Restructuring and Insolvency Regimes in South East Asia

CONTENTS

INTRODUCTION 3

PART I – Cambodia, Myanmar, Laos,

Philippines and Vietnam 4

PART II – Thailand, Malaysia, Indonesia and Singapore 16 KEY CONTACTS 24

OUR REGIONAL OFFICES 25 DISCLAIMER 26

INTRODUCTION

As business and commerce becomes increasingly cross-border in nature, it is important for businesses to have knowledge of restructuring and insolvency regimes of foreign jurisdictions. This is particularly relevant in the Southeast Asia region, given the close connection and links amongst the Southeast Asian states.

In this publication, we take a broad look at the key areas of interest in the restructuring and insolvency regimes across the region. The comparative overview covers various differences and similarities in the respective restructuring and insolvency frameworks in these jurisdictions.

Rajah & Tann Asia, as a regional network of law firms, has an established presence across Southeast Asia. Our regional offices have the requisite restructuring and insolvency expertise to assist with your queries and restructuring and insolvency needs across these jurisdictions.

This publication is up to date as of September 2020.

PART I – Cambodia, Myanmar, Laos, Philippines and Vietnam

Areas Cambodia Laos Myanmar Philippines Vietnam

Rehabilitation  A plan of compromise  Upon the Court  Rehabilitation  Court-supervised  Court-convened and can be proposed by accepting the petition process can be voluntary rehabilitation Creditors’ Meeting Restructuring the debtor, the or request for initiated (i) voluntarily (court administration). (court administration). Regime administrator or a adjudication and by the company; (ii) creditor (court declaration of by a secured creditor  Court-supervised administration). bankruptcy, the debtor who holds security involuntary may apply for Court over all or majority of rehabilitation (court  A plan of compromise sanctioned mediation. the property of the administration). needs to be Mediation is kept company; and (iii) by  Pre-negotiated submitted to the confidential. an order of the Court. rehabilitation (court Court no more than administration). seven days before  The Asset Supervision Committee or a the first creditors’  Informal restructuring creditor representing rehabilitation plan meeting. ¼ of the total debt (debtor in  Creditors vote on a may call a creditor’s possession). plan of compromise meeting. The creditor’s meeting at the creditors’ shall consider and, if meeting after an approved, propose to insolvency the Court the proceeding is open. rehabilitation plan for consideration.  A plan of compromise can only be implemented if

Areas Cambodia Laos Myanmar Philippines Vietnam adopted by the creditors.

Eligible  All debtors with the  All enterprises which  All companies  Sole proprietorships  Enterprises and Companies exception of regulated are insolvent, and incorporated in registered with the cooperatives based in entities under the Law which are located or Myanmar. Department of Trade the territory of Vietnam on Banking, Law on conduct business in and Industry (DTI), Non-Governmental the Lao People’s partnerships Securities, and Law Democratic Republic, registered with the on Insurance, unless regardless of whether Securities and there is a provision their activities are Exchange under any of these conducted by Commission (SEC), laws allowing for it. themselves or by and corporations representative(s). organized and existing under

Philippine law. o Banks, insurance companies, pre- need companies and national and local government agencies or units are not covered o Government financial institutions other than banks and government- owned or- controlled corporations are covered unless © Rajah & Tann Asia 5

Areas Cambodia Laos Myanmar Philippines Vietnam their charters provide otherwise

Scope of  A stay is imposed by  The law states that the  During the Rescue  For Court-supervised  Court-convened Moratorium the Court once the Court may impose Stage of the rehabilitation plans – Creditors’ Meeting – insolvency proceeding temporary measures rehabilitation process, The moratorium (i) Includes the is open and shall be to protect the debtor. the rehabilitation suspends all actions suspension of (i) civil effective from the We understand this to manager has a period or proceedings, in execution pertaining to beginning until the end include a moratorium. of three months to court or otherwise, for assets and civil cases of the insolvency work out a viable the enforcement of related to the financial proceeding. No action,  The Asset Supervision rehabilitation plan and claims against the obligations in which

proceedings, Committee as part of present it before a debtor; (ii) suspends the insolvent entity is a its supervision could execution of any kind meeting of the all actions to enforce litigant, and (ii) by or on behalf of any propose to the Court company’s creditors any judgment, competent authorities creditor may be to decide on the use for approval. attachment or other from handling of necessary and commenced or provisional remedies collateral for secured continued against the urgent measures on a  During the against the debtor; (iii) debts of the insolvent temporary basis to aforementioned debtor and the assets prohibits the debtor entity. of the estate. protect the assets of period, a moratorium from selling,

