Rating History
Dissemination Date Long-Term Rating Short-Term Rating Outlook Action Rating Watch
18-Sep-26 A- A2 Stable Maintain -
19-Sep-25 A- A2 Stable Maintain -
20-Sep-24 A- A2 Stable Maintain -
22-Sep-23 A- A2 Stable Maintain -
23-Sep-22 A- A2 Stable Maintain -
About the Entity

Nagina Cotton Mills Limited ("NCML" or "the Company"), incorporated in 1967 as a public limited company, is part of the Nagina Group, which holds approximately 91% of the Company's shareholding through group companies and sponsoring individuals. The management team is headed by CEO Mr. Amin Ellahi Shaikh, who is well-versed in the textile business, supported by a seasoned finance and operations team, providing the requisite expertise to steer the Company's operations.

Rating Rationale

Nagina Cotton Mills Limited ("NCML" or "the Company") is part of one of Pakistan's oldest and well-established medium-sized textile clusters - the Nagina Group. The Group's spinning operations are carried out through NCML and Ellcot Spinning Mills Limited, while Prosperity Weaving Mills Limited undertakes weaving operations. The Company continues to derive rating comfort from the Group's diversified, vertically integrated textile profile. NCML is considered the Group's flagship spinning entity, historically catering mainly to the export segment, and manufactures carded and combed cotton, core-spun, and blended yarn through a spinning unit of 62,508 spindles, operating at optimum utilization. Intra-group linkages remain a key operational strength, with coarser, export-specification yarn also being directed toward the Group's weaving entity, lending greater revenue confidence. Energy needs are met through a diversified mix of gas, grid, furnace oil, and solar; solar capacity has been enhanced to approximately 6.5MW, now meeting around 16% of the unit's daily energy requirements. The Group's continued competitiveness continues to be underpinned by a sustained Balancing, Modernization and Replacement (BMR) program across all its units. The spinning and weaving segment of the textile industry remained largely a price-taker during FY26, with limited control over raw material and energy costs. Domestic cotton output continues to meet only a modest share of the market's overall requirement, keeping reliance on imported cotton elevated. The local cotton prices stayed broadly range-bound during the year. Export demand improved in recent quarters, though visibility remains limited amid continued softness in international, particularly European, demand. Against this backdrop, NCML's topline for 9MFY26 stood at PKR 15,444mln, with the sales mix continuing to reflect a meaningful local orientation even as export demand showed some recovery during the latest quarter. Gross margin remained broadly steady at 7.9% (FY25: 8.1%), while net margin improved to 0.5% (FY25: 0.3%). The bottom line has already surpassed the full FY25 outturn, supported by a more stable financial risk profile, as reflected in improved debt servicing capacity and lower reliance on borrowings, particularly short-term debt. Working capital remained broadly stable, although liquidity moderated during the period. Governance comprises a 10-member Board with adequate representation across non-executive, independent, and executive categories, supported by active committee oversight. Continued sponsoring-family presence in both ownership and executive roles provides continuity to the Company’s strategic direction, while a stable management team, led by a CEO with extensive experience in the textile business, has maintained consistent execution and oversight, supporting operational and financial discipline.

Key Rating Drivers

The ratings remain underpinned by NCML's improving coverage and leverage profile, set against a structurally constrained, margin-restricted environment and continued export demand uncertainty. Sustaining margins through operational efficiencies, maintaining a balanced sales mix, and preserving comfortable coverage and leverage metrics will remain key rating considerations going forward.

Profile
Legal Structure

Nagina Cotton Mills Limited ("NCML" or "the Company") was incorporated in 1967 under the Companies Ordinance, 1984 (repealed with the enactment of the Companies Act, 2017) as a public limited company.


Background

The foundation of NCML was laid by Mr. Enam Shaikh Ellahi (late) in 1967, marking the origin of what has since grown into the Nagina Group. The Company commenced operations as a single spinning enterprise and has, over successive decades, expanded its footprint organically into a multi-entity textile group. NCML is regarded as the flagship entity within the Group, around which the broader Group structure has been developed. The Group has progressively grown from a standalone spinning concern into a constellation of spinning and weaving companies, comprising three publicly listed entities and six private limited companies.


