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Embracing Indian investment abroadIn this edition:
> What is the current state and target for FPI / FDI within India?
> What needs to be done to achieve India’s targets?
> What actions can India implement to take advantage of the opportunities arising from the current macroeconomic state?
> Is Mauritius an appealing proposition?
> What is the state of outbound investments within India?
1 / 14
SANNEGROUP.COMIssue 13 | August 2019
MAKING THE DIFFERENCE FOR OUR CLIENTS
2 / 14
SANNEGROUP.COM
Welcome to Connect, SANNE’s regular
technical bulletin for fund managers,
their intermediaries and investors.
As part of our commitment of servicing clients and
sharing knowledge with the industry, this special edition
of SANNE Connect focuses on what next can we do to
embrace India’s strategies to harness inbound growth as
well as diversify outbound investments.
SANNE hosted a Mumbai roundtable featuring industry
leading experts to discuss recent investment trends.
Interwoven through these themes, our expert panel
explore the Indian market, both inbound and outbound.
Our expert panel included the following people:
> Brij Bhushan – Senior Vice President, Product & Market Management, South Asia, HSBC Securities Services
> Siddharth Shah – Partner, Khaitan & Co
> Rashmi Guptey – Chief Financial Officer Lightbox India Advisors
> Dr. Ramakrishna Sithanen – Chairman and Director SANNE in Mauritius
> Keyur Shah – Chief Financial Officer HDFC Property Ventures
> Kunal Shah – Partner, PwC Financial Services
The key themes under discussion by our expert panel were:
> What is the current state for FPI / FDI within India?
> What needs to be done to achieve India’s targets?
> What actions can India implement to take advantage of the opportunities arising from the current macroeconomic state?
> Is Mauritius an appealing proposition?
> What is the state of outbound investments within India?
The aim of this special edition of Connect, is to share what
we have learnt from industry leaders, this time from our
panel of experts in Mumbai.
Enjoy the read!
Peter NagleCountry Head – Mauritius
e. peter.nagle@sannegroup.com
1 2 3 4 5 6
1. Brij Bhushan 2. Siddharth Shah 3. Dr. Ramakrishna Sithanen 4. Rashmi Guptey 5. Kunal Shah 6. Keyur Shah
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There has been a perceptible shift in overseas investment over the last decade. Analysis of the trends in direct investments over the last decade reveal that while investment flows, both inward and outward, they gained momentum during the latter half of the past decade.
FPI prioritised over FDI
Brij Bhushan outlined the current state of Foreign Portfolio
Investment (FPI) in India, “Since we [India] started this
regime in 1991/1992, we have seen a progressive regime
which has allowed a lot of liberalization and reform in the
policies themselves. This has been attracting a lot of capital
from across the world. The traditional sources of capital are
the developed markets such as America, Europe and Japan
though money may be flowing from other jurisdictions. I
think that the AUC of FPI currently stands at US$ 500bn
which is quite sizable and larger than India’s mutual fund
industry at this point in time.”
While India has historically seen more FPI than Foreign
Direct Investment (FDI), with global investors having a
positive perception of India’s FPI regime, the framework and
the ease of investing into India have big benefits.
Recent trends show FDI catching up
In the 2018 fiscal year alone, total FDI into India stood at
US$ 42bn, with the Government aiming to increase this to
US$ 100bn by 2022. The leading challenge for India relating
to FDI is to catch up with the likes of China and America.
To remain ahead, India must find ways to attract money into
the economy which is then deployed into productive assets
directly.
What is the current state and future for FPI and FDI within
India?
KEY TOPICS
> Are investments broad-based with high increasing future targets?
> Are Real Estate and Infrastructure the future?
“Last year we saw inflows of US$ 42bn into India. A large chunk goes to the USA (US$ 250bn) and China (US$ 250bn, inclusive of Hong Kong). When we look at China, they have seen a consistently high level of FDI inflows. This is a challenge that we as an economy must overcome going forward. India must get more money into the country that goes into productive assets directly.” BRIJ BHUSHAN
Looking ahead, despite the challenges facing the country in
increasing FDI into India, Rashmi Guptey shared how FDI
inflows and the ambitious targets set by the Government
would impact the asset classes of start-up and venture
capital. “We believe that this (investments into the larger
sectors such as construction, real estate, telecoms and
services), will be a great feeder for the start-up economy.
