Documents show questions have been raised about some of LCF’s dealings with various entities including HealthifyMe.

A “compliance report” from AsiaCiti Trust, dated February 27, 2018, mentions that at least four transactions carried out in 2017-2018 by the LCF were marked as “high risk” due to their “PEP structure. – PEP refers to an exposed person.

Documents with the Registrar of Companies show that as of March 31, 2020, Tushar Vashisht held 10 shares and HealthifyMe Pte Ltd, Singapore held 2,43,318 shares of HealthifyMe Wellness Private Limited. They are the only shareholders.

HealthifyMe’s website states that this is “the only health and fitness app you’ll ever need.” Over 25 million satisfied users, over 5 million pounds lost, over 1,500 trainers ”.

AsiaCiti Trust records show Vashisht’s Singapore holding company is linked to Lang Capital Fund owned by Kirill Androsov

HealthifyMe Pte Ltd, Singapore, is one of the LCF related companies. Established on December 11, 2014 in Singapore, LCF’s trustee is AsiaCiti Trust Singapore Pte Ltd while Atlas Asset Management Pte Ltd is its investment manager.

The sole unitholder of LCF is Grand Asset Investment Ltd, based in Samoa, which owns 48,585,858 shares.

HealthifyMe Pte Ltd, Singapore, is the holding company of HealthifyMe Wellness Private Limited. HealthifyMe Wellness Private Limited revenue was Rs 54.52 crore as of March 31, 2020.

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The documents show that the LCF transactions in question included a payment which was made “for the subscription of 122,066 Compulsory Convertible and Non-Cumulative Preference Shares Series B2 in the capital of HealthifyMe Pte Ltd”.

In response to this, Pawan Agrawal, Vice President (Finance) of HWPL, said, “We are not aware of it. “

Atlas Asset Management, LCF’s investment manager, had ordered to hand over $ 1,000,000 to HealthifyMe Pte Ltd and the money was transferred on February 20, 2018, according to documents.

A payment for “management services provided by Atlas Asset Management Pte Ltd” was also marked as “PEP related structure (high risk)” because “Atlas Asset Management Pte Ltd is the appointed investment manager of Lang Capital Fund. The payment relates to the management services provided as an investment manager ”.

A “legal due diligence checklist” in November 2017 noted that Tushar Vashisht is the promoter director of the holding company, but “details of the shareholding and direction of the holding company were not disclosed to the board of directors. ‘administration of the company (HealthifyMe Wellness Products and Services Private Limited) via form MBP-1 ”for the financial years 2015-2016, 2016-2017 and 2017-2018.

He underlined: “In accordance with article 184 of the law read with rule 9 of the rules on companies (management and administration), 2014, each director is required to disclose his concerns or interests, including his participation, in any company, company or legal person, companies, other association of natural persons, during the first board of directors of each financial year.

Agrawal said: “The Board of Directors of HealthifyMe Wellness Private Limited, India is fully aware of this fact.”

On whether these interests had been declared to Indian authorities, he said: “We have been transparent to the tax authorities.”

HealthifyMe Pte Ltd, Singapore, was incorporated on December 2, 2014. HealthifyMe Wellness Products and Services Private Limited, incorporated on June 22, 2015, became HealthifyMe Wellness Private Limited on March 12, 2018.