Flour Mills of Nigeria Plc and Southern Star Shipping, Inc
Final Report
CLIENT WORK PRODUCT
CONFIDENTIAL
To:
Mr. Daniel Maldonado, Bunge Latin America
Date: March 7, 2011
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
T A B L E OF C O NT E N T S
INTRODUCTION .................................................................................................................................4
METHODOLOGY .................................................................................................................................4
SOUTHERN STAR SHIPPING COMPANY .................................................................................................7
GEORGE S. COUMANTAROS ...................................................................................................................8
JOHN G. COUMANTAROS......................................................................................................................10
FLOUR MILLS OF NIGERIA PLC.............................................................................................................11
NIGERIAN DIRECTORS OF FLOUR MILLS OF NIGERIA PLC ...............................................................13
INVESTIGATIVE FINDIN GS ......................................................................................................15
UNITED STATES......................................................................................................................................15
Southern Star Shipping Co., Inc. ....................................................................................................15
Corporate Information ........................................................................................................................15
Litigation History...............................................................................................................................16
U.S. Federal: Criminal and Civil ............................................................................................................. 16
State: Criminal and Civil ......................................................................................................................... 17
Miscellaneous Records Check .............................................................................................................18
Uniformed Commercial Codes (UCCs) .................................................................................................... 18
US Tax Court ........................................................................................................................................... 18
Real Estate Properties ........................................................................................................................18
Media Review .....................................................................................................................................19
George S. Coumantaros ....................................................................................................................19
Background.........................................................................................................................................19
Corporate and Professional Affiliations .............................................................................................21
Litigation History...............................................................................................................................22
U.S. Federal: Criminal and Civil ............................................................................................................. 22
State: Criminal and Civil ......................................................................................................................... 22
Miscellaneous Records Check .............................................................................................................23
Uniformed Commercial Codes (UCCs) .................................................................................................... 23
US Tax Court ........................................................................................................................................... 23
Properties............................................................................................................................................23
Media Review .....................................................................................................................................24
Page 2 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
John G. Coumantaros ........................................................................................................................25
Background.........................................................................................................................................25
Corporate and Professional Affiliations .............................................................................................25
Litigation History...............................................................................................................................26
U.S. Federal: Criminal and Civil ............................................................................................................. 26
State: Criminal and Civil ......................................................................................................................... 27
Miscellaneous Records Check .............................................................................................................28
Uniformed Commercial Codes (UCCs) .................................................................................................... 28
US Tax Court ........................................................................................................................................... 28
Real Estate Properties ........................................................................................................................28
Media Review .....................................................................................................................................29
NIGERIA ..................................................................................................................................................29
Flour Mills of Nigeria Plc.................................................................................................................29
Overview ............................................................................................................................................29
Capital Raising & Expansion.............................................................................................................31
Directors .............................................................................................................................................31
Shareholders .......................................................................................................................................32
Subsidiaries ........................................................................................................................................33
Reputation ..........................................................................................................................................46
Ahmed A Joda ....................................................................................................................................50
Emmanuel Ukpabi.............................................................................................................................52
Page 3 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
INTRODUCTION
FTI Consulting, Inc. (“FTI”) was retained by Bunge Latin America (“Client”) to conduct a due
diligence investigation of Flour Mills of Nigeria Plc and Southern Star Shipping Company Inc., a
United States corporation. Specifically, the focus of this investigation is to identify any information
of potential material concern that may be deemed to be prejudicial against the two companies. This
investigation was conducted in Nigeria and the United States.
Southern Star Shipping Company, Inc. is a privately held company based in New York, USA. As
part of this investigation, two principals of Southern Star Shipping Company, Inc., were also
investigated to identify any possible negative issues or potential issues of material concern. These
individuals are George S. Coumantaros and John G. Coumantaros.
Flour Mills of Nigeria Plc is a publicly traded company on the Nigerian Stock Exchange. As part of
this investigation, Flour Mills of Nigeria’s subsidiaries and two principal Nigerian Directors were
also included.
METHODOLOGY
The investigation in the United States encompassed comprehensive searches of state and federal
criminal and civil records to identify any past and/or current litigations, tax proceedings and
bankruptcies. Additionally, U.S. public records, proprietary and restricted-access databases were
searched to identify liens, tax and administrative proceedings, real estate and other financial
information. Additionally, the investigation included a review of corporate registries to identify
potential share holdings, directorships and/or other involvements in corporations, affiliates, and
business partners and activities. Confidential inquiries were also made with high-level business
sources in the industry to further establish the reputations of the individuals.
Searches were conducted of in-house databases and international black lists naming individuals
and organizations suspected of involvement in criminal or unethical behavior. The searches
Page 4 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
incorporate lists produced by various international organizations such as the World Bank, The
Office of Foreign Assets Control (OFAC), the FBI and the European Union Blacklist.
Likewise, a comprehensive on-line search and review of U.S. and global media was conducted, as
well as consultations of specialized, proprietary and restricted access databases, in order to
develop relevant personal, professional and legal information regarding the U.S. entities and
individuals.
A similar investigative approach was taken in Nigeria and included collecting and reviewing
corporate registry filings of Flour Mills of Nigeria Plc and its subsidiaries to identify date of
incorporation, shareholders, directors, and other pertinent data. Financial statements for Flour
Mills of Nigeria filed with the Nigerian Stock Exchange were also obtained to identify significant
shareholders.
Additionally, confidential inquiries were also placed with the following sources:

Senior sources at the Economic and Financial Crimes Commission, to identify possible past
and current investigations into the Company and/or its subsidiaries.

Senior political contacts in Nigeria to determine Flour Mills’ political relationships,
including and any implications of the April 9 presidential election.

Security professionals to identify security concerns that may exist in Nigeria or past
security incidents involving the Company.

Counter-parties of Flour Mills obtain information on past business transactions,
relationships and any other issues that surface.

Additional trusted sources to obtain reputational information on the Company.
Additionally, in-depth local and international media searches were conducted through public and
restricted access databases.
Page 5 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
EXECUTIVE SUMMARY
Flour Mills Nigeria Plc (“FMN”) is the holding company of a diversified Nigerian industrial group
with operations in food production and marketing, shipping and cement. It listed on the Nigerian
Stock Exchange on August 14, 1979.
As reported in its 2009 Annual Financial Statements submitted to the Nigerian Stock Exchange,
approximately 48% of FMN’s shares are traded publicly, without further specification of
ownership in regard to these.
The same report identifies the majority, private shareholder of FMN as Excelsior Shipping
Company Limited, with 51.59%.
George Coumantaros and his family are believed to be the owners of Excelsior Shipping Company
Limited. Excelsior is incorporated in Liberia and inquiries with the Liberian registry confirmed
that the company is owned by Greek interests. A 1964 U.S. civil litigation case against a Liberian
registered shipping vessel names John Coumantaros, George Coumantaros’ son, as Excelsior’s sole
shareholder.
A source within the Nigerian Stock Exchange identified West African Investments Company Ltd.
as owner of 4% of FMN publicly traded stock and stated that several FMN directors had less than a
1% ownership interest in the company. No additional information on West African Investments
Company was identified at this time.
The following is the summary of additional principal findings of the investigation into Southern
Star Shipping Company and Flour Mills of Nigeria:
Page 6 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
S O U T HE R N S T A R S HI P P I NG C OM P A NY

Southern Star Shipping Co., Inc., specializes in merchant shipping of bulk cargo. It shares a
name with a subsidiary of Flour Mill of Nigeria, Southern Star Shipping Company
(Nigeria) Limited.

The company was incorporated on July 15, 1947, in New York. It is currently an active
company located at 712 Fifth Avenue, 33rd Floor, New York, New York 10019-4102. It was
previously incorporated in Louisiana on October 13, 1978, but it is currently inactive in that
state.


Corporate records listed the following officers:

George S. Coumantaros – CEO, CFO

George D. Kapetanakos – Finance Officer and Executive Secretary

Martha Romo – Agent and Sales Executive
FTI was initially advised by the Client that Southern Star Shipping Company, Inc., was
believed to be the entity through which George Coumantaros owns the majority interest in
Flour Mills of Nigeria Plc. However, as mentioned previously, it is Excelsior Shipping
Company which privately owns the majority interest in Flour Mills of Nigeria Plc, with
51.59%.

FTI identified six federal civil records and one state civil record under the name of Southern
Star Shipping Co., Inc. All of the cases appear to be related to the nature of the business and
all except one are closed. The only current open case was filed in Pennsylvania on January
27, 2011, and names multiple plaintiffs and defendants, including Southern Shipping Co,
Inc. The case relates to maritime commerce regulation in the U.S., specifically asbestos
products.

An additional court of appeals case filed in 1987 named Southern Star Shipping Company,
Inc., and West Wind Africa Line, Ltd. as defendants. Southern Star Shipping Co., Inc., was
Page 7 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
dismissed from the original case prior to trial. Southern Star Shipping Co., Inc., was the
shipping agent of Westwind Africa Line Ltd., a Liberian corporation which media reviews
indicated may be related to George Coumantaros.