Operations

Nagina Cotton Mills Ltd (NCML) is engaged in the manufacturing and sale of carded and combed cotton yarn, core-spun yarn, and blended yarn, catering to both knitting and weaving end uses. The Company operates 62,508 spindles, with a yarn production capacity of ~24 million kilograms based on 18/s count (coarse) yarn. The manufacturing facility is located at Kotri Industrial Trading Estate in Sindh. The Company's installed energy capacity stands at 21.62MW against a daily requirement of 6.26MW, comprising 6.71MW of gas-based generation, 7.5MW of HESCO grid supply, 5.41MW of solar power, and 2.0MW of Nagata furnace capacity.


Ownership
Ownership Structure

NCML's shareholding is concentrated within the Ellahi family, who collectively hold 90.88% of the Company through a combination of direct personal stakes and group company holdings. Group companies account for 16.37% of the shareholding, while the sponsoring individuals hold 74.52%, with the principal stakeholders being Mr. Shaukat Ellahi Shaikh (17.47%), Mr. Shahzada Ellahi Shaikh (17.26%), and Mr. Shafqat Ellahi Shaikh (17.26%). Financial institutions hold 0.08% of the Company's shares. The free float available to the general public constitutes 9.04% of the total shareholding.


Stability

The ownership structure of NCML has remained stable and unchanged over the review period, with effective control firmly vested in the Ellahi family. The considerable positions across the Nagina Group are held by the same family, and no ownership disputes or material changes in the shareholding pattern have been reported. The Group maintains a structured line of succession; however, the formal transfer of ownership to the succeeding generation has not yet been executed. The sponsors have demonstrated a sustained commitment to the Company across multiple business and interest rate cycles, providing continuity to the entity's strategic direction.


Business Acumen

The Ellahi family has been actively engaged in Pakistan's textile sector for over five decades, during which time they have navigated multiple economic downturns, policy shifts, and commodity price cycles. The Group's evolution from a single spinning mill to a diversified textile house encompassing spinning and weaving operations is reflective of the family's understanding of the industry value chain and their capacity to identify and execute growth opportunities. The management of three publicly listed entities alongside six private enterprises attests to the organizational and commercial depth of the sponsoring family. Their ability to sustain the Group's operations through periods of macroeconomic stress lends confidence to their continued stewardship of NCML.


Financial Strength

The Nagina Group comprises three publicly listed entities, namely Ellcot Spinning Mills Limited, Prosperity Weaving Mills Limited, and NCML, in addition to six private limited companies: Monell (Pvt.) Limited, Icaro (Pvt.) Limited, Haroon Omer (Pvt.) Limited, Ellahi International (Pvt.) Limited, ARH (Pvt.) Limited, and Pacific Industries (Pvt.) Limited. The collective presence of the Group across multiple operating entities provides a degree of financial depth and support capacity that lends comfort in scenarios where extraordinary financial obligations may arise for any individual entity within the Group.


Governance
Board Structure

As at end-FY26, the Company's Board comprises ten members, of which five are non-executive, two occupy executive roles – including the CEO – and three directors are independent. During the year, the Board inducted Miss Zoe Khurshid Khan as an Independent Non-Executive Director, effective January 28, 2026, maintaining the Board's overall composition and independence.


Members’ Profile

Mr. Shahzada Ellahi Shaikh, the Chairman, possesses 48 years of experience in the textile industry and holds a bachelor's degree in Economics and International Relations. Mr. Shafqat Ellahi Shaikh has 44 years of industry-specific experience and holds a BA in Economics and Religion from Columbia University. Mr. Shaukat Ellahi Shaikh, an Executive Director, has 46 years of overall experience in the textile industry and holds a bachelor's degree in Economics and Political Science from Columbia University. Miss Zoe Khurshid Khan, the newly inducted Independent Non-Executive Director, holds an LLM qualification and carries approximately 20 years of overall experience; she serves as a member of the Audit Committee and the HR & Remuneration Committee.


Board Effectiveness

Three committees – Audit, Executive, and Human Resource & Remuneration – are in place to assist the Board in relevant matters and ensure proper oversight. During FY26, the Board met four times to discuss the Company's performance and progress against projected targets, with meeting minutes documented properly. Most directors attended all four meetings, while Miss Zoe Khurshid Khan, who was inducted mid-year, attended two of the meetings held following her induction. The Sponsors continue to play an active role and provide guidance to management in the Company's operations.


