New Delhi: For an organisation that has been around since 2009 producing monographs on themes like radical Islam in Kerala and the ‘forced conversion’ of adivasis, the rise of the India Foundation since 2014 has been nothing short of meteoric.

It is today India’s most influential think-tank, providing a platform for foreign and Indian captains of industry to rub shoulders with ministers and officials and discuss the finer points of government policy. But the India Foundation’s opaque financials, the presence of senior ministers as directors and the fact that executive director Shaurya Doval’s day job is running Gemini Financial Services – a firm that specialises in “transactions and capital flows between the OECD and the emerging Asian economies” – also raise the prospect of conflict of interest and lobbying, problems Narendra Modi had promised to banish forever from the corridors of power.

Shaurya Doval happens to be the son of the politically influential national security advisor Ajit Doval, and this ‘coincidence’ adds a new element to the dynasticism that plagues politics and public affairs in India. Given the current political climate, it is also a relationship that is seldom discussed in public. To get a sense of how unusual the silence is in the face of potential conflicts of interest, assume for a moment Sonia Gandhi’s son-in-law Robert Vadra as the partner of a financial services firm connected to a Saudi prince signing up India’s defence minister and commerce minister as directors of his think-tank and then holding a series of events paid for by companies whose names are not made public.

Run by the younger Doval and BJP national general secretary Ram Madhav Varanasi, the India Foundation lists among its directors defence minister Nirmala Sitharaman and commerce and industry minister Suresh Prabhu, and two ministers of state – Jayant Sinha (civil aviation) and M.J. Akbar (external affairs).

Together, the four ministers, a Sangh parivar heavyweight and a businessman with an influential father in the PMO have given the India Foundation the kind of institutional heft that well-established players in the think-tank space can only dream about. Every event the foundation organises is attended by key decision-makers in that field, which in turn guarantees not just a full house but also sponsorship – both by government bodies and private companies, Indian and foreign.

The source of its success, however, is also the India Foundation’s greatest weakness, for the very visible presence of the six raises troubling questions about conflicts of interest, and the possibility of foreign and Indian companies leveraging their support for foundation ‘events’ in order to seek favours from the government on issues where they may have a business stake.

As a trust, the foundation is not obliged to make public its balance sheet or financials. Despite the presence of ministers on its board of directors, it refuses to part with any information about its source of revenue. As part of the research for this story, a detailed questionnaire was sent to all six high-profile directors. The ministers chose not to reply while Madhav promised that the “appropriate person” would respond with answers. That never happened. All that Shaurya Doval was prepared to tell The Wire when asked about the source of the foundation’s revenue was: “Conferences, Advertisement, Journal.” He did not answer questions about the origins of this revenue or explain how the India Foundation, which he said was registered as a trust, financed its day-to-day operations, including the rent for its posh premises on Hailey Road in Lutyens’ Delhi, and salaries for its staff.

Doval’s coyness about the India Foundation’s source of funds is not new. In 2015, this was all he was willing to tell the Economic Times:

Asked about funding – the foundation is registered as a trust – Doval said the monthly journal is a big revenue source. “We raise sponsorship and get endowments from various sources. It is all done around the work we do or seminars we organise. We get into partnership with various stakeholders and we do our share and they do theirs.”

With ministers as directors, the source of these “endowments” and “sponsorship” is a matter of great public interest. Yet little or nothing is known, other than what can be gleaned from photographs the India Foundation has published on its website. (For the record, issues of the India Foundation Journal that The Wire reviewed are not exactly brimming with advertisements.)

Boeing, Boeing

For two India Foundation events – on the Indian Ocean and on ‘smart border management’ – the names of sponsors were visible in photographs. Foreign defence and aviation companies like Boeing and the Israeli firm Magal, for instance, as well as foreign banks like DBS, and many private Indian companies are listed as sponsors, though the nature of this sponsorship – how much was paid and to whom, the India Foundation or a ‘partner’ – is not known.

The Wire wrote to the four ministers who serve as directors about the propriety of the India Foundation hosting events funded by donations or sponsorship from companies that may have business matters with their ministries.

