India pharma

Sector outlook

Alok Dalal US FDA inspections resume in India

[email protected] History suggests most plants receive observations, but very few escalate
+91 22 6650 5063
Recent US FDA inspections for Lupin and Aurobindo may well result in resumption
of inspections in India, which have been on pause since the outbreak of the
pandemic last year. Products requiring pre-approval inspections, plants with
compliance issues and those supplying high-volume products to the US could be
of priority to the agency, in our view. Many leading Indian companies affected by
US FDA scrutiny over 2018-19 have completed remedial action and await re-
inspections. Stock-price movements for companies that receive inspection
observations tend to be volatile, with the initial reaction being negative. However,
21 September 2021 historical data suggests that very few observations escalate into adverse
outcomes, like a warning letter or import alert.
India Lupin and Aurobindo plants saw US FDA inspection recently
Healthcare  Over the last two months, the US FDA has inspected manufacturing plants of Lupin
(Goa) and Aurobindo (Unit 1). These plants were under a warning letter and an OAI
(Official Action Indicated, a quasi-warning letter) status for some time.
Key Indian plants awaiting US  The inspection for Aurobindo was conducted by the local team of US FDA in India,
FDA inspection:
whereas the inspection details for Lupin are awaited.
 In Aug-21, the US FDA had said that they had no plans to resume onsite foreign
Company Plant
inspections for operations that are not deemed “mission critical” during the Covid-19
Aurobindo Unit XI
public health emergency. Instead, it was relying on the expanded use of mutual
Biocon Bengaluru
recognition agreements as an alternative tool to boost on-the-ground inspections
Cadila Maraiya
Cipla Goa
along with desktop audits wherever possible.
Glenmark Baddi What will be the US FDA’s approach to inspections in India?
Ipca Ratlam  Our interaction with industry participants suggests the US FDA may prioritise pre-
Lupin Indore Unit II approval inspections (PAIs) for products with unmet medical needs in the US followed
Sun Pharma Halol by manufacturing plants with existing compliance issues, like a warning letter/import
Torrent Pharma Indrad, Dahej
alert or an OAI status.
 Manufacturing plants that are compliant with US FDA guidelines but supplying high
volumes to the US could be inspected next.
 Manufacturing plants supplying products to the US having no disruptions at the
moment may not be a priority for the US FDA initially.
Companies affected by US FDA scrutiny in 2019-19 await re-inspections
 A lot of Indian plants were affected by US FDA scrutiny in 2018-19. Examples of such
plants under our coverage are Aurobindo (3 plants including Unit 1), Cadila (Moraiya),
Cipla (Goa), Glenmark (Baddi), Lupin (4 plants including Goa), Sun Pharma (Halol), and
Torrent Pharma (2 plants). These plants have completed remedial work and are
awaiting inspections which has been delayed due to the pandemic
 We believe Lupin’s Indore Unit-2, Cadila’s Moraiya, Cipla’s Goa, Sun Pharma’s Halol
and Torrent Pharma’s Indrad/Dahej plants are important to drive US growth in
FY23/24 and timely inspection/clearance is important.
 Biocon’s plant in Bengaluru, from which it has filed biosimilar Bevacizumab (Avastin), is
also awaiting inspection. Timely approval and launch is important for Biocon before
competition catches up in the product.
Historical data suggests most plants receive observations, but very few escalate
 Stock-price movements for companies that receive inspection observations (listed in
Form 483 by the US FDA) tend to be volatile, with the initial reaction being negative.
 Historical data suggests ~80-85% of inspections globally result in observations, but
only 10-12% of those result in escalations, like OAI, warning letter or import alerts.
 While it is difficult to predict inspection outcomes, we are encouraged by the nature of
observations received by Indian companies over the last few years. These do not
involve data integrity issues, but are directed more towards manpower training,
production process and lab control practices which can be corrected over time.