Financial Transparency

M/s. Yousuf Adil, Chartered Accountants, continue to serve as the external auditors of the Company. The firm is listed in the A category on the State Bank of Pakistan's panel of auditors and has expressed an unqualified opinion on the financial statements of the Company for FY25.


Management
Organizational Structure

The top-tier management positions across the Nagina Group's listed operating companies, including NCML, are occupied by members of the Ellahi family, with a clearly defined reporting line that supports operational continuity. The Company's organizational structure is broadly divided into seven functional departments: marketing, finance, accounts, administration and corporate affairs, commercial (covering fixed asset procurement), export, and internal audit. Decision-making within the Company is relatively centralized, with the sponsoring family providing strategic direction and the professional management cadre executing within those parameters.


Management Team

The management team is led by Mr. Amin Ellahi Shaikh (Director/CEO), who holds a BBA and possesses 16 years of overall industry experience, including 11 years with the Company, supplemented by a team of seasoned professionals. Mr. Shaukat Ellahi Shaikh, an Executive Director associated with the Group for 42 years, brings strong business acumen in the textile business. Mr. Tariq Zafar Bajwa, the Chief Financial Officer, holds an MBA and has been associated with the Company for 23 years. The senior management bench is further strengthened by Mr. Syed Mohsin Gilani (FCA), Company Secretary/Director Finance, with 33 years of overall experience including 5 years with the Company, and Mr. Sajid Mehmood Haider, General Manager – Technical, a textile engineering graduate with 27 years of overall experience, including 7 years with the Company.


Effectiveness

Management meetings are held on a daily basis, with follow-up points identified to resolve existing and proactively address potential operational issues, ensuring smooth and efficient business operations. The Company’s MIS reports are categorized into three reporting frequencies, namely daily, weekly, and monthly, facilitating timely monitoring, informed decision-making, and effective operational oversight.


MIS

The Company has transitioned its management information system from the legacy FOXPRO platform to an Oracle ERP solution. The Oracle ERP enables loom-wise packed production recording, BAM-wise recording of warping, sizing, loom, and folding processes, and supports the streamlining of core business operations. The system also enhances financial management capabilities and provides real-time operational insights for management decision-making. Management reporting is structured across three periodicities: daily, weekly, and monthly, with each tier designed to support different levels of operational oversight and strategic review.


Control Environment

NCML holds several quality and compliance certifications, including ISO 9001:2008, Standard 100 by OEKOTEX, Global Organic Textile Standards (GOTS), Organic Content Standard, Organic Content Standard 100, and Organic Content Standard Blended. These accreditations reflect the Company's commitment to product quality assurance and compliance with international supply chain standards. An internal audit function is in place as a distinct department within the Company's organizational structure, providing a layer of independent control over operational and financial processes.


Business Risk
Industry Dynamics

Pakistan's textile manufacturing sector, which carries a substantial weight of 18.16% in the Large-Scale Manufacturing Index, exhibited a broad-based contraction during Jun-26, with the index declining 6.67% YoY and 4.18% MoM, extending a mild 0.63% cumulative decline for Jul-June 2025-26 compared to the corresponding period last year. The weakness was most pronounced in jute goods (down 69.00% YoY) and woollen blankets (down 95.06% YoY), reflecting sharp demand attrition in these niche segments, while terry towels & bath robes and woollen & carpet yarn also posted double-digit YoY declines of 27.35% and 13.45%, respectively. Core segments showed comparatively resilient, near-flat performance, with yarn output down a modest 1.85% YoY and cloth production essentially stable (up 0.17% YoY), underscoring continued, albeit subdued, demand for base textile inputs. In contrast, the manufacture of wearing apparel — with a weight of 6.08% — despite a 13.45% YoY decline in Jun-26, registered a healthier 5.49% cumulative growth over Jul-June 2025-26, suggesting relatively better resilience in value-added, export-oriented garment production compared to upstream textile manufacturing. Overall, the divergent trends highlight ongoing pressure on primary and niche textile categories, even as downstream apparel manufacturing continues to outperform on a cumulative basis.


Relative Position

The Nagina Group boasts a long operating history in Pakistan's local spinning industry. Although the Company's share of the spinning industry is minimal on a standalone basis, the Group's consolidated spinning capacity enhances the Company's market position.