the debtor enterprise. is imposed on any encumbering,  One exception to the actions or legal transferring or stay is when it is in proceedings (including disposing in any the best interest of arbitration) being manner any of its the estate, the carried out against the properties except in

administrator may company, or actions to the ordinary course of enforce any security allow a creditor to business; and (iv) against the company. foreclose a security prohibits the debtor No step can be taken from making any interest on an asset. without the leave of payment of its the Court. liabilities outstanding as of the commencement date © Rajah & Tann Asia 6

Areas Cambodia Laos Myanmar Philippines Vietnam Scope of except as may be Moratorium provided herein. The moratorium shall not apply to: o cases pending appeal before the

Supreme Court;

o cases pending before a specialized court capable of resolving the claim more quickly, fairly and efficiently than the Court;

o enforcement of claims against sureties and other persons liable with the debtor, and third party or accommodation mortgagors; o actions of customers or clients of a securities market participant to recover monies and securities entrusted to the debtor in the © Rajah & Tann Asia 7

Areas Cambodia Laos Myanmar Philippines Vietnam Scope of ordinary course of Moratorium business; o actions of a licensed broker or dealer to sell pledged securities

of a debtor pursuant to a securities pledge or margin agreement for the settlement of securities transactions;

o clearing and settlement of financial transactions through the facilities of a

clearing agency;

o criminal actions against the individual debtor or owner, partner, director or officer

of a debtor; and

o actions to preserve a claim against the debtor or to toll the running of the © Rajah & Tann Asia 8

Areas Cambodia Laos Myanmar Philippines Vietnam Scope of prescriptive period Moratorium to file the claim.  For pre-negotiated restructuring rehabilitation – The Court may issue a suspension or stay order upon receipt of a valid petition regarding pre-negotiated rehabilitation.  For informal restructuring rehabilitation – The debtor and creditors may agree to a standstill period of 120 days pending negotiation and finalization of the out- of-Court or informal restructuring/workout agreement or rehabilitation plan. The standstill period shall be binding on all creditors, subject to compliance with certain requirements.

Areas Cambodia Laos Myanmar Philippines Vietnam

Invocation of  The stay is automatic  The Court may, on the  The moratorium is  For Court-supervised  Automatically after five Moratorium upon the opening of application of the automatic. Any action rehabilitation plans working days from an insolvency debtor, impose sought to be initiated and pre-negotiated Court’s acceptance of proceeding by the temporary measures against the company restructuring the petition to initiate Court. to protect the debtor. during the Rescue rehabilitation plans – bankruptcy process. Stage of the Automatic moratorium  The Asset Supervision rehabilitation process, upon the Court’s Committee, appointed can only be initiated determination that the by the court following with the permission of petition is sufficient in a petition for the Court. form and substance. bankruptcy, may propose to the Court  For informal measures to protect restructuring the assets of the rehabilitation – debtor. Subject to agreement of the standstill period among negotiating parties. The parties may request the Court’s assistance to enforce the standstill period.

Territorial  Silent.  Silent.  Local effect: There is  The Model Law on  Local effect: There is Effect of no indication that the Cross-Border no indication that the Moratorium moratorium applies to Insolvency of the moratorium as actions initiated United Nations Center prescribed under against the debtor in a for International Trade Vietnam’s Law on foreign jurisdiction. and Development was Bankruptcy applies to adopted. Local courts actions taken against a may cooperate with debtor and its property foreign courts for in a foreign jurisdiction. purposes of information or © Rajah & Tann Asia 10

Areas Cambodia Laos Myanmar Philippines Vietnam assistance subject to compliance with certain conditions.

