Clarification 13

                   Guidelines for ADR/GDR issues by the Indian Companies

1.         A scheme for issue of Foreign Currency Convertible Bonds and Ordinary Shares (Through Depository Receipts Mechanism) was notified by the Government of India in November, 1993. Revisions/modifications in the operative guidelines for Euro-issues are announced from time to time.

2.         With a view to further liberalising the operational guidelines and in particular track record scrutiny of the ADR/GDR proposals and approval mechanism various options were considered by the Government. Given the fact that investments through ADR/GDR being risk capital, it has been decided that the track record scrutiny process for ADR/GDR issues and the two stage approval by the Ministry of Finance, Department of Economic Affairs could be dispensed with.

3.         The following guidelines for ADR/GDR issues, in continuation of the Notification of November, 1993 (amended in November, 1999) shall come into effect from the date of issue of these guidelines. These guidelines will also extend to proposals which have already been filed with the Ministry of Finance as also in cases where an ‘in principle’ approval has been issued by the Ministry of Finance, Department of Economic Affairs. These modified guidelines will, however, not extend to Foreign Currency Convertible Bond (FCCB) issues which will continue to be governed by existing guidelines. Further, the issue of ADRs/GDRs under the liberalised guidelines would be only against expansion of the existing capital base through issuance of fresh equity shares as underlying shares for ADRs/GDRs.

4.         ADR/GDR are reckoned as part of Foreign Direct Investment (FDI). Accordingly, such issues would need to conform to the existing FDI policy and only in areas where FDI is permissible.

5.         Approvals

5.1       Indian Companies raising money through ADRs/GDRs through registered exchanges would henceforth be free to access the ADR/GDR markets through an automatic route without the prior approval of the Ministry of Finance, Department of Economic Affairs. Private placement of ADRs/GDRs would also be eligible for the automatic approval provided the issue is lead managed by an investment banker. (For the purpose of this scheme, an investment Banker would be defined as an Investment Banker registered with the Securities and Exchange Commission in the USA, or under Financial Services Act in U.K., or the appropriate regulatory authority in Europe, Singapore or in Japan). The track record condition will not be operative for ADR/GDR issues.

5.2       Automatic route for ADR/GDR issue would also cover issue of Employee Stock Options by Indian Software Companies/Companies in the IT Sector in conformity with the guidelines dated 23-6-1998 and 16-9-1998 issued for ADR/GDR linked employees stock options by Indian Software Companies/Companies in the IT Sector, subject to other approval requirements, as indicated in para 6 below.

5.3       Issue of ADRs/GDRs arising out of business reorganisation/merger/demerger would also be governed by Automatic route subject to the guidelines issued by this Department on 17th August, 1998.

6.         Mandatory Approval Requirements

6.1       In all cases of automatic approval mentioned above, the mandatory approval requirement under FDI policy, approvals such as under the Companies Act, approvals for overseas investments/business acquisition (where ADR/GDR proceeds are utilised for overseas investments) etc., would need to be obtained by the company prior to the ADR/GDR issues.

6.2       The issuer company would need to obtain RBI approval under the provisions of FERA/FEMA prior to the overseas issue.

6.3       Reserve Bank of India will be issuing necessary guidelines.

7.         Option for retention of funds abroad/repatriation

7.1       Existing guidelines on Euro issues providing for the option of retention of issue proceeds abroad or repatriation of funds into the country in anticipation of deployment towards the purposes for which the funds have been raised would continue to be applicable.

7.2       Retention and deployment of funds abroad would be as prescribed by RBI.

8.         End uses

While no detailed end uses are specified, the existing bar on investments in stock markets and real estate would continue to be operative.

9.         Issue related expenses

The issue related expenses (covering both fixed expenses like underwriting commissions, lead managers charges, legal expenses and other reimbursable expenses) shall be subject to a ceiling of 4% in the case of GDRs and 7% in the case of listing on US Exchange. Issue expenses beyond the ceiling would need the approval of RBI.

10.       Reporting

After completing the transactions, the companies would be required to furnish full particulars thereof including amount of ADRs/GDRs issued, number of underlying fresh equity shares issued, percentage of foreign equity level in the Indian company on account of issue of ADRs/GDRs (stating whether under automatic route or with FIPB approval), detailed issue parameters to the Ministry of Finance, Department of Economic Affairs and the Exchange Control Department of the Reserve Bank of India, Central Office, Mumbai within 30 days of completion of such transactions.

Source : Circular : F. No. 15/7/1999-NRI, dated 19-1-2000.