Once you have those many investments and an expected
US$ 2trn being spent within these sectors by 2020 in the
economy, what we want to see is a trickle-down effect to the
start-ups eco system and any new business models that
evolve to solve problems associated with these large
sectors.”
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“Overall 2018 was fantastic with the Flipkart exit that paves a long way forward for the Startup Sector. Such exits reassure the market and are proof that Indian investments can garner great returns. The fact that the same Government is going to continue (re-election in 2019), hopefully we will now see these reforms pan out over the coming years, especially with the Start-Up India action plan.” RASHMI GUPTEY
Real Estate and Infrastructure is the future
When looking at composition and asset classes, India is
witnessing the largest FPI and FDI inflows to date.
Siddharth Shah, comments, “We have traditionally seen
Services, ICPs, Pharma, Life-sciences have always been at
the top. We are seeing a lot of more real asset classes
becoming interesting. While in the short run, assets such as
Infrastructure and Real Estate have gone through their own
pain due to governance, performance and regulatory
overhang – which created its own challenges for operators.
As we see the trend going forward that these (Real Estate
and Infrastructure) are the asset classes that we expect to
see a lot more allocation of capital from global investors.”
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SANNEGROUP.COM
There is wide agreement on Real Estate and Infrastructure,
with instruments such as REITs and InvITs, being the
growth drivers for the Indian FDI market, capable of
absorbing the inflows expected by the Government when
aiming to increase to US$ 100bn by 2022.
Since 2014, the Indian Government has made great strides
in inviting representation from the industry when
developing the FDI policies pertaining to attracting REITs
and additional inbound FDI flows. The thought put forward
to the Government was the question of
“Is Indian ownership of commercial Real Estate a
necessity?”.
“Real Estate is one of the largest contributors to FDI in India. It is omnipresent and across all businesses.” KEYUR SHAH
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Rashmi GupteyChief Financial Officer
Lightbox India
e. rashmi@lightbox.vc
5 / 14
SANNEGROUP.COM
Real estate ownership is a drag on the return on capital
employed or return on equity experienced by industries
such as pharmaceuticals, ecommerce and manufacturing.
The current Indian Government is aware of the challenges
facing the real estate market space. Now that India has
seen the first REIT launched in 2019, we will see substantial
capital coming into the real estate sector, especially after
the real estate policy was amended.
“The Government wants foreign investors to make money in real estate. They are aware of the challenges which foreign investors have faced in real estate investments. Hence they have simplified the regulations and opened up investments in the sector.” KEYUR SHAH
Problems still remain within the real estate market from
the historic foreign investments made during 2007 to 2009,
most of these have yet to be exited to date.
Regarding opportunity in future exits, Keyur Shah said,
“In 2018 and 2019 we have seen substantial exits, and
when exits happen, foreign investors become more
confident on the notion that there is money to be made in
India and we can put out more money.
My perspective is that there is a lot more capital that will
come into real estate and we have just seen the tip of the
iceberg.”
Despite the future being optimistic for FPI and FDI, the
current situation from the angle of taxation for foreign
investments and attracting foreign investors, taxation
regimes are a very important feeder to have in place.
Looking back four or five years ago, India had a negative
taxation sentiment from foreign investments and investors,
however, to-date, several tax law changes have now
opened up avenues to attract money flows back into India.
Grandfathering gains made on assets before 31
January 2018
“When listed shares became taxable, the Government made the right move by saying that any gains that were made from the date of amendment, which was 31 January 2018, were only grandfathered. Meaning that you paid tax prospectively rather than retrospectively which definitely added more confidence since we are not taxing any individual who had invested for many years and made gains out of it.” KUNAL SHAH
Despite positive moves, several steps are still left to be
made by both the industry and Government relating to
policy, regime and implementation.
