Академический Документы
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October 2015
2• Our approach
3• Executive Summary
4• Detailed Observations
5• Process understanding
BRPL has taken over the assets of the closed Bihar Alloys & Steel Limited located at Patratu in Jharkhand. At present the company is having two
operational units:
► Wire and Rod Mill (WRM) – The first unit of steel plant at Patratu. It was commissioned in March 2010, with an annual production capacity of 0.6 MT
► Bar Mill (BRM) – The second unit was commissioned in March 2014 with an annual production capacity of 1.0 MT
Key features:
► Both mill are designed and set up by Morgan Construction Company India Pvt. Ltd., a group company of Siemens Ltd.
► “Billet” is the key raw material used by both mills, which is sourced from BRPL Raigarh
► Billets are heated in furnace and passed through various stages to produce coil and bars
► Apart from billets, both mills majorly consume, FO for heating of their furnaces. Prior to March 2015, LDO was used for furnace heating
► Stores and spares for both mills are OEM item and procured either by Morgan or Siemens or of make recommended by them
Objective:
► “Fraud vulnerability assessment of “Procurement to Pay” and “Dispatch process” at BRPL, plant
Coverage:
► Review will cover a sample of indigenous and imported purchases for key raw material and operational items for the period 01 October 2014 to 31
March 2015
1. Understanding of business model and key processes to assess areas for fraud vulnerability assessment
Discussion with key officials (for details refer to slide 8) Process walkthrough (for details refer to slide 8)
Billets LDO/ FO Services Stores & spares Scrap sale Gate entry Weighment
3. Data analytics and transaction testing to ascertain (for details refer to slide 9)
jobs as per land area purchased compete in bidding process and secure
2. Vendors ► 23 vendors appearing in the list of 48 vendors under 1.25 ► Favoured vendors are included in the list of
under “land seller category” doesn’t appear either as a land land seller, so that they do not have to
category seller or as their nominee in the records of the land compete in bidding process and secure
“land sellers” department. However, they have been awarded civil contract easily
4. Services ► Lack of transparency in vendor selection- Vendors are 1.23 ► Potential instance of vendor favouritism
selected and finalised by HOD Projects and HOD
Admin
► Vendor quotes invited post start of work by the vendor, 0.22 ► Potential instance of vendor favouritism
who was not part of the initial negotiations ► Managing quotations to show adherence to
► Extension of the work order at the same rate to the company policies
same vendor without negotiation with other vendors
► Adjustment entry of 179.64 mt was made in the SAP 0.59 ► Stock siphoned off can be covered up via
consumption to reconcile book stock with physical adjustment entry in consumption
stock
► Historical record of log book is not maintained - ► Audit trail missing to verify the actual consumption
► Calibration is not done on regular basis and - ► Possible chance of consumption data being
certificate provided for calibration is undated inaccurate
► In 7 cases of PO value more than 5 lacs, rate 1.56 ► Lack of fairness in rate negotiation
negotiation done by purchase department in violation
of the unit ‘s policy to refer such cases to rate
committee
8. Scrap ► Quotes invited and accepted from the same group of 0.06 ► Group vendors can rig the auction to gain a favourable
sale vendors price
9. Others ► GRN amount can be changed during invoice ► Payment in excess to receipt of material
processing
► Advance given to a vendor is adjusted manually ► Full payment made without settlement of advance
and there is no system in-built control of advance
adjustment during subsequent payments
► Lack of segregation of duty- Stores and purchase ► Dummy procurement and GRN entry can be passed to release
have single line of control. Stores head and payment
purchase head report to GM, Commercial
► Contract cell provided a list of 67 vendors, to whom the civil contracts are awarded on SOR basis without any bidding:
► As understood from discussion with contract cell officials, land department officials, HOD admin and HOD projects:-
A. As per company norms, for every acre of land acquired, company commits a job to the land seller or their nominee. However, no written
policy shared with us confirming the same.
