TEF analyses adjudication orders issued by Indian regulatory authorities to determine whether the conduct giving rise to a finding discloses additional violations of Indian law or of the laws of the jurisdictions in which the corporate body operates. Where such violations are identified, TEF brings the matter to the attention of the relevant authorities, domestic and international, through structured, evidence-based engagement.
We study public adjudication orders, regulatory records and company disclosures and publish our findings in the public interest.
Where findings disclose additional violations, we formally notify the corporate body and afford an opportunity to respond before escalating to the relevant regulatory authorities.
Where systemic compliance failures by corporate bodies create downstream harm to intermediaries and service providers, TEF supports their legitimate interests and professional integrity in regulated sectors.
Where research warrants it, we make representations to competent authorities, domestic and international, always in accordance with law.
TEF operates as a research institution first — publishing analysis grounded in public records — and as an institutional participant in regulatory and governance processes where the research warrants it.
Systematic analysis of public adjudication records cross-referenced against company disclosures — identifying where characterisations made before Indian authorities are inconsistent with the same group's own public statements.
Where research identifies a documented governance concern, TEF formally brings the matter to the attention of the corporate body, presenting the inconsistency between the adjudication record and the company's own public commitments or disclosures, and affording an opportunity to respond. This is always the first step before any regulatory referral.
Supporting Custom House Agents, freight forwarders and trade professionals whose professional integrity or livelihood is affected by systemic compliance failures by corporate bodies — a core registered object of TEF.
Research reports, policy briefs, governance assessments and compliance notes — published for regulators, financial institutions, trade professionals and the wider public.
Specific areas where the interface between intercompany arrangements, customs characterisations and public disclosures raises governance questions of public interest.
How global corporate bodies characterise franchise fees, royalties and management charges for customs assessable value — and whether those characterisations are consistent with the group's own public functional disclosures.
Core ProgrammeIdentifying where a corporate body's characterisation of group functions before Indian regulatory authorities appears inconsistent with the same group's public descriptions of its own structure and entity roles.
Core ProgrammeWhether material facts, agreements and group arrangements were fully and accurately disclosed to Indian customs authorities during Special Valuation Branch review.
Active ResearchCases where the same intercompany payment is characterised differently for transfer pricing versus customs valuation — a risk area that has attracted international regulatory scrutiny.
Active ResearchCases where licensed CHAs and trade professionals face regulatory proceedings in circumstances where the underlying non-compliance originated with the corporate principal, not the professional.
Active ResearchMaterial discrepancies between ESG commitments and BRSR disclosures made by listed entities and independently verifiable compliance data from regulatory records and databases.
Active ResearchTEF's analytical approach is grounded in practitioner knowledge of how characterisation patterns between regulatory records and public disclosures first emerged when India's trade opened in the 1990s, giving TEF a reading fluency that research institutions and law firms alone cannot replicate.
Adjudication orders issued by Indian regulatory authorities are public documents. They record positions corporate bodies took before authorities — often reproducing the corporate body's own group structure descriptions within the same record.
Annual reports, BRSR filings, investor presentations and group structure descriptions are public. We read what the corporate body tells the public about how it is organised and how its entities function.
Where the position recorded before an authority cannot be reconciled with the group's own public functional descriptions, that gap is the governance concern — documented, sourced, ready for institutional engagement.
TEF's first step is always a formal governance notice to the corporate body — affording an opportunity to verify facts and respond. This is a governance question, not a legal allegation.
Where a corporate body's response is inadequate or absent, TEF submits documented research findings to relevant statutory authorities, domestic and international, financial institutions or courts — always in accordance with law.
TEF does not rely on leaked documents, confidential information or insider disclosures. Every finding is based on what is already publicly available.
This means TEF's analysis cannot be challenged on grounds of confidentiality breach or misuse of insider information. The source is always a public document.
All TEF research and submissions are undertaken in good faith, based on information reasonably believed to be accurate, and solely in furtherance of TEF's registered public interest objects — as recorded in Trade Ethics Forum's Memorandum of Association filed with the Registrar of Companies under the Companies Act, 2013.
Regulatory and institutional engagement is the outcome of research — not the starting point. TEF follows a defined sequence: corporate body first, then regulatory submission to domestic or international authorities where necessary, then judicial or financial escalation where warranted.
TEF goes to the corporate body before going to any authority. A formal governance notice is always the first step — affording the corporate body an opportunity to respond. Only where the response is inadequate does TEF escalate externally. This produces a documented record of prior notice that strengthens any subsequent regulatory or judicial engagement.
A structured notice to the corporate body's leadership — board, legal or compliance — identifying the governance concern, presenting the inconsistency between the adjudication record and the corporate body's own public commitments or disclosures, and affording an opportunity to respond. This is not a legal notice. It is a governance inquiry.
