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Reducing dependence on core tobacco business to now,
diversified consumer business– a big milestone achieved
ITC is transforming itself by reducing dependence on tobacco
products. From quite some time company was focusing on shift-
ing itself from tobacco business into consumer business. Thus,
for the first time during FY19, cigarette division contributed
45.8% to gross revenue which is quite less than a 52.08%
share a year ago & nearly two-thirds of sales i.e. 62.70% &
61.82% in FY16 and FY17 respectively. Thus, from past few
years dependence on cigarette division reduced to less than half
from 62.70% to 45.8%, which is remarkable.
Also, steep increase in taxes on tobacco by government & trading
volumes in illegal cigarettes has affected such business.
Thereby, now the consumer business i.e. the foods division, com-
prising cookies, staples and snacks, now accounts for 21.3% of
revenue, while agri-business generated 13.4% of ITC’s gross turn-
over last fiscal.
Aspires to achieve `1lakh cr revenue from FMCG by
FY2030
ITC is aspiring to become India’s largest pure-play FMCG firm by
FY 2030 from the branded consumer goods, to account for ` 1
lakh crore in revenue, that is roughly a 16-17 per cent year-on
year growth. In the last 12 years, revenues from the segment have
grown from ` 1,704 crore in 2006-07 to ` 12,505 crore in
2018-19.
With brands such as Aashirvaad, Bingo, and Sunfeast, ITC is the
leader in the branded wheat-flour market and a dominant player
in cookies. It is India’s second-largest company in segments
such as noodles, deodorants and incense sticks. It is also India’s
second-largest hotel chain, with revenues in excess of ` 1,648
crore.
LEAD RATIONALE
27 AUG 2019
Index Detail
Sensex 37641.27
Nifty 11105.35
Index A / S&P BSE
CMP 245
Target 282
M.Cap (` in cr) 301228.20
Equity ( ` in cr) 1228.50
52 wk H/L ` 310/234.70
Face Value ` 1.00
Div. Yield 2.38
NSE Code ITC
BSE Code 500875
Stock Data
P/E 22.70
EV/EBITDA 14.16
P/BV 4.81
Valuation Data
EV 297089.61
Net Worth 62577.38
BV 50.94
EPS(TTM) 10.80
Financial Data
` In crores except EPS
FUNDAMENTAL UPDATE
ITC LTD
www.rudrashares.com 2
Moreover, it is continuously improving distribution footprint
in terms of adding more markets and outlets. In the rural
areas, ITC sells it products in villages having a population size
of 5000 currently. They have van-based, selling arrangements
wherein new clusters are being approached.
ITC has delivered a robust growth in revenues & profitability for
the FY 19. The non-cigarette FMCG segment recorded growth
ahead of the industry despite subdued demand environment,
that Being achieved despite heightened competitive intensity,
elevated input costs, gestation costs of new products/categories
and manufacturing facilities, and ongoing restructuring of the
lifestyle retailing business, as stated in the AR (Annual Report)
.
No doubt that ITC already sells packaged foods, personal care,
and stationery under its consumer goods portfolio, spanning
brands such as Aashirwad, Sunfeast biscuits, Yippie noo-
dles, B Natural juices, Vivel soaps, Bingo chips and in-
cense sticks. Last year, the company also forayed into dairy
products. Over 50 products were launched last year to
strengthen existing categories and enter newer segments
During Q1FY20, company has launched 25 new products
which is half of what being done in the whole FY18-19. How-
ever, management guided that for the remaining year, the
product launches are likely to be at the same level. No doubt,
ITC is driving growth with new products, but now, with new
management this focus is combined with profitability.
Also, to fight the slowdown it is into the introduction of low -
unit price packs in multiple categories to make product af-
fordable to a much larger audience & induce trials. Some of
the value packs have been created keeping slowdown in mind,
while existing ones are being pushed aggressively. For in-
stance, in biscuits, it has introduced a mom’s magic bulk
pack & a 300grm pack for dark fantacy choco fills.
New product launches
FUNDAMENTAL UPDATE
ITC LTD
www.rudrashares.com 3
Now, the newer FMCG businesses contribute 25% to ITC’s segment revenue; while
EBITDA for the segment jumped over 50% to ₹688 crore in FY19, Some of its key brands
also achieved scale. In the last financial year, its packaged foods brand Aashirvaad
touched ₹4,500 crore in sales; Sunfeast is over Rs.3,800 crores; Bingo! became
a ₹2,500-crore brand.