Rescue  Cambodian Law on  Laotian law provides  The Myanmar  Rehabilitation plans:  Vietnamese law Financing Insolvency is silent on for increase in capital Insolvency Law does No specific rescue permits the company rescue financing. in the company during not have any financing provisions. to submit to the Court However, the the period of the provisions that deal Having said that, the its plans to resume its administrator is implementation of the with rescue financing. rehabilitation plan, operations, in which provided with the rehabilitation plan as should provide how solutions for the rights to prepare and proposed by the the debtor will be resumption may propose a plan of creditors meeting. rehabilitated which include, among others, compromise under may include debt raising capital. Court- Article 23 of the Law  The increase of capital forgiveness, debt convened creditors’ on Insolvency which may be done via: rescheduling, meeting will decide plan may include such o Increasing values reorganization or whether to agree to proposal for of the shares quasi-reorganization, such plans. consideration and dacion en pago, debt- adoption by the o Making a creditor equity conversion and  The Law on creditors. a shareholder sale of the business Bankruptcy does not specify the method by Increase in the (or parts of it) as a o which capital can be number of shares going concern, or setting-up of a new raised, and it would be o Loans business entity or subject to the proposal other similar by the company (e.g.,  However, the law is issuance of new silent as to whether arrangements as may be necessary to shares). The law is priority can be also silent as to accorded to such an restore the viability of the debtor. whether priority can be increase in capital. accorded to an increase in capital.

Areas Cambodia Laos Myanmar Philippines Vietnam

Approval of  The plan of  Court-ordered  The rehabilitation plan  Court-supervised  Court-convened Plan compromise is made mediation – In the is placed before the rehabilitation (both creditors’ meeting – available for review event the creditors creditors in a meeting voluntary and Creditors attending and approval by the and debtor enterprise convened by the involuntary): The must represent 51% of creditors at the first can agree on rehabilitation rehabilitation plan the total unsecured creditors’ meeting or settlement, the manager. must be approved by debts and any other meetings for settlement would be all classes of representatives of at this purpose. approved.  The plan is deemed to creditors. The least 65% of the total

be approved if a rehabilitation plan is unsecured debts must  Creditors are majority of creditors considered approved vote to approve the classified into groups vote to approve the by a class of creditors plan.  Creditor’s meeting by plan. The requisite (secured creditors, Asset Supervision if members of a class state, unsecured majority is defined as holding more than Committee – Creditors both: creditors) and shall may resolve to 50% of the total vote in accordance rehabilitate the o creditors the values claims of that class with the amounts of of whose claims approve the plan. enterprise with a equal or exceed debt owed to them. resolution at the o The Court may meeting where there 50% of the total of confirm the  Approval shall be has been a vote of claims of creditors rehabilitation provided either: creditors representing voting at the plan, despite its at least 2/3 of the total meeting; and o By creditors of all rejection by the debt. groups with each creditors in number creditors, if all of o group of creditors that equal or exceed the following having right of 50% of the total requirements are claim which is no number of creditors present: (i) the less than ¾ of the voting at the plan complies with legal right of claim of all meeting. creditors present at requirements; (ii) the meeting the rehabilitation approving; or receiver recommends the o At least by one confirmation of group of creditors the plan; (iii) the © Rajah & Tann Asia 12

Areas Cambodia Laos Myanmar Philippines Vietnam Approval of having claims no shareholders, Plan less than ¾ of the owners or total claims of all partners lose at creditors at the least their meeting. controlling interest as a result of the plan; and (iv) the plan will likely provide the objecting class with compensation which has a net

present value greater than that which they would have received if the debtor were under liquidation.

 Pre-negotiated rehabilitation – approved by (i) debtor; (ii) creditors holding at least 2/3 of the total liabilities; (iii) creditors holding 50% of secured claims; and

(iv) creditors holding 50% of unsecured claims.

 Informal restructuring rehabilitation – approved by (i) debtor; © Rajah & Tann Asia 13

Areas Cambodia Laos Myanmar Philippines Vietnam Approval of (ii) creditors holding Plan 67% of the secured obligations; (iii) creditors holding 75% of the unsecured obligations; and (iv) creditors holding 85% of the total liabilities.

Cram-Down  None.  A resolution of a  The rehabilitation plan  Restructuring plan  There are no cram- creditor’s meeting is binding on all shall have the same down procedures shall be effective unsecured creditors legal effect as a plan prescribed. when there has been whether or not they approved under a a vote of creditors were present at the Court-supervised representing at least creditors meeting or if rehabilitation. 2/3 of the total debt. they voted in favour of the plan.  Secured creditors are not prevented from realising or otherwise dealing with the secured property unless the rehabilitation plan covers such secured property and the secured creditor voted in favour of the plan.

