Thomas Cook (India) Limited has informed the Exchange about Investor Presentation
May 24, 2022
The Manager, Listing Department BSE Limited Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai – 400 001 Scrip Code: 500413
The Manager,
Listing Department National Stock Exchange of India Limited Exchange Plaza, 5th Floor, Plot No. C/1, G Block, Bandra‐Kurla Complex, Bandra (E), Mumbai – 400 051 Scrip Code: THOMASCOOK
Fax No.: 2272 2037/39/41/61
Fax No.: 2659 8237/38
Dear Sir/ Madam,
Sub: Analysts and Investors Conference Call presentation for the quarter and year ended March 31, 2022
In furtherance of our intimation date d May 21, 2022 giving intimation on the “Q4 & FY22 earning Conference Call for the analysts and investors”, please find enclosed the investor presentation on the performance of the Company for the quarter and year ended March 31, 2022, to be presented before Analysts and investors on Wednesday, May 25, 2022.
The presentation https://www.thomascook.in/
is also being made available on
the Company's website at
This is for your information and records.
Thank you.
Yours faithfully,
For Thomas Cook (India) Limited
Amit J. Parekh Company Secretary and Compliance Officer
Encl: a/a
TCIL Q4 & FY22 Earnings Presentation
Thomas Cook (India) Limited (TCIL)
Thomas Cook India Group at a glance
Spread across 25 countries across 5 continents
Integrated business model creates value through scale and flexibility
Integrated business model creates value through scale and flexibility
Premier brand portfolio with multi-format strategy
Business is uniquely positioned to provide true value for our customers and shareholders
2
Thomas Cook India Group at a glance
Foreign Exchange & Related Services
• Retail & Wholesale • Forex Cards • Remittance
Digital Imaging Solutions
• Digiphoto Entertainment Imaging Ltd. (DEI)
Travel & Related Services
Leisure Hospitality & Resorts
• B2C: Leisure Holidays (Domestic & Outbound)
Sterling Holiday Resorts Limited
• B2B: MICE, Corporate Travel, DMS (India
+ International)
3
3
•4 BRANDSEST.1963EST.1961EST.1994EST.2017•24 SALES /REPRESENTATIVE OFFICES ACROSS THE GLOBEUSA·Brazil·UK·France·Germany·Hungry·Italy·Portugal·Russia Spain·South Africa·Malaysia·Lebanon·Japan·China •TOP 5 SOURCE MARKETS UK · Russia· Germany· France· USA •LARGEST SUPPLIERS TO TOP HOTEL CHAINS IN INDIA•KEY ACCOUNTS Leveraging technology to build scale & resilience
CRM powered lead management and propensity model for higher conversion
Virtual branches improved CX
Location agnostic Virtual Agents
Robotic Process Automation enabled faster & accurate process
Use of AI to reduce TAT
Empowering Customers & Vendors
Enhanced Customer experience
Improved TAT
Product Innovation
Dynamic Customization
Source of savings
New efficiencies
Optimized Scale
Technology & Platform Innovation
Enhanced Cybersecurity & Compliance
Reduced DSO
Streamlined processes
Building competitive advantage
Innovative models
Omni channel Approach
Virtual Branches
Cross utilize resources
Modernizing core technology capabilities
4
Technology Initiatives
Pre
Astra for Omnichannel
Post
Pre
Canvas for Holidays
Post
Pre
Mudra for FX
Post
Only B2C website
Omni channel tool
Unique frameworks for TCIL, SOTC
Single system
Documents stored physically
Document Management System (DMS)
Fixed land packages & flight sold separately
Real time flights to land packages
Offline customer service management
Customization via email communication
Dynamic packaging
Only static content for Holidays
Dynamic API content
Adhoc updation of Visa
Manual Vendor Payments & Advances
Customer self serve
Staff associated with physical store & location
Virtual branch process via CRM & Dialler
Whiteboard system
Agent business via email with branch staff
FX Mate B2B tool
Vendor Portal + self service via NewGen
Corporates managed via email & implants
Corporate Booking Tool
Paper based/offline invoices
E-Invoicing
Offline paper based KYC
Integrated Virtual KYC
Pre
Mantra for MICE
Post
Product accessibility limited to individual computers
Unified product repository: faster TAT & accessibility
Sales Funnel: High human intervention driven
Funnel on CRM with live and accurate projections
Core system was outdated; tedious legacy workflows
Smarter workflows
End customer servicing: analog
Gateway CSS: End to End digital interaction
Direct payment collections: Manual
Online direct payment mgmt
5
Corporate Travel
Click to Book(C2B)
Online Booking tool
Eva: Enable online bookings and self serve via Bots too
Happay: Integrated expense management system
Concur: for global clients
Mobile App: traveler self serve
iBook
E-Invoicing
eSubmission which is integrated with customers ERP
Robotic QC to enable faster reporting
Leveraging our Omnichannel Approach
HOW?