B. There is a constraint on number of jobs that the company can provide. Incase company is unable to provide job to the land seller or their
nominee, company provides them with an alternative source of income through allocation of civil contracts to them on SOR basis, without any
bidding process
► As per SAP, company has spend INR 47 cr for purchase of land from the local residents
► Work order for sum of INR 37.18 cr has been awarded to vendors who are deemed to be land sellers (48 such vendors as confirmed by contract cell)
during the period Feb’13 to Mar’15
1. ► In 38 cases, number of jobs given to the family members of the land ► Extra jobs awarded in lieu of kickbacks Refer annexure
seller exceeds the eligibility of jobs as per land area purchased
► To validate the land seller list, maintained by contract cell, we performed the Test results
three way match on the following data: A
► Contract cell confirmed that the list of 19 vendors under category of non-land seller are local residents with muscle power or political influence
► To validate the list of 19 vendors maintained by contract cell, we performed the two way match on the following data:
Test results
•19 vendor names provided by contract cell who fall under A
the category of “vendors with political influence”
A 17
B
2
•Supporting documents provided by contract cell for 2
vendors out of the 19
B
1. ► SOR has been made basis the previous work order and as per contract cell ► Lack of transparency in SOR and vendors willing to work at
the rate is fixed for last two years that rate indicates that the rates may be on the higher side
► On sample basis, we verified the rates with previous work orders, but
couldn’t find the link to the source of the initial rate
► Vendor selection is done by HOD Projects solely or jointly with HOD ► Potential risk of vendor favouritism
Admin
2. ► Rate negotiation post start of work by the vendor. Vendor who ► Potential instance of vendor favoritism. The process of vendor selection
was awarded the work order was not part of initial negotiation and rate finalization by inviting quotations and negotiations with
vendors seem to be mere formality
WO No. Vendor Service PO Value Observations / Remarks
description (INR Cr.)
4571501893 M/s Om Construction Bending 0.06 ► Order created on 22 Feb 2015 with service start date as 09 Feb 2015.
Works TMT Bar However, as per 1st running bill paid against this order, the work had
already started on 28 January 2015 by Om Constructions
► It was observed that initially contract was awarded to Khushbu
Enterprise on 01 February 2015., which is post the work start date by
Om Constructions. No quotations received from Om Constructions at
that time. Khushbu Enterprise refused to accept the offer, hence fresh
quotations were invited
► Quote from Om Construction was received on 06 February 2015, and
the contract was finally awarded to Om Construction on 07 February
2015
4571502147 M/s Om Construction Bending 0.16 ► Extension of work order no. 4571501893
Works TMT Bar ► No vendor selection or rate negotiation carried out for the same
Total 0.22
3. ► Similar language and formats on quotations submitted by ► Potential instance of bid rigging. Vendors may submit their quotes in
different vendors collusion with each other resulting in work orders being awarded at
unfair prices
► Potential instance of managing quotations from vendors. Buyer may be
managing quotes to award business to favored vendor
WO No. Vendor Service description PO Value Observations / Remarks
(INR Cr.)
4571502159 M/s Om Material handling at 0.74 ► Quotes received from nine vendors
Construction Bar mill
Work ► Similar language and format of quotes submitted by:
► Hind Construction and M M Enterprise (In quotation of Hind
Construction, M M Enterprise is mentioned in the signatory
details)
► Sai Construction, Ram Prasad Yadav and Raj Enterprise(Prop.
Amar Yadav)
► Owner of Raj Enterprise (Prop. Prem Prasad) and Sai Construction are
brother-in-law
4571501830 Raj Enterprises Loading, shifting 1.38 ► Quotes received from three vendors
and stacking of wire
rod ► Similar language on quotes submitted by Raj Enterprises (Prop. Amar
Yadav) and M/s Sai Construction
4571501828 B K Enterprises Cold Inspection of 0.25 ►Quotes received from four vendors
Rounds
►Same address and mobile number mentioned on the letter head of quotes
submitted by M/s Raj Technical Services and Prashant Enterprises
Total 2.46
4. ► Service vendors likely to be related parties ► Potential risk of bid rigging. Vendors may submit their quotes in
collusion with each other resulting in work orders being awarded at
unfair prices
32322 Harsh Constructions Sanjay Prasad 0.21 1.11 ► Owner of Harsh Constructions and Om
II
32339 Om Constructions Pramod Prasad 0.19 1.20 Constructions are brothers
► Load cell (weighbridge) are installed at the charging point of furnace near CP-1 (Control Pulpit-1) to measure the weight of each billet charged into the
furnace. Weight is displayed in the online system of CP-1.