www.clsa.com
CLSA and CL Securities Taiwan Co., Ltd. (“CLST”) do and seek to do business with companies covered in its research reports. As such,
investors should be aware that there may be conflicts of interest which could affect the objectivity of the report. Investors should consider
this report as only a single factor in making their investment decisions. For important disclosures please refer to page 5.
Prepared for: [email protected]
 US FDA inspections resume in India India pharma

We would like to thank Evalueserve for its help in preparing our research reports. Akshay Chandak (Strategy and Oil & Gas), Ayush Gandhi (Strateg y), Dhaval
Parekh (Materials), Keshub Bhat (IT) and Zen Javeri (Power, Infra and Capital Goods) provide research support services t o CLSA.

Figure 1

Recent US FDA inspections of Indian plants

Date Company, Plant No of observations Status
US FDA inspections in India 19-Sep 2021 Lupin, Goa 7 Warning letter
have resumed 12-Aug 2021 Aurobindo, Unit 1 6 OAI
12-Mar 2021 Jubilant Generics 7 OAI
8-Feb 2021 Alembic Pharma, Karkhadi 5 New facility
Source: Companies, US FDA, CLSA, OAI is Official Action Indicated

Figure 2

Products requiring pre- What will be the US FDA’s approach to inspections in India?
approval inspections, plants
with compliance issues and
those supplying high- Pre-approval inspections for Plants with an import
volume products to the US products with unmet medical need alert/warning letter/OAI status
could be of priority to the
agency, in our view

US FDA's approach
to inspections

Products with adequate supplies to

Plants supplying high-volume
the US may not be a priority at this
products to the US
point

Source: CLSA

Figure 3

Clearance of plants is Key Indian plants awaiting US FDA re-inspections

critical for our coverage Company Plant Capability Last inspected Status
companies as Cadila Aurobindo Unit IX API Feb-19 OAI status
(Moraiya), Cipla (Goa), Unit XI API Feb-19 Warning letter
Glenmark (Baddi), Ipca
Biocon PAI for biosimilar
(three plants), Lupin Bengaluru Biologic products -
Bevacizumab
(four plants), Sun Pharma
Cadila Moraiya Formulations May-19 Warning letter
(Halol), Biocon (approval for
biosimilar Avastin) and Glenmark Baddi Formulations Apr-19 Warning letter
Torrent (two plants) are Ipca Ratlam API Jul-14 Import alert
seeing a drag Indore Formulations Oct-14 Import alert
Somerset, NJ Formulations Nov-20 OAI status
Lupin Mandideep (Unit 1) Formulations Dec-18 Warning letter
Pithampur (Unit 2) Formulations Jan-19 Warning letter
Sun Pharma Halol Formulations Dec-19 OAI status
Indrad Formulations & API Apr-19 Warning letter
Torrent
Dahej Formulations & API Mar-19 OAI status
Source: Companies, US FDA

Find CLSA research on Bloomberg, Thomson Reuters, FactSet and CapitalIQ - and profit from our evalu@tor proprietary database at clsa.com

21 September 2021 [email protected] 2

Prepared for: [email protected]
 US FDA inspections resume in India India pharma

Figure 4

Issuance of warning letters Trend in warning letters by country

increased in 2019 before 100
the Covid pandemic (#) India China USA Others Total
resulted in inspection 90
stoppages 80
70
60
50
40
30
20
10
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Source: US FDA, CLSA

Figure 5

Import alerts have been on Trend in import alert by country

a declining trend since 2017 60 (#) India China Total

50

40

30

20

10

0
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Source: US FDA, CLSA

Figure 6

While 80-85% of plants Trend in plant classification by the US FDA

receive US FDA 140 (#) NAI OAI VAI
observations (Form 483),
only 10-12% escalate into 120
OAIs/warning letters
100

80

60

40

20

0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
Source: US FDA, CLSA, NAI is No Action Indicated, OAI is Official Action Indicated and VAI is Voluntary Action
Indicated

