IN THE HONOURABLE LAHORE HIGH COURT, LAHORE

(Constitutional Jurisdiction)

In re:

W.P. No. 8671/2017

Sannia Kanwal

Versus

Government of Punjab & Others

PARA-WISE COMMENT ON BEHALF OF FAISALABAD INDUSTRIAL ESTATE DEVELOPMENT

& MANAGEMENT COMPANY / RESPONDENT NO. _______

Respectfully sheweth:-

1. That the instant para-wise comments are being filed on behalf of Faisalabad
Industrial Estate Development and Management Company (“FIEDMC”)
which is arrayed as Respondent No. _______ in the titled writ petition.

2. That the instant para-wise comments on behalf of FIEDMC are being filed
through its ______________ who is duly authorized under Board Resolution
dated ______.

Copy of the Board Resolution dated _______ is attached herewith as

Annexure A.

Preliminary Objections

1. That the titled writ is a compilation of conjectures and surmises without

exposing any illegality whatsoever.

2. That the Petitioner has no locus standi against FIEDMC and other
Respondents. The relief sought by the Petitioner is in nature of a declaration
with respect to legality of the SOEs working in Punjab, which makes the
 titled petition a writ under Article 199 (1) (a) (ii) that can only be filed by an
aggrieved person.

Preliminary Submissions

3. That FIEDMC categorically denies each and every allegation made in the
titled petition. A brief description of FIEDMC, its operations and its
governance structure is as follows:

Operations and Governance

3.1. FIEDMC has been incorporated with Securities and Exchange
Commission of Pakistan (“SECP”) under S. 42 of the Companies
Ordinance, 1984 as a wholly owned entity of Government of the
Punjab.

Copy of Incorporation Certificate of FIEDMC and its Article &

Memorandum of Association is attached herewith as Annexure
B/1 & B/2.

3.2. FIEDMC is established with an aim to promote economic

development of Pakistan through establishment of industrial estates.
Its creation is meant to effectively utilize the industrial potential of
Faisalabad district. To achieve the aforementioned goal, it is
imperative to provide a congenial environment to the stakeholders
who wish to develop or expand their businesses in Faisalabad
district. FIEDMC is setup on 4700 acre as an industrial hub in
Faisalabad district wherein basic utilities like electricity and gas etc.
are provided without any interruption along with certain incentives
and benefits to the enterprises launching their projects therein. An
independent board is in charge of FIEDMC’s affairs and managing its
mandate in a transparent manner and without any political influence
whatsoever.

3.3. FIEDMC has successfully completed the following projects so far:

3.3.1. Value Addition City (VAC): It’s a fully functional state of the
art aesthetically developed industrial estate catering the needs
of SMEs. Its spread over an area of 215 acres where nearly all
the plots have been sold out and industries have been
developed. This project is expected to generate employment for
50,000 people.

3.3.2. M-3 Industrial City covers an area of 4356 acre and will focus
on textile, engineering and construction, chemicals,
 pharmaceuticals, electronics, food and beverages, I.T. etc. this
project is likely to generate employment for 500000 to 600000
individuals.

3.3.3. Both the VAC and M-3 have been declared as Special Economic
Zones by the competent authority and the incentives and
privileges granted under the Special Economic Zones Act, 2012
(“SEZ Act”) will be available to the investors within the
aforementioned industrial estates.

Service Structure of Key Position Holders

3.4. FIEDMC’s management consists of a dedicated BoD containing 13

individuals from private sector, 3 ex-officio trade bodies and 5 ex-
officio government officials which was appointed through
Notification dated 15.07.2015. The BoD is working on pro bono basis
and drawing no salary / remuneration for their services to FIEDMC.
The Articles of Association of FIEDMC specifically directs that no
remuneration shall be paid to the BoD and the CEO. The details
members of BODs are as follows:

Mian M. Adrees Mr. Shahid Arshad

Chairman Director
Sitara Chemicals Crescent Cotton & Sugar

Mr. Nazim Ahmed Sheikh, Mr. Omer Farooq Khan

Ittehad Textiles (Pvt) Limited CEO
PEPSI Cola, Punjab Beverages
(Pvt) Limited

Mr. Muzammil Sultan Khawaja M. Amjad,

CEO Chairman
Sultan Trading Company Khawaja Cotton Industries

Maj. Shahnawaz-ul-Hassan Engr. Rizawan Ashraf

Chairman M.A. Textile (Pvt) Limited
Pasban Group of Companies

Mr. Abid Kamal Mrs. Sharmeen Aseem

Director Director
Kamal Group Khursheed Spinning

Mrs. Sadaf Amir Mr. Eram Waqar

CEO CEO
Farm Fresh (Pvt.) Limited Cosmetic Industry, Eram
Associates Faisalabad
 Mrs. Nighat Shahid, Secretary
CEO Industries, Commerce &
Shan Industries Investment Department
Secretary Secretary
Finance Department Labour & Human Resource
Department

Secretary District Coordination Officer

Environment Protection Faisalabad
Department

Chairman President
Pakistan Hosiery Manufactures Faisalabad Chamber of
Association (PHMA) Commerce & Industry (FCCI)

Chairman
All Pakistan Cloth Exporter
Association

The copy of the Notification dated 15.07.2017 is attached

herewith as Annexure C/1

3.5. That the designations held by the members of the BOD speak their
qualifications for holding such position in FIEDMC.