Multi-dimensional model
WHY?
Mobile Apps
Virtual Branch
Website
In store Branch
Call centre
Chat Bots
6
Choice
Source of differentiation
Higher Customer Satisfaction
Uniform Experience
Truly Integrated
Channel Agnostic
Holidays
Forex
Value Added Services
Customized
Seamless
Real-time data
Contactless
Convenient
Self-service
7
Key Highlights: Q4 FY22
•
•
•
Thomas Cook (India) Limited (TCIL) announces strong results for Q4 FY22 despite Omicron wave and delayed reopening of Indian skies Consolidated Income from Operation for the quarter grew by 46% from Rs. 3,573 mn for Q4 FY21 to Rs. 5,221 mn in Q4 FY22 Reports Consolidated Operating EBITDA of Rs. 239 mn in Q4 FY22 Vs loss of Rs. 361 mn in Q4 FY21
TCIL Standalone •
Income from operation for the quarter grew by 25% from Rs. 636 mn in Q4 FY21 to Rs. 794 mn; Margins for the Holiday business & Foreign Exchange grew by 326 bps and 29 bps respectively Operating EBITDA of Rs. 28 mn in Q4 FY22 Vs loss of Rs. 74 mn over Q3 FY22, strong sales recovery by Forex 56%; Corporate Travel: 50% Vs pre-pandemic levels The trend continued in April ‘22 with Foreign Exchange, Corporate Travel and Domestic Holidays registering a recovery of 62%, 81% and 85% of pre-pandemic sales respectively The Company continued its focus on cost prudence with reduced costs for Q4 FY22 at Rs. 767 mn, registering a 51% saving from pre-pandemic levels of Q4 FY20
Group Companies report sustained profitability at EBITDA level – Leisure Hospitality & Resorts business (Sterling Holidays) for 6th successive quarter; Digiphoto Entertainment Imaging Ltd. (DEI) and Desert Adventures for 2nd successive quarter and Private Safaris (East Africa) turned profitable this quarter at EBITDA
•
•
•
•
8
•
•
•
•
•
Cash and bank balances at a consolidated level as on 31 March 2022 is at Rs. 6,399 mn
At a consolidated level the Company continued its focus on cost prudence with reduced costs for Q4 FY22 at Rs. 2754 Mn., registered 37% saving at pre- pandemic levels in Q4 FY20
CRISIL reaffirmed its ratings of CRISIL A+/Negative and Short-term rating of CRISIL A1, reflecting the Company’s leadership in Forex & Travel Services, rapid recovery and Balance Sheet strength
The Company’s sustained focus on technology delivered end-to-end digitization across its businesses, including B2C and B2B self-booking/ servicing tools and dynamic customization, vendor management and automated accounting/payment solutions. The digital acceleration serves to further augment the Company’s omnichannel model towards an enriched customer experience; cost and efficiency benefits
Conversion of Optionally Convertible Cumulative Redeemable Preference Shares: 133 mn balance OCCRPS converted into 28 mn equity shares of Re. 1/- each at the approved rate of Rs. 47.30 per equity share. Upon conversion, the promoter equity shareholding would increase to 72.34% from the present 70.58%
Business wise recoveries from pre-pandemic Levels
Forex
01
Corporate Travel
01
Q4 FY22
56% Recovery from Q4 FY19
Q1 FY23 (e)
63% Recovery from Q1 FY20
Q4 FY22
46% Recovery from Q4 FY19
Q1 FY23 (e)
84% Recovery from Q1 FY20
Domestic Holidays
01
International Holidays
01
MICE