Clarification 14

            Guidelines for overseas business acquisition by Indian Software Companies through ADR/GDR Realisations/stock             swap

Under the existing guidelines for overseas investments by the Indian companies, one of the automatic approval route available without reference to RBI/Government is where :

(i)     such overseas investments are funded upto a maximum of 50% out of the proceeds of American Depository Receipts/Global Depository Receipts (ADRs/GDRs) raised; and

(ii)    floating of ADR/GDR issue has been approved by the Government.

Proposals not conforming to the criteria stipulated above are required to be referred to RBI or the Special Committee constituted under RBI as the case may be for consideration and approval.

2.      Considering the increasing opportunities presenting before the Indian Software Companies for expanding globally and making an international presence and to transform into Multi-National Companies through acquisitions abroad, it has been decided to liberalise the operational norms governing overseas investments and mode of financing acquisitions of overseas software companies.

3.         Coverage

The liberalised norms will cover acquisition of overseas software companies only by Indian Software Companies which have been defined as those registered in India and engaged in manufacturing or production of software where 80% of the turnover is from software activities in the three previous financial years.

4.      The eligibility for automatic approval will be operative only in respect of those Indian Software Companies which have already floated an ADR/GDR issue and are currently listed in the overseas exchange. In addition, companies who obtain one time “Blanket Approval” from the Special Composite Committee, would also be eligible for automatic approval.

5.         Limit for acquisition

5.         Financial limit specified in paras 6(A) and (B) below.

6.         Approval mechanism

Overseas acquisition of software companies by Indian software companies would be governed by the following guidelines :

(A) Business Acquisition abroad by Indian software companies upto the value limit of US $ 100 million

(i)             Indian Software Companies which have already floated an ADR/GDR issue and are currently listed in the overseas exchange, would be eligible to acquire overseas software companies and issue ADRs/GDRs of the value of the cost of acquisition, on a back to back basis, on an automatic basis without reference either to the Government or the RBI.

(ii)            In addition, Indian software companies not covered by (i) above, may obtain a one time “Blanket Approval” from the Special Composite Committee, by an application made to RBI, and would thereafter be eligible for automatic approval as in the case of Indian software companies which have already floated an ADR/GDR issue and are currently listed in the overseas exchange.

(iii)           Such transaction would be exempt from the prior approval requirement either from the Government or from the Reserve Bank of India subject to the condition that the cost of acquisition is met with ADRs/GDRs realisation/stock swaps on a back to back basis.

(iv)           At present, ADR/GDR offerings require a two stage approval by the Department of Economic Affairs - an ‘in principle’ approval based on track record requirement and the final approval for issue parameters. The two stage approval requirement will not be required for ADR/GDR offerings/stock swap which are being raised/issued specifically for the purpose of overseas business acquisition by the Indian software companies as defined above.

(v)            The existing limit of use of upto 50% of the ADR/GDR proceeds for overseas investment is also removed. Under the revised norms, limited to such acquisition, upto 100% of the ADR/GDR proceeds may be utilised for such business acquisition.

(vi)           The value limit of US $ 100 million under the above ADR/GDR stock swap would be an annual limit for each company for one or more acquisitions.

(B) Overseas Business acquisition beyond $ 100 million

In the case of proposals which do not meet the conditions at (A) above and where the cost involved in the transaction/overseas business acquisition exceeds $ 100 million, the Indian software company would need to send the proposal to RBI for consideration by a Special Composite Committee on overseas investment and ADR/GDR approvals. The Committee would consider according a composite approval, prescribing a ceiling for overseas acquisition under the above scheme. The company would, thereafter, report to the committee after finalising the acquisition, of the details of the transaction.

7.         Criteria for automatic approval

The liberalised approval mechanism is subject to the following norms :

(i)             The existing foreign equity including on account of any existing ADR/GDR offering and the proposed ADR/GDR issue/stock swap in the expanded capital base is within the limit operative for RBI automatic approval for FDI in the software sector. No FIPB approval would be required in such cases even if the ADRs/GDRs are issued otherwise than in cash.

(ii)            The proposed ADR/GDR stock swap for purposes of acquisition of business abroad is by way of expansion in the capital base or to be precise by way of issue of fresh underlying shares.

(iii)           The present ADR/GDR guidelines provides for redemption of the ADRs/GDRs into the underlying rupee denominated shares of the Indian company, sale in the domestic market, and full repatriation of sale proceeds subject to payment of prescribed tax. The same provision would extend to ADR/GDR holders of the acquired company. Reconversion of the underlying shares into ADRs/GDRs is not permissible.

