day during which such failure
continues or one crore rupees, whichever is less;
Penalty for non-disclosure of acquisition of shares and takeovers.
15H. If any person, who is required under this Act or any rules or regulations
made thereunder, fails to,
...
(ii) make a public announcement to acquire shares at a minimum price;
...
he shall be liable to a penalty of twenty-five crore rupees or three times the
amount of profits made out of such failure, whichever is higher.
22. In this regard, the provisions of Section 15J of the SEBI Act and Rule 5 of the
Rules require that while adjudging the quantum of penalty, the adjudicating
officer shall have due regard to the following factors namely;
a.

the amount of disproportionate gain or unfair advantage wherever


quantifiable, made as a result of the default

b.

the amount of loss caused to an investor or group of investors as a


result of the default

c.

the repetitive nature of the default

23. With regard to the above factors to be considered while determining the quantum
of penalty, it is noted that the disproportionate gain or unfair advantage made by
the noticees or loss caused to the investors as a result of violations committed by
the noticees are not available on record. Further, it may also be added that it is
difficult to quantify the unfair advantage made by the noticees or the loss caused
to the investors in a default of this nature.

24. In view of the abovementioned conclusions and after considering the factors
under Section 15J of the SEBI Act, I hereby impose a penalty of ` 1,75,00,000
/- (Rupees One Crore Seventy Five Lakhs only) jointly and severally on all
noticees mentioned at para 2 for violation of Regulation 11(1) read with
Regulation 14(1) of the SAST Regulations, 1997, a penalty of ` 20,00,000 /Brought to you by http://StockViz.biz

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(Rupees Twenty Lakhs only) jointly and severally on all noticees mentioned at
para 2 for failure to comply with Regulation 13(2)(c) read with Regulation 13(1) of
SAST Regulations, 2011 and a penalty of ` 5,15,000 /- (Rupees Five Lakh
Fifteen Thousand only) each on Shri. Anil Monga, Ms. Renu Monga and Shri B.B
Gandhi and a penalty of ` 1,00,000 /- (Rupees One Lakh only) on Shri Rajesh
Monga for failure to comply with Regulation 29(2) of the SAST Regulations, 2011
under Section 15A(b) and Section 15H (ii) of the Securities and Exchange Board
of India Act, 1992 which is appropriate in the facts and circumstances of the
case.

ORDER
25. In exercise of the powers conferred under Section 15 I of the Securities and
Exchange Board of India Act, 1992 read with Rule 5 of Securities and Exchange
Board of India (Procedure for Holding Inquiry and Imposing Penalties by
Adjudicating Officer) Rules, 1995, I hereby impose a penalty of ` 1,75,00,000 /(Rupees One Crore Seventy Five Lakhs only) under Section 15 H(ii) of SEBI Act
jointly and severally on Shri. Anil Monga, Ms. Renu Monga, Shri Rajesh Monga
and Shri B.B Gandhi for violation of Regulation 11(1) read with Regulation 14(1)
of the SAST Regulations, 1997 and a penalty of ` 20,00,000 /- (Rupees Twenty
Lakhs only) under Section 15 H(ii) of SEBI Act jointly and severally on Shri. Anil
Monga, Ms. Renu Monga, Shri Rajesh Monga and Shri B.B Gandhi for failure to
comply with Regulation 13(2)(c) read with Regulation 13(1) of SAST Regulations,
2011. Further, a penalty of ` 5,15,000 /- (Rupees Five Lakh Fifteen Thousand
only) each under Section 15 A(b) of SEBI Act on Shri. Anil Monga, Ms. Renu
Monga and Shri B.B Gandhi and a penalty of ` 1,00,000 /- (Rupees One Lakh
only) on Shri Rajesh Monga for failure to comply with Regulation 29(2) of the
SAST Regulations, 2011. In the facts and circumstances of the case, I am of the
view that the said penalty is commensurate with the default committed by all the
noticees.

26. The penalty shall be paid by way of Demand Draft drawn in favour of SEBI
Penalties Remittable to Government of India payable at Mumbai within 45 days
of receipt of this order. The said demand draft shall be forwarded to Chief
General Manager- Enforcement Department, Securities and Exchange Board of
India, Plot No. C4-A, G Block, Bandra Kurla Complex, Bandra (E), Mumbai
400 051.
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27. In terms of the provisions of Rule 6 of the Securities and Exchange Board of
India (Procedure for Holding Inquiry and Imposing Penalties by Adjudicating
Officer) Rules 1995, copies of this order are being sent to Shri. Anil Monga (PAN
AAIPM8309E), Shri Rajesh Monga (PAN AAIPM8310R), Ms. Renu Monga (PAN
AAIPM8311Q) and Shri B.B Gandhi (PAN AAGPG5883M) and also to the
Securities and Exchange Board of India, Mumbai.

Place: Mumbai

D. RAVI KUMAR
CHIEF GENERAL MANAGER &
ADJUDICATING OFFICER

Date: 25.03.2015

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