01
Q4 FY22
63% Recovery from Q4 FY19
Q1 FY23 (e)
108% Recovery from Q1 FY20
Q4 FY22
16% Recovery from Q4 FY19
Q1 FY23 (e)
19% Recovery from Q1 FY20
Q4 FY22
9% Recovery from Q4 FY19
Q1 FY23 (e)
38% Recovery from Q1 FY20
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Update on Business operations : Forex
Revenue from Operations Rs mn
380
277
EBIT Rs mn
55
36
Q4FY22
Q4FY21
Q4FY22
Q4FY21
1,104
1,084
141.1
FY22
FY21
FY22
FY21
(32.2)
•
Foreign Exchange: Strong turnover growth of 80% compared to Q4 FY21
10
Update on Business operations : Travel & Related Services
Revenue from Operations Rs mn 2,709
1,887
EBIT Rs mn
(465)
(648)
Q4FY22
Q4FY21
Q4FY22
Q4FY21
10,470
3,489
FY22
FY21
11
Travel & Related Services
•
•
Domestic Holidays: 43% growth in sales Vs. Q4 FY21
Corporate Travel: 155% growth in turnover Vs. Q4 FY21
• MICE: 36% growth in sales Vs. Q4 FY21
DMS (Destination Management Service) Business: • The quarter witnessed sales improvement in select DMS entities with further easing of travel restrictions and
increased vaccinations.
• Dubai based DMS - Desert Adventures witnessed a healthy Q4 FY22 sales with continuation of demand in high
season and Expo 2020 Dubai; Business from UK, LATAM and US markets was encouraging.
• Private Safaris (East Africa) reported sales were healthy and led by charter business and adhoc groups. • AlliedTPro - in US has started witnessing encouraging sales primarily driven by FIT (Free Independent
Travellers)
• Asian Trails Q4 FY22 continued to see very limited business in APAC region due to on-going travel
restrictions/obstacles and partially closed borders, however there is progressive easing of travel restrictions in destinations like Singapore, Thailand and Vietnam
Partnerships: • Appointed as Preferred Sales Agents (PSA) for the Indian market by Emirates Holidays, the tour operating arm
of Emirates Airlines
• Thomas Cook collaborated with Mastercard and HDFC Bank for exclusive Expo 2020 Dubai holiday promotion • Thomas Cook partnered with Singapore tourism Board, Singapore Airlines and Changi Airport for a joint
marketing activity for air-inclusive holidays to Singapore
• Partnered with Abu Dhabi Tourism and Yas Island for jointly promoting the destination to Indian travellers
(2,512)
(3,113)
Awards: •
‘Innovation in Omni-experience’ Award at International Data Corporation’s (IDC) Industry Innovation Awards 2021 won by Thomas Cook India & SOTC
FY22
FY21
• Thomas Cook India and Singapore Tourism Board’s virtual game to promote Singapore won a silver at IAMAI
India Digital Awards 2022
• Thomas Cook India and SOTC were honoured at CIO100 Award for digital innovation
Key Initiatives- Holidays
12
Update on Business operations: Leisure Hospitality (Sterling Resorts)
Revenue from Operations Rs mn
853
722
EBIT Rs mn
327
187
Key Indicators
Q4FY21
Q4 FY22
FY21
FY22
Cumulative member base
86,917
86,324
86,917
86,324
Resort Occupancy
ARR
54%
4,259
52%
5,070
43%
52%
4,306
5,159
Key Highlights
•
•
•
•
•
•
Sterling Holidays Resorts: EBIT of Rs. 187 Mn. in Q4 FY22, despite the impact of Omicron during the quarter. For FY22 EBIT grew by almost 7 times to Rs. 582 Mn. (from Rs. 77 Mn. in FY21).