“Would you accept that there is a conflict of interest involved in you serving as a director on a foundation that receives funding, directly or indirectly, from foreign companies,” The Wire asked Nirmala Sitharaman, “especially those that have dealings with ministries you have handled such as commerce and industry, and now defence?” Similar questions were put to Prabhu, Akbar and Sinha. Till the time of publication, none of them chose to reply.

“It is certainly avoidable”, a former defence secretary told The Wire when asked about the propriety of a defence minister serving as a director of a foundation that received financial support from a company with which the ministry had dealings.

In May this year, the Central Bureau of Investigation registered a preliminary inquiry in to India’s purchase of Boeing aircraft during the Manmohan Singh government’s tenure. “The allegations relate to purchase of 111 aircraft for national airlines costing about Rs 70,000 crore to benefit foreign aircraft manufacturers. Such a purchase caused an alleged financial loss to the already stressed national carriers,” CBI spokesperson R.K. Gaur was quoted by PTI as saying. Sinha, a director of the foundation, is minister of state for aviation and there would appear to be a clear conflict of interest in being part of a think tank that solicits funds from a company whose aircraft sales are part of an investigation.

The Wire asked a former cabinet secretary about the propriety of ministers serving as directors on the board of the India Foundation. “If the ministers are directors on the foundation and the foundation holds conferences relating to their subjects – such as what sort of defence acquisition strategy should India have – then there is clear conflict of interest and this is best avoided,” he said, adding, “Even companies funding the foundation can involve conflict of interest if the conferences relate to policy which the corporates have an interest in.”

Charter “does not include lobbying’, says Doval

The India Foundation describes itself officially as “an independent research centre focussed on the issues, challenges and opportunities of the Indian polity” but Shaurya Doval, in a video interview, makes no bones about the fact that the foundation “works very closely with the BJP and the government in terms of many aspects of our policy formulation.”

This admission could be an effort at transparency by the head of a think-tank – or an advertisement of proximity to power by someone in the business of ‘corporate finance and advisory’, which may help explain why the interview is posted on the website of Gemini Financial Services.

Doval, who earlier ran the private equity firm Zeus Capital, merged his company to form Gemini Financial Services in 2016. GFS’s chairman is Prince Mishaal Bin Abdullah Bin Turki Bin Abdullaziz Al-Saud, a member of the Saudi ruling family and son of Prince Abdullah bin Turki bin Abdulaziz Al-Saud.

“We get involved as strategic advisers for our core relationships on a case-by-case basis,” Gemini’s home page tells prospective clients, adding: “Typically these are non-traditional situations involving matters such as corporate dispute resolution, entry into (or exit from) new/difficult markets and joint ventures.”

Given Gemini’s mandate, The Wire asked Doval whether there is a conflict of interest in his role as director of the India Foundation – where he clearly has privileged access to cabinet ministers and senior government officials, many of whom make regular appearances at ‘breakfast meetings’ and other events organised by the think-tank – and as partner in a firm that deals with foreign and domestic investors.

“There is no conflict of interest as India Foundation does not conduct any commercial transactions either on its own or on behalf of anybody,” he insisted, adding, “India Foundation is a think tank which has been around since 2009. Its activities include: research, convening and dissemination of a point of view on issues of national importance. It’s charter does not include lobbying or any such related activities.”

While the foundation per se may not engage in lobbying, its events are clearly structured around the promise of getting corporates and other “stakeholders” in the same room as key officials. Those officials are likely to clear their schedules in response to an India Foundation invitation precisely because of its clout in the highest levels of government. Consider this pitch from the promotion brochure for an India Foundation event on ‘smart border management’ held in association with FICCI: “Whom do you Expect to Meet” it asks prospective clients in a somewhat ungrammatical manner, before proceeding to list the full range of ministries and departments that are going to be represented.

Government officials and private sector players interact with each other at conferences and events all the time. But when ministers are directors, it gives the India Foundation an added edge, raising the question of whether ministerial office is being used to boost the credentials and clout of a think-tank that makes no bones about its political affiliation.