21 September 2021 [email protected] 3

Prepared for: [email protected]
 US FDA inspections resume in India India pharma

Figure 7

Observations for Indian Trend in nature of observations for Indian companies

companies over the last few
% of observations Till 2010 2010 onwards
years have not pointed to
data integrity issues which 43
45
is an encouraging sign 40
40 More procedural in 36
35 nature
30
30
25
20 18
14 15
15
10
5 3

0
Building, equipment Organization and Production, process Records and reports
and packaging personnel and lab controls
Source: US FDA, CLSA

Figure 8

US FDA approach to a plant inspection

US FDA inspects facilities for pre-approval, compliance with cGMP or product specific compliance

Inspectional
Causes for observations Observations

Lack of Difference in Intentional Form 483

knowledge interpretation manipulation issued

US FDA follows an Response needs to be submitted

US FDA provides Level of scrutiny
open approach within 15 working days
time for gaining may become more
through granular; may result In the past, the US FDA
proper knowledge of
communication, in an immediate used to respond within
compliance and to Based on the
frequent follow up import alert if there 3-6 months to
adequately adhere responses given
to allow companies are severe data remedial action taken
with the compliance by firms
to develop better integrity or patient by companies but
requirements
compliance safety issues, it recently the timelines
mechanism could also lead to have got extended to
criminal 12-14 months
investigation or Warning letter
penalties

In a warning letter, there is no supply constraint

for existing products but no future approvals will
be granted from the said facility till issues are
- Import alert is issued based on the response given by a firm to the resolved
warning letter or failure to achieve prompt remedial action
- Repeat violations of observations made in the warning letter or
significant data integrity issues may lead to an import alert Import alert
- Import alerts follow warning letters within 2-4 months (average)
- Products from such facilities are not allowed to be sold in the US until Response needs to be submitted
all violations are corrected. No fresh approvals are granted. within 15 working days

Source: US FDA, CLSA

21 September 2021 [email protected] 4

Prepared for: [email protected]
 Important disclosures India pharma

Research subscriptions
To change your report distribution requirements, please contact your CLSA sales representative or email us at [email protected].
You can also fine-tune your Research Alert email preferences at https://www.clsa.com/member/tools/email_alert/.

Companies mentioned
Alembic Pharma (N-R)
Aurobindo Pharma (ARBP IB - RS726.4 - O-PF)
Biocon (BIOS IB - RS367.1 - SELL)
Cadila Healthcare (CDH IB - RS550.1 - BUY)
Cipla (CIPLA IB - RS956.0 - BUY)
Glenmark Pharma (GNP IS - RS506.2 - SELL)
Ipca (IPCA IB - RS2,433.9 - O-PF)
Jubilant Generics (N-R)
Lupin (LPC IB - RS929.8 - SELL)
Sun Pharma (SUNP IB - RS764.5 - BUY)
Torrent Pharma (TRP IB - RS3,043.1 - BUY)

Analyst certification
The analyst(s) of this report hereby certify that the views expressed in this research report accurately reflect my/our
own personal views about the securities and/or the issuers and that no part of my/our compensation was, is, or will
be directly or indirectly related to the specific recommendation or views contained in this research report.