No state or federal criminal records were identified under the company’s name. Also, no
additional tax, credit, or other regulatory issues were identified.

Extensive media searches on the company did not reveal any negative information. In fact,
FTI found very limited information available on the entity through detailed searches using
multiple publicly accessible and restricted access databases.
G E OR GE S. C O U M A N T A R O S

George S. Coumantaros and his son, John George Coumantaros, control Southern Star
Shipping Company, Inc., Flour Mills of Nigeria Plc and its subsidiaries.

As previously mentioned, George Coumantaros and his family are believed to be the
owners of Excelsior Shipping Company Limited, the controlling shareholder of Flour Mills
of Nigeria Plc. Excelsior is incorporated in Liberia and details of its corporate records are
held with the Greek branch of the registry, which is located in Piraeus. Since it is common
for Greek shipping companies to be registered in Liberia, a corporate registries office is
located there.

Verbal inquiries with the Liberian registry established that Excelsior is owned by Greek
interests. A 1964 case of U.S. litigation claim against a Liberian owned vessel names John
Coumantaros as Excelsior’s sole shareholder.

The Coumantaros family is a well-connected Greek-U.S. shipping family and has a
significant profile on the New York social scene, where it appears to be extremely well
connected.
Page 8 of 53
Final Report
Flour Mills of Nigeria Plc

Client Work Product
Confidential
Politically, the family also appears to have important ties. FTI noted several contributions
to the Republican Party, as well as an apparent family connection to John Negroponte, a
former senior U.S. diplomat under the George W. Bush and Ronald Reagan administrations
whose ambassadorial posts included Iraq in 2004 and 2005, following which he was the
Director of National Intelligence until 2007.

George Coumantaros holds a leadership position with the following corporations:

Southern Star Shipping Company, Inc. – Founder, CEO and CFO

Flour Mills of Nigeria Plc – CEO

Interstate Grain Corporation (U.S. entity) – Director

Athens College – U.S. Board of Trustees

The West of England Ship Owners Mutual Insurance Association – Former
Vice Chairman

FTI identified one federal civil litigation case naming George Coumantaros. The case was
filed against Southern Star Shipping Company for alleged job discrimination demanding
$250,000 in damages. The case was closed and apparently settled out of court in 1998.

Research in a nationwide index of federal courts maintained by the U.S. Department of
Justice did not identify any criminal, or bankruptcy proceedings involving George
Coumantaros as a plaintiff or defendant.

Research in statewide indices of criminal history and civil dockets did not identify any legal
proceedings involving George Coumantaros as a plaintiff or defendant.

Through researching address histories and registered assets, FTI established that George
Coumantaros has the profile of a very wealthy individual. He owns a property on Fifth
Avenue in New York appraised at US$15.4 million, a multi-million dollar sailing yacht, and
five properties in the Greenwich, Connecticut.
Page 9 of 53
Final Report
Flour Mills of Nigeria Plc

Client Work Product
Confidential
FTI did not identify any disparaging information on George Coumantaros in extensive and
detailed media searches. Most media articles were related to his hobby of long-distance
sailing races involving exclusive yacht clubs.

Discreet inquiries into George Coumantaros’ reputation provided no negative information
and depicted him in a positive manner. One Lagos-based corporate source stated that
George Coumantaros is widely viewed as the driving force behind Flour Mills of Nigeria
Plc and is responsible for its profitability. Another source also noted him to be well
regarded among Nigerian shipping and business circles.
J O HN G. C O U M A N T A R OS

John George Coumantaros was born on December 10, 1961, and resides in New York. He is
the son of George Coumantaros and information indicates that he is currently the ultimate
holder of the family’s stake in the family’s companies.

John Coumantaros holds a leadership position with the following corporations:
o
o

Nigerian Entities

Flour Mills of Nigeria Plc – Group Managing director

Nigerian Bag Manufacturing Company (Nigerian Entity) – Chairman

United Cement Company of Nigeria (Nigerian Entity) – Chairman
U.S. Entities

Kestral Navigation, LTD (owns the families two yachts) – President

Greenfield Summer, LLC – Manager

Concordia Investments, LLC – Manager

Oxbow Carbon & Minerals, LLC – Former Manager

Long Island Sound Realty Corp. – Former President
FTI identified one federal civil litigation case naming John Coumantaros. This is the same
case mentioned previously against Southern Star Shipping Company, Inc., and also naming
his father, which alleged job discrimination.
Page 10 of 53
Final Report
Flour Mills of Nigeria Plc

Client Work Product
Confidential
Research in a nationwide index of federal courts maintained by the U.S. Department of
Justice did not identify any criminal, or bankruptcy proceedings involving John
Coumantaros as a plaintiff or defendant.

Research in statewide indices of criminal history and civil dockets did not identify any legal
proceedings involving John Coumantaros as a plaintiff or defendant.

FTI did not identify any disparaging information on John Coumantaros in extensive and
detailed media searches. Most media articles related to his sailing pursuits.
F L O U R M I L L S OF N I G E R I A P L C

Flour Mills of Nigeria Plc (“FMN”) is Nigeria’s market leader in the production and
marketing of flour and flour products. It is the apex company of a diversified and vertically
integrated Nigerian holding company with subsidiaries in the cement, shipping and food
manufacturing industries.

FMN and its subsidiaries Nigerian Bag Manufacturing Company and Northern Nigerian
Flour Mills are listed on the Nigerian Stock Exchange. The group has a high profile as one
of Nigeria’s largest and most established business conglomerates.

An April 2010 report by analysts at HSBC’s Global Research team expected FMN’s main
rival Dangote Flour Mills to remain a “distant second” to FMN, which it predicted to retain
a 46% market share until 2013.

The company’s 2009 Annual Report named its shareholders as Excelsior Shipping
Company Limited (51.59%), West African Investments Company Ltd. (4%), with the
remaining shares being publicly traded.

Corporate filings in Nigeria list the company’s directors as:
Page 11 of 53
Final Report
Flour Mills of Nigeria Plc

Client Work Product
Confidential
George Stavros Coumantaros
Alhaji Ahmed Joda
Emmanuel Akwari Ukpabi
(Chairman)
(Vice Chairman)
(Managing Director)
Aris Plytas
Alhaji Ali Kotoko
Folarin Rotini Williams Junior
John N. Katsaounis
John George Coumantaros
Adebayo Alade-Loba
Rabiu Muhammad Gwarzo
Alhaji Abdullahi Ardos Abba
Thanasis Mazarakis
Atedo N. A. Peterside
Alhaji Yunis Olalekan A. Saliu
Eric David Rainton
FTI identified the following subsidiaries of FMN and FMN’s ownership interest in them:
Entity
Niger Mills Company Ltd.
Golden Pasta Company Ltd.
Golden Noodles Company
Golden Transport Company
Premier Feed Mills Ltd.
Golden Shipping Company Nigeria Ltd.
Apapa Bulk Terminal Ltd.
Southern Star Shipping Company (Nigeria) Ltd.
Golden Sugar Company
Nigerian Bag Manufacturing Company Ltd.
Northern Nigeria Flour Mills
Nigerian Eagle Flour Mills
United Cement Company of Nigeria Ltd.
Maiduguri Flour Mills Ltd.

Stake (%)
100.0
100.0
100.0
100.0
100.0
100.0 (-2 shares)
100.0 (-1 share)
100.0 (-1 share)
95.0
70.0
52.6
51.0
22.0
16.7
FMN does not appear to have a strong political alignment in Nigeria. It has benefitted from
government concessions through its cement manufacturing facility and in its securing of
the concession to operate two freight terminals at Lagos port. Sources believe FMN to be in
good standing with the current Nigerian leadership.

One Western journalistic source, who has written extensively on Nigeria, noted the extent
to which FMN took care to develop relations with the administration of Umaru Musa
Yar'Adua, the President of Nigeria between May 2007 and his death in May 2010. Yar'Adua
served as governor of Katsina State in northern Nigeria from May 29, 1999, to May 28, 2007
and was a member of the People's Democratic Party (PDP).

A source at the Nigerian Corporate Affairs Commission, which regulates the formation and
management of companies in Nigeria, noted that filings for FMN and its subsidiary firms
Page 12 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
had been moved to the Compliance Unit for an inspection. The source was unaware of the
reasons for the inspection, although he speculated that there may have been a disagreement
between shareholders over share allocation. As a result of the inspection, corporate filings
could not be obtained for Golden Pasta Company and United Cement Company.

Research in Nigeria identified no regulatory or reputational issues concerning FMN or its
subsidiaries.

FMN and its group companies all have conventional profiles as listed companies in
Nigeria. Media coverage of the Group is focused on their activities and capital raising. No
reputational issues were identified concerning FMN or any of its subsidiaries or principals.

In regard to political risk, one source noted that FMN’s level of foreign ownership could
potentially pose a risk in the future, but he added that its strong Nigerian political and
business connections would most likely afford it protection.