‘Indian nationalist perspective’, with foreign funds?

According to its website, the India Foundation “seeks to articulate Indian nationalistic perspective (sic) on issues. India Foundation’s vision is to be a premier think tank that can help understand the Indian civilisational influence on our contemporary society.” Like other NGOs that the BJP and the Modi government often accuse of being “anti-national”, however, the India Foundation also relies on foreign money for its activities.

Given India Foundation’s status as a trust – i.e. a non-governmental organisation – its use of foreign contributions is regulated by the Foreign Contributions Regulation Act (FCRA).

Though Doval, Madhav and the four minister-directors chose not to answer The Wire‘s queries on the foundation’s foreign receipts, the ministry of home affairs’s run fcraonline.nic.in website confirmed that India Foundation has a valid FCRA certificate valid until 2022 and that this was “renewed” on June 6, 2017.

The FCRA website does not indicate when the India Foundation was first granted an FCRA certificate. The reference to “last renewed date” indicates the foundation had FCRA clearance before but a search of the database of mandatory “foreign currency (FC) return” filings by all NGOs with FCRA licenses for the past four financial years drew a blank for Shaurya Doval’s India Foundation. There is an India Foundation shown for each of the years but that is a trust run by Ambassador Suryakanti Tripathi, registered in 2004 with its activities focused on providing food and shelter for street children and health care for the poor.

Assuming the FCRA website has erroneously described the India Foundation certificate as a renewal – one chartered accountant that The Wire consulted averred that the certificate is likely to be a new one based on the serial number – the absence of FC returns is not a problem. But a new FCRA registration does raise questions about how the NGO has been able to draw on foreign contributions until now. The MHA has a provision for NGOs to get “prior permission” to use foreign funds for specific activities but the FCRA websites database listing the grant of such permissions for the Delhi region drew a blank for the India Foundation up to 2015, the last year for which data is available.

The Wire asked Shaurya Doval for details of the India Foundation’s FCRA application and whether it had received any foreign money through the “prior permission” route on the assumption the FCRA database is incomplete. But he did not answer.

NGOs sometimes receive foreign payments via commercial service contracts, but Doval, in an earlier reply had said the India Foundation “does not conduct any commercial transactions,” which would appear to foreclose that route as well.

At a time when the Modi government has used violations of the FCRA – real or imagined – to freeze the bank accounts of NGOs, the fact that a think-tank whose directors include ministers and a senior BJP leader is not being transparent about its own use of foreign funds is likely to invite charges of double standards.

Silence from PMO

The Wire asked the prime minister’s principal secretary, Nripendra Misra, if he and Modi had taken note of the potential conflict of interest of the directors who double up as ministers and the fact that Shaurya Doval’s father is a top official in the PMO whose remit may include being part of deliberations that concern decisions involving companies that may have sponsored India Foundation events. Again, no answer was forthcoming.

Besides, the four ministers, Madhav and Doval, other directors of the India Foundation are drawn from the inner circle of the BJP establishment – Swapan Dasgupta, former columnist and Rajya Sabha member in the nominated quota, Shakti Sinha, retired IAS official and now director of the Nehru Memorial Museum and Library, and A. Surya Prakash, chairman of the Prasar Bharti board. Besides these, the other directors are Dhruv C. Katoch, former director of the Indian Army’s think tank Centre for Land Warfare Studies, Alok Bansal, a former navy officer who worked at the IDSA earlier, Ashok Mittal who describes himself as the managing director of a student mentoring company, Chandra Wadwa, ex president of the ICWA, and Binod Bawari, chairman of Bawri group, Kolkata.

Swati Chaturvedi is a Delhi-based journalist

Note: In an earlier version of this article, Prince Mishaal Bin Abdullah Bin Turki Bin Abdullaziz Al-Saud was wrongly identified as a son of the late King Abdullah. He is, in fact, the son of Prince Abdullah bin Turki bin Abdulaziz Al-Saud.