Important disclosures

The policy of CLSA, CLSA Americas, LLC ("CLSA Americas") and CL has/have not been placed under any undue influence, intervention or
Securities Taiwan Co., Ltd. (“CLST”) is to only publish research that is pressure by any person/s in compiling this research report. In
impartial, independent, clear, fair, and not misleading. Regulations or addition, the analysts included herein attest that they were not in
market practice of some jurisdictions/markets prescribe certain possession of any material, nonpublic information regarding the
disclosures to be made for certain actual, potential or perceived subject company at the time of publication of the report. The analysts
conflicts of interests relating to a research report as below. This further confirm that none of the information used in this report was
research disclosure should be read in conjunction with the research received from CLSA's Corporate Finance department or CLSA's Sales
disclaimer as set out at www.clsa.com/disclaimer.html and the and Trading business. Save from the disclosure below (if any), the
applicable regulation of the concerned market where the analyst is analyst(s) is/are not aware of any material conflict of interest.
stationed and hence subject to. Investors are strongly encouraged to Key to CLSA/CLSA Americas/CLST investment rankings: BUY:
review this disclaimer before investing. Total stock return (including dividends) expected to exceed 20%; O-
Neither analysts nor their household members/associates/may PF (aka ACCUMULATE): Total expected return below 20% but
have a financial interest in, or be an officer, director or advisory board exceeding market return; U-PF (aka REDUCE): Total expected return
member of companies covered by the analyst unless disclosed herein. positive but below market return; SELL: Total return expected to be
In circumstances where an analyst has a pre-existing holding in any negative. For relative performance, we benchmark the 12-month total
securities under coverage, those holdings are grandfathered and the forecast return (including dividends) for the stock against the 12-
analyst is prohibited from trading such securities. month forecast return (including dividends) for the market on which
(For full disclosure of interest for all companies mention on this the stock trades.
report, please refer to "High Conviction" Ideas are not necessarily stocks with the most
http://www.clsa.com/member/research_disclosures/ for details.) upside/downside, but those where the Research Head/Strategist
The analysts included herein hereby confirm that they have not believes there is the highest likelihood of positive/negative returns.
been placed under any undue influence, intervention or pressure by The list for each market is monitored weekly.
any person/s in compiling this research report. In addition, the Overall rating distribution for CLSA (exclude CLST) only Universe:
analysts attest that they were not in possession of any material, non- Overall rating distribution: BUY / Outperform - CLSA: 77.02%,
public information regarding the subject company at the time of Underperform / SELL - CLSA: 22.98%, Restricted - CLSA: 0.18%; Data
publication of the report. Save from the disclosure below (if any), the as of 30 Jun 2021. Investment banking clients as a % of rating
analyst(s) is/are not aware of any material conflict of interest. category: BUY / Outperform - CLSA: 12.59%, Underperform / SELL -
As analyst(s) of this report, I/we hereby certify that the views CLSA: 1.76%; Restricted - CLSA: 0.18%. Data for 12-month period
expressed in this research report accurately reflect my/our own ending 30 Jun 2021.
personal views about the securities and/or the issuers and that no Overall rating distribution for CLST only Universe: Overall rating
part of my/our compensation was, is, or will be directly or indirectly distribution: BUY / Outperform - CLST: 93.44%, Underperform / SELL
related to the specific recommendation or views contained in this - CLST: 6.56%, Restricted - CLST: 0.00%. Data as of 30 Jun 2021.
report or to any investment banking relationship with the subject Investment banking clients as a % of rating category: BUY /
company covered in this report (for the past one year) or otherwise Outperform - CLST: 0.00%, Underperform / SELL - CLST: 0.00%,
any other relationship with such company which leads to receipt of Restricted - CLST: 0.00%. Data for 12-month period ending 30 Jun
fees from the company except in ordinary course of business of the 2021.
company. The analyst/s also state/s and confirm/s that he/she/they There are no numbers for Hold/Neutral as CLSA/CLST do not

21 September 2021 [email protected] 5

Prepared for: [email protected]