► The weight as displayed in the online system is recorded billet wise, in a manual log book maintained by CP-1. CP-1 makes entry for discharge of
billets in SAP as per log book records
► CP-4 makes the release in SAP for each billet discharged by CP1, if there is not hot out. In case there is a hot out, CP1 reverses the entry
► MIS reports being circulated to the senior management is prepared based on log book records
1. ► MIS report of CP-1 compared with ► Excess consumption booked in SAP ► Excess billets shown as consumed , stand risk of
consumption booked in SAP being siphoned off
2. ► Discussion with CP1 executives ► Historical record of log book is not ► Audit trail missing to verify the actual
maintained consumption
3. ► Calibration report checked ► Calibration is not done on regular ► Error in consumption recording
basis and certificate provided for
calibration is undated
Excess
Consumption as Consumption as
Operating unit Period Consumption in Value (INR cr.) Remarks
per SAP (in mt) per MIS (in mt)
SAP (in mt)
Bar Mill Oct’11 – Mar’12 72,925 72,389 536 1.77
Wire and Rod Mill Oct’11 – Mar’12 151,903 151,239 664 2.19
Total 224,828 223,630 1,198 3.96
► As understood from discussion with IA Head, Finance Head and Billet shop in-charge:-
► Physical verification was conducted on 07 January 2015 where-in shortage of 1,131.46 mt was found in physical stock.
► Physical verification was conducted only for the stock of WRM and not for Bar mill.
► Adjustment entry for consumption of 179.64 mt was booked in SAP on the following dates:
§ 26-Feb-12- 22.80 mt
► Write-off of 959.45 mt was done on 24 March 2015 based on the PV report of 07 January 2015
► The quantity of write-off in books was done for 1139.09 mt , however there was shortage of 1131.46 mt as per PV of 07 January 2015
Amount involved
Sr# Observation Risk implication
(in INR cr)
1. ► Physical verification was done only for WRM and not Bar 3.74 ► Possibility of physical stock of WRM lying in Bar
mill mill area
► Segregation of Billet yard mill wise is not sacrosanct
2. ► Adjustment entry of 179.64 mt was made in the SAP 0.59 ► Stock siphoned off can be covered up via
consumption to reconcile book stock with physical stock adjustment entry in consumption
1. ► GRN is done by PPC via MIGO option in SAP without gate ► Excess GRN shown to cover up the short receipt at Refer “Table (i)”
entry gate
► Quantity received as per GRN is1,458 mt more than
quantity received as per SAP “gate in-gate out” data
2. ► GRN quantity is recorded as per DO of BRPL Raigarh ► Unaccounted loss Refer “Table (ii)”
► GRN quantity is 184 tons less than DO quantity
1 2
Misappropriation in-transit Misappropriation at plant
Quantity of billets
Quantity of billets
dispatched by Raigarh
plant received by Patratu plant
Excess
consumpti
on booked
in SAP
Shortage
write-off
in books
► Flow meter is installed at the charging point of furnace near CP-1 (Control Pulpit-1) to measure the quantity of LDO consumed in heating the furnace.
Quantity in litres is recorded in the displayed system of CP-1.
► The quantity as displayed in the online system ,for each shift, is recorded in a manual log book maintained by CP-1.
► Daily MIS reports being circulated to the senior management is prepared basis the log book
► Consumption in SAP is booked by operations team based on the consumption figure received from CP1 over SMS and cross-verification with
measurement of the utility tank confirmed by the stores over phone
1. ► MIS report of CP-1 compared with ► Excess consumption booked in SAP ► Excess LDO shown as consumed , stand
consumption booked in SAP by CP-4 risk of being siphoned off
Bar Mill Oct’11 – Feb’12 2,165.39 2,121.24 44.15 0.24 For details refer
Wire Rod Mill Oct’11 – Feb’12 4,219.47 4,076.69 142.78 0.79 annexure 14
Total 6,384.86 6,197.93 186.93 1.03
2. ► Calibration report checked ► Calibration of flow meter is not done on ► Error in consumption recording
regular basis. Last calibration of flow meter
was done on 18 June 2014
3. ► Discussion with operations team ► Inconsistency in consumption booking ► Misappropriation of fuel from utility
► Consumption is usually booked as per the tank or short receipt of fuel by the utility
figure confirmed by CP1 over phone, but on tank shall remain undetected
some days the consumption is booked as per
figure confirmed by stores over phone to
match book stock
4. ► Discussion with CP1 executives and ► As confirmed by CP1, historical record of log ► Audit trail missing to verify the actual
operations team book is not maintained consumption
► Operations team books the consumption in
SAP as per figures confirmed over phone and
there is no written record basis which the
figures has been booked in SAP
► Flow meter is installed at the charging point of furnace near CP-1 (Control Pulpit-1) to measure the quantity of FO consumed in heating the furnace.
Quantity in litres is recorded in the displayed system of CP-1.
