5/22/22, 4:28 PM Telenor sale to military-linked consortium to be complete in mid-February | Myanmar NOW ACRA’s records on the transfer of Investcom Pte’s 49% of the shares to Shwe Byain Phyu Telecom However, on January 20, some 49 percent of the shares in Investcom Pte Ltd were transferred to Shwe Byain Phyu Telecom Co Ltd, according to company data, with the remaining 51 percent held by the Cayman Islands-registered business. Shwe Byain Phyu Telecom is a registered company in Myanmar. It was previously registered as Shwe Byain Phyu Manufacturing Co Ltd and only changed its name on November 3, 2021. Despite gaining 49 percent of the Investcom Pte Ltd, Shwe Byain Phyu did not appoint a director. The involvement of a Cayman Islands shell company conceals the ownership of the buyers of Telenor Myanmar and raises transparency concerns. The non-profit Tax Justice Network ranks the Cayman Islands first in its Financial Secrecy Index and second in its index of corporate tax havens. https://www.myanmar-now.org/en/news/telenor-sale-to-military-linked-consortium-to-be-complete-in-mid-february 4/18