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Keyur ShahChief Financial Officer
HDFC Property Ventures
e. keyursshah@gmail.com
6 / 14
SANNEGROUP.COM
Are Khan’s recommendations a force of good?
On 24 May 2019, the Khan Committee submitted its
report to the Securities and Exchange Board of India
(SEBI) outlining the recommended amendments that
would be required to further rationalise and simplify
the existing SEBI FPI regulations. There are three key
recommendations that are most likely to improve the
state of affairs for foreign investors.
1) Fast track registration process
> Market sentiment persisted towards the process of
registering with a local custodian before an FPI can
invest into India being long, tedious and often ill-timed.
> Solutions outlined to allow Public Retail Funds (PRF) to
have a fast track process when applying for FPI
registration. PRF are already regulated entities and have
broad-based investors making both SEBI and policy
makers very comfortable.
> Doing away with a lot of the registration requirements
for such funds would have a big impact on the status-
quo of FPI in India.
2) Private wealth money
Historically, India has not seen Private Wealth Money
flowing into the market within the existing FPI
framework.
KEY TOPICS
> Are Khan’s recommendations a force of good?
> Looking at the bigger picture of foreign investments
> Criticality of consistency, clarity and certainty
“In India, you have to register, and you have to create a broad-based fund structure. Once you have created a fund structure, that specific fund structure becomes the FPI. In the market, the feedback from private banks and broker dealers, who are providing wealth management services at an individual level, is that they do not want their assets to be comingled into a fund where personalized investment and advisory services cannot be given. This was an obvious handicap for the market and industry.” BRIJ BHUSHAN
The recommendation provided outlines that private
banks and broker dealers who do not want to create a
fund should still be allowed a Category 3 FPI license to
invest their client’s money.
What needs to be done to achieve
India’s target by 2022
Brij BhushanSenior Vice President, Product &
Market Management, South
Asia, HSBC Securities Services
e. brij.bhushan@hsbc.co.in
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3) Reversing the 24% threshold
> Currently, a group of FPIs are not allowed to hold more than 24% of a company’s equity, with no individual FPI or FPI group being able to hold more than 10%.
> Regulations allow for a company to pass a board regulation to increase the threshold from 24% up to the sectoral cap, however, this caused more friction and rising costs than benefits.
Brij Bhushan described market challenges faced by funds
and FPIs as, “What we saw in the market was that
companies were either not bothered about increasing the
cap, it is an administrative process. So, we saw a lot of
companies, by default being stuck at 24%. And also, the law
allows them to fit in an intermediate cap as well from 24%
to the sectoral cap, a lot of companies came out with
innovative caps of 26.5%, 30%, 32%, etc. So, it added to the
compliance cost as well, in one sector you could have three
companies at different caps. The market as a whole really
struggles with the compliance of that.”
> The recommendation aims to resolve this going forward,
opting from a sectoral down threshold approach and limiting
thresholds to one of three levels only – 74%, 51% and 24%.
> The panel unanimously in agreed that this recommendation
would increase the amount of floating stock that is available
to foreigners. The expectation is that this will have a positive
impact on the weighting of India within global indices,
improving money flow into India.
Looking at the bigger picture
Looking at the Khan committee recommendations, the ball
is now with SEBI and the whole industry is hoping to see
changes in the coming weeks and months, however, to
progress and further change the landscape of FPI and FDI
within India, there must be a shift in mentality both within
the industry and among policy makers on how foreign
investments are visualised and classified.
“I think from a policy maker perspective, we
have just been programmed to think along the
lines of how the foreign investment regime has
been conceived and developed. It was always
an FPI that overshadowed a lot of FDI capital,
where any policy change would be geared
around FPIs to give them a certain specific
treatment. Maybe it is time, for a policy maker
today, in my view, to start looking at it so that
the policy moves to foreign investment if at all,
or more general, rather than creating
complexity around FPI, FDI, FVCI, etc.”