► The quantity as displayed in the online system ,for each shift, is recorded in a manual log book maintained by CP-1..
► Since FO is accounted in SAP in mt and the flow meter gives the reading in KL, the reading of flow meter is converted into mt by use of conversion
ratio. Both mills use different conversion factor. Bar Mill divides the flow meter reading by 0.91 to arrive at the consumption figure in mt, whereas
WRM multiplies the flow meter reading by 0.85.
► Daily MIS reports being circulated to the senior management is prepared basis the log book records
► Consumption in SAP is booked by operations team based on the consumption figure received from CP1 over SMS and cross-verification with
measurement of the utility tank confirmed by the stores over phone
1. ► MIS report of CP-1 compared with ► Excess consumption booked in SAP ► Excess FO shown as consumed , stand
consumption booked in SAP by CP-4 risk of being siphoned off
Excess
Consumption as Consumption as Value (INR
Name of the Mill Period Consumption in Remarks
per SAP (in mt) per MIS (in mt) cr.)
SAP (in mt)
Bar Mill Feb’12-May’12 3,326.97 3,297.68 29.31 0.13 For details refer
Wire Rod Mill Feb’12 – May’12 3,740.83 3,597.34 143.49 0.65 annexure 15
Total 7,067.80 6,895.02 172.80 0.78
2. ► Calibration report checked ► Calibration of flow meter is not done on ► Error in consumption recording
regular basis. Last calibration of flow meter
was done on 18 June 2014
3. ► Discussion with operations team ► Inconsistency in consumption booking ► Misappropriation of fuel from utility
► Consumption is usually booked as per the tank or short receipt of fuel by the utility
figure confirmed by CP1 over phone, but on tank shall remain undetected
some days the consumption is booked as per
figure confirmed by stores over phone to
match book stock
4. ► Discussion with CP1 executives and ► As confirmed by CP1, historical record of log ► Audit trail missing to verify the actual
operations team book is not maintained consumption
► Operations team books the consumption in
SAP as per figures confirmed over phone and
there is no written record basis which the
figures has been booked in SAP
5. ► Discussion with CP1 executives ► Inconsistency in conversion factor used by ► Variance between actual consumption
both mills for concersion freom kl to mt. and SAP consumption figures
40
1500
30
1000
20
Available
500 10
Unavailable 0
0
Pan TIN Bank Pan copy Other VAF II
Account documents
Available
Unavailable
Total no. of vendor code created by
purchase department = 1279 1. Vendor master
2. Inadequate
is not
comprehensive documentation 48 samples reviewed
1. ► Vendor master is not comprehensive ► Multiple code for same vendor can be created
► Important fields like pan no., contact no. ► Dummy code can be created
and address are not mandatory fields ► Out of 1890 vendors, 121
► Lack of review of vendor master vendors codes were found to
2. ► Conflict of interest- Vendor code ► Dummy code can be created for personal favour contain certain common details
creation is controlled by purchase ► Vendor master can be manipulated
department
3. ► Absence of periodic assessment of ► Poor quality vendors getting orders resulting in
vendor procurement of sub-standard material and services
► Absence of blacklisting of vendors
► Billets is the key raw material consumed by both the mills. This is a captive item and constitutes 95% of total material procurement.
► Besides billets, major procurement is of LDO/ FO which constitutes 2.74% of total material procurement. It is procured from public sector companies.
► Third major category is procurement of stores and spares, which constitutes 1.13% of total material procurement. Under stores and spares, major
procurement is of “OEM” items, which constitute 40% of the total stores and spares procurement.
Grand Risk
Material procurement Capex Opex Percent
Total Category Grand
Category %
Raw Materials - 2,203.51 2,203.51 95.07 Low Total
Fuel and Lubricants 0.29 63.13 63.42 2.74 Low OEM 10.25 39.06
Stores and Spares 16.80 9.44 26.24 1.13 High ARC 0.91 3.47
Power - 22.24 22.24 0.96 Low Others 15.08 57.47
Others 1.63 0.73 2.37 0.10 High Total 26.24 100.00
Total 18.73 2,299.05 2,317.78 100.00
1. ► OEM item is procured from single vendor single quote basis. There ► High cost of procurement
is no rate negotiation
► No quotation obtained from the manufacturer
Date PO # Vendor Vendor Name PO_Qu New Rate Old Rate Increased cost
antity (INR per (INR per (INR cr)
in ltrs ltr) ltr)
1-Feb-12 4571005232 17035 MODI SALES AGENCY 29,120 135.00 65.00 0.20
16-Feb-12 4571005291 17035 MODI SALES AGENCY 7,696 135.00 65.00 0.05
30-Mar-12 4571005524 17035 MODI SALES AGENCY 4,160 134.50 65.00 0.03
Total 0.29
2. ► Contract has been awarded to a vendor different from the vendor ► Potential instance of vendor favouritism
approved by the rate committee
PO# 4571004890 dated 19 November 2014 for amount INR 5.10 lacs
Remarks
► Buyer told us that order was given to Lakhotia since Volta had submitted dealership certificate of Lakhotia and not of the original
manufacturer, Gates Unitta Asia.