        (iv)           The proposal would have to conform to the following valuation norms :

(a)       The valuation of the transaction and of the overseas company shall be as per the recommendation of an Investment Banker;

(b)       In the case of a listed overseas company, the valuation will be based on the current market capitalisation of the overseas company (based on the monthly average trading on the overseas exchange, for the three months preceding the month in which the acquisition is committed to) and premium, if any, as per the recommendations of the Investment Banker in the Due-diligence reports;

(c)        In the case of an unlisted overseas company, the valuation will be based on the recommendations of the Investment Banker.

        (v)            The proposal being in conformity with all provisions of the Companies Act, 1956.

(vi)           The companies are required to report full details of the transaction including value of the transaction/acquisition cost, foreign equity level in the Indian software company on account of issue of ADRs/GDRs, as detailed in paragraph 8 below.

        (vii)          Compliance with RBI Regulations.

        (viii)         Other clearances as applicable being obtained by the Company.

(For the purpose of this scheme, an Investment Banker would be defined as an Investment Banker registered with the Securities and Exchange Commission in the USA, or under Financial Services Authority in U.K. or the appropriate regulatory authority in Germany, France, Singapore or in Japan).

8.         Reporting

After completing the transactions/acquisitions, Indian companies should furnish full particulars thereof including amount of ADRs/GDRs issued, percentage of foreign equity level in Indian company on account of such issue, name/s of the overseas company/ies acquired, cost of acquisition, percentage of holding of Indian company in the foreign company, details of its line of activity, country of location, etc., together with relevant documents like valuation report by the investment banker to the Ministry of Finance, Department of Economic Affairs and Reserve Bank of India, Exchange Control Department, Overseas Investment Division, Mumbai within 30 days of completion of such transactions. On receipt of these particulars, Reserve Bank will issue specific identification number in respect of each overseas company acquired and Indian companies will have to comply with the existing requirement regarding submission of Annual Performance Reports, repatriation of entitlements from the overseas concerns, etc.

9.         Format of the application

The application will have to be submitted to the Reserve Bank of India in the existing forms of overseas investment and for ADR/GDR together by an applicant, for the time being, who will have the option to supplement the information.

10.       This scheme is in addition to the existing routes available for overseas investment including the automatic approval route.

Source : Circular : F.No. 15/22/99 - NRI, dated 27-12-1999.

 

Clarification 15

                         Permission to issue Global/American Depository Receipts to Foreign Investors under Automatic Route of RBI

1.         In pursuance of clause (a) and clause (d) of sub-section (1) of section 19 and clause (b) of sub-section (1) of section 29 of the Foreign Exchange Regulation Act, 1973 (46 of 1973), and all other powers enabling it in this regard, the Reserve Bank is pleased to permit—

    (a)       a company incorporated in India which fulfils the eligibility criteria laid down in para 2,

(i)         to make an international offering of rupee denominated equity shares of the company by way of issue of Global Depository Receipts (GDRs)/American Depository Receipts (ADRs) to persons resident outside India;

        (ii)        to export the said securities to investors outside India; and

    (b)       the investors to acquire the securities so purchased.

2.         (i)         The issuing company has necessary approval from the Ministry of Finance, Government             of India to issue such ADRs/GDRs or is eligible to issue ADRs/GDRs in terms of the             relevant scheme or notification issued by the Ministry of Finance.

(ii)        The issuing company is eligible to issue shares to foreign investors under the automatic route of Reserve Bank of India or has necessary approval from Secretariat for Industrial Assistance (SIA)/Foreign Investment Promotion Board (FIPB) and the percentage of foreign equity does not exceed the limits specified under the automatic route or the limits specified by the SIA/FIPB.

3.         The company issuing GDRs/ADRs is also permitted—

(i)         to issue shares in the name of the depository or its nominees and to place the share certificates in respect of the said shares in the physical custody of a custodian in India against which the depository will issue GDRs/ADRs outside India;

(ii)        to remit dividends through an authorised dealer as and when due subject to payment of Indian taxes as applicable;

    (iii)       to issue rights or bonus shares that may accrue in respect of the GDRs/ADRs;

(iv)       to incur issue related expenses as approved by the Ministry of Finance, Government of India or up to the limits laid down in the relevant guidelines issued by the Government of India;

(v)        to pay the issue related expenses by way of deductions from the issue proceeds as approved by the Ministry of Finance, Government of India or up to the limits laid down in the relevant guidelines issued by the Government of India;

(vi)       to remit and pay for filing, listing, agency or other fees on ongoing basis in respect of international stock exchange where the GDRs/ADRs are listed;

    (vii)      to maintain a foreign register of members, if so required;

            (viii)     to open an account abroad to receive the subscription monies in foreign currency;

