NEWTON CIRCUS PTE. LTD.

This sub-class includes holding companies of firms engaged in non-financial and/or insurance activities (e.g., real estate, construction, production, distribution) that hold the assets (owning controlling-levels of equity) of a group of subsidiary corporations and whose principal activity is owning the group. The holding companies in this sub-class generally do not administer or manage the other businesses in which the equity is held and have little or no employment and revenue from the sale of goods and services. This sub-class also includes the activities of financing conduits where units are created by a non-financial group to raise or borrow funds (often on the open market) and to remit those funds to their parent or another entity within the group.