► However, as per dealership certificate of Lakhotia, it’s dealership of Gates has expired on 31st December, 2010 whereas this
order was awarded in the month of Nov'11. The expiry date on the certificate has been manipulated to 2016.
3. ► As per process flow explained to us by Purchase Head, vendor and ► Potential cases of lack of fairness in rate negotiation
rate finalisation is done by rate committee for every procurement of
INR 5 lacs and above
► Exception to the above process was found in sample cases reviewed
prior to mid December 2014
Date of Amount
Sr# PO # Vendor name Approved by
creation (INR cr)
1. 22-Oct-11 4571004714 Amardeep Steel Center 0.09 Purchase Head, Aml Kumar Roy
2. 08-Dec-11 4571005018 Amardeep Steel Center 0.12 Purchase Head, Aml Kumar Roy
3. 15-Nov-11 4571004848 Gontermann Peipers (India) Limited 0.33 Purchase Head, Aml Kumar Roy
4. 11-Nov-11 4571004819 Sanura Packsys 0.53 Purchase Head, Aml Kumar Roy
5. 10-Dec-11 4571005039 Technomech Solutions 0.30 Purchase Head, Aml Kumar Roy
6. 27-Oct-11 4571004743 Wendt India Limited 0.13 Purchase Head, Aml Kumar Roy
7. 24-Oct-11 4571004723 WMI Konecranes India Limited 0.06
Total 1.56
► During offline auction for sale of 15 kl of used and waste oil, quotes were received from three parties Meghani Enterprises, North East Lubricants and
Mangalam Lubricants (P) Ltd.
► It was observed that Meghani Enterprises and North East Lubrica Pvt Ltd have same owner. The auction was closed in favour of North East Lubrica
Pvt Ltd on 13 October 2014 @ INR 34.50 per ltr. No evidence of negotiation with the only non-related vendor Mangalam observed.
► On 20 October 2014, revised auction was done for the same material and a new bidder, Shrishti Lube (India) Pvt Ltd was included apart from the
earlier bidders. The auction was closed in favour of Shrishti Lube @ INR 35.60 per ltr
► On 26 November, 2014, earlier decision was superseded by new decision in favour of Meghani Enterprises @ INR 40.50 per ltr. No subsequent trail of
negotiations with Shrishti Lube and Mangalam could be found.
► The concerned official who dealt with scrap sale knew that both Meghani Enterprises and North east Lubrica Pvt Ltd is one and the same party. The
said vendors were also recommended by that official to Metal junction for e-auction
1. ► Quotes invited and accepted from same group of vendors ► Group vendors can rig the auction to gain a favourable price
1. ► GRN amount can be changed during IV processing ► Payment in excess to receipt of material
3. ► Advance given to a vendor is adjusted manually and there is no ► Full payment made without settlement of advance
system in-built control of advance adjustment during subsequent
payments
4. ► Lack of segregation of duty- Stores and purchase have single line ► Dummy procurement and GRN entry can be passed to release
of control. Stores head and purchase head report to GM, payment
Commercial
No PO creation by
Purchase
Rate negotiation and vendor department
User Budget finalization
department exists
Release of purchase order in
Order SAP*:
Yes value
YES NO` a. Up to INR 5 lacs – HOD
>= Purchase
PR creation INR 5 b. INR 5 lacs to INR 50 lacs – HOD
by user lacs Purchase and HOD Projects
department
c. Above INR 50 lacs – HOD
(* In case PO amount exceeds INR1 lakh, PO Rate Purchase Purchase, HOD Projects and
documents will be released post audit clearance) committee Head Plant Head
Vendor Code is
User raises purchase requisition (PR) which flows to generated against
purchase department (PD)
vendor name in SAP
by two “buyers” in
purchase department
Details provided in VAF- designated for the
I & VAF-II is checked purpose
Based on material, PR is routed to particular buyer in with the supporting
PD documents provided with
them. In case of any
discrepancies, purchase /
user department is asked
to revert for rectification /
necessary documents
Buyer identifies Vendor
prospective suppliers code Yes No new
through existing vendors/ already code
references / search / exist in required
business directories SAP
No
Verification / Quality
Tare weight of vehicle
check of material by the
Quality check user
and GRN
posting Gate out of the vehicle
by Stores / PPC in SAP
Approval / Rejection of system
GRN by the user
► The following points should be borne in mind while reading these observations:
► The engagement was carried out in accordance with our engagement letter dated xxxxxx and the terms & conditions mentioned therein
► The scope, coverage and approach mentioned in this report was arrived at based on discussions with Mr. Sudesh Mehra
► All matters, issues and information referred to in this report arise from our discussions with identified personnel involved in
overseeing/managing the operations at the Client
► Our findings are based on the sample transactions reviewed by us and are based on the information/documents (including photocopies/scan
copies and emails) furnished to us and to the extent reviewed by us. Though our endeavor was to analyze/review the documents in their
complete perspective and present our findings thereupon, such findings are based only upon data/information to the extent reviewed by us.