 Important disclosures India pharma

have such investment rankings. For a history of the recommendation, the use of this publication/communication or its contents.
price targets and disclosure information for companies mentioned in To maintain the independence and integrity of our research, our
this report please write to: CLSA Group Compliance, 18/F, One Pacific Corporate Finance, Sales Trading, Asset Management and Research
Place, 88 Queensway, Hong Kong and/or; (c) CLST Compliance (27/F, business lines are distinct from one another. This means that CLSA’s
95, Section 2 Dun Hua South Road, Taipei 10682, Taiwan, telephone Research department is not part of and does not report to CLSA
(886) 2 2326 8188). EVA® is a registered trademark of Stern, Stewart Corporate Finance department or CLSA’s Sales and Trading business.
& Co. "CL" in charts and tables stands for CLSA estimates, “CT” stands Accordingly, neither the Corporate Finance nor the Sales and Trading
for CLST estimates, "CRR" stands for CRR Research estimates and department supervises or controls the activities of CLSA’s research
“CS” for Citic Securities estimates unless otherwise noted in the analysts. CLSA’s research analysts report to the management of the
source. Research department, who in turn report to CLSA’s senior
Charts and tables sourced to CLSA in this report may include data management. CLSA has put in place a number of internal controls
extracted from CLSA’s automated databases, which derive their designed to manage conflicts of interest that may arise as a result of
original data from a range of sources. These can include: companies; CLSA engaging in Corporate Finance, Sales and Trading, Asset
analyst estimates/calculations; local exchanges and/or third-party Management and Research activities. Some examples of these
data or market pricing providers such as Bloomberg, FactSet or IBES. controls include: the use of information barriers and other controls
Additional information on data sources for specific charts or tables designed to ensure that confidential information is only shared on a
can be obtained by contacting the publishing analysts. “need to know” basis and in compliance with CLSA’s Chinese Wall
This publication/communication is subject to and incorporates policies and procedures; measures designed to ensure that
the terms and conditions of use set out on the www.clsa.com website interactions that may occur among CLSA’s Research personnel,
(https://www.clsa.com/disclaimer.html). Neither the Corporate Finance, Asset Management, and Sales and Trading
publication/communication nor any portion hereof may be reprinted, personnel, CLSA’s financial product issuers and CLSA’s research
sold, resold, copied, reproduced, distributed, redistributed, published, analysts do not compromise the integrity and independence of CLSA’s
republished, displayed, posted or transmitted in any form or media or research.
by any means without the written consent of CLSA, CLSA Americas Subject to any applicable laws and regulations at any given time,
and/or CLST. CLSA, CLSA Americas and/or CLST has/have produced CLSA, CLSA Americas, CLST, their respective affiliates, officers,
this publication/communication for private circulation to directors or employees may have used the information contained
professional, institutional and/or wholesale clients only, and may not herein before publication and may have positions in, or may from time
be distributed to retail investors. The information, opinions and to time purchase or sell or have a material interest in any of the
estimates herein are not directed at, or intended for distribution to or securities mentioned or related securities, or may currently or in
use by, any person or entity in any jurisdiction where doing so would future have or have had a business or financial relationship with, or
be contrary to law or regulation or which would subject CLSA, CLSA may provide or have provided corporate finance/capital markets
Americas, and/or CLST to any additional registration or licensing and/or other services to, the entities referred to herein, their advisors
requirement within such jurisdiction. The information and statistical and/or any other connected parties. As a result, you should be aware
data herein have been obtained from sources we believe to be that CLSA, CLSA Americas, and/or CLST and/or their respective
reliable. Such information has not been independently verified and we affiliates, officers, directors or employees may have one or more
make no representation or warranty as to its accuracy, completeness conflicts of interest. Regulations or market practice of some
or correctness. Any opinions or estimates herein reflect the judgment jurisdictions/markets prescribe certain disclosures to be made for