SIDDHARTH SHAH
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This indecisiveness is sometimes what is probably pushing
investors away because there is no certainty or clarity on
the regime where you are investing. It causes
apprehension on “You do not know what is coming next”,
and this is something that is critical to attract investors
from a long-term perspective.
“From a regulatory standpoint, if you look at
the overall FPI regime, there was an April
circular which caused more disruption within
the market. Now there is this Khan committee
recommendation which is ultimately going to
be going to regulation, and again people will
have to relook at their structure and see if they
meet the requirements or not. In fact, we were
trying to track the number of changes which
have come through in the FPI regulation - in
the last six to eight months there have been
30 to 40 changes.” KUNAL SHAH
Can India better facilitate growth of FDI and FPI
India is not exempt nor immune from the global economic
slowdown that is expected, however, there is a way in
which Indian growth can be sustained but requires the
definite and cooperative role played by the Government.
One way to kick-start the Indian economy or make it grow
or sustain growth is to push the real estate sector.
Rashmi Guptey said, “We need to stop thinking of
acronyms like FPI, FDI, FVCI and go beyond thinking of
regulations in such an isolated manner. I think it is time
to understand that foreign capital comes into India and
that it is our job to make sure that the Capital invested
achieves the kind of returns expect from a burgeoning
economy like India.”
Criticality of consistency, clarity and certainty
With expected requirements from the policy makers
within India evolving beyond that of visualizing foreign
investments from a wider, macro lens instead of being
niche to fund buckets, an essential improvement area
for the Government is the ability to be consistent in the
reforms made.
With a prime example of Government inconsistency in
policy and the direct impact on FinTech companies
Rashmi Guptey advised, “Aadhaar (form of personal
identification in India) was fantastic, you had FinTech
companies basing their models on Aadhaar. Their KYC
had come down to 50 Indian Rupees per customer,
which is significant for a business based on a FinTech
model. Suddenly the Supreme Court says “Aadhaar is no
longer the only source of identity and you do not need to
be held to it”.
A KYC which previously cost 50 INR, will now cost
you 400 INR for the same process, which
effectively impacts the bottom line of the business.
The Government started off well, but somewhere
down the line, they undid what they did and went
five years back in time.
This indecisiveness of the Government in policies
and reforms is a consistent pain point. It has been
identified as a driver of uncertainty and lack of
confidence in India among global investors.
Though positive on the overall recommendations, a
sustained period of policy stability and clarity has
been directly affecting businesses and industries. It
has investors doing business instead of focusing on
assessing if their individual structures are still
compliant with regulatory standards.
RASHMI GUPTEY
Kunal ShahPartner
PwC Financial Services
e. kunal.s.shah@in.pwc.com
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“We, as a country, do not have organized rental
housing set-ups for participation by large
institutional investors. Globally there are funds
and institutions investing extensively and
exclusively in rental housing. Today in India,
owing to lack of institutionalized rental housing
set up, only renting of housing is seen more at
an individual level with lack of scale. This is
clearly one area where the Government can play
a more defining role to create a great
investment asset class which will not only
attract investors and boost the economy, but
create huge employment opportunity and
achieve the ambitious goal of housing for all for
the billion plus population of the country.”
SIDDHARTH SHAH
It would be a win/win situation for both the developers of
real estate and the Government in its ambition to achieve the
Pradhan Mantri Awas Yojana Housing for all by 2022.
Developers of real estate can be motivated to rent out
instead of selling if they receive the required cash flow and
they are not listed, however, the road is suitably challenging
to realise this opportunity.
“It is a complex situation but with appropriate
regulation, and with some policy initiatives, a
big push can be given to rental housing,
because today, everything is moving to
‘Uberisation’, you can rent cars, you can rent a
camera, you can rent a tent”. KEYUR SHAH
Why do you need to buy when you can rent?
In the residential sector we need to figure out a way where
we push rental housing in a big way – a policy or regulatory
initiative from the Government is needed. It will also
achieve the Government’s agenda of housing for all by
2022, whether it is owned, or it is rented, it does not
matter. It can be shelter for all by 2022.