FY22 operating EBITDA margin at 37% driven by strong restructuring and cost optimization measures adopted in the previous year and in the current year
Resort Revenues grew by 73% YoY; Average Room Rates (ARR) grew by 19% YoY;
Occupancy improved to 52% and increased 9% YoY
Membership EBITDA grew by 9% YoY based on the lowered cost of acquisition as the company continued its focus on acquiring members
Operating Free Cash Flow (OFCF) improved by 25% YoY
Q4FY22
Q4FY21
Q4FY22
Q4FY21
2,708
582
1,717
77
FY22
FY21
FY22
FY21
13
Update on Business operations
Leisure Hospitality (Sterling Resorts)
Hill Station
Beach
Waterfront
Heritage
Jungle
Adventure
Rishikesh De Laila Srinagar
Atharva Jaipur
Corbett Kanha Sariska
Puri
Rudra Gir
Sajan (NT) Durshet (NT) Dabhosa (NT) Kundalika (NT)
GIR
NATURE TRAILS
Palavelli Godavari Alleppey
Guruvayur Thiruvanna malai Madurai
Thekkady
Wayanad
North
Mussoorie Nainital Kufri Manali
East
Darjeeling Gangtok Kalimpong
West
Lonavala Mount Abu
Goa –Varca Karwar
Anaikatti Munnar Yelagiri Yercaud Ooty – Elk Hill Ooty – Fern Hill Kodai – Lake Kodai - Valley
South
14
38 Resorts: 15 Owned resorts, 10 Leased resorts & 13 Management contract
Number of Rooms: 2335
SRINAGAR
MANALI
MUSSOORIE
RISHIKESH
NAINITAL
KUFRI
JAIPUR
CORBETT
DARJEELING
GANGTOK
SARISKA
MOUNT ABU
LONAVALA
GOA
KARWAR
KANHA
PURI
GODAVARI
WAYANAD
GURUVAYUR OOTY
YELAGIRI
YERCAUD
TIRUVANNAMALAI
ANAIKATTI
MUNNAR
ALLEPPEY
KODAIKANAL
THEKKADY
Update on Business operations : Digiphoto Entertainment Imaging Ltd. (DEI)
Revenue from Operations Rs mn
1,409
EBIT Rs mn 80
Key Highlights
557
Q4FY22
Q4FY21
4,600
1,661
FY22
FY21
Q4 FY22
-133 Q4 FY21
•
•
Income from operations has increased by 153% YoY from Rs. 557 mn in Q4
FY21 to Rs. 1,409 mn In Q4 FY22, and has reported profit at EBIT level of Rs.
80 mn in Q4 FY22 as against loss of Rs. 133 mn in Q4 FY21 and profit of Rs.74
Mn. in Q3 FY22
The quarter saw the launch of several new partnerships like LEGOLAND
Korea Resort (South Korea), Andamanda Phuket (Thailand), Attack on Titan -
(65.1)
Exhibition (Singapore), The Storm Coaster, Waldorf Astoria (UAE), Bounce
Inc. (India) an Aquasplash (DR Congo), Adventure Park (UAE), Sky Walk – KL
Tower (Malaysia), Holiday Inn (Maldives) and Trans Studio Surabaya
(Indonesia)
•
DEI renewed its imaging operation terms with 10 partners during the quarter
(493.4)
FY22
FY21
Imaging Services & Solutions
Experiences first. Memories second
Global Presence
3 Continents 18 Countries 125+ Partners
Marquee Partnerships
Trusted by leading brands in the world
Technology expertise to drive business outcomes
Aligned with evolving consumer, industry & technology trends
An Evolved Guest Journey
Delivering an integrated and frictionless guest experience
15
Q4 & FY22 Performance
16
Results – Q4 FY22 Consolidated
Particulars (Rs. mn)
Q4 FY22
Q4 FY21
Particulars (Rs. mn)
Q4 FY22
Q4 FY21
Income from Operations
5,220.6
3,573.2
Other Income
67.2
443.2
Total Income from Operations
5,287.9
4,016.4
Total Costs
EBITDA
5,295.7
4,172.3
(7.8)
(156.0)
Operating EBITDA*
239.2
(361.0)
Depreciation / Amortization
307.6
331.5
EBIT
(315.4)
(487.5)
Interest and Finance cost
172.5
156.3
PBT before exceptional
(487.9)
(643.7)
Exceptional Items
(29.8)
(37.3)
PBT
Tax expense
PAT
*Excluding Quess MTM and dividend
17
(517.7)
(681.0)
(4.8)
(474.8)
(512.9)
(206.2)
Segment Revenue
(a) Financial Services
(b) Travel and Related Services
380.5
277.2
2,708.8
1,886.9
(c) Leisure Hospitality & Resorts business
722.3
852.7
(d) Digiphoto Imaging Services
Total
Segment Results (EBIT)
(a) Financial Services
(b) Travel and Related Services
1,409.0
556.5
5,220.6
3,573.2
54.7
35.6
(464.7)
(647.5)
(c) Leisure Hospitality & Resorts business
187.3
327.4
(d) Digiphoto Imaging Services
Total
Less : Interest and Finance expenses
Less : Common Expenditure