of CLSA, CLSA Americas, and/or CLST at the date of this certain actual, potential or perceived conflicts of interests relating to
publication/communication and are subject to change at any time research reports. Details of the disclosable interest can be found in
without notice. Where any part of the information, opinions or certain reports as required by the relevant rules and regulation and
estimates contained herein reflects the views and opinions of a sales the full details are available at
person or a non-analyst, such views and opinions may not correspond http://www.clsa.com/member/research_disclosures/. Disclosures
to the published view of CLSA, CLSA Americas, and/or CLST. Any therein include the position of CLSA, CLSA Americas, and CLST only.
price target given in the report may be projected from one or more Unless specified otherwise, CLSA did not receive any compensation
valuation models and hence any price target may be subject to t he or other benefits from the subject company, covered in this
inherent risk of the selected model as well as other external risk publication/communication, or from any third party. If investors have
factors. Where the publication does not contain ratings, the material any difficulty accessing this website, please contact
should not be construed as research but is offered as factual [email protected] on +852 2600 8111. If you require disclosure
commentary. It is not intended to, nor should it be used to form an information on previous dates, please contact
investment opinion about the non-rated companies. [email protected].
This publication/communication is for information purposes only This publication/communication is distributed for and on behalf
and it does not constitute or contain, and should not be considered as of CLSA (for research compiled by non-US and non-Taiwan analyst(s)),
an offer or invitation to sell, or any solicitation or invitation of any CLSA Americas, and/or CLST (for research compiled by Taiwan
offer to subscribe for or purchase any securities in any jurisdiction analyst(s)) in Australia by CLSA Australia Pty Ltd (ABN 53 139 992
and recipient of this publication/communication must make its own 331/AFSL License No: 350159); in Hong Kong by CLSA Limited
independent decisions regarding any securities or financial (Incorporated in Hong Kong with limited liability); in India by CLSA
instruments mentioned herein. This is not intended to provide India Private Limited, (Address: 8/F, Dalamal House, Nariman Point,
professional, investment or any other type of advice or Mumbai 400021. Tel No: +91-22-66505050. Fax No: +91-22-
recommendation and does not take into account the particular 22840271; CIN: U67120MH1994PLC083118; SEBI Registration No:
investment objectives, financial situation or needs of individual INZ000001735 as Stock Broker, INM000010619 as Merchant Banker
recipients. Before acting on any information in this and INH000001113 as Research Analyst,; in Indonesia by PT CLSA
publication/communication, you should consider whether it is Sekuritas Indonesia; in Japan by CLSA Securities Japan Co., Ltd.; in
suitable for your particular circumstances and, if appropriate, seek Korea by CLSA Securities Korea Ltd.; in Malaysia by CLSA Securities
professional advice, including tax advice. Investments involve risks, Malaysia Sdn. Bhd.; in the Philippines by CLSA Philippines Inc (a
and investors should exercise prudence and their own jud gment in member of Philippine Stock Exchange and Securities Investors
making their investment decisions. The value of any investment or Protection Fund); in Singapore by CLSA Singapore Pte Ltd and solely
income my go down as well as up, and investors may not get back the to persons who qualify as an "Institutional Investor", "Accredited
full (or any) amount invested. Past performance is not necessarily a Investor" or "Expert Investor" MCI (P) 024/12/2020; in Thailand by
guide to future performance. CLSA, CLSA Americas, and/or CLST CLSA Securities (Thailand) Limited; in Taiwan by CLST and in the EU
do/does not accept any responsibility and cannot be held liable for and United Kingdom by CLSA Europe BV or CLSA (UK).
any person’s use of or reliance on the information and opinions Australia: CLSA Australia Pty Ltd (“CAPL”) (ABN 53 139 992
contained herein. To the extent permitted by applicable securities 331/AFS License No: 350159) is regulated by ASIC and is a Market
laws and regulations, CLSA, CLSA Americas, and/or CLST accept(s) no Participant of ASX Limited and CHI-X. This material is issued and
liability whatsoever for any direct or consequential loss arising from distributed by CAPL in Australia to "wholesale clients" only. This