Moreover, management stated that it is also scaling its manufacturing infrastructure, by
“investing in building state-of-the-art manufacturing infrastructure across the country to rap-
idly scale up the FMCG businesses.." For this an investment outlay of Rs 25000cr has been envis-
aged. This includes the creation of 20 Integrated Consumer Goods Manufacturing and Logistics
(ICML) facilities that will aid the company with economies of scale, freshness and close-to-
market distribution.
.Also, to drive growth, ITC is continuing to strengthen and scale up existing categories and
foraying into new categories across FMCG segments including branded packaged foods, per-
sonal care products, education and stationery products as well as agarbatti and matches.
Further, is open up for any acquisitions that brings in value.
FY 19 Key Highlights
 Gross Sales Value for the year stood at ` 75309.36 cr, representing a growth of 12.3%
over 2017-18 driven mainly by Agri Business, Branded Packaged Foods, Education & Station-
ery Products Business, Hotels and Paper boards.
 Profit After Tax at ` 12464.32 cr registered growth of 11.1% over the previous year. Total
Comprehensive Income for the year stood at ` 12826.88 cr (previous year ` 11605.59 cr).
EPS for the year stood at ` 10.19 (previous year ` 9.22). Cash generated from operations ag-
gregated ` 17234.93 cr.
 Company’s FMCG-Others Segment Revenue at ` 12505.28 cr grew ahead of industry and
recorded an increase of 12% (on a comparable basis and excluding Lifestyle Retailing Busi-
ness). Most major categories enhanced their market standing during the year.
 While ‘Bingo!’ snacks, ‘Aashirvaad’ atta, YiPPee!’ noodles and ‘Dark Fantasy Choco Fills’
super-premium cream biscuits were the key drivers of growth in the Branded Packaged
Foods Businesses, ‘Engage’ deodorants, ‘Vivel’/‘Fiama’ shower gels & bodywash and ‘Savlon’
handwash reported robust growth in the Personal Care Products Business.
 New blended spices variants were launched catering to regional tastes and preferences
such as ‘Chicken 65’ & ‘Mutton Chukka Masala’ in Tamil Nadu and ‘Garam Masala’ in Uttar
Pradesh. With extension of the portfolio to the new geographies of North India and Gujarat,
Aashirvaad range of spices is now available in most states of India.
FUNDAMENTAL UPDATE
ITC LTD
www.rudrashares.com 4
COMPANY OVERVIEW
ITC has sustained its position as one of the fastest growing FMCG businesses in the coun-
try, leveraging a robust portfolio of brands, a slew of first-to-market offers, a range of distinc-
tive, customised products, innovation, premiumisation, along with an efficient supply chain
and expanding distribution network.
The strategy to pursue multiple drivers of growth across all 3 sectors – agriculture, manu-
facturing and services, has led to ITC’s journey of transformation from a single product
company to a multi-business corporation, with market leadership in several segments.
Within a relatively short span of time, ITC has built over 25 mother brands, many of which
are market leaders in their segments. Today, ITC’s FMCG products reach over 124 million In-
dian households.
This vibrant portfolio of brands represents an annual consumer spend of over `18,000 cr
today. ITC’s world-class Indian brands anchor competitive and inclusive value chains that
create, capture and retain larger value within the country as opposed to brands owned over-
seas that rely on global supply chains besides necessitating payments in the form of royalties,
etc.
ITC has achieved a big milestone by reducing its dependence on core tobacco business and has
now, shifted to diversified consumer business, which the company was also focusing on from a
quite some time. Moreover, it Aspires to achieve `1lakh cr revenue from FMCG by FY2030. By
launching new products and enter newer segments company has launched 25 new products
during Q1FY20 which is half of what being done in the whole FY18-19.
Thus, despite being slowdown in the economy ITC has delivered good results. Also, is scal-
ing its manufacturing infrastructure, and for this an investment outlay of ` 25000cr has been
envisaged.
Taking a long term view on the stock, we suggest “Add more” to the stock at the current
levels @245 for a price target @282 and tenure of 1 year.
VALUATION CONCLUSION
FUNDAMENTAL UPDATE
ITC LTD
www.rudrashares.com 5
Disclosures :
Business Activity :
Rudra Shares & Stock Brokers Limited is engaged in the business of providing broking services & distribu-
tion of various financial products. RUDRA is also registered as a Research Analyst under SEBI(Research
Analyst) Regulations, 2014. SEBI Reg. No. INH100002524.