Documented representations to statutory authorities responsible for the relevant compliance domain — based entirely on public records and in furtherance of TEF's registered objects. The prior formal governance notice provides context and evidences good faith process.
Governance risk memoranda to lenders, investors and credit agencies, or PIL filings and writ petitions before courts — where the matter is of sufficient public interest and regulatory action alone has proven insufficient.
TEF is inviting distinguished professionals in law, trade, corporate governance, public policy and finance to serve as founding Advisory Council members in an honorary, non-executive capacity.
Expert institutional oversight substantiates public interest standing under Articles 32 and 226.
Institutionally reviewed findings carry greater weight before DRI, SEBI and SFIO.
Institutionally vetted research is significantly harder for corporates to characterise as motivated.
TEF is a Section 8 company and eligible recipient of CSR contributions. Corporate bodies with CSR obligations may direct funds to TEF's governance research and public interest activities.
Trade Ethics Forum is an independent research and regulatory engagement institution, built to fill a gap that neither law firms nor academics were positioned to fill.
India's regulatory environment has moved through three distinct phases. The governance gap TEF exists to address was created in Phase 2 and has compounded, unexamined, through Phase 3.
Before 1991, India operated under strict import substitution. Trade barriers were among the world's highest. Nearly 90% of tradable goods required import licences. Trade administration was dominated by licence navigation, not valuation complexity. Multinational corporate structures and intercompany payment characterisation were not yet regulatory issues.
The governance gap TEF was built to address formed at the inflections of 1989, 1991, 1993, 2001, 2008 and 2014. As global corporate bodies entered India, adjudication orders and regulatory findings across customs, taxation and disclosure frameworks recorded one characterisation, while the same groups' annual reports and public disclosures described their structures differently. No institution has ever systematically cross-referenced those two bodies of public information. TEF was built to do exactly that.
The three phases of India's trade and regulatory evolution are the institutional context in which TEF's mandate is grounded. The governance gap was opened in Phase 2, compounded through Phase 3, and remains, to date, unexamined as a body of public information.
TEF's analytical approach is grounded in practitioner knowledge of how characterisation patterns between regulatory records and public disclosures first emerged when India's trade opened in the 1990s — giving TEF a reading fluency that research institutions and law firms alone cannot replicate.
Adjudication orders, regulatory findings and corporate disclosures are public documents — but reading them as primary evidence of governance inconsistency requires fluency with the regulatory interface between multinational group structures and Indian law. TEF's analytical approach is grounded in that practitioner knowledge.
Customs adjudication orders, SEBI proceedings, CESTAT orders, income tax findings and SFIO reports are public — but no organisation has been reading them alongside the same corporate bodies' annual reports, BRSR filings, investor presentations and OECD, UN Global Compact and FATF commitments. TEF does.
Custom House Agents, freight forwarders and other intermediaries and service providers in regulated sectors have no forum that can represent their collective governance and professional integrity interests before regulatory authorities and courts. TEF fills that role as a core registered object of its mandate.
Academic and policy institutions studying corporate governance and trade compliance rarely have practitioner reading fluency in the room. TEF brings frontline regulatory practice to research that is typically confined to legal commentary or theoretical analysis.
Every research output and institutional submission is made in good faith, based on information reasonably believed to be accurate. This is not only an ethical commitment — it is a registered obligation in TEF's Memorandum of Association.
No submission is made without documented research. No formal governance notice to the corporate body is issued without cross-referencing the regulatory record against public disclosures. The research always precedes the action.
TEF's first step is always a formal governance notice to the corporate body, affording an opportunity to respond. Regulatory referral to domestic or international authorities follows only where the response is inadequate or absent. Lawful channels only — no extrajudicial pressure, no parallel process.
The professional integrity and livelihood of intermediaries and service providers in regulated sectors — including Custom House Agents, customs brokers and freight forwarders — is a core registered object of TEF, not an ancillary consideration.
TEF's research methodology is built on a single principle: every finding is sourced from documents that are already publicly available. We do not rely on leaks, insider disclosures or confidential information.
Two types of public document sit at the heart of every TEF research output: the adjudication record from any Indian regulatory authority and the corporate body's own public disclosures. The methodology maps the space between them.
Adjudication orders issued by Indian regulatory authorities — including customs (Commissioner, CESTAT, SVB), SEBI, income tax, FEMA and SFIO — are public documents. They record the position corporate bodies took before the authority, the authority's findings, and often reproduce the corporate body's own group structure descriptions within the record itself.
From the adjudication order, TEF extracts the exact characterisation advanced by the corporate body for the relevant transaction or arrangement — how the entity was described, what functions were attributed to it, and on what basis the matter was presented to the regulatory authority.