Research into possible regulatory issues relating to corruption revealed that the political
use of anti-corruption agencies to pursue opponents, a tactic favored by Oluṣẹgun Mathew
Okikiọla Arẹmu Ọbasanjọ, a former Nigerian Army general and President of Nigeria
between 1976 and 1979, and again from May 1999 to May 2007 has not been a feature of
the current government of President Goodluck Ebele Azikiwe Jonathan, former Governor of
Bayelsa State until 2007. One expert on anti-corruption issues in Nigeria thought it highly
unlikely that FMN would become the focus of any Nigerian Economic and Financial Crimes
Commission investigation for either political or legal reasons.
N I GE R I A N D I R E C T O R S OF F L O U R M I L L S OF N I GE R I A P L C

Alhaji Ahmed Joda, Vice Chairman of Flour Mills of Nigeria Plc, is a well-respected former
senior civil servant in Nigeria. Joda served as a “Super Permanent Secretary” during the
military rule of Olusegun Obasanjo and remains a part of Obasanjo’s circle. Sources spoke
highly of Joda’s connections and abilities.
Page 13 of 53
Final Report
Flour Mills of Nigeria Plc

Client Work Product
Confidential
Joda is not openly affiliated to any political parties, although a Nigerian journalistic source
speculated that his sympathies would lie with the incumbent President Goodluck Jonathan.

Research identified no criminal or civil records against Joda. Joda was not identified as
implicated in any fraud allegations.

Emmanuel Akwari Ukpabi, Managing Director of FMN, has served with FMN since the
1970s. He does not appear to enjoy any significant personal connections in Nigeria. Sources
consulted praised Ukpabi’s performance with FMN.

Ukpabi graduated from the University of Nigeria in Nsukka in 1971 with a BSc in
Chemistry. He has completed advanced management programs at Lagos Business School
and the University of Barcelona.

Research identified no criminal or civil records against Ukpabi and he was not identified as
being implicated in any fraud allegations.

Research identified no red flags or reputational issues concerning either executive.
Page 14 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
INVESTIGATIVE FINDINGS
The following sections summarize the main investigative findings regarding Southern Star
Shipping Co., Inc., George S. Coumantaros and John G. Coumantaros in the U.S. and Nigeria.
U NI T E D S T A T E S
Southern Star Shipping Co., Inc.
Southern Star Shipping Co., Inc., specializes in merchant shipping of bulk cargo. The Company
shares a name with a subsidiary of Flour Mill of Nigeria, Southern Star Shipping Company
(Nigeria) Limited.
Corporate Information
According to the Department of State, Division of Corporations of the State of New York, Southern
Star Shipping Co., Inc., was incorporated on July 15, 1947, and was issued the Employer
Identification Number (EIN) 13-5535116. The company is currently active and in good standing.
No registered agent was identified. The company is located at 712 Fifth Avenue, 33rd Floor, New
York, New York 10019-4102.
The company was incorporated in Louisiana but currently has inactive status in that state.
The company has reportedly issued 1,500 shares at no par value. It should be mentioned that the
Department of State, Division of Corporations of the State of New York, does not record
information regarding shareholders and only limited information on shares.
Public records reviewed established that the officers and directors of Southern Star Shipping Co.,
Inc., are George S. Coumantaros as Chief Executive Office and Chief Financial Officer, George D.
Kapetanakos as Finance and Executive Secretary and Martha Romo as Agent and Sales Executive.
Page 15 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
The New York entity is currently licensed to export grain from the U.S. The first reference to this
license was identified in 2002.
Litigation History
U.S. Federal: Criminal and Civil
The name of the company, Southern Star Shipping Company, Inc., was researched in an online
system operated by the Administrative Office of the U.S. Courts providing direct access to the
dockets of all federal district courthouses. The system covers all criminal and civil proceedings
filed in any U.S. District Courts (exceptions: District of New Mexico, Southern District of Indiana,
and District of the Virgin Islands).
The following federal civil cases were identified:

Case number 2:11-CV-31465, Craig v. A-C Product Liability Trust et al, filed on January 27,
2011, before the U.S. District Court Eastern District of Pennsylvania. This case included
multiple plaintiffs and defendants, including Southern Star Shipping Co, Inc., as defendant.
The case was filed as a “Jones Act” case, an act that regulates maritime commerce in U.S.
waters and between U.S. ports. Specifically, this was an asbestos products litigation. No
additional information was obtained and the case remains open.

Case number 2:10-CV-38365-ER, Hollander et al v. Foster Wheeler Company et al, filed on
June 11, 2010, before the U.S. District Court Eastern District of Pennsylvania. Southern Star
Shipping Co., Inc., was another defendant in this case, which was also filed as a “Jones Act”
case. On May 7, 2010, it was ordered by the court that all claims against all defendants to be
dismissed. It was settled and dismissed on July 12, 2010.

Case number 97-CV-06942, Constantine Touloumis v. Southern Star Shipping Company, et
al, filed on September 17, 1997, before the U.S. District Court Southern District of New
Page 16 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
York. The other defendants in the case were Atlantic Bulk Carriers Ltd, Westwind Africa
Ltd, George Coumantaros, John Coumantaros and Panos Zachariadis. Constantine
Touloumis filed this lawsuit claiming that his job was terminated due to job discrimination
and demanded US$250,000 in compensation. The case was dismissed and terminated on
September 23, 1998.

Case number 2:92-CV-00457-MLCF, Jackson et al v. Belsom et al, filed on February 6, 1992,
before the U.S. District Court Eastern District of Louisiana (New Orleans). Southern Star
Shipping Co., Inc., was a “third party defendant.” The cause of this lawsuit was “marine
personal injury” and it was settled and dismissed on January 7, 1993.

Case number 8:90-CV-00781-WJC, Gravely v. Southern Star Shipping et al, filed on June 21,
1990, before the U.S. District Court Middle District of Florida. It was filed as a personal
injury case. The lawsuit was settled and dismissed on November 30, 1991. Further details
can be obtained if specifically requested from the courts.

Case number 2:90-CV-04429-RFC, Feiteria Gavina et al v. Tansit Ent Ltd et al, filed on
November 6, 1990, before the U.S. District Court Eastern District of Louisiana (New
Orleans). Southern Star Shipping Co., Inc., was a defendant in this lawsuit involving
several plaintiffs and defendants. The cause of this lawsuit was “personal injury” and it
was settled and dismissed on December 10, 1990. Further details can be obtained if
specifically requested from the courts.
Further searches did not surface any federal criminal or other civil litigations, as well as no
bankruptcies naming Southern Star Shipping Co., Inc., as a defendant, plaintiff or debtor.
State: Criminal and Civil
Southern Star Shipping’s name was researched in a commercial database that aggregates court and
corrections records from U.S. states. Although the depth and breadth of coverage varies from state
to state, FTI has found this data source to be an effective means of identifying records of
Page 17 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
convictions that may have occurred outside the scope of the address history. This database
encompasses records from the U.S. District Courts, U.S. Supreme Court, and U.S. Court of
Appeals, federal and state civil and criminal litigations.
Additionally, a comprehensive search was conducted for all case records that may have been filed
before the New York State Unified Court System, which includes criminal and civil cases, as well
as cases filed before the Supreme Court of New York.
The following civil case was identified:

CV-008508-94/NY; Allstate Financial Corporation, AAO Ivory, Inc., DBA Mark Express v.
Southern Star Shipping Co, Inc.; filed on March 10, 1994, before the New York County Civil
Court. The case was disposed on June 7, 2008. Further details can be obtained if specifically
requested from the courts.
Miscellaneous Records Check
Uniformed Commercial Codes (UCCs)
The entity had one UCC filing in 1991 indicating a creditor registering a lien on collateral.
US Tax Court
The name of Southern Star Shipping Co., Inc., was researched in an online system operated by the
Administrative Office of the U.S. Courts providing direct access to the docket of United States Tax
Court. No results surfaced.
Real Estate Properties
Real estate property searches were conducted under the name of Southern Star Shipping Co., Inc.,
through a commercial database that aggregates files from various jurisdictions and government
Page 18 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
entities nationwide, but surfaced no properties owned by the company. Additional searches were
conducted through the New York City Finance Department, but surfaced no properties owned by
the company.
Media Review
Media searches were conducted through an online U.S. database that encompasses information
from more 28,000 sources from more than 157 countries in 23 languages, including nearly 600
continuously updated newswires, including the combination of Dow Jones, Reuters and The
Associated Press, The Wall Street Journal, The New York Times, Washington Post, the Times, and other
local newspapers from around the globe. This source also includes more than 900 wires, including
the Press Association, Asia Pulse, Agence France Presse, Agencia EFE, the Australian Associated Press,
ANSA, and other industry, press release and local newswires.
A court of appeals case filed in 1987 identified through media reviews named Southern Star
Shipping Company, Inc., and West Wind Africa Line, Ltd. as defendants. Southern Star was
dismissed from the original case prior to trial. Southern Star was the shipping agent of Westwind
Africa Line Ltd., a Liberian corporation which media reviews indicated may be related to George
Coumantaros.
No negative information surfaced during the media search of Southern Star Shipping Company,
Inc.
George S. Coumantaros
Background
George S. Coumantaros was born on July 23, 1922, in London, England. He was issued a social
security number in New York, U.S.A., between 1936 and 1951. Media searches identified that he
has been married for more than 52 years, has four children and 11 grandchildren.
Page 19 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
He is the patriarch of a well-connected Greek-US shipping family. The current ultimate holder of
the family’s stake in the family’s companies is his son, John George Coumantaros. The
Coumantaros family is noted to have a significant profile on the New York social scene, where
they appear to be extremely well connected.
The Coumantaros family is believed to be connected to U.S. former senior diplomat John
Negroponte through his mother, Catherine Coumantaros. Negroponte, whose father was a Greek
shipping magnate, served under the George W. Bush and Ronald Reagan administrations and his
ambassadorial posts included Iraq in 2004 and 2005, following which he was the Director of
National Intelligence until 2007. Negroponte’s mother has only a six-year age difference with
George Coumantaros, and may be either a sister or cousin.
In February 2011 George Coumantaros received a Lifetime Achievement Award from the Nigerian
This Day Group of Newspapers for his services to Nigerian corporate life.
Sources close to George Coumantaros describe him as loyal to those who have helped him. A
shipping executive consulted pointed out that when his good friend Folarin Rotini Abiola Williams
died, George Coumantaros replaced him on the FMN board by his son. The source noted that the
Williams’ chamber was one of Nigeria’s most prestigious law firms.
Abiola Williams Junior
currently serves on the board of FMN.
An address history for George Coumantaros was developed through a collection of public records
in order to locate the specific jurisdictions where he has resided; and, thus perform further public
records inquiries. Based on these searches, it was determined that George Coumantaros resides at
944 Fifth Ave, Number 12, New York, NY 10021.
According to his biography, published on the Athens College Board of Trustees, New York Office,
website1, George Coumantaros graduated from the Makris School in Athens, Greece.
1
http://www.athenscollege.org/html/coumantaros.html
Page 20 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Corporate and Professional Affiliations
George Coumantaros is the Chief Executive Officer (“CEO”) and Chief Financial Officer (“CFO”)
of Southern Star Shipping Co, Inc. Also, Media sources established that George Coumantaros was
its founder.
George Coumantaros is the CEO of Flour Mills of Nigeria Plc, established in 1962, the largest
single-site flour mill complex in the world, capable of milling 6,000 tons of wheat per day, in
addition to importing bulk cement, fertilizers and the manufacture of polypropylene bags.
A Lagos-based businessman stated that George Coumantaros is widely viewed as the driving force
behind FMN and is responsible for its profitability and success. A source also noted him to be well
regarded in the Nigerian shipping and business circles.
George Coumantaros is part of the U.S. Board of Trustees of Athens College, located in New York.
George Coumantaros retired last year as Vice Chairman of The West of England Ship Owners
Mutual Insurance Association. He has served on the Board of the American Bureau of Shipping
and on various banks and organizations along with many Hellenic shipping groups.
According to the U.S. Board of Trustees, George Coumantaros is a member of several yacht clubs
and many social organizations.
According to database and media searches, Mr. Coumantaros has also been associated with the
following U.S. entity:

Interstate Grain Corporation – George Coumantaros serves as a director. The company’s
Employer Identification Number (EIN) was identified as 74-1986508. This entity is a private
company categorized under Grain Elevators. Reportedly, it was established in 1978 and
incorporated in Texas. The company is associated with two Addresses: 5700 up
Page 21 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
River Rd, Corpus Christi TX 78407 and Po Box 9924, Corpus Christi TX 78469. As of 2010,
the company was in good standing.
Litigation History
U.S. Federal: Criminal and Civil
The name of George Coumantaros was researched in an online system operated by the
Administrative Office of the U.S. Courts providing direct access to the dockets of all federal district
courthouses. The system covers all criminal and civil proceedings filed in any U.S. District Courts
(exceptions: District of New Mexico, Southern District of Indiana, and District of the Virgin
Islands).
George Coumantaros was identified as a defendant in the same lawsuit identified above involving
Southern Start Shipping Co, Inc. This lawsuit was:

Case number 97-CV-06942, Constantine Touloumis v. Southern Star Shipping Company, et
al, filed on September 17, 1997, before the U.S. District Court Southern District of New
York. The lawsuit was filed claiming job discrimination and the plaintiff demanded
US$250,000 in compensation. The case was dismissed and terminated on September 23,
1998.
Further searches did not surface any federal criminal or any other federal civil litigations, as well
as no bankruptcies naming George Coumantaros as a defendant, plaintiff or debtor.
State: Criminal and Civil
George Coumantaros’ name was researched in a commercial database that aggregates court and
corrections records from U.S. states. Although the depth and breadth of coverage varies from state
to state, FTI has found this data source to be an effective means of identifying records of
convictions that may have occurred outside the scope of the address history. This database
Page 22 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
encompasses records from the U.S. District Courts, U.S. Supreme Court, and U.S. Court of
Appeals, federal and state civil and criminal litigations.
Additionally, a comprehensive search was conducted for all case records that may have been filed
before the New York State Unified Court System, which includes criminal and civil cases, as well
as cases filed before the Supreme Court of New York.
No civil, criminal or family cases were identified naming George Coumantaros as either defendant
or plaintiff.
Miscellaneous Records Check
Uniformed Commercial Codes (UCCs)
FTI identified 12 UCC “fixture filings” under George Coumantaros’s name in New York. Fixture
filings are security interests filed against permanent property to insure the ability to collect
collateral on a loan. The filings were made between 1987 and 1990. One additional filing was
identified in Connecticut.
US Tax Court
George Coumantaros’ name was researched in an online system operated by the Administrative
Office of the U.S. Courts providing direct access to the docket of United States Tax Court, which
surfaced no results.
Properties
Real estate property searches were conducted under the name of George Coumantaros through a
commercial database that aggregates files from various jurisdictions and government entities
nationwide, but surfaced no properties owned by the company. Additional searches were
conducted through the Finance Department of New York State.
Page 23 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
The following properties were identified owned by George Coumantaros:

944 Fifth Ave, number 12, New York, NY 10021. This residence has an appraised value of
$15.4 million.

0 Broad Raod, Greenwich, CT. This lot has an appraised value of $1.9 million.

511 Field Point Road, Greenwich, CT. It has an appraised value of $5.6 million.

501 Field Point Road, Greenwich, CT. It has an appraised value of $2.3 million.

0 Shore Road, Greenwich, CT (parcel number 02-1302/S). It has an appraised value of $1.97
million.

0 Shore, Road, Greenwich, CT (parcel number 02-1303/S). It has an appraised value of $2
million.
Also, public records searched identified that George Coumantaros is the owner of a 72.83
ft boat named “Baccara”. Its registration number 105470 is current valid.
Media Review
Media searches were conducted through an online U.S. database that encompasses information
from more 28,000 sources from more than 157 countries in 23 languages, including nearly 600
continuously updated newswires, including the combination of Dow Jones, Reuters and The
Associated Press, The Wall Street Journal, The New York Times, Washington Post, the Times, and other
local newspapers from around the globe. This source also includes more than 900 wires, including
the Press Association, Asia Pulse, Agence France Presse, Agencia EFE, the Australian Associated Press,
ANSA, and other industry, press release and local newswires.
These searches identified that George Coumantaros yearly donates to the Republican Party and its
members.
According to the Newport Bermuda Race, George Coumantaros is a veteran sailor who has
participated in 26 races since 1952. He has set the record for the most elapsed-time victories. This
Page 24 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
same source indicated that in 1996 George Coumantaros set a new speed record of 57 hours, 31
minutes (an average speed of 11 knots) and accomplished a rare double victory by also winning
that race on handicap.
No negative or additional information surfaced during the media search of George Coumantaros.
John G. Coumantaros
Background
John G. Coumantaros was born on December 10, 1961. He was issued a social security number in
New York between 1974 and 1975.
An address history for John Coumantaros was developed through a collection of public records in
order to locate the specific jurisdictions where he has resided; and, thus perform further public
records inquiries. Based on these searches, it was determined that John Coumantaros resides at 535
Park Ave, Apt. 2A, New York NY 10065.
His voter’s registration is currently active, registered with the Republican Party. He last voted in
November 2006.
Corporate and Professional Affiliations
John G. Coumantaros serves as the Group Managing Director of Flour Mills of Nigeria and the
Chairman of Nigerian Bag Manufacturing Company. Mr. Coumantaros is also the Chairman of
United Cement Company of Nigeria (UNICEM).
According to database and media searches, Mr. Coumantaros’s other past and present affiliations
include:
Page 25 of 53
Final Report
Flour Mills of Nigeria Plc

Client Work Product
Confidential
Kestral Navigation, Ltd – John G. Coumantaros serves as the president. The company
possesses two vessels named “Bambakou” and “Bambakou 52.” This entity is associated
with following address: 11 Memorial Blvd, Newport RI 02840-3596.

Greenfield Summer, LLC – John G. Coumantaros serves as the manager. The company is
currently active and it is associated with the following address: 101 Federal St, Boston MA
02110-1817.