(ix)       to pay any foreign tax in the nature of sales or value added tax in respect of services provided to the issuing company and reimburse any out of pocket expenses;

(x)        to repatriate the proceeds of the issue to India for deployment for purposes permitted by the Government of India; pending repatriation of issue proceeds to India—

(a)       to invest the funds as an interim arrangement on short-term basis as deposits in foreign banks which are rated for short-term obligations A1 + by Standard and Poor or P1 by Moody’s or with the branches of Indian banks abroad; or

(b)       to invest in treasury bills and other monetary instruments with maturities and exceeding one year; or

(c)        to keep the funds as foreign currency deposits with authorised dealers and/or public financial institutions in India; or

(d)       to invest in certificate of deposit or other paper issued outside India by bank incorporated in India.

4.         The issuing company shall—

(i)         furnish a statement to Exchange Control Department of Reserve Bank of India, Central Office, Mumbai, within thirty days from the date of closing of the issue providing full particulars of the issue such as amount of GDRs/ADRs issued, a number of underlying fresh equity shares issued, listing arrangements, total amount raised, amount retained abroad and other relevant details regarding launching and initial trading of the GDRs;

(ii)        furnish capital structure of the company before and after the issue within thirty days from the closure of the issue;

(iii)       inform Reserve Bank of any repatriation of issue proceeds held abroad immediately on such repatriation.

Source : Notification No. GSR 109(E), dated 20-1-2000, issued by the Reserve Bank of India.

 

Clarification 16

            Guidelines for overseas business acquisition by Indian companies engaged in information technology, entertainment             software, pharmaceuticals, bio-technology through ADR/GDR stock swap

Guidelines were issued on 27th December, 1999 to liberalise the operational norms including approval mechanism for overseas business acquisition by the Indian Software Companies. In his Budget Speech 2000-2001, the Finance Minister had announced the intent to further liberalise the policy for acquisition of companies abroad and to extend the policy to wider spectrum of companies in the knowledge-based sectors to expand globally and transform into Multi-National Companies in areas where India has comparative economic advantage.

2.         In partial modification of the guidelines issued on 27-12-1999, following parameters are set out for overseas business acquisition through ADR/GDR stock swap :

3.         Coverage

The liberalised norms will extend to Indian companies engaged in areas/activities as indicated in Annexure to these guidelines for acquisition of overseas companies in their respective areas of business. The Indian companies in the specified sectors/areas are defined as those registered in India and 80% of the turnover is from these respective areas of the operation/business of the company in the three previous financial years. In the case of multi-product diversified company, not conforming to the 80% criteria, the liberalised norms would be applicable if they have an average annual export earnings of at least Rs. 100 crores in the three previous financial years in these sectors/areas.

4.         Limit for acquisition

Overseas business acquisition by specified Indian Companies would be governed by the following guidelines :

(A) Overseas business acquisition abroad by the specified Indian companies under the automatic route

The financial limit to overseas business acquisition on an automatic basis without reference either to the Government or the RBI on a back to back basis i.e., through stock swap will be as follows :—

    (i)         US $ 100 million; or

(ii)        Upto 10 times the export earning of the investing company during the preceding year as reflected in the audited balance sheet of the company.

For (ii) above if any other facility has been availed by the investing company for overseas investment through any other window including item (i) above during the financial year, the same would be adjusted and the entitlement would be for the balance amount.

The value limits indicated above would be an annual limit (financial year) for each company for one or more acquisitions.

Other criteria for qualifying for automatic route would continue to apply.

(B) Overseas business acquisition not governed by the automatic route

Cases not covered by (A) above, the specified Indian Company would send the proposal to RBI for consideration by the Special Composite Committee for Overseas Investment through ADR/GDR Stock Swap.

5.  The criteria for automatic approval and other norms contained in the guidelines of 27th December, 1999 including the mandatory requirement of conforming to the FDI policy, an existing ADR/GDR listing abroad and reporting requirement, etc., would continue to be operative.

6.         After issue of ADRs/GDRs for acquisitions, the particulars thereof, along with the copy of the documents submitted to the regulatory authorities in the host country should be transmitted to DEA and RBI within a month as post facto reports along with certification about compliance with the eligibility with reference to the definition of the company in the specified permitted category/sector and entitlement based on export earnings.

7.         In respect of each overseas company acquired under the scheme, an Annual Performance Report, as per the existing procedure, citing the Identification Number allotted by RBI in respect of such overseas companies should be sent to RBI for the purpose of compilation of data and monitoring.