Should additional relevant statements or documents be made available subsequently, it may be necessary to revisit the findings accordingly
► We have relied on the documents/information furnished to us by the Client and its officials. It may not be possible to check the accuracy and
authenticity of all the information provided to us. We were provided only with the photocopies of documents in some cases and our
observations are based on analysis of those documents.
► This review is in the nature of a fact finding engagement and is not a re-audit / audit of the accounts balances/financial statements or parts thereof.
The procedures performed for this fact finding review do not constitute an audit conducted in accordance with Indian GAAS or any other national or
international auditing or accounting standards.
► The sufficiency of the work steps/procedures is solely the responsibility of the management. Consequently, we make no representation regarding
the sufficiency of the procedures performed either for the purpose for which the report was requested or for any other
► Our findings cannot be taken to be exhaustive, in view of the fact that only specific sample of transactions were reviewed. Our findings are based on
information and documents to the extent provided to us. For this reason, it is possible that our observations may have been different had we
reviewed the whole documentation/ information on a particular matter
► Our scope did not require and our work steps were not tailored to identify regulatory / statutory non-compliances. Our observations on statutory
regulations, if any, do not purport to be an opinion, expert or otherwise. It merely represents our understanding of the facts and possible
interpretations of law. Management is advised to take expert opinion before initiating any action
► Management shall be fully and solely responsible for applying independent judgment, with respect to the findings included in this fact finding
report, to make appropriate decisions in relation to future course of action, if any. MMC shall not take responsibility for the consequences resulting
from decisions based on information included in the report
► While MMC made appropriate efforts to ensure confidentiality and discreteness of the engagement, employees of the Client or the Subject (or the
Target/Entity or the Individual) may have come to know about the same. MMC will not be liable for any loss/damage of whatsoever nature arising
due to such disclosure/ knowledge /awareness
► Our findings in this report are based on the fieldwork which was substantially completed as on 14 February 2015. We undertake no responsibility to
update this report for events or circumstances occurring after the date of completion of fieldwork
► Under no circumstances shall we be liable, for any loss or damage, of whatsoever nature, arising from information being withheld or concealed from
us or misrepresented to us by any person/agency to whom information requests were made.
► We are not intending or agreeing to act as an expert witness or provide an expert opinion or expert testimony during the course of any legal
proceeding or be deemed as representing or advocating any position on behalf of any party in any legal matter or proceeding
► This report is furnished solely for the information of the Client management with its request to MMC to conduct a fact finding review vide
engagement letter dated XXXX and should not be used, circulated, quoted or otherwise referred to for any other purpose, nor included or referred to
in whole or in part in any document without our prior written consent
► MMC assumes no responsibility to any user of the report other than the Client. Any other persons who choose to rely on our report do so entirely at
their own risk
► We have not given any part of our report to the process owners at the Client/Target, a practice we sometime adopt to be able to identify information,
if any, in our reports that may not be factually correct, if any. For this reason, it is possible that there are factual inaccuracies where we have not
been provided with the complete picture/information/ documentation on a particular matter by the process owners
► Please note that limited information was made available to us during the engagement, and the project cannot be interpreted as being complete in terms
of the scope agreed in our engagement letter. Following relevant information was not available/ provided:
► Land seller list for the period 01 January 2015 to 31 March 2015
► Monthly calibration report for Bar Mill and WRM