PBT before exceptional
Add: Exceptional Items
PBT
79.9
(132.8)
(142.8)
(417.3)
172.5
172.6
156.3
70.0
(487.9)
(643.7)
(29.8)
(37.3)
(517.7)
(681.0)
Results – FY22 Consolidated
Particulars (Rs. mn)
FY22
FY21
Particulars (Rs. mn)
FY22
FY21
Income from Operations
18,882.5
7,950.0
Other Income
578.1
1,507.4
Total Income from Operations
19,460.6
9,457.4
Total Costs
EBITDA
20,758
11,482
(1,297)
(2,025)
Operating EBITDA*
(1,273)
(2,757)
Depreciation / Amortization
1,286.7
1,480.5
EBIT
(2,583.7)
(3,505.1)
Interest and Finance cost
615.8
622.1
Segment Revenue
(a) Financial Services
(b) Travel and Related Services
1,103.6
1,083.6
10,470.5
3,489.0
(c) Leisure Hospitality & Resorts business
2,708.0
1,716.7
(d) Digiphoto Imaging Services
Total
Segment Results (EBIT)
(a) Financial Services
(b) Travel and Related Services
4,600.4
1,660.6
18,882.5
7,950.0
(32.2)
141.1
(2,511.8)
(3,113.4)
(c) Leisure Hospitality & Resorts business
581.9
77.3
(d) Digiphoto Imaging Services
(65.2)
(493.4)
PBT before exceptional
(3,199.5)
(4,127.1)
Total
Exceptional Items
(29.8)
(37.3)
Less : Interest and Finance expenses
PBT
Tax expense
PAT
(3,229.3)
(4,164.4)
(683.1)
(1,212.6)
Less : Common Expenditure
PBT before exceptional
Add: Exceptional Items
(2,546.2)
(2,951.8)
PBT
(2,027.3)
(3,388.5)
615.8
556.3
622.1
116.7
(3,199.5)
(4,127.1)
(29.8)
(37.3)
(3,229.3)
(4,164.4)
*Excluding Quess MTM, dividend and one time reversal of provisions (FY21)
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Management comments- Q4 & FY22
Mr. Madhavan Menon, Managing Director, Thomas Cook (India) Ltd., said,
“Despite the Omicron wave reducing the quarter to 45 days and the reopening of
Indian skies for scheduled international flights only on March 27th, our teams
have delivered a commendable performance this quarter with an operating
EBITDA of Rs. 239 Mn. The Group’s strong performance was led by Foreign
Exchange, Business Travel, Sterling Holidays, DEI & Desert Adventures. With other
markets opening up, we expect the other Group companies to stage quick
recoveries too.
Our focus on sustainable cost management balanced with a thrust on technology
over the past three years is delivering results in the form of speed, productivity
and improved customer experience. Recovery is accelerating continually, with our
Foreign Exchange, Corporate Travel and Domestic Holidays businesses registering
an estimated sales recovery of 57%, 81% and 99% of pre pandemic levels as of end
May 2022 and strong pipelines for the coming quarter and beyond.”
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Contact Us
For further information please contact
Debasis Nandy President and Group CFO Tel: +91 22 4242 7000 Email: Debasis.Nandy@thomascook.in
Urvashi Butani General Manager- Investor Relations Tel: +91 22 4242 7095 Email: Urvashi.Butani@thomascook.in
Corporate Identification No: L63040MH1978PLC020717 Investor e-mail id: sharedept@thomascook.in Regd. Office: Thomas Cook India Ltd, Marathon Futurex, A Wing, 11Th & 13th Floor, N.M. Joshi Marg, Lower parel (E), Mumbai 400013 Website : www.thomascook.in
About Thomas Cook (India) Limited: Set up in 1881, Thomas Cook (India) Ltd. (TCIL) is the leading integrated travel and travel related financial services company in the country offering a broad spectrum of services that include Foreign Exchange, Corporate Travel, MICE, Leisure Travel, Insurance, Visa and Passport services and E-Business. It operates leading B2C and B2B brands including Thomas Cook, SOTC, TCI, SITA, Asian Trails, Allied T Pro, Australian Tours Management, Desert Adventures, Luxe Asia, Kuoni Hong Kong, Sterling Holiday Resorts Limited, TC Forex, Distant Frontiers, TC Tours, TC Visa, Travel Circle International Limited, Ithaka, Digiphoto Entertainment Imaging (DEI), Private Safaris East & South Africa.