Revenues

During 9MFY26, the Company reported revenue of PKR15,444mln, reflecting a sales growth of 3.7% for the period (FY25: PKR19,858mln, a decline of 2.9% for the year). Of the 9MFY26 revenue, local sales contributed PKR12,278mln while export sales contributed PKR3,166mln (FY25: local PKR18,987mln, export PKR4,077mln). The Company continues to optimize its sales mix between local and international markets in line with prevailing price dynamics to sustain profitability.


Margins

During 9MFY26, the Company's gross margin was recorded at 7.9% (FY25: 8.1%, FY24: 7.9%), while the operating margin stood at 4.8% (FY25: 5.2%, FY24: 5.3%). Finance cost declined to PKR461mln during 9MFY26 (FY25: PKR721mln, FY24: PKR851mln), which supported an improvement in the net profit margin to 0.5% (FY25: 0.3%, FY24: 0.4%).


Sustainability

The Company's management remains focused on optimizing the sales mix, pursuing product differentiation, and consistently identifying cost-reduction opportunities to enhance profitability and drive market growth. However, the international market outlook remains uncertain, characterized by a rising cost structure due to higher energy prices, an increased tax burden, and political instability. In anticipation, the Company is installing a further 1.1MW solar power project at its mills, providing cheaper green energy while reducing its cost structure and supporting environmental sustainability. Upon commissioning of the additional solar project, the Company's total renewable energy capacity will increase to 6.51MW.


Financial Risk
Working capital

The Company continues to fund its working capital requirement through a mix of internal cash flows and short-term borrowings. Short-term borrowings from financial institutions declined to PKR1,126mln at end-Mar26 (FY25: PKR2,804mln), while the current maturity of long-term borrowings increased marginally to PKR791mln (FY25: PKR734mln). The Company's net working capital cycle stood at 109 days during 9MFY26 (FY25: 110 days), with trade receivable days at 50 days (FY25: 49 days) and inventory days at 63 days (FY25: 64 days). Trade assets (receivables and advances to suppliers) stood at PKR3,194mln at end-Mar26 (FY25: PKR3,398mln). The current ratio moderated to 3.6x at end-Mar26 (FY25: 5.2x), mainly on account of a reduction in current assets — particularly inventories, which declined to PKR2,456mln (FY25: PKR4,644mln) — during the period.


Coverages

During 9MFY26, EBITDA was recorded at PKR1,237mln against a lower finance cost of PKR461mln (FY25: EBITDA of PKR1,687mln against finance cost of PKR721mln), resulting in an improved interest coverage of 2.8x (FY25: 2.4x). Free Cash Flow from Operations (FCFO) stood at PKR931mln during 9MFY26 (FY25: PKR1,273mln for the full year), translating into an improved FCFO/finance cost coverage of 2.1x (FY25: 1.8x). The debt payback ratio improved to 7.4x at end-Mar26 (FY25: 8.5x).


Capitalization

At end-Mar26, the Company's leverage improved to 55.1% (FY25: 61.9%) as total borrowings declined to PKR5,926mln (FY25: PKR7,720mln), while the equity base marginally increased to PKR4,820mln (FY25: PKR4,760mln). Short-term debt constituted 19.0% of total borrowings (FY25: 36.3%), reflecting a reduced reliance on short-term financing during the period.


 
 

Sep-26

www.pacra.com


(PKR mln)


