Entities exist for reasons
It is crucial at this moment that we understand that Adani’s web of shell companies in Australia exist for reasons unknown, but comprehensible if we can get answers to the right questions. Adani entities such as Carmichael Rail Network Pty Ltd and Adani Infrastructure Pty Ltd are enmeshed in Adani’s dealings over the rail corridor which is nearing completion, and the North Galilee Water Scheme which is under review. Adani Australia entities can refer to either of these 2 former shell companies as ‘Bravus’ in their communications on their website and in media statements under the language and framing contained in the Bravus privacy policy.
Exoneration mechanisms
Over the last 6 months I have sought answers to questions about the Adani entity names used in communications from the Queensland government department responsible for coordinating and regulating development projects and proponents including mining companies – the Office of the Coordinator-General (OCG). I made requests for clarification and information to a communications officer, but I was given a flat refusal. I submitted a complaint regarding ethical conduct of the officer and the department itself, sought an internal review, and then an external review with the Queensland Ombudsman. None of my efforts were successful.
After what I can only describe as a chain of exoneration and obfuscation where I am left with more questions than answers, I can make one clear statement:
The OCG are confident that they can refer to ‘Bravus’ rather than the listed proponents in their communications and in the commissioning of reports without consequence.
It might reasonably be expected that the OCG would use the names of the Adani entities it coordinates under the State Development and Public Works Organisations Act (SDPWO Act) in its communications, but a recent report on an investigation into allegations of environmental breaches on the North Galilee Basin Rail Project (NGBR) failed to identify Adani’s rail proponent or name the project where the alleged breaches took place and physical inspections had been conducted (including OCG staff). I wrote about how the OCG were “masking” the relevant project proponents in March and again in May this year.
The Office of the Coordinator-General and Adani: Masking the rail proponent
A very questionable investigation: The OCG, Adani and public sector ethics in Queensland
24 Adani entities
How is it that a business name that is the product of re-branding came to be used as a substitute for the specific entities coordinated and regulated by the OCG? Why do media and NGOs take little to no interest in unpacking Adani’s corporate structure and branding? The answer to both questions starts with a look at the Bravus Mining and Resources website.
The Bravus privacy policy is effectively a guide to understanding the language in Bravus branded communications. It frames what is meant when “we” or “us” statements are used.
At Bravus Mining & Resources (being one or more of the companies listed in the Appendix at the end of this privacy policy) (“Bravus Mining & Resources”), we are committed to protecting your privacy.
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https://www.bravus.com.au/privacy-policy/
An archived version of Bravus privacy policy page:
https://web.archive.org/web/20220812145644/https://www.bravus.com.au/privacy-policy/
The appendix to the Bravus privacy policy lists 24 different Adani entities, none of which are ‘Bravus Mining and Resources’ which is listed with the Australian Securities and Investments Commission (ASIC) as a business name with no ABN or ACN listed. Among those 24 different Adani entities are Carmichael Rail Network Pty Ltd who possess all the rail approvals, are in line for a water licence, are responsible for the CCMR – Separable Portion 1/Stage B – North Galilee Water Scheme (NGWS) pipeline corridor, were the likely NAIF loan applicant, and are said to possess the royalty deed for the Carmichael mine; and Adani Infrastructure Pty Ltd who were central to the NGWS which is currently under review.
Quote from the Bravus privacy policy:
Appendix – Adani companies in Australia, which collect and use personal information
This list is accurate at the date of this privacy policy. For the latest list of Adani companies to which this privacy policy applies please contact our Privacy Officer.