Concordia Investments, LLC – John G. Coumantaros serves as the manager. The company’s
Employer Identification Number (EIN) was identified as 64-0953281. The entity’s current
status is “inactive – consolidated” and is associated with the following address: 101 Federal
St, Boston MA 02110-1817.

Oxbow Carbon & Minerals, LLC – John G. Coumantaros served as the manager as of July of
2007. The company’s Employer Identification Number (EIN) was identified as 23-2432218.
The entity’s current status is active and is located at 1601 Forum PL #P-2, West Palm Beach
Fl 33401-8101. According to the company’s website, Oxbow Carbon and its two affiliated
companies – Gunnison Energy and Oxbow Steel International – have yearly sales in excess
of $4 billion, combined assets of nearly $2 billion and over 1100 employees worldwide.
Oxbow’s primary businesses are the mining and marketing of energy and commodities
such as coal, natural gas, petroleum, metallurgical and calcined coke.

Long Island Sound Realty Corp. - John G. Coumantaros served as the president as of
November of 2007. This entity is associated with following address: 11 Memorial Blvd,
Newport RI 02840-3596 and with the phone number 401-849-1510.
Litigation History
U.S. Federal: Criminal and Civil
The name of John Coumantaros was researched in an online system operated by the
Administrative Office of the U.S. Courts providing direct access to the dockets of all federal district
courthouses. The system covers all criminal and civil proceedings filed in any U.S. District Courts
(exceptions: District of New Mexico, Southern District of Indiana, and District of the Virgin
Islands).
Page 26 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
John Coumantaros was identified as a defendant in the same lawsuit identified above involving
Southern Start Shipping Co, Inc., and George Coumantaros. This lawsuit was:

Case number 97-CV-06942, Constantine Touloumis v. Southern Star Shipping Company, et
al, filed on September 17, 1997, before the U.S. District Court Southern District of New
York. The lawsuit was filed claiming job discrimination and the plaintiff demanded
US$250,000 in compensation. The case was dismissed and terminated on September 23,
1998.
Further searches did not surface any federal criminal or any other federal civil litigations, and no
bankruptcies naming John Coumantaros as a defendant, plaintiff or debtor.
State: Criminal and Civil
John Coumantaros’s name was researched in a commercial database that aggregates court and
corrections records from U.S. states. Although the depth and breadth of coverage varies from state
to state, FTI has found this data source to be an effective means of identifying records of
convictions that may have occurred outside the scope of the address history. This database
encompasses records from the U.S. District Courts, U.S. Supreme Court, and U.S. Court of
Appeals, federal and state civil and criminal litigations.
Additionally, a comprehensive search was conducted for all case records that may have been filed
before the New York State Unified Court System, which includes criminal and civil cases, as well
as cases filed before the Supreme Court of New York.
No civil, criminal or family cases were identified naming John Coumantaros as either defendant or
plaintiff.
Page 27 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Miscellaneous Records Check
Uniformed Commercial Codes (UCCs)
FTI identified two “Cooperative” UCC filings under John Coumantaros’ name in New York. UCC
filings are made to ensure a creditor’s ability to collect on the collateral. The filings were in 2001
and 2004.
US Tax Court
John Coumantaros’s name was researched in an online system operated by the Administrative
Office of the U.S. Courts providing direct access to the docket of United States Tax Court, which
surfaced no results.
Real Estate Properties
Real estate property searches were conducted under the name of John Coumantaros through a
commercial database that aggregates files from various jurisdictions and government entities
nationwide, but surfaced no properties owned by the company. Additional searches were
conducted through the Finance Department of New York City.
No real estate properties surfaced under the name of John Coumantaros.
However, John Coumantaros’ current address listed below is currently owned by his wife Elena
Coumantaros:

535 Park Ave Apt 2A, New York, NY 10065-8167. This residence was appraised at US$12.4
million.
Page 28 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Public record searches identified that John Coumantaros owns a 2006 52 ft vessel named
“Bambakou.” Its registration appears under the name of Kestral Navigation Ltd and it is currently
valid. The vessel number is 812328.
Media Review
Media searches were conducted through an online U.S. database that encompasses information
from more 28,000 sources from more than 157 countries in 23 languages, including nearly 600
continuously updated newswires, including the combination of Dow Jones, Reuters and The
Associated Press, The Wall Street Journal, The New York Times, Washington Post, the Times, and other
local newspapers from around the globe. This source also includes more than 900 wires, including
the Press Association, Asia Pulse, Agence France Presse, Agencia EFE, the Australian Associated Press,
ANSA, and other industry, press release and local newswires.
Media searches identified that John Coumantaros yearly donates to the Republican Party and its
members.
According to The Daily Sail, John Coumantaros is a veteran sailor who has participated in many
races, including in the Mediterranean.
N I GE R I A
Flour Mills of Nigeria Plc
Overview
Flour Mills Nigeria Plc (“FMN”) is the apex company of a diversified Nigerian industrial group
with operations in food production and marketing, shipping and cement. FMN was established on
29th September 1960 under registration number 2343. FMN was previously called Golden Penny
Flour Mills. It markets its flour products in Nigeria under the Golden Penny brand. It listed on the
Page 29 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Nigerian Stock Exchange on 14th August 1979. FMN lists a registered office address at Apapa Mills,
2 Old Dock Road, Apapa, Lagos.
FMN is one of Nigeria’s largest and most established industrial groups, operating both directly
and through a number of subsidiaries incorporated in the country. FMN’s immediate activity is the
milling and distribution of flour and flour products. Its wheat milling complex at Apapa, reputed
to be the world’s largest, was thought by a journalist source to be its central asset. The complex has
a daily milling capacity of 6,200 metric tons.
Through its subsidiaries, FMN is active in other food production, bag production, shipping and
cement and has recently announced plans to diversify into sugar production. The activities of FMN
group subsidiaries are closely integrated. In August 2009 media reports noted that FMN was
collaborating with the management of the Nigerian Railway Corporation to procure five new
locomotives to improve rail freight capacity between Kano, Maiduguri and Lagos.
An April 2010 report by analysts at HSBC’s Global Research team expected FMN’s main rival
Dangote Flour Mills to remain a “distant second” to FMN, which it predicted to retain a 46%
market share until 2013.
In its annual report for the year ended 31st March 2009 FMN reported a turnover of NGN 180.07
(US$1=NGN146 as of 3/31/2009) billion and a profit before tax of NGN 11.92 billion. This was
revised to NGN 5.47 billion after “exceptional item” tax and NGN 3.89 billion after tax. FMN paid
a dividend of 50 kobo per share, amounting to NGN 854.19 million.
In February 2011 FMN announced pre-tax profits for the first nine months of its financial year
ending 31st March 2011 of NGN 12.5 billion. Turnover rose over the period to NGN 117.5 billion as
compared to NGN 112.2 billion the previous year. It expected profits for the year to reach NGN
16.5 billion.
FMN is audited by Akintola Williams Deloitte.
Page 30 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Capital Raising & Expansion
FMN raised NGN 37.5 billion through a December 2010 corporate bond issue, the first in Nigeria
outside the banking sector for a number of years. The issue was oversubscribed with the Group
claiming to have received NGN 49.8 billion in bids from banks and a variety of other institutional
investors.
The issue was the first of a planned NGN 70 billion debt programme.
Following the issue, Treasury Director Vlassis Liakouris (“Liakouris”) was quoted in the media
stating that FMN was aiming to invest at least NGN 20 billion per year in expansion and
acquisitions before 2014. The plans included adding four to six new mills to increase daily
production capacity at its Apapa facility to over 8,000 tons.
On 28th January 2011 FMN concluded a US$143.3 million, five-year loan with a group of Nigerian
banks to finance the construction of a sugar refinery complex in Lagos. The refinery was expected
to include a 65,000 ton capacity storage facility and a 12 MW gas fuelled power plant.
The loan also included a US$13.3 million credit facility to partly finance the development of a
sugar farm. Media reports have estimated FMN’s total investment in the project at $200 million.
The facility is expected to be completed by 2012.
FMN’s sugar investment supports the government’s target of achieving 70% raw sugar selfsufficiency.
Directors
Corporate filings in Nigeria list the following directors for FMN:

George Stavros Coumantaros (Chairman)

Alhaji Ahmed Joda (Vice Chairman)
Page 31 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential

Emmanuel Akwari Ukpabi (Managing Director)

Aris Plytas

John N. Katsaounis

Rabiu Muhammad Gwarzo

Atedo N. A. Peterside

Alhaji Ali Kotoko

John George Coumantaros

Alhaji Abdullahi Ardos Abba

Alhaji Yunis Olalekan A. Saliu

Folarin Rotini Abiola Williams (Junior)