Mar-26
9M
Jun-25
12M
Jun-24
12M
Jun-23
12M
A. BALANCE SHEET
1. Non-Current Assets 5,812 5,576 5,966 6,214
2. Investments 613 179 1,168 230
3. Related Party Exposure 0 0 0 0
4. Current Assets 6,630 8,842 5,596 6,144
a. Inventories 2,456 4,644 2,346 3,506
b. Trade Receivables 2,775 2,894 2,424 1,207
5. Total Assets 13,055 14,598 12,730 12,589
6. Current Liabilities 1,838 1,702 1,713 1,686
a. Trade Payables 246 216 174 190
7. Borrowings 5,926 7,720 6,048 6,044
8. Related Party Exposure 0 0 0 0
9. Non-Current Liabilities 471 417 241 192
10. Net Assets 4,820 4,759 4,728 4,667
11. Shareholders' Equity 4,820 4,760 4,728 4,667
B. INCOME STATEMENT
1. Sales 15,444 19,858 20,448 12,819
a. Cost of Good Sold (14,230) (18,249) (18,834) (11,479)
2. Gross Profit 1,215 1,609 1,614 1,340
a. Operating Expenses (473) (572) (534) (432)
3. Operating Profit 742 1,037 1,079 907
a. Non Operating Income or (Expense) 68 (84) 82 156
4. Profit or (Loss) before Interest and Tax 810 953 1,162 1,063
a. Total Finance Cost (461) (721) (851) (259)
b. Taxation (269) (181) (234) (214)
6. Net Income Or (Loss) 80 50 77 590
C. CASH FLOW STATEMENT
a. Free Cash Flows from Operations (FCFO) 931 1,273 1,464 1,054
b. Net Cash from Operating Activities before Working Capital Changes 393 561 620 898
c. Changes in Working Capital 2,687 (3,170) 434 (1,303)
1. Net Cash provided by Operating Activities 3,080 (2,609) 1,055 (404)
2. Net Cash (Used in) or Available From Investing Activities (1,034) 948 (983) (1,022)
3. Net Cash (Used in) or Available From Financing Activities (867) 698 599 1,589
4. Net Cash generated or (Used) during the period 1,178 (963) 670 163
D. RATIO ANALYSIS
1. Performance
a. Sales Growth (for the period) 3.7% -2.9% 59.5% 14.1%
b. Gross Profit Margin 7.9% 8.1% 7.9% 10.5%
c. Net Profit Margin 0.5% 0.3% 0.4% 4.6%
d. Cash Conversion Efficiency (FCFO adjusted for Working Capital/Sales) 23.4% -9.5% 9.3% -1.9%
e. Return on Equity [ Net Profit Margin * Asset Turnover * (Total Assets/Shareholders' Equity )] 2.2% 1.1% 1.6% 13.1%
2. Working Capital Management
a. Gross Working Capital (Average Days) 113 113 85 138
b. Net Working Capital (Average Days) 109 110 81 133
c. Current Ratio (Current Assets / Current Liabilities) 3.6 5.2 3.3 3.6
3. Coverages
a. EBITDA / Finance Cost 2.8 2.4 2.1 5.5
b. FCFO / Finance Cost+CMLTB+Excess STB 0.9 0.9 1.1 1.7
c. Debt Payback (Total Borrowings+Excess STB) / (FCFO-Finance Cost) 7.4 8.5 8.4 6.2
4. Capital Structure
a. Total Borrowings / (Total Borrowings+Shareholders' Equity) 55.1% 61.9% 56.1% 56.4%
b. Interest or Markup Payable (Days) 50.7 83.7 66.3 224.2
c. Entity Average Borrowing Rate 8.2% 9.9% 12.1% 4.6%