MUNDRA PORT PTY LTD 61 150 498 098 150 498 098
ADANI ABBOT POINT TERMINAL PTY LTD 93 149 298 206 149 298 206
MUNDRA PORT HOLDINGS PTY LTD 94 150 520 835 150 520 835
MUNDRA PORT HOLDINGS TRUST 34 296 288 922 N/A
ADANI ABBOT POINT TERMINAL HOLDINGS PTY 17 154 644 685 154 644 685
ADANI MINING PTY LTD 27 145 455 205 145 455 205
ADANI MINERALS PTY LTD 32 151 649 740 151 649 740
GALILEE TRANSMISSION HOLDINGS PTY LTD 83 161 992 481 161 992 481
GALILEE TRANSMISSION PTY LTD 32 161 992 641 161 992 641
GALILEE TRANSMISSION HOLDINGS TRUST 98 979 077 365 N/A
ADANI AUSTRALIA COAL TERMINAL PTY LTD 77 163 186 383 163 186 383
ADANI AUSTRALIA COAL TERMINAL HOLDINGS 44 168 582 045 168 582 045
ADANI ABBOT POINT COMPANY PTY LTD 77 163 218 335 163 218 335
ADANI AUSTRALIA COMPANY PTY LTD 87 163 221 609 163 221 609
ADANI AUSTRALIA COAL TERMINAL FINANCE 62 601 738 578 601 738 578
ADANI ABBOT POINT HOLDING TRUST 14 212 294 591 N/A
ADANI AUSTRALIA HOLDING TRUST 80 796 296 329 N/A
CARMICHAEL RAIL PTY LTD 80 601 873 492 601 873 492
CARMICHAEL RAIL HOLDINGS PTY LTD 32 601 738 827 601 738 827
CARMICHAEL RAIL NETWORK PTY LTD 87 601 738 685 601 738 685
CARMICHAEL RAIL NETWORK HOLDINGS PTY 59 601 738 943 601 738 943
CARMICHAEL RAIL NETWORK TRUST 78 466 438 945 N/A
CARMICHAEL RAIL NETWORK HOLDINGS TRUST 52 857 090 548 N/A
ADANI INFRASTRUCTURE PTY LTD 16 606 764 827 606 764 827
Nothing official
When the media, NGO spokespeople and government departments repeat Adani’s statements without questioning if those statements should detail the entities regulated and coordinated under state and federal law, they are failing to properly inform the people. Adani Australia’s re-branding as Bravus was designed to suggest that its marquee company Adani Mining Pty Ltd, holder of the majority of environmental approvals and all Indigenous land use agreements, was the sole subject of the name change. Adani didn’t need to lie (though they kinda did and still kinda are), they simply anticipated the dearth of interrogation from the media and NGOs which allowed suggestion to do the work for them. It fooled me and everyone who wrote about the Bravus re-branding.
The Adani Mining Pty Ltd ASIC listing does not specify that they are trading as ‘Bravus Mining and Resources’. Adani Mining Pty Ltd are still the EPBC approval holder for both the Carmichael Coal Mine and Rail Project (CCMR) and the North Galilee Basin Rail Project, and hold all Indigenous land use agreements. The introduction of the ‘Bravus Mining and Resources’ business name/brand was not accompanied by any change of name on any documents on the public record.
A statement can be found below Adani media releases hosted on the Bravus website that predate the branding exercise. This statement asserts that the name of “Adani Mining” which we can reasonably assume is a reference to “Adani Mining Pty Ltd” was “officially changed” to “Bravus Mining and Resources”.
On November 5th, Adani Mining officially changed it’s name to Bravus Mining and Resources.
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https://www.bravus.com.au/adani-partners-with-decmil-in-another-win-for-regional-queensland/
Recent changes
Sometime between September 19, 2021 and October 23, 2021, the ASIC listing for Bravus Mining and Resources was amended to include the details of the business name holder, Adani Mining Pty Ltd, including an ABN, and a business and mailing address. I was able to establish this fact by comparing ASIC summaries downloaded on the dates listed. The amended ASIC listing is the first piece of evidence placed on the public record showing that Adani Mining Pty Ltd has an official connection to the Bravus Mining and Resources business name. It raises the question of why Adani Mining Pty Ltd took 11 months to include basic information about its new business name on the public record. Perhaps they saw the tweet I sent to Ben Smee on September 21 or the email I sent to an Adani legal counsel on September 20?
The law and proper communications
While the government departments have built-in exoneration mechanisms, the media and NGO spokespeople can choose to take a more interrogatory approach that takes account of the web of Adani entities that exist under the Bravus brand. In theory this is the professional responsibility of journalists and their editors, and should be the imperative reflected in the output of various NGOs. Think tanks and environmental law firms should be the leaders in this regard, but they are not. I suspect this is because narrative framing and funding for particular themed campaigns has left the NGO sector without the necessary agility to identify and respond to Adani’s marketing strategies. In the process of failing to interrogate Adani’s branding the environmental NGOs and the media leave us all misinformed. In adopting the branded nomenclature of ‘Bravus’ over the names of the Adani entities coordinated and regulated under Queensland legislation, the OCG have allowed the Bravus re-branding to determine their communications.
We Suspect Silence 
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