8.                  The above policy will be subject to review as considered necessary by the Government.

 

Annexure

(1)       Information Technology [as defined in the recommendation Nos. 19(a) and (b) of Gazette Notification, dated 25-7-1999 issued by the Planning Commission] and Entertainment Software.

(2)       Pharmaceuticals.

(3)       Bio-technology.

(4)       Any other activity within the knowledge based sector as notified by the Government from time to time.

Source : Press release, dated 23-3-2000.

 

Clarification 17

                       Employees of Indian subsidiary companies engaged in IT Software and IT Services entitled to get ADR/GDR linked stock                        options

1.        Guidelines by way of a press note were issued on June 23, 1998, containing operational parameters and modalities for issue of ADR/GDR linked stock options to its employees by the Indian software companies. Revisions/modifications to expand the scope of application to the Indian companies engaged in information technology software and information technology services had been issued on September 16, 1998. Enabling amendment notification operating the facility for ADR/GDR linked employees stock options had been issued by the Government on November 10, 1999, under the “Scheme for issue of Foreign Currency Convertible Bonds and Ordinary Shares (Through Depository Receipts Mechanism)”.

2.         The Government has been considering expansion in the coverage of employees who would be entitled to the ESOPs in line with the SEBI guidelines on ESOPs which covers employees of a subsidiary company for the purposes of ESOPs.

3.        Keeping in view the essential features of the relationship between the parent company and subsidiaries, viz., interchangeability of the employees between the parent and subsidiary companies, inter-linkage of the parent and subsidiary companies and complementality of the functions between the two, it has since been decided to expand the facility for issue of ADR/GDR linked stock options to include employees of eligible subsidiary companies of the parent company, under the scheme. Accordingly, Indian companies engaged in the IT software and IT services, would be entitled to issue ADR/GDR linked stock options to the permanent employees (including Indian and overseas working directors) of its subsidiary companies incorporated in India or out of India and engaged in information technology software and information technology services subject to the eligibility criteria and other parameters prescribed in the press note dated June 23, 1998 and September 16, 1998.

4.         These guidelines will come into force with immediate effect.

Source : PIB Press release, dated 16-6-2000, issued by the Press Information Bureau.

 

Clarification 18

            Liberalised guidelines for issue of ADR/GDR linked employees stock options by the Indian companies

Guidelines by way of a Press Note were issued on 23rd June, 1998 containing operational parameters and modalities for issue of ADR/GDR linked stock options to its employees by the Indian Software Companies. Revisions/modifications to expand the scope of application to the Indian companies engaged in Information Technology Software and Information Technology Services had been issued on 16th September, 1998. These guidelines were further modified by the Government on the 16th June, 2000, expanding the coverage of employees who would be entitled to the ESOPs in line with the SEBI guidelines on ESOPs, which include employees of a subsidiary company for the purposes of ESOPs. Enabling amendment Notification operating the facility for ADR/GDR linked employees stock options had been issued by Government on 10th November, 1999, under the “Scheme for issue of Foreign Currency Convertible Bonds and Ordinary Shares (Through Depository Receipts Mechanism).”

2.     Guidelines were issued on the 23rd March, 2000, liberalising the norms for overseas business acquisition by Indian companies in terms of which :

(i)             the norms for acquisition of overseas companies was extended to Information Technology and Entertainment Software, Pharmaceuticals, Bio-technology and any other activity within the knowledge based sector as notified by the Government from time to time; and

(ii)            in the case of multi-product diversified company, not conforming to the eligibility criteria of 80% of the turnover from the sectors/areas mentioned above, the liberalised norms would be applicable if they have an average annual export earnings of Rs. 100 crores in the three previous financial years in these sectors/areas.

3.     It has been decided to extend the liberalised norms as mentioned in para 2 above in respect of the issue of ADR/GDR linked Employee Stock Options as well. This would imply that :

(I)             The companies in the following knowledge based sectors would be eligible to issue ADR/GDR linked ESOPs with a view to enable retaining their highly skilled personnel :

(i)             Information Technology (as defined in the recommendation No. 19(a) and (b) of Gazette Notification, dated 25-7-1999 issued by the Planning Commission) and Entertainment software.

        (ii)            Pharmaceuticals.

        (iii)           Bio-technology.

(iv)           Any other activities within the knowledge based sector as notified by the Government from             time to time.

(II)            The liberalised norms would also be available to multi-product, diversified companies which do not conform to the criteria of 80% of its turnover from the sectors mentioned in para 3(1) above, in case they fulfil the condition of average annual export earnings of Rs. 100 crores from these sectors in the three previous financial years.

4.         These guidelines will come into force with immediate effect.

Source : Press release, dated 15-9-2000.