21 September 2021 [email protected] 6

Prepared for: [email protected]

 Important disclosures India pharma

material does not take into account the specific investment compiled by US analyst(s), it is distributed by CLSA Americas. Where
objectives, financial situation or particular needs of the recipient. The any section is compiled by non-US analyst(s), it is distributed into the
recipient of this material must not distribute it to any third party United States by CLSA solely to persons who qualify as "Major US
without the prior written consent of CAPL. For the purposes of this Institutional Investors" as defined in Rule 15a-6 under the Securities
paragraph the term "wholesale client" has the meaning given in and Exchange Act of 1934 and who deal with CLSA Americas.
section 761G of the Corporations Act 2001. CAPL’s research However, the delivery of this research report to any person in the
coverage universe spans listed securities across the ASX All United States shall not be deemed a recommendation to effect any
Ordinaries index, securities listed on offshore markets, unlisted transactions in the securities discussed herein or an endorsement of
issuers and investment products which Research management deem any opinion expressed herein. Any recipient of this research in the
to be relevant to the investor base from time to time. CAPL seeks to United States wishing to effect a transaction in any security
cover companies of relevance to its domestic and international mentioned herein should do so by contacting CLSA Americas.
investor base across a variety of sectors. The European Union (“EU”) and the United Kingdom: In these
India: CLSA India Private Limited, incorporated in November 1994 jurisdictions, this research is a marketing communication. It has not
provides equity brokerage services (SEBI Registration No: been prepared in accordance with the legal requirements designed to
INZ000001735), research services (SEBI Registration No: promote the independence of investment research, and is not subject
INH000001113) and merchant banking services (SEBI Registration to any prohibition on dealing ahead of the dissemination of
No.INM000010619) to global institutional investors, pension funds investment research. The research is disseminated in these countries
and corporates. CLSA and its associates may have debt holdings in the by either CLSA (UK) or CLSA Europe BV. CLSA (UK) is authorised and
subject company. Further, CLSA and its associates, in the past 12 regulated by the Financial Conduct Authority. CLSA Europe BV is
months, may have received compensation for non-investment authorised and regulated by the Authority for Financial Markets in the
banking securities and/or non-securities related services from the Netherlands. This document is directed at persons having
subject company. For further details of “associates” of CLSA India professional experience in matters relating to investments as defined
please contact [email protected]. in the relevant applicable local regulations. Any investment activity to
Singapore: This report is distributed in Singapore by CLSA which it relates is only available to such persons. If you do not have
Singapore Pte Ltd to institutional investors, accredited investors or professional experience in matters relating to investments you should
expert investors (each as defined under the Financial Advisers not rely on this document. Where the research material is compi led
Regulations) only. Singapore recipients should contact CLSA by the UK analyst(s), it is produced and disseminated by CLSA (UK)
Singapore Pte Ltd, 80 Raffles Place, #18-01, UOB Plaza 1, Singapore and CLSA Europe BV. For the purposes of the Financial Conduct Rules
048624, Tel: +65 6416 7888, in respect of any matters arising from, in the United Kingdom and MIFID II in other European jurisdictions
or in connection with, the analysis or report. By virtue of your stat us this research is prepared and intended as substantive research
as an institutional investor, accredited investor or expert investor, material.
CLSA Singapore Pte Ltd is exempted from complying with certain For all other jurisdiction-specific disclaimers please refer to
requirements under the Financial Advisers Act (Chapter 110), the https://www.clsa.com/disclaimer.html. The analysts/contributors to
Financial Advisers Regulations and the relevant Notices and this publication/communication may be employed by any relevant
Guidelines issued thereunder (as disclosed in Part C of the Securities CLSA entity or CLST, which is different from the entity that
Dealing Services – Singapore Annex of the CLSA terms of business), distributes the publication/communication in the respective
in respect of any financial advisory services that CLSA Singapore Pte jurisdictions.© 2021 CLSA and/or CL Securities Taiwan Co., Ltd.
Ltd may provide to you. MCI (P) 024/12/2020 (“CLST”).
United States of America: Where any section of the research is

21 September 2021 [email protected] 7

Prepared for: [email protected]