TEF obtains the same corporate body's annual reports, BRSR filings, investor presentations, exchange filings and group structure descriptions — all public documents. These state how the group describes its own entities, functions and intercompany arrangements to investors and the market.
Where the characterisation recorded in the adjudication order cannot be reconciled with the corporate body's own public functional disclosures, that gap is the governance concern. TEF frames it precisely: not as a legal allegation, but as a governance question — were the facts accurate and consistent with the group's own public disclosures?
The documented governance concern is taken first to the corporate body through a formal governance notice, then — where the response is inadequate — to relevant regulatory authorities, domestic and international, and where further warranted, to financial institutions or courts. Each channel is sequential and conditional on the response received at the prior stage.
TEF's analytical approach is grounded in practitioner knowledge of how characterisation patterns between regulatory records and public disclosures first emerged when India's trade opened in the 1990s, giving TEF a reading fluency that research institutions and law firms alone cannot replicate.
TEF reads corporate disclosures, including annual reports, BRSR filings, investor presentations and exchange filings, as primary evidence, not background reading.
TEF's institutional independence from the corporate body under review, from the regulatory authority, and from any transactional interest is the basis on which its referrals carry weight.
Where a corporate body has publicly committed to international normative frameworks, including the OECD Guidelines for Multinational Enterprises, the UN Global Compact, FATF compliance standards, or WTO trade facilitation commitments, TEF's research examines whether the conduct documented in Indian adjudication records is consistent with those commitments. Cross-border regulatory engagement is grounded in the corporate body's own public commitments, not in extraterritorial assertion of Indian law.
Commissioner-level orders, CESTAT judgments, orders-in-original — all public, all containing the company's own submissions.
Special Valuation Branch proceedings documenting how intercompany transactions were characterised and assessed.
Directors' reports, financial statements, notes to accounts — containing group structure descriptions and related-party disclosures.
Business Responsibility and Sustainability Reports — containing ESG commitments and governance disclosures filed by listed entities.
Analyst presentations, IPO filings, capital market disclosures — often containing detailed group functional allocations and entity descriptions.
Exchange filings, related-party transaction disclosures, corporate governance reports — filed with SEBI and the Ministry of Corporate Affairs.
TEF's core research programme focuses on a specific and recurring pattern that emerged during India's liberalisation phase: as global corporate bodies entered India from the early 1990s, they brought group structures — franchise arrangements, royalty flows, management charges — that Indian regulatory frameworks across customs, taxation and disclosure had to absorb. The characterisations those corporate bodies advanced before regulatory authorities were not always consistent with how the same groups described their own structures in public disclosures. That gap — first observable in the adjudication record of the liberalisation era — is what TEF now systematically researches using public records.
A franchise fee or royalty is presented to an Indian regulatory authority as compensating only a specific, limited function — retail concept, brand licence, or logistics support. The same group's own annual reports describe the paying entity as providing retail operations, range management, supply chain and logistics — a materially broader set of functions than the regulatory characterisation records.
A distinctive feature of this research programme is that the adjudication order itself often reproduces the corporate body's own submissions about its group structure — including organisational charts and entity descriptions provided by the corporate body. When compared against the same group's annual report, the inconsistency becomes visible within documents the corporate body itself authored.
Where a corporate body's representations before an Indian regulatory authority cannot be reconciled with its own public functional disclosures, several governance and compliance questions arise — including the accuracy of representations made to a statutory authority, the completeness of related-party disclosures in audited accounts, and the integrity of the corporate body's governance and oversight processes for cross-border transactions.
TEF documents the inconsistency as a governance question and takes it first to the corporate body through a formal governance notice. The notice identifies the discrepancy, cites both source documents, and affords the corporate body an opportunity to verify the accuracy of its representations and review its controls. Only where the response is inadequate does TEF escalate to regulatory authorities, domestic or international.
Franchise fees characterised as compensating only "retail concept" or "brand use" before Indian regulatory authorities — while the same group's disclosures describe the franchisor entity as providing range management, supply chain integration, technology platforms and full business model support.
Royalties presented as covering only intellectual property licensing for Indian customs and tax purposes — while the licensor's own annual report describes the arrangement as encompassing know-how transfer, operational support, quality systems and ongoing service provision.
Material agreements, group arrangements and intercompany service contracts not disclosed to the SVB or other regulatory authorities during enquiry proceedings — agreements that are referenced, or their terms described, in the same corporate body's publicly filed annual reports and SEBI disclosures.
The same intercompany payment treated as an arms-length transaction for transfer pricing purposes — with a detailed functional analysis supporting the TP characterisation — while a materially different characterisation is advanced before Indian customs authorities or in BRSR/ESG disclosures.
A public record of TEF's institutional engagement — formal governance notices to corporate bodies, regulatory representations, financial institution memoranda and judicial filings. All entries are based on public-record research undertaken in good faith.