As one of the largest travel service provider networks headquartered in the Asia-Pacific region, The Thomas Cook India Group spans 29 countries across 5 continents, a team of over 9700 and a combined revenue in excess of Rs. 6718.7 Cr. (over $ 0.96 Bn.) for the financial year ended March 31, 2019.
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Disclaimer
This presentation has been prepared by Thomas Cook (India) Limited (“Company") solely for information purposes without any regard to any specific objectives, financial situations or informational needs
of any particular person. This presentation may not be copied, distributed or disseminated, directly or indirectly, in any manner. Failure to comply with this directive may result in a violation of the applicable law in certain jurisdictions.
This presentation does not constitute or form part of and should not be construed as, directly or indirectly, any offer or invitation or inducement to sell or issue, or any solicitation of any offer to purchase or subscribe for, any securities of the Company by any person in any jurisdiction, including in India, nor shall it or any part of it or the fact of its distribution form the basis of, or be relied on in connection with, any investment decision or any contract or commitment therefore
This presentation contains statements that may constitute forward looking statements. These statements include descriptions regarding the intent, belief or current expectations of the Company or its
directors and officers with respect to the results of operations and financial condition of the Company. These statements can be recognized by the use of words such as ''expects", "plans", 'will", "estimates", "projects", or other words of similar meaning. Such forward-looking statements are not guarantees of future performance and involve risks and uncertainties, and actual results may differ materially from those in such forward-looking statements as a result of various factors and assumptions which the Company believes to be reasonable in light of its operating experience in recent years. The risks and uncertainties relating to these statements include, but not limited to, risks and uncertainties, regarding fluctuations in earnings, our ability to manage growth, competition, our ability to manage our international operations, government policies, regulations, etc. The Company does not undertake any obligation to revise or update any forward looking statement that may be made from time to time by or on behalf of the Company including to reflect actual results, changes in assumptions or changes in factors affecting these statements. Given these risks, uncertainties and other factors, viewers of this presentation are cautioned not to place undue reliance on these forward looking statements. This presentation may contain certain currency exchange rates and the same have been provided only for the convenience of readers. No representation is made that the Rupee amounts actually represent such USD amounts or could have been, or could be, converted into USD at the indicated rates
This presentation is not a complete description of the Company and may not be all inclusive and may not contain all of the information that you may consider material. The information contained in this presentation has not been independently verified. No representation, warranty, guarantee or undertaking, express or implied, is or will be made as to, and no reliance should be placed on, the accuracy, completeness, correctness or fairness of the information, estimates, projections and opinions contained in this presentation. Viewers of this presentation must make their own assessment of the relevance, accuracy and adequacy of the information contained in this presentation and must make such independent investigation as they may consider necessary or appropriate for such purpose. Such information and opinions are in all events not current after the date of this presentation. Further, past performance is not necessarily indicative of future results. Any opinions expressed in this presentation or the contents of this presentation are subject to change without notice. This presentation should not be construed as legal, tax, accounting, investment or other advice
Any person placing reliance on the information contained in this presentation or any other communication by the Company does so at his or her own risk and none of the Company nor any of its affiliates,
advisers or representatives, any placement agent, promoters or any other persons that may participate in any offering of any securities of the Company shall have any responsibility or liability whatsoever, whether arising in tort, contract or otherwise, for any errors, omissions, insufficiencies or inaccuracies in such information or opinions or for any loss, cost or damage suffered or incurred howsoever arising, directly or indirectly, from any use of this presentation or its contents or otherwise in connection with this presentation
This presentation has not been and will not be registered as a prospectus with any Registrar of Companies in India. This presentation is not a prospectus, a statement in lieu of a prospectus, an offering circular, an advertisement, a private placement offer letter or an offer document under the Companies Act, 2013 and the rules made thereunder, the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2009, as amended, or any other applicable law
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