Siddharth ShahPartner
Khaitan & Co
e. siddharth.shah@khaitanco.com
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There are counter-prevailing forces at work. Depreciation of the Rupee, increasing yield in other countries, reversing monetary accommodation in the US. Similarly, the two largest economies are currently in a trade war. These events are likely to be bad for emerging markets because global output, trade and investment will be affected as two of the largest economies are fighting. On the other hand, there might be niche opportunities for India.
What can the private sector or the Government in India
piece together to take advantages of some of these
situations?
Short term gains but long-term concerns
There are definite short-term gains that may come in the
direction of India as a result of the trade dispute between
China and America. Gains in the form of potential investment
inflows into India as well as greater trade being allocated to
India as a stop-gap. There is however significantly more
concerning items on the horizon that will likely negatively
impact India instead of opening doors.
KEY TOPICS
> What sectors need developing?
> What new avenues to explore.
> Ensuring digital platforms support new services.
The trade disputes from the USA are not limited just to China as
they have challenged Canada, Mexico, Europe, UK and Japan. A
trade war is never localised to the players alone, it threatens to
involve everybody, and there is no winner.
Outlining the risk of dumping from China Siddharth Shah
commented, “America has been the largest trading partner with
China and with that relationship slowing down, would China look
elsewhere, because they have the capacities that they have
created over many years, to a trend of dumping? This again
could act as a stress factor between India and China.”
The differences in infrastructure between China and India is a
leading barrier to the potential realisation of any trade
opportunities for India.
“From the face of it, it looks like a lot of
opportunity. India has a lot of demand and supply,
but the infrastructure and the level of capacity that
China has built against India is phenomenal. The
logistics and infrastructure such as ports to roads,
roads to freights, freights to logistics, all of that
needs to be developed a lot more in India before
the opportunity can switch that drastically. I think
there is a long way to go, but we can definitely
look at it as an opportunity.” RASHMI GUPTEY
KEY TOPICS
> Can India take advantage of macroeconomic situations globally, most notably the geopolitical uncertainty of Brexitor the trade war between China and the USA?
What is India’s next step and where do the opportunities lie?
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KEY TOPICS
A short-term blip with specific challenges
Mauritius has not lost its shine as a unique selling proposition
for global funds. Mauritius is still benefiting from the long-
standing history with India, especially in terms of investments
and the tax treaty signed in 1982. Further, Mauritius is still
called upon as a market over Singapore due to the ease of set-
up, cost, timing, availability of good administrative services
and time zone perspective.
Any of the short-term movements from Mauritius to
Singapore have largely been driven from the uncertainty and
lack of clarity around GAAR (General Anti-Avoidance Rules)
and the market anticipation of how these rules will be
ultimately be tested within the realms of fund structure.
Managers and Investors are taking their own position and
viewpoint of whether the pooling is sufficient or if they need
to have an office.
“As rules evolve, people may start
re-evaluating the situation as to whether
they need to go through Singapore. Some
may get comfortable continuing to do
business through Mauritius relying on the
substance created through pooling of
investors and other strong commercial
justifications such as ease of business,
conducive regulatory frame work diversified
investment base, cost effectiveness,
> Is Mauritius an appealing proposition?
KEY TOPICS
Mauritius consolidates USP for global pooling structures
political and economic stability etc. while choosing Mauritius which remains a strong contender.” SIDDHARTH SHAH
Challenges Mauritius may face going forward
The allure of Singapore is perhaps driven by the demand for
different asset classes as funds look to move away from
equity funds.
“If you look at different asset classes, moving
from equity to others which includes maybe
debt investors, debt funds, or classic distress
funds who will earn income other than equity.
They are still looking at Singapore and
Luxembourg as options.” KUNAL SHAH
For players covering these funds, they do not necessarily have
a pooling vehicle in Mauritius or Singapore. They are already
pooling in the Cayman Islands because they are still part of a
larger global fund. Hence a decision of pooling locations are
being made on which jurisdiction will provide better
substance to claim a treaty benefit.
Those with a strong investment team on the ground in
Singapore may also look to having the pooling structure n
Singapore.