3.6. That the Board has appointed CEO of the Company, the qualification
and profile of whom has been given in para_______, hereunder. It is
important to mention that CEO reports to the Board, as per the
provisions of the Companies Act 2017 and CG Rules 2013. Moreover,
the Chief Internal Auditor directly reports to the Board with regard to
its duties and functions. The Board has also appointed Chief
Operating Officer (“COO”), Chief Financial Officer (“CFO”) and
Chief Internal Auditor as per rule 13 of the CG Rules 2013. It is
important to mention that these officers are fully qualified as per rule
14 of the CG Rules 2013.

3.7. That the CEO of Company has further delegated its power COO, and
CFO, Manger Strategy and Business Development, Manger
Partnerships and Placements, Manger Program Development and
Manager Marketing and Communications. It is pertinent to mention
that the Chief Internal Auditor administratively reports to the CEO.

3.8. That the COO of the Company is further assisted by Manager MIS &
IT, Manager Procurement, Manger Program Management and
Manger Human Resource and Administration. The CFO of the
Company is also assisted by Manger Finance. Needless to mention
 that these aforementioned officers have subordinate officers and
support staff.
PSDF Organogram – Approved by Board of Directors is
attached herewith Annexure C.

Profile of CEO1

3.9. That Mr. Muhammad Adrees is currently working as Chief Executive

of the Company and has been appointed through the notification
dated 15.07.2015

3.10. That it is humbly submitted that the CEO of the Company not only
have requisite qualification but he is an eminent person from his field.
The CEO has excellent academic qualifications. Mr. Muhammad
Adrees graduated from Punjab University and did his post-graduation
from England. He also studied various professional courses from
LUMS, Pakistan Institute of Management and Leadership and
Canadian based Universities.

3.11. The CEO of Company have corporate leadership qualities due to

which M/s. Sitara Chemicals is largest complex of chlor-alkali in
Pakistan with annual turnover of PKR 8.8 Billion per annum. Mr.
Muhammad Adrees have held many other key post in past the details
of which are as follows:

Company / Sector Profile / Post Held

Committee on Broadening Tax Chairman
Constituted by Ministry of Finance (2015)

Caustic Soda Manufactures Association Chairman

Federation of Pakistan Chambers of Regional Chairman /
Commerce & Industry Vice President
(2009-10)
Standing Committee Chairman
Federation of Pakistan Chambers of
Commerce & Industry
(2007-08) & (2012-13)
Office Management Committee Chairman
Faisalabad Chamber of Commerce and
Industry (2007-15)
Human Resource Committee Chairman
Faisalabad Chamber of Commerce and
Industry (2007-15)

1 The said information and data is incorporated in the reply in compliance of letter dated
11.10.2017 issued by Dr. Shahid Ali, Additional Secretary, Punjab
 Land & Building Committee Chairman
Faisalabad Chamber of Commerce and
Industry (2009-15)
Standing Committee on Research & Chairman
Development
Faisalabad Chamber of Commerce and
Industry (2009-10)
Advisory Committee to President Chairman
Faisalabad Chamber of Commerce and
Industry (2005-06)
Standing Committee on Energy, Chairman
Petroleum, Natural Resource & Electric
Power Generation
Faisalabad Chamber of Commerce and
Industry (2001-02)

The CEO of the Company had also played a role in Corporate Social
Responsibility and in this regard he is managing trustee of Aziz
Fatimah Trust Hospital, Sitara Institute of Management & Technology.
He was remained secretary general of Message Foundation Lahore.

The curriculum vitae of Mr. Muhammad Adrees (CEO) is

attached herewith as Annexure E

Salary of Key Position Holders of the Company:2

3.12. That the salary, perks and privileges of the key position holders are as
follows:

Designation Gross Salary

CEO Nil (Honorary Post)
COO 714,150/- p.m.
G.M. Technical 704,652/- p.m.
Sr. Manager Contract 339,364/- p.m.
Company Sectary 232,099/- p.m.

3.13. That it is pertinent to mention that the Company has returned 27% of
the loan price to the Government of Punjab and the rest of the balance
is payable up to Financial Year 2020 under the loan agreement.

3.14. That the Company is perfect example of self-sustainable. The PPP

model developed Value Addition City on 215 acres Developed MI-3
Industrial City on 4356 acres Generated 100,000 Emp Opportunities so
far (direct and indirect). Moreover, the Company have fetched local

2 The said information and data is incorporated in the reply in compliance of letter dated
11.10.2017 issued by Dr. Shahid Ali, Additional Secretary, Punjab
 Investments about Rs. 50 billion and also procured Foreign Direct
Investment of Rs. 40 billion plus sales of Rs. 14.9 billion. The Projects
of the Company are self-sustainable without help of the Government.
3.15.