Adebayo Alade-Loba

Thanasis Mazarakis

Eric David Rainton

James Oladipo Fagbemi
Shareholders
FMN has NGN 854,186,000 of paid-in capital, distributed between over 60,000 registered FMN
private and public shareholders. According to its annual report for 2009, FMN’s largest
shareholders are:
Entity
Stake (%)
Excelsior Shipping Company Limited
51.59
Public
44.41
Excelsior Shipping Company Limited (“Excelsior”) is incorporated in Liberia. Inquiries with the
Liberian registry established that Excelsior’s details are held with Nigerian registry branch located
in Piraeus and that the company is owned by Greek interests.
Excelsior’s ultimate beneficial owners are believed to be New York-based shipping magnate
George Stavros Coumantaros and his family. Media reports describe George Coumantaros as
Page 32 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
FMN’s founder. One 1964 case of US litigation named John George Coumantaros as Excelsior’s
sole shareholder.
Subsidiaries
Research suggests that FMN holds stock in the following companies:
Entity
Stake (%)
Niger Mills Company Limited
100.0
Golden Pasta Company Limited
100.0
Golden Noodles Company
100.0
Golden Transport Company
100.0
Premier Feed Mills Limited
100.0
Golden Shipping Company Nigeria Limited
100.0 (-2 shares)
Apapa Bulk Terminal Limited
100.0 (-1 share)
Southern Star Shipping Company (Nigeria) Limited
100.0 (-1 share)
Golden Sugar Company
95.0
Nigerian Bag Manufacturing Company Limited
70.0
Northern Nigeria Flour Mills
52.6
Nigerian Eagle Flour Mills
51.0
United Cement Company of Nigeria Limited
22.0
Maiduguri Flour Mills Limited
16.7
FMN’s activities are centred on the southern Nigerian cities of Lagos and Calabar. Northern Bag
Manufacturing Company, Northern Nigerian Flour Mills and Kaboji Farms operate in the northern
city of Kano. Maiduguri Flour Mills is also located in the north of Nigeria.
A source at the Nigerian Corporate Affairs Commission, which regulates the formation and
management of companies in Nigeria, noted that filings for FMN and its subsidiary firms had been
moved to the Compliance Unit for use in an investigation. Access to the documents is only
Page 33 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
available following a formal written application and files cannot be removed from the unit in order
to prevent tampering.
The source was unaware of the reasons for the investigation, although he speculated that there
may have been a disagreement between shareholders over share allocation. He did not believe the
investigation would have a negative impact on the firm. He stated:
''I will not attribute much to this investigation. I think it is basically routine, and aimed at
resolving disagreements.''
Inquiries with sources close to FMN identified no further information concerning the investigation.
Due to the investigation, filings for Golden Pasta Company and United Cement Company were
also unavailable.
Apapa Bulk Terminal Limited
Apapa Bulk Terminal Limited (“ABT”) is a wholly-owned subsidiary of FMN. It was incorporated
in 2005 with registration number 632098. ABT holds the concession for the operation of terminals
A and B at the Apapa Port Complex. Under the terms of the concession, FMN will undertake a
US$14 million redevelopment of the quay at terminal A. ABT’s registered address is:
2 Old Dock Road
Apapa
Lagos
PO Box 341
ABT was awarded the concession to operate terminals at Apapa port by Nigeria’s Bureau of Public
Enterprises (“BPE”) in April 2006.
Page 34 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
ABT has 20 million issued shares. A single share is held by FMN director Aris Plytas, with the
remainder owned by FMN.
According to Nigerian Corporate Filings, ABT’s directors are:

Emmanuel Akwari Ukpabi

Eric David Rainton

Aris Plytas

Anthony Osahon Ogbebor

Yunus Olalekan Saliu

Emmanuel Sunmola Omotayo

Athanasios Mitrofanis

Murray MacMillan
Media reports name Emmanuel Sunmola Omotayo as ABT’s Managing Director.
Research has identified no legal or regulatory issues concerning ABT. ABT has a low media profile.
No reputational issues were identified concerning ABT.
Privatization
The privatization of Nigeria’s ports has been the subject of strong opposition from the country's
trade union movement. BPE’s Director General, Irene Chigbue, has claimed that the program will
earn Nigeria US$2.5 billion from port concessions over 10 years.
One former Nigeria correspondent for a Western international business paper noted the allocation
of terminal operating concessions to be a tool of political patronage in Nigeria. He pointed out that
the privatisation of Nigeria’s port operations had come at a time when then President Olusegun
Obasanjo was seeking to build a constituency in the business and political elite to support his bid
to change the constitution to allow him to stay on in power for a third four-year term. He
continued:
Page 35 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
“The Apapa Shipping Terminal concession is hugely strategic and potentially highly
lucrative. It is therefore inconceivable that the award might have been based on technical
expertise or financial capacity alone. While it may indeed prove the case that a process of
tendering was completed, there can be no doubt that 'political factors' would have played a
significant role in the award of the concession. This, however, would be consistent with
most government contract awards in Nigeria and may not necessarily indicate clear proof
of any wrong doing.”
Research has not identified any allegation that any of Nigeria’s port concessions have been
awarded improperly.
Golden Pasta Company Limited
Golden Pasta Company Limited (“GPCL”) is a wholly-owned subsidiary of FMN. It began
operations in 1972. GPCL produces pasta products for FMN and is considered to be one of its key
areas of growth. Speaking in December 2010, FMN’s Vlassis iakouris was quoted as stating that
FMN enjoyed a 50% share of pasta sales in Nigeria and expected to double its business within four
years.
In the year ending 31st March 2009 GPCL had a turnover of NGN 14.5 billion and a profit
before tax of NGN 870 million.
Media reports name the following GPCL executives:

Yannis Katsichtis (General Manager)

Paul Gbededo
Research has identified no legal or regulatory issues concerning GPC. GPC has a low media
profile. No reputational issues were identified concerning GPC.
Page 36 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Golden Shipping Company Nigeria Limited
Golden Shipping Company Nigeria Limited (“GSC”) was incorporated on 21st September 1992
with registration number 205362. It began operations on 1st April 1995. GSC’s official address is:
Flour Mills Building
2 Old Dock Road
Apapa
Lagos
PO Box 428
GSC is a shipping agent engaged in clearing and forwarding activities at the Apapa docks. Its
clients include FMN and its subsidiaries.
GSC has 10 million issued shares. FMN Managing Director Emmanuel Ukpabi (“Ukpabi”) and
GSC director Dennis Muakpo Osah each hold a single share, with the remainder held by FMN.
Filings with the Nigerian corporate registry name the following GSC directors:

Emmanuel Ukpabi

Eric David Rainton

Aris Plytas

Yunus Olalekan Saliu

Dennis Muakpo Osah

Emmanuel Sunmola Omotayo
Research has identified no legal or regulatory issues concerning GSC. GSC has a low media profile.
No reputational issues were identified concerning GSC.
Page 37 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Niger Mills Company Limited
Niger Mills Company (“NMC”) was incorporated in 1967 with registration number 5480. It
produces wheat flour and other flour products for FMN. NMC’s registered address is:
79 Murtala Mohammed Highway
Calabar
PO Box 339
NMC was jointly owned by the government of Cross River State until it was bought out by FMN
in March 2002.
In 2009 NMC had a turnover of NGN 6.3 billion, making a loss after tax of NGN 107 million.
NMC has 33,860,500 issued shares, all held by FMN. NMC’s directors are:

Olabode Debayo-Doherty

Emmanuel Akwari Ukpabi

Yunus Olalekan Saliu

Solomon Ubaka Ubichukwu

Nnamdi Okudo

Ogban Ekpei Ogban
Research has identified no legal or regulatory issues concerning NMC. NMC has a low media
profile. No reputational issues were identified concerning NMC.
Nigerian Bag Manufacturing Company Limited
Nigerian Bag Manufacturing Company Limited (“BagCo”) was established in 1972 with
registration number 3584. It listed on the Nigerian Stock Exchange in 2007. In its annual report for
the year ending 31st March 2009 FMN stated it held a 70% shareholding in BagCo. The remainder is
publicly traded. BagCo’s registered address is:
Page 38 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Plot 45
Eric Moore Road
Iganmu Industrial Layout
Surulere
Lagos
PO Box 589
BagCo manufactures a variety of types of bag for industrial concerns. According to information
published by the company, BagCo has a production capacity of 30 million sacks per month.
According to FMN’s annual report for 2009, BagCo controls two subsidiaries: Northern Bag
Manufacturing Company (“NBMC”), established in 1990, and BagCo Morpack (“Morpack”),
established in 2007. Morpack produces high quality plastic film packaging for the consumer
products industry.
In the year ending 31st March 2009 BagCo made a loss after tax of NGN 310.8 million on a turnover
of NGN 10.3 billion. Much of this was attributable to losses associated with the establishment of
Morpack, which generated a loss of NGN 246.2 million.
BagCo is audited by Akintola Williams Deloitte.
BagCo’s directors are:

John George Coumantaros (Chairman)