SANNEGROUP.COM
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Small niches need policy attention and revisions
There is broad agreement that India as a market is not yet
ready for outbound investments, and the restrictions in place
by the Government do not allow an easy-to-deal environment
for such opportunities.
“People are making meaningful and cautious outbound investments. India still continues to be a market that is more inbound focused in a way, and there is still enough potential that businesses see.” SIDDHARTH SHAH
There are pockets of investors that have ventured into the
offshore investment space. Most notably, India has seen the
classic case of resources with the moves into Africa, with
supporting targets within the Government to achieve a total
investment into Africa of US$ 160bn by 2025. India has more
recently seen outbound investment trends in the strategic
M&A space for the sectors of Technology and Pharma where
a presence in the USA is required.
What is the state of outbound investments
within India?
KEY TOPICS
> What restrictions are Government placing?
> Are investors looking more to Africa for outbound opportunities?
“The regulator in a way has not allowed a full-
blown regime which allows you to start going
and investing in companies that are pure
offshore. They still want some or other benefit
coming back to India.” KUNAL SHAH
The Alternative Investment Funds (AIFs) is the only regime
that is currently available for pooling money from domestic
investors, however, in order to make outbound investments,
the number of restrictions are onerous.
With outbound investments not growing any faster than the
current rate due to India being a capital deficit country. Brij
Bhushan comments, “We still need a lot of money ourselves
before we can start investing money abroad.”
Our panel concluded by agreeing that the underlining focus
for the vast majority of fund managers, institutions and
regulators within India is still, and will continue to largely
be, focused on inbound investments. The questions remain
whether the Government of India will be able to provide
certainty, clarity and consistency that the Indian market
need to fully grasp the growth capability in India and boost
the confidence of foreign investors.
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AMERICAS
BVI*
Cayman Islands*
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EMEA
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Dubai
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GuernseyJersey
London
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ASIA-PACIFIC
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More than 1,600 people worldwide
FTSE 250 listed business
In excess of £250bn AUA
SANNE has undertaken to engage with all of the markets in which it operates to share knowledge, collaborate with peers and hear from industry leaders as to their thoughts on the key issues and topics affecting the industry and its practitioners.
Established for over 30 years and listed on the Main
Market of the London Stock Exchange, SANNE has more
than 1,600 employees worldwide and has in excess of £250
billion assets under administration. Our network of offices
provide global managers with highly skilled and director-led
teams of asset class specialists.
As a leading global provider of alternative asset and
corporate services we are delighted to announce that we
have further extended our global reach with the opening of
our new office in Mumbai, India. With existing offices in 18
leading international finance centres, SANNE now has a
local presence in one of the world’s fastest growing
alternative markets.
Global alternative asset and corporate administration done differently
Should you wish to find out more about our services and operations please speak to us, we would be delighted to hear from you.
“We have been providing high quality alternative and corporate services to clients in India for more than 25 years, this next phase of evolution in the region is an exciting one for us.” PETER NAGLE
RUBINA TOORAWAChief Operating Officer − SANNE in
Mauritius
t. +230 4671300
e. rubina.toorawa@sannegroup.com
VAROUNEN GOINDENDirector, Head of Business Development
Mauritius & India
t. +230 454 9985
e. varounen.goinden@sannegroup.com
KHUSHBOO CHOPRAHead of Business Development − India
t. +91 022 4445 1064
e. khushboo.chopra@sannegroup.com
PETER NAGLECountry Head − Mauritius
t. +230 4673000
e. peter.nagle@sannegroup.com
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VALÉRIE MANTOTHead of Business Development
Asia Pacific & Mauritius
t. +65 3158 7474
e. valerie.mantot@sannegroup.com
14 / 14
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To find out more about SANNE, please email Varounen Goinden, our Director, Head of Business Development – Mauritius & India, varounen.goinden@sannegroup.com or alternatively visit us online, sannegroup.com
Information on Sanne and its regulators can be accessed via sannegroup.com
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EDITOR: Sivani Pillay – Marketing & Communications ManagerDESIGN: Kieran Blake – Marketing Administrator
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