Disciplinary History :
There has been no instance of any Disciplinary action, penalty etc. levied/passed by any regula-
tion/administrative agencies against RUDRA and its Directo` Pursuant to SEBI inspection of books and re-
cords of Rudra, as a Stock Broker, SEBI has not issued any Administrative warning to Rudra.
Terms & Conditions of issuance of Research Report:
The Research report is issued to the registered clients. The Research Report is based on the facts, figures
and information that are considered true, correct and reliable. The information is obtained from publicly
available media or other sources believed to be reliable. The report is prepared solely for informational pur-
pose and does not constitute an offer document or solicitation to buy or sell or subscribe for securities or
other financial instruments for clients.
Disclosures with regard to ownership and material conflicts of interest :
Rudra or its research analysts, or his/her relative or associate has any direct or
Indirect financial interest in the subject company. NO
Rudra or its research analysts, or his/her relative or associate has any other
material conflict of interest at time of publication of the research report. NO
Rudra or its research analysts, or his/her relative or associates have actual
ownership of one per cent or more securities of the subject company. NO
Disclosures with regard to receipt of compensation :
Rudra or its associates have received any compensation from the subject
company in the past twelve months. NO
Rudra or its associates have managed or co-managed public offering of
securities for the subject in the past twelve months. NO
Rudra or its associates have received any compensation or other benefits
from the subject company or third party in connection with the
research report . NO
FUNDAMENTAL UPDATE
ITC LTD
www.rudrashares.com 6
Other Disclosures:
The research analyst has served as an officer,director,employee of the
subject company. NO
Rudra or its research analyst has been engaged in market making activity
for the subject company. NO
Rudra or its or associates have received any compensation from the
subject company in the past twelve months. NO
Disclaimers:
This Research Report (hereinafter called report) has been prepared and presented by RUDRA SHARES & STOCK
BROKERS LIMITED, which does not constitute any offer or advice to sell or does solicitation to buy any securities.
The information presented in this report, are for the intended recipients only. Further, the intended recipients are ad-
vised to exercise restraint in placing any dependence on this report, as the sender, Rudra Shares & Stock Brokers
Limited, neither guarantees the accuracy of any information contained herein nor assumes any responsibility in rela-
tion to losses arising from the errors of fact, opinion or the dependence placed on the same.
Despite the information in this document has been previewed on the basis of publicly available information, internal
data , personal views of the research analyst(s)and other reliable sources, believed to be true, we do not represent it as
accurate, complete or exhaustive. It should not be relied on as such, as this document is for general guidance only.
Besides this, the research analyst(s) are bound by stringent internal regulations and legal and statutory requirements
of the Securities and Exchange Board of India( SEBI) and the analysts' compensation was, is, or will be not directly
or indirectly related with the other companies and/or entities of Rudra Shares & Stock Brokers Ltd and have no bear-
ing whatsoever on any recommendation, that they have given in the research report. Rudra Shares & Stock Brokers
Ltd or any of its affiliates/group companies shall not be in any way responsible for any such loss or damage that may
arise to any person from any inadvertent error in the information contained in this report. Rudra Shares & Stock Bro-
kers Ltd has not independently verified all the information, which has been obtained by the company for analysis
purpose, from publicly available media or other sources believed to be reliable. Accordingly, we neither testify nor
make any representation or warranty, express or implied, of the accuracy, contents or data contained within this
document. Rudra Share & Stock Brokers Ltd and its affiliates are engaged in investment advisory, stock broking,
retail & HNI and other financial services. Details of affiliates are available on our website i.e. www.rudrashares.com.
We hereby declare, that the information herein may change any time due to the volatile market conditions, therefore,
it is advised to use own discretion and judgment while entering into any transactions, whatsoever.
Individuals employed as research analyst by Rudra Shares & Stock Brokers Ltd or their associates are not allowed to
deal or trade in securities, within thirty days before and five days after the publication of a research report as pre-
scribed under SEBI Research Analyst Regulations.
Subject to the restrictions mentioned in above paragraph, we and our affiliates, officers, directors, employees and
their relative may: (a) from time to time, have long or short positions acting as a principal in, and buy or sell the secu-
rities or derivatives thereof, of Company mentioned herein or (b) be engaged in any other transaction involving such
securities and earn brokerage or profits.