Emmanuel Akwari Ukpabi

Peter Soutar Low

Abiodun Sunday Ogunkoya

Peter Barraclough

Paul Murphy

Rabiu Muhammad Gwarzo

John Katasaounis
Page 39 of 53
Final Report
Flour Mills of Nigeria Plc

Thanakis Mazarakis

Eric David Rainton

Alhaji Yunus Olalekan A. Saliu

Muhammad M. Daggash

Jerry Gan
Client Work Product
Confidential
In the notes to its 2007 prospectus BagCo noted long-term contracts with Nigerian cement
companies including FMN subsidiary United Cement Company of Nigeria Limited (“UNICEM”).
It stated its expectation that it would profit from the government-backed growth of the Nigerian
cement industry. Media reports in Nigeria have noted BagCo to be supplier of first choice to
UNICEM, a factor in its dominance of services to the Nigerian cement industry.
Research has identified no legal or regulatory issues concerning BagCo. No reputational issues
were identified concerning BagCo.
Northern Bag Manufacturing Company
NBMC was incorporated in 1990 with registration number 157093. NBMC is a subsidiary of BagCo
which produces bags for industrial and commercial use at a factory in Kano. NBMC’s registered
address is:
47/48 Sharada Industrial Estate
Phase 111
Kano
PO Box 10602
According to filings with the Nigerian corporate registry, NBMC has 20 million issued shares.
Ukpabi holds a single share with the remainder retained by BagCo. NBMC has the following
directors:

John George Coumantaros
Page 40 of 53
Final Report
Flour Mills of Nigeria Plc

Peter Soutar Low

Peter Barraclough

Alhaji Hamisu Dankaka

Emmanuel Akwari Ukpabi

Eric David Rainton

Alhaji Yunus Olalekan .A. Saliu

Abiodun Sunday Ogunkoya

Rabiu Muhammad Gwarzo

John Katasaounis

Declan Joseph Griffin
Client Work Product
Confidential
Research has identified no legal or regulatory issues concerning NBMC. No reputational issues
were identified concerning NBMC.
Northern Nigeria Flour Mills
Northern Nigeria Flour Mills (“NFMN”) was incorporated on 29th October 1971 with registration
number 9409. It listed on the Nigerian Stock Exchange in 1978. NFMN is one of Nigeria’s largest
flour milling concerns.
Its official address is:
15 Mal Malari Road
Bompal Industrial Estate
Kano
PO Box 6640
NFMN produces Golden Penny branded flour and semovita. It has a milling capacity of 1,750 tons
per day. According to an analyst’s report published by FSDH Securities Limited in December 2009,
NFMN controls a market share of around 60% of the flour milling market in Northern Nigeria. At
its stock price on 3rd March 2011 NFMN had a market capitalisation of US$38.3 million.
Page 41 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
In the year ending 31st March 2009 NFMN had a turnover of NGN 8.5 billion and a profit before
tax of NGN 236.3 million.
As at 31st March 2009 NFMN had the following shareholders:
Entity
Stake (%)
Flour Mills of Nigeria
52.61
Northern Nigeria Investment Ltd
8.01
Dantata Investment and Securities Ltd
6.45
Kano State Investment and Securities Ltd
5.10
Public
27.83
NFMN’s directors are:

Aminu Dantata (Chairman)

George Stavros Coumantaros (Vice Chairman)

Rabiu Gwarzo (Managing Director)

Trevor Augustine

Emmanuel Ukpabi

C. Theodorakopoulos

Alhaji Yunus Olalekan .A. Saliu

John Coumantaros

Abbas Gashash

Alhaji Mahmoud Isa Dutse

Muhammad Gwarzo

Alhaji Abbas Aliyu Waziri
Research has identified no legal or regulatory issues concerning NNFM. No reputational issues
were identified concerning NNFM.
Page 42 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Southern Star Shipping Company (Nigeria) Limited
Southern Star Shipping Company (Nigeria) Limited (“SSS”) was incorporated on 22nd December
1961 with registration number 6726. SSS’s official address is:
Flour Mills Building
2 Old Dock Road
Apapa
Lagos
PO Box 318
SSS provides forwarding and clearing services at the Apapa docks.
SSS has 3,999,998 issued shares. They are wholly owned by FMN with the exception of a single
share which is held by Ukpabi.
Filings with the Nigerian corporate registry list the following directors for SSS:

Emmanuel Akwari Ukpabi

Eric David Rainton

Alhaji Yunus Olalekan .A. Saliu

Aris Plytas

Emmanuel Sunmola Omotayo
A Swiss entity called Southern Star Shipping was identified in US media reports in August 2002 as
a vehicle for illicit payments made by a group of Miami investors. Research suggests that it does
not relate to the Subject.
Research has identified no legal or regulatory issues concerning SSS. SSS has a low media profile.
No reputational issues were identified concerning SSS.
Page 43 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
United Cement Company of Nigeria Limited
UNICEM was established in 2002 as a joint-venture between FMN and Egyptian Cement
Company, a partnership between Switzerland’s Holcim Group and Egyptian construction firm
Orascom. It acquired the assets of the state-owned Calabar Cement Company, which was at the
time in liquidation, following two payments to the Cross River State government totalling NGN
1.04 billion. UNICEM’s address is:
Spring Road
DiamondHill
PMB 1017
Calabar
UNICEM secured investment from Aliko Dangote’s Dangote group in 2004, and from international
cement firm Lafarge SA in December 2007.
UNICEM operated the original factory after some outlay in improving its facilities. In March 2007
UNICEM received a $205 million syndicated loan from a group of Nigerian banks in order to help
in the funding of a new facility on the site. In May 2009 UNICEM inaugurated a new cement
factory in the town of Mfamosing. The factory has a capacity of 2.5 metric tonnes per annum. The
estimated cost of the plant’s construction was $428 million. Shortly following the plant’s
inauguration, UNICEM mothballed the site’s original facility.
At the plant’s inauguration in May 2009 UNICEM was praised by then-President Ummaru
Yar'Adua for its contribution to the government’s efforts to increase cement production in the
country. Yar’Adua noted the “landmark achievement” by UNICEM to have demonstrated the
success of the Federal Government's policy on cement production in the country.
UNICEM is one of Nigeria’s largest cement companies and has been at the centre of developments
in the country’s national cement policy. Cement production has been an issue for the Nigerian
Page 44 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
government since 2001 when President Olusegun Obasanjo banned imports of bagged cement and
ordered that imported cement be bagged locally in order to stimulate domestic industry.
UNICEM is one of a small number of Nigerian cement producers with its own bag production
facilities. It has historically been able to secure substantial import licenses for non-bagged cement.
In August 2008 UNICEM was one of 13 local manufacturers licensed to import bagged cement to
ease cement supply issues to Nigeria.
In July 2010 President Goodluck Jonathan approved the import of 2.5 million metric tonnes of bulk
cement by local manufacturers. UNICEM received a license for 600,000 tons – the second largest
after Dangote Cement, which was allocated 895,000 tons.
Achike Udenwa, Nigeria’s former Minister of Commerce and Industry has forecast that the
country will become self-sufficient in cement production by the year 2013.
In September 2010 current Minister of Commerce and Industry Senator Jubril Martins Kuye was
quoted at the opening of an international cement conference in Lagos stating that the government
would seek to regulate cement imports more closely. Kuye also praised the new UNICEM facility
as an example of investment in indigenous production.
UNICEM has the following shareholders:
Entity
Stake (%)
Lafarge SA
28
Holcim Trading SA
28
Dangote Cement Company
22
Flour Mills
22
In an earnings call for the second quarter of 2010 Holcim Trading SA stated its share of losses for
the year from UNICEM was CHF 44 million.
Page 45 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
In November 2008 Nigerian newspaper Vanguard reported that UNICEM was collaborating with
Nigeria’s Federal Road Safety Commission to promote safety measures along major roads between
Mfamosing and Calabar, including the provision of infrastructural support to FRSC.
Research has identified no legal or regulatory issues concerning UNICEM. No reputational issues
were identified concerning UNICEM.
Kaboji Farms Limited
Kaboji Farms Limited (“KFL”) is not a direct subsidiary of FMN, although it is identified in media
reports and corporate profiles as a related concern. KFL is a farming concern which grows maize,
soya beans and rice. It owns 10,000 hectares of land in Niger State, 3,000 hectares of which are
under cultivation.
KFL sells produce to FMN and its subsidiaries and has been described in the media as an example
of FMN’s “backward integration” policy.
KFL has 30 million issued shares split equally between its two directors, both executives with
FMN:

Rabiu Muhammad Gwarzo

Emmanuel Akwari Ukpabi
Research has identified no legal or regulatory issues concerning KFL. No reputational issues were
identified concerning KFL.
Reputation
FMN and its group companies all have reasonable profiles as listed companies in Nigeria. Media
coverage of the Group is focused on their activities and capital raising. No reputational issues were
identified concerning FMN or any of its subsidiaries or principals.
Page 46 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Corporate and journalistic sources consulted all commented on FMN’s profile and reputation as
one of the country’s most respected and durable companies. One source described FMN as “a rare
example of a Nigerian business success story.”
One corporate source noted:
“FMN is highly regarded in the West African region and is noted for its quality products
and reputable brand name.”
He continued:
“FMN is considered to have one of the best dividend policies as a quoted company in the
Nigerian economy. The company has recovered fully from the capital market crisis, its
share price has been on the upward swing and it is considered one of the most stable stocks
on the country’s capital market.”
FMN’s directors and senior managers were also generally noted by sources to be well-regarded in
the Nigerian corporate world and considered to be professional and capable.
A senior analyst in a Lagos-based investment advisory noted:
“FMN is a good, safe investment because they have survived the vagaries and unfriendly
environment of doing business in Nigeria for over half a century. They must know
something. Very few start ups survive in Nigeria after five years. FMN has beaten the
odds.”
This view was echoed by an investment banker, who described the company as one of Nigeria’s
“soundest” businesses, continuing:
Page 47 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
“You have to credit their efficiency. For example, they are in a business where 40% of
overheads goes into generating private power supply – by Nigerian standards, that puts
FMN definitely ahead of the herd.”
One owner of a finance and investment company explained that while FMN was a solid company,
it was unlikely to prove a star performer compared with other investment opportunities for
speculative shareholders. He stated:
“I will always advise clients not to look at fundamentals alone without the background
story. FMN is great but I think Nigerian banks are a better buy. FMN is a sound institution
by Nigerian standards and certainly stands miles ahead of its peers as a business, but as an
investment it’s not going to set the world alight.”
A commodities trader noted:
“The company is still a desirable destination among top graduates who are entering the
industry.”
He continued:
“Their greatest competitor is Dangote Flour Mill, but FMN is a more established company
with a corporate structure not built around an individual. In that sense, I think in another
50 years the company will still be standing but I may not say that about Dangote, which is
built around an individual and sometimes on the vagaries of Nigerian politics.”
Another trader noted:
“I have dealt with the company many times over supplying refined products, their margin
is cut throat but they pay and from a Nigerian point of view, you can get funds to activate
an LPO (Local Purchase Order) if it’s from FMN. For me that is the true test of their
credibility from a Nigerian economic point of view.”
Page 48 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
A Nigerian journalist who has covered the Nigerian Stock Exchange for a number of years stated:
''To the best of my knowledge, Flour Mills is one of the most stable and reliable firms in the
NSE. It is a toast of investors, and that explains why it is highly capitalized. In my daily
interaction with brokers and shareholders here, they have continued to hold the company
up as an epitome of good management, and its Managing Director, Mr. Emmanual Ukpabi,
has always been singled out as the main driver of the company's phenomenal growth. But I
also know that the political connection of the company's Vice Chairman, Ahmed Joda, has
been a great asset to the company. As you know, in this country, you are as good as your
connections. Having served creditably and reached the highest echelon of the public
service, it is little wonder that Joda can penetrate any layer of government bureaucracy to
the benefit of this company.''
One Western journalistic source, who has written extensively on Nigeria, noted the extent to which
FMN took care to develop relations with the Yar'Adua administration after the change in
government in 2007.
Change of Political Climate and FMN
The source noted the Nigerian cement industry to be “hugely lucrative and highly politicized”,
speculating that FMN had enjoyed some support during the rule of President Yar'Adua as part of a
general strategy to cultivate a rival business constituency to that favored by Former President
Obasanjo, who had been the previous incumbent.
Under Former President Obasanjo, Dangote had enjoyed significant government support. FMN
had historically been a major obstacle to his efforts to establish a near monopoly in cement.
Dangote enjoyed far weaker connections to Yar'Adua and to the current incumbent, President
Jonathan.
Page 49 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
The source noted Jonathan to have retained an ambiguous position – he has not worked hard to
develop relationships with former allies of Obasanjo and Yar'Adua, but had generally favored a
less confrontational approach to politics.
According to a Lagos-based former intelligence officer who has also worked as an investigative
journalist, FMN appears well equipped to weather the vagaries of Nigerian political instability and
appears to have adapted well to the country’s shifts to and from military and civilian rule. In the
last decade of civilian rule, lobbying by the company appears to have produced good results.
The source noted that FMN’s level of foreign ownership could potentially pose a risk in future,
although he stated that despite the presence of several Greek and US nationals on the FMN board,
they would most likely be protected by their very well-connected Nigerian colleagues. The source
considered FMN’s Nigerian directors to have the necessary connections to prevent aggressive
moves by competitors and to block deportation orders – a common move made by competitors of
Nigerian firms with foreign stakeholders.
Anti-Corruption Agency
A source who has written extensively on the Nigerian corporate environment noted that the
political use of anti-corruption agencies to pursue opponents, a tactic favored by Former President
Obasanjo, has not been a feature of President Jonathan's government. The source thought it highly
unlikely that FMN would become the focus of any Economic & Financial Crimes Commission
investigation for either political or legal reasons.
Ahmed A Joda
Ahmed A Joda (“Joda”) was born in 1930. He is Vice Chairman of Flour Mills. A Nigerian source
noted Joda to be a part of the traditional elite in the predominantly Islamic north, from Yola, in
Adamawa state. A source familiar with the Nigerian corporate environment noted that, as a wellrespected northerner, Joda’s presence on the FMN board was important for the company to retain
a truly national image.
Page 50 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Joda is a high-profile former civil servant who became a federal permanent secretary in 1967 and
served in the ministries for Industries and Education. He is noted to be particularly close to former
President Obasanjo and during his military rule served as a “Super Permanent Secretary” between
1976 and 1979. Following his retirement from state service in 1978, Joda remained involved in
government and sources noted him to be highly respected. One source noted that Joda was briefly
considered a contender for the Nigerian Presidency during the rule of Babangida, when politicians
with previous experience in elected office were banned.
Joda is a past chairman of the Nigerian Communications Commission, the independent national
regulatory authority for the telecommunications industry. He has won three major national
honors, awarded to him by the Federal Government in recognition of his services to the Nigerian
state. He is the former publisher of national broadsheet newspaper, The Democrat, and a former
Chairman of the Nigerian-French chamber of commerce.
Joda holds stock in Nigerian companies including Scoa Nigeria Plc and Nestle Plc. He was one of
the major investors in the now defunct Credit Lyonnais project, Commercial Bank.
A business source said of Joda:
“He is generally seen as one of the very few Nigerians who reached the peak of their career
without fraudulently enriching themselves.”
Another noted Joda to be regarded “as a man of integrity”.
Joda was described by a journalistic source as “an establishment person.” The source noted:
“He is highly connected with the bureaucratic class and still has connections in government
because of his record in the civil service.”
Page 51 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
Another business source described Joda as “an encyclopedia of civil service policies and
ministerial development strategies”, who still gets “top government institutional appointments.”
Joda is noted to be a close friend of George S. Coumantaros. One source claimed
that Coumantaroswas guardian to Joda’s children when they were at school in the US.
Joda is not openly affiliated to any political parties, although a Nigerian journalistic source
speculated that his sympathies would lie with the incumbent President Goodluck Jonathan.
Research identified no criminal or civil records against Joda. Joda was not identified as implicated
in any fraud allegations.
Emmanuel Ukpabi
Emmanuel Ukpabi (“Ukpabi”) is from the town of Arochukwu in Abia State. He has been
Managing Director of FMN since January 2002.
Ukpabi joined FMN as a trainee in 1972, rising to serve as Production Director, Personnel Director
and Flour Operations Director.
Research identified no criminal or civil cases brought against Ukpabi. Ukpabi has not been
implicated in any fraud allegations.
In recognition of his contribution to the Nigerian business world, Ukpabi was recently awarded an
honorary doctorate degree in business administration.
Ukpabi graduated from the University of Nigeria in Nsukka in 1971 with a BSc in Chemistry. He
has completed advanced management programs at Lagos Business School and the University of
Barcelona.
An expatriate business source noted that Ukpabi enjoyed a high level of access to government
officials by virtue of his commercial success. The source noted in particular that Ukpabi enjoys
Page 52 of 53
Final Report
Flour Mills of Nigeria Plc
Client Work Product
Confidential
high-level access in the Ministry of Finance, Customs, the Ministry of Transport and the Central
Bank of Nigeria. Research identified no suggestion that Ukpabi had used political patronage to
advance his commercial career. Ukpabi is not openly affiliated to any political parties.
Ukpabi appears to have a good reputation in Nigeria. He was widely credited by corporate sources
for the success of FMN and for diversifying the company away from food processing and milling.
Sources at the Nigerian Stock Exchange and the Securities Exchange Commission also spoke
highly of Ukpabi. Ukpabi was described by a business source as “quiet and self-effacing”. The
source continued:
“Ukpabi’s reputation is very good in the industry...he is regarded by his colleagues as
transparent and a stickler for high standards.”
A senior executive of a construction company that has dealt with Ukpapi at FMN noted:
“He is thorough, and when you operate a manufacturing and trading concern of that
magnitude in this kind of hostile Nigerian business climate bedevilled by lack of
infrastructure, you must give kudos to Ukpabi and his board.”
A source at a major distributor of FMN stated:
“This guy is seriously old school but it seemed to have worked for him and his company”
A source close to Ukpapi noted him to be:
“A decent man and a very serious old school accountant. I worked with him once during
an audit – it was an education.”
Research identified no red flags or reputational issues concerning Ukpabi.
Page 53 of 53