Sep-26

www.pacra.com

Sep-26

www.pacra.com

  1. Rating Team Statements
    1. Rating is just an opinion about the creditworthiness of the entity and does not constitute a recommendation to buy, hold, or sell any security of the entity rated or to buy, hold, or sell the security rated, as the case may be. (Chapter III; 14-3-(x))
    2. Conflict of Interest
      1. The Rating Team or any of their family members have no interest in this rating (Chapter III; 12-2-(j))
      2. PACRA, the analysts involved in the rating process, and members of its rating committee and their family members do not have any conflict of interest relating to the rating done by them (Chapter III; 12-2-(e) & (k))
      3. The analyst is not a substantial shareholder of the customer being rated by PACRA [Annexure F; d-(ii)]
      4. Explanation: for the purpose of the above clause, the term "family members" shall include only those family members who are dependent on the analyst and members of the rating committee.
  2. Restrictions
    1. No director, officer, or employee of PACRA communicates the information acquired by him for use for rating purposes to any other person, except where required under law to do so. (Chapter III; 10-(5))
    2. PACRA does not disclose or discuss with outside parties or make improper use of the non-public information which has come to its knowledge during a business relationship with the customer. (Chapter III; 10-7-(d))
    3. PACRA does not make proposals or recommendations regarding the activities of rated entities that could impact a credit rating of the entity subject to rating. (Chapter III; 10-7-(k))
  3. Conduct of Business
    1. PACRA fulfills its obligations in a fair, efficient, transparent, and ethical manner and renders high standards of services in performing its functions and obligations. (Chapter III; 11-A-(a))
    2. PACRA uses due care in the preparation of this Rating Report. Our information has been obtained from sources we consider to be reliable, but its accuracy or completeness is not guaranteed. PACRA does not, in every instance, independently verify or validate information received in the rating process or in preparing this Rating Report. (Clause 11-(A)(p))
    3. PACRA prohibits its employees and analysts from soliciting money, gifts, or favors from anyone with whom PACRA conducts business. (Chapter III; 11-A-(q))
    4. PACRA ensures before the commencement of the rating process that an analyst or employee has not had a recent employment or other significant business or personal relationship with the rated entity that may cause or may be perceived as causing a conflict of interest. (Chapter III; 11-A-(r))
    5. PACRA maintains the principle of integrity in seeking rating business. (Chapter III; 11-A-(u))
    6. PACRA promptly investigates in the event of misconduct or a breach of the policies, procedures, and controls, and takes appropriate steps to rectify any weaknesses to prevent any recurrence, along with suitable punitive action against the responsible employee(s). (Chapter III; 11-B-(m))
  4. Independence & Conflict of Interest
    1. PACRA receives compensation from the entity being rated or any third party for the rating services it offers. The receipt of this compensation has no influence on PACRA’s opinions or other analytical processes. In all instances, PACRA is committed to preserving the objectivity, integrity, and independence of its ratings. Our relationship is governed by two distinct mandates: i) rating mandate - signed with the entity being rated or issuer of the debt instrument, and ii) fee mandate - signed with the payer, which can be different from the entity.
    2. PACRA does not provide consultancy/advisory services or other services to any of its customers or their associated companies and associated undertakings that are being rated or have been rated by it during the preceding three years, unless it has an adequate mechanism in place ensuring that the provision of such services does not lead to a conflict of interest situation with its rating activities. (Chapter III; 12-2-(d))
    3. PACRA discloses that no shareholder directly or indirectly holding 10% or more of the share capital of PACRA also holds directly or indirectly 10% or more of the share capital of the entity which is subject to rating or the entity which issued the instrument subject to rating by PACRA. (Chapter III; 12-2-(f))
    4. PACRA ensures that the rating assigned to an entity or instrument is not affected by the existence of a business relationship between PACRA and the entity or any other party, or the non-existence of such a relationship. (Chapter III; 12-2-(i))
    5. PACRA ensures that the analysts or any of their family members shall not buy, sell, or engage in any transaction in any security which falls in the analyst’s area of primary analytical responsibility. This clause, however, does not apply to investments in securities through collective investment schemes. (Chapter III; 12-2-(l))
    6. PACRA has established policies and procedures governing investments and trading in securities by its employees and for monitoring the same to prevent insider trading, market manipulation, or any other market abuse. (Chapter III; 11-B-(g))
  5. Monitoring and Review
    1. PACRA monitors all the outstanding ratings continuously, and any potential change therein due to any event associated with the issuer, the security arrangement, the industry, etc., is disseminated to the market immediately and in an effective manner after appropriate consultation with the entity/issuer. (Chapter III; 17-(a))
    2. PACRA reviews all the outstanding ratings periodically on an annual basis. Provided that public dissemination of annual review and in an instance of change in rating will be made. (Chapter III; 17-(b))
    3. PACRA initiates an immediate review of the outstanding rating upon becoming aware of any information that may reasonably be expected to result in downgrading of the rating. (Chapter III; 17-(c))
    4. PACRA engages with the issuer and the debt securities trustee to remain updated on all information pertaining to the rating of the entity/instrument. (Chapter III; 17-(d))
  6. Probability of Default
    1. PACRA’s Rating Scale reflects the expectation of credit risk. The highest rating has the lowest relative likelihood of default (i.e., probability). PACRA’s transition studies capture the historical performance behavior of a specific rating notch. Transition behavior of the assigned rating can be obtained from PACRA’s Transition Study available at our website. (www.pacra.com) However, the actual transition of rating may not follow the pattern observed in the past. (Chapter III; 14-3(f)(vii))
  7. Proprietary Information
    1. All information contained herein is considered proprietary by PACRA. Hence, none of the information in this document can be copied or otherwise reproduced, stored, or disseminated in whole or in part in any form or by any means whatsoever by any person without PACRA’s prior written consent.

Sep-26

www.pacra.com