FUNDAMENTAL UPDATE
ITC LTD

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ITC Reduces Dependence on Tobacco to 45

  • 1. www.rudrashares.com 1 Reducing dependence on core tobacco business to now, diversified consumer business– a big milestone achieved ITC is transforming itself by reducing dependence on tobacco products. From quite some time company was focusing on shift- ing itself from tobacco business into consumer business. Thus, for the first time during FY19, cigarette division contributed 45.8% to gross revenue which is quite less than a 52.08% share a year ago & nearly two-thirds of sales i.e. 62.70% & 61.82% in FY16 and FY17 respectively. Thus, from past few years dependence on cigarette division reduced to less than half from 62.70% to 45.8%, which is remarkable. Also, steep increase in taxes on tobacco by government & trading volumes in illegal cigarettes has affected such business. Thereby, now the consumer business i.e. the foods division, com- prising cookies, staples and snacks, now accounts for 21.3% of revenue, while agri-business generated 13.4% of ITC’s gross turn- over last fiscal. Aspires to achieve `1lakh cr revenue from FMCG by FY2030 ITC is aspiring to become India’s largest pure-play FMCG firm by FY 2030 from the branded consumer goods, to account for ` 1 lakh crore in revenue, that is roughly a 16-17 per cent year-on year growth. In the last 12 years, revenues from the segment have grown from ` 1,704 crore in 2006-07 to ` 12,505 crore in 2018-19. With brands such as Aashirvaad, Bingo, and Sunfeast, ITC is the leader in the branded wheat-flour market and a dominant player in cookies. It is India’s second-largest company in segments such as noodles, deodorants and incense sticks. It is also India’s second-largest hotel chain, with revenues in excess of ` 1,648 crore. LEAD RATIONALE 27 AUG 2019 Index Detail Sensex 37641.27 Nifty 11105.35 Index A / S&P BSE CMP 245 Target 282 M.Cap (` in cr) 301228.20 Equity ( ` in cr) 1228.50 52 wk H/L ` 310/234.70 Face Value ` 1.00 Div. Yield 2.38 NSE Code ITC BSE Code 500875 Stock Data P/E 22.70 EV/EBITDA 14.16 P/BV 4.81 Valuation Data EV 297089.61 Net Worth 62577.38 BV 50.94 EPS(TTM) 10.80 Financial Data ` In crores except EPS FUNDAMENTAL UPDATE ITC LTD
  • 2. www.rudrashares.com 2 Moreover, it is continuously improving distribution footprint in terms of adding more markets and outlets. In the rural areas, ITC sells it products in villages having a population size of 5000 currently. They have van-based, selling arrangements wherein new clusters are being approached. ITC has delivered a robust growth in revenues & profitability for the FY 19. The non-cigarette FMCG segment recorded growth ahead of the industry despite subdued demand environment, that Being achieved despite heightened competitive intensity, elevated input costs, gestation costs of new products/categories and manufacturing facilities, and ongoing restructuring of the lifestyle retailing business, as stated in the AR (Annual Report) . No doubt that ITC already sells packaged foods, personal care, and stationery under its consumer goods portfolio, spanning brands such as Aashirwad, Sunfeast biscuits, Yippie noo- dles, B Natural juices, Vivel soaps, Bingo chips and in- cense sticks. Last year, the company also forayed into dairy products. Over 50 products were launched last year to strengthen existing categories and enter newer segments During Q1FY20, company has launched 25 new products which is half of what being done in the whole FY18-19. How- ever, management guided that for the remaining year, the product launches are likely to be at the same level. No doubt, ITC is driving growth with new products, but now, with new management this focus is combined with profitability. Also, to fight the slowdown it is into the introduction of low - unit price packs in multiple categories to make product af- fordable to a much larger audience & induce trials. Some of the value packs have been created keeping slowdown in mind, while existing ones are being pushed aggressively. For in- stance, in biscuits, it has introduced a mom’s magic bulk pack & a 300grm pack for dark fantacy choco fills. New product launches FUNDAMENTAL UPDATE ITC LTD