An independent body of regulatory, legal and domain experts that supports TEF's research methodology, reviews findings within members' areas of expertise, and provides institutional oversight of TEF's engagement with domestic and international regulatory authorities.
The Advisory Council provides TEF with the depth of regulatory, legal and domain expertise required to assess governance concerns across the full scope of TEF's mandate. Council members contribute to research methodology, review findings in their areas of expertise, and provide institutional oversight of TEF's engagement with domestic and international regulatory authorities.
The Advisory Council draws from senior professionals whose institutional standing and subject-matter authority most directly strengthen TEF's research outputs and regulatory submissions.
Where TEF's research identifies a documented governance concern, engagement with the corporate body proceeds first by way of a formal governance notice. The Advisory Council reviews findings within members' areas of expertise before such a notice is issued, and provides institutional oversight of any subsequent escalation to domestic or international regulatory authorities.
Findings underpinning a formal governance notice to the corporate body are reviewed by Council members with relevant subject-matter expertise.
Council members contribute to TEF's research methodology and the standards applied to cross-referencing adjudication records against corporate disclosures.
Where a formal governance notice receives an inadequate response, the Council provides institutional oversight of TEF's onward engagement with domestic and international regulatory authorities.
Individuals who meet the criteria above and wish to express an interest in serving on TEF's Advisory Council may do so in confidence. TEF will acknowledge receipt. All expressions of interest are held in strict confidence.
TEF will acknowledge receipt of all expressions of interest. All information provided is held in strict confidence.
TEF is a Section 8 company eligible to receive CSR contributions under Schedule VII of the Companies Act 2013. Corporate bodies with corporate social responsibility obligations may direct funds to TEF's governance research and public interest activities.
| Criterion | Status | Notes |
|---|---|---|
| Section 8 Company | ✓ Eligible | TEF is incorporated as a Section 8 company under the Companies Act 2013 |
| Schedule VII Alignment | ✓ Eligible | TEF's activities align with Schedule VII — covering education, research, governance, and livelihood enhancement |
| CSR-1 Registration | In Process | CSR-1 registration on MCA CSR portal — required before receiving CSR contributions |
| 80G Tax Exemption | Application in Process | Application to be filed with Income Tax authorities. Donors should note pending status. |
| FCRA Registration | Not yet eligible | FCRA registration requires 3 years of existence and track record. Not applicable at this stage. |
| Utilisation Reports | ✓ Provided | TEF provides utilisation certificates and annual reports to all donors |
| No Member Distribution | ✓ Confirmed | TEF's MOA prohibits distribution of income or assets to members — all funds applied to objects |
TEF's research, publications, training programmes and compliance awareness activities advance governance and compliance education across India's regulatory framework.
TEF's support for intermediaries and service providers in regulated sectors, including Custom House Agents and customs brokers, whose livelihoods may be affected by systemic compliance failures by corporate bodies.
Where TEF's training and capacity-building programmes specifically support women professionals and intermediaries in regulated sectors.
Not applicable to TEF.
Where TEF's compliance awareness and research activities support businesses and intermediaries in rural and semi-urban trade corridors.
Not the primary focus of TEF's work.
Contact TEF to discuss your CSR committee's focus areas and how TEF's work may align
TEF provides MOA, annual returns and all documents your CSR committee and legal advisers require
Activity-specific proposal prepared for CSR committee approval, with outcomes and reporting framework
Funds applied to agreed activities — research, publications, training programmes or institutional submissions
Utilisation certificate, progress report and MCA CSR portal compliance reporting provided to donor
TEF welcomes documented information from trade professionals, customs brokers, compliance officers and others with knowledge of regulatory proceedings, compliance records or governance disclosures involving corporate bodies subject to Indian regulatory jurisdiction. This includes customs valuation, SVB proceedings and intercompany arrangement disclosures, as well as ESG and BRSR discrepancies and intermediary harm arising from corporate compliance failures.
Information about how a corporate body has characterised franchise fees, royalties, management charges or other intercompany payments before Indian customs authorities
Information about under-valuation, SVB non-disclosure, misclassification or other potential non-compliance in customs or trade regulatory proceedings
Information about cases where a licensed Custom House Agent, customs broker or other intermediary or service provider in a regulated sector faces proceedings in circumstances where the underlying non-compliance originated with the corporate principal
Information about material discrepancies between a corporate body's ESG or BRSR disclosures and independently verifiable compliance data or regulatory records
Anonymous submissions are fully accepted. You are not required to provide any identifying information. If you wish to receive TEF's acknowledgement or be kept informed of developments, you may optionally provide contact details below.
Thank you. TEF has received your submission. All information is held in strict confidence and will be reviewed by TEF's research team in accordance with our documented triage process.