  • 3. www.rudrashares.com 3 Now, the newer FMCG businesses contribute 25% to ITC’s segment revenue; while EBITDA for the segment jumped over 50% to ₹688 crore in FY19, Some of its key brands also achieved scale. In the last financial year, its packaged foods brand Aashirvaad touched ₹4,500 crore in sales; Sunfeast is over Rs.3,800 crores; Bingo! became a ₹2,500-crore brand. Moreover, management stated that it is also scaling its manufacturing infrastructure, by “investing in building state-of-the-art manufacturing infrastructure across the country to rap- idly scale up the FMCG businesses.." For this an investment outlay of Rs 25000cr has been envis- aged. This includes the creation of 20 Integrated Consumer Goods Manufacturing and Logistics (ICML) facilities that will aid the company with economies of scale, freshness and close-to- market distribution. .Also, to drive growth, ITC is continuing to strengthen and scale up existing categories and foraying into new categories across FMCG segments including branded packaged foods, per- sonal care products, education and stationery products as well as agarbatti and matches. Further, is open up for any acquisitions that brings in value. FY 19 Key Highlights  Gross Sales Value for the year stood at ` 75309.36 cr, representing a growth of 12.3% over 2017-18 driven mainly by Agri Business, Branded Packaged Foods, Education & Station- ery Products Business, Hotels and Paper boards.  Profit After Tax at ` 12464.32 cr registered growth of 11.1% over the previous year. Total Comprehensive Income for the year stood at ` 12826.88 cr (previous year ` 11605.59 cr). EPS for the year stood at ` 10.19 (previous year ` 9.22). Cash generated from operations ag- gregated ` 17234.93 cr.  Company’s FMCG-Others Segment Revenue at ` 12505.28 cr grew ahead of industry and recorded an increase of 12% (on a comparable basis and excluding Lifestyle Retailing Busi- ness). Most major categories enhanced their market standing during the year.  While ‘Bingo!’ snacks, ‘Aashirvaad’ atta, YiPPee!’ noodles and ‘Dark Fantasy Choco Fills’ super-premium cream biscuits were the key drivers of growth in the Branded Packaged Foods Businesses, ‘Engage’ deodorants, ‘Vivel’/‘Fiama’ shower gels & bodywash and ‘Savlon’ handwash reported robust growth in the Personal Care Products Business.  New blended spices variants were launched catering to regional tastes and preferences such as ‘Chicken 65’ & ‘Mutton Chukka Masala’ in Tamil Nadu and ‘Garam Masala’ in Uttar Pradesh. With extension of the portfolio to the new geographies of North India and Gujarat, Aashirvaad range of spices is now available in most states of India. FUNDAMENTAL UPDATE ITC LTD
  • 4. www.rudrashares.com 4 COMPANY OVERVIEW ITC has sustained its position as one of the fastest growing FMCG businesses in the coun- try, leveraging a robust portfolio of brands, a slew of first-to-market offers, a range of distinc- tive, customised products, innovation, premiumisation, along with an efficient supply chain and expanding distribution network. The strategy to pursue multiple drivers of growth across all 3 sectors – agriculture, manu- facturing and services, has led to ITC’s journey of transformation from a single product company to a multi-business corporation, with market leadership in several segments. Within a relatively short span of time, ITC has built over 25 mother brands, many of which are market leaders in their segments. Today, ITC’s FMCG products reach over 124 million In- dian households. This vibrant portfolio of brands represents an annual consumer spend of over `18,000 cr today. ITC’s world-class Indian brands anchor competitive and inclusive value chains that create, capture and retain larger value within the country as opposed to brands owned over- seas that rely on global supply chains besides necessitating payments in the form of royalties, etc. ITC has achieved a big milestone by reducing its dependence on core tobacco business and has now, shifted to diversified consumer business, which the company was also focusing on from a quite some time. Moreover, it Aspires to achieve `1lakh cr revenue from FMCG by FY2030. By launching new products and enter newer segments company has launched 25 new products during Q1FY20 which is half of what being done in the whole FY18-19. Thus, despite being slowdown in the economy ITC has delivered good results. Also, is scal- ing its manufacturing infrastructure, and for this an investment outlay of ` 25000cr has been envisaged. Taking a long term view on the stock, we suggest “Add more” to the stock at the current levels @245 for a price target @282 and tenure of 1 year. VALUATION CONCLUSION FUNDAMENTAL UPDATE ITC LTD
  • 5. www.rudrashares.com 5 Disclosures : Business Activity : Rudra Shares & Stock Brokers Limited is engaged in the business of providing broking services & distribu- tion of various financial products. RUDRA is also registered as a Research Analyst under SEBI(Research Analyst) Regulations, 2014. SEBI Reg. No. INH100002524. Disciplinary History : There has been no instance of any Disciplinary action, penalty etc. levied/passed by any regula- tion/administrative agencies against RUDRA and its Directo` Pursuant to SEBI inspection of books and re- cords of Rudra, as a Stock Broker, SEBI has not issued any Administrative warning to Rudra. Terms & Conditions of issuance of Research Report: The Research report is issued to the registered clients. The Research Report is based on the facts, figures and information that are considered true, correct and reliable. The information is obtained from publicly available media or other sources believed to be reliable. The report is prepared solely for informational pur- pose and does not constitute an offer document or solicitation to buy or sell or subscribe for securities or other financial instruments for clients. Disclosures with regard to ownership and material conflicts of interest : Rudra or its research analysts, or his/her relative or associate has any direct or Indirect financial interest in the subject company. NO Rudra or its research analysts, or his/her relative or associate has any other material conflict of interest at time of publication of the research report. NO Rudra or its research analysts, or his/her relative or associates have actual ownership of one per cent or more securities of the subject company. NO Disclosures with regard to receipt of compensation : Rudra or its associates have received any compensation from the subject company in the past twelve months. NO Rudra or its associates have managed or co-managed public offering of securities for the subject in the past twelve months. NO Rudra or its associates have received any compensation or other benefits from the subject company or third party in connection with the research report . NO FUNDAMENTAL UPDATE ITC LTD
  • 6. www.rudrashares.com 6 Other Disclosures: The research analyst has served as an officer,director,employee of the subject company. NO Rudra or its research analyst has been engaged in market making activity for the subject company. NO Rudra or its or associates have received any compensation from the subject company in the past twelve months. NO Disclaimers: This Research Report (hereinafter called report) has been prepared and presented by RUDRA SHARES & STOCK BROKERS LIMITED, which does not constitute any offer or advice to sell or does solicitation to buy any securities. The information presented in this report, are for the intended recipients only. Further, the intended recipients are ad- vised to exercise restraint in placing any dependence on this report, as the sender, Rudra Shares & Stock Brokers Limited, neither guarantees the accuracy of any information contained herein nor assumes any responsibility in rela- tion to losses arising from the errors of fact, opinion or the dependence placed on the same. Despite the information in this document has been previewed on the basis of publicly available information, internal data , personal views of the research analyst(s)and other reliable sources, believed to be true, we do not represent it as accurate, complete or exhaustive. It should not be relied on as such, as this document is for general guidance only. Besides this, the research analyst(s) are bound by stringent internal regulations and legal and statutory requirements of the Securities and Exchange Board of India( SEBI) and the analysts' compensation was, is, or will be not directly or indirectly related with the other companies and/or entities of Rudra Shares & Stock Brokers Ltd and have no bear- ing whatsoever on any recommendation, that they have given in the research report. Rudra Shares & Stock Brokers Ltd or any of its affiliates/group companies shall not be in any way responsible for any such loss or damage that may arise to any person from any inadvertent error in the information contained in this report. Rudra Shares & Stock Bro- kers Ltd has not independently verified all the information, which has been obtained by the company for analysis purpose, from publicly available media or other sources believed to be reliable. Accordingly, we neither testify nor make any representation or warranty, express or implied, of the accuracy, contents or data contained within this document. Rudra Share & Stock Brokers Ltd and its affiliates are engaged in investment advisory, stock broking, retail & HNI and other financial services. Details of affiliates are available on our website i.e. www.rudrashares.com. We hereby declare, that the information herein may change any time due to the volatile market conditions, therefore, it is advised to use own discretion and judgment while entering into any transactions, whatsoever. Individuals employed as research analyst by Rudra Shares & Stock Brokers Ltd or their associates are not allowed to deal or trade in securities, within thirty days before and five days after the publication of a research report as pre- scribed under SEBI Research Analyst Regulations. Subject to the restrictions mentioned in above paragraph, we and our affiliates, officers, directors, employees and their relative may: (a) from time to time, have long or short positions acting as a principal in, and buy or sell the secu- rities or derivatives thereof, of Company mentioned herein or (b) be engaged in any other transaction involving such securities and earn brokerage or profits. FUNDAMENTAL UPDATE ITC LTD