Areas Cambodia Laos Myanmar Philippines Vietnam

 For Court-supervised Approval of  Not possible.  The approval of plan  The approval of the  The approval of plan is and pre-negotiated is contingent on a plan is not possible contingent on approval Plan without rehabilitation, the successful mediation without approval of the of the same at a Creditors’ approval of a plan is or creditors' meeting. creditors at the creditors' meeting. Meeting contingent on a creditors' meeting. creditors’ meeting.

 For informal restructuring rehabilitation plan, there is no specific requirement for a creditors’ meeting.

PART II – Thailand, Malaysia, Indonesia and Singapore

Areas Thailand Malaysia Indonesia Singapore

Rehabilitation  Reorganisation under  Scheme of Arrangement  Legal debt moratorium or  Judicial Management (judicial and section 90/12 of the (debtor in possession). suspension of payment managers appointed). Restructuring Bankruptcy Act 1940 (as proceedings (“PKPU”) (joint  Corporate Voluntary  Scheme of Arrangement Regime amended) (court administration). administration). Arrangements (debtor in (debtor in possession). possession).  Scheme in Judicial  Judicial Management (court Management (hybrid). administration).  Conservatorship (government administration).

Eligible  Reorganisation - A limited  Scheme of Arrangement –  Indonesian companies and  Singapore companies. Companies company, a public company Any corporation liable to be non-Indonesian companies or any juristic person as wound up under the having domiciled in  Foreign companies with specified in the ministerial Insolvency Act (“Act”) (s 365 Indonesia. substantial connection with Singapore. Factors showing regulations. of the Act). This includes foreign companies since  If the debtor is a bank, the substantial connection can

“corporation” is defined as PKPU petition can only be include: Singapore is the centre any body corporate formed filed by Bank Indonesia. of main interests of the company (“COMI”); business or or incorporated or existing in  If the debtor is a securities Malaysia or outside Malaysia substantial assets in Singapore; company, stock exchange, company is a registered foreign and including any foreign clearing and custodian company (s 3 of the Act). company; choice of Singapore institution, settlement and law as governing or dispute depository institution, the  Corporate Voluntary resolution law for loan or Arrangements – Private PKPU petition can only be transaction; submission to

companies incorporated filed by the Financial Singapore court for dispute Services Authority (Otoritas under the Act except resolution of loan or companies that are holders Jasa Keuangan). transaction. © Rajah & Tann Asia 16

Areas Thailand Malaysia Indonesia Singapore

Eligible of licenses issued under the  If the debtor is an insurance Companies Financial Services Act company, reassurance ("FSA") and the Capital company, pension funds, or Markets and Services Act state-owned enterprise 2007 ("CMSA"). Any engaged in the sectors of company that has created a public interest, the PKPU charge over its assets is also petition can only be filed by ineligible (s 395 of the Act). the Ministry of Finance.  Judicial Management – Companies incorporated under the Act except companies holding licenses under the FSA and holders of capital markets and securities industry licenses under the CMSA (s 403 of the Act).  Conservatorship – Corporate entities indebted to a financial institution which is a member institution under the deposit insurance scheme administered by the Malaysia Deposit Insurance Corporation.

Areas Thailand Malaysia Indonesia Singapore

Scope of  Reorganisation - Moratorium  Scheme of Arrangement –  PKPU – Temporary  Judicial Management and Moratorium or “automatic stay” On application by the moratorium arising upon Scheme of Arrangement – preventing, for example, company or a member or application for a suspension Moratorium against all security creditors from pursuing creditor of the company, the of payments (45 days) which and quasi-security enforcement claims against the debtor Court may grant a may be extended to a and legal proceedings, but not and restricting the creditors’ moratorium restraining permanent moratorium (not against the exercise of right to enforce security. The further proceedings in any exceeding 270 days). The contractual rights and set-offs. automatic stay applies to action or proceeding against moratorium stays the rights

both civil claims and the company for an initial of secured creditors to  Scheme of Arrangement – If debtor company obtains a arbitration proceedings. The period of not more than enforce their interest, stays civil or arbitration three months, which may be all legal proceedings and moratorium, the subsidiary, proceedings that have renewed for a period of up enforcement processes and holding company or ultimate holding company of debtor already been submitted to to a further nine months. In lift all attachments over the arbitration will be addition, the company is not debtor and its assets. company may also apply for moratorium, if it plays a suspended. permitted to dispose of any property or to acquire new necessary and integral role in property other than in the the scheme and its creditors will not be unfairly prejudiced. ordinary course of business.  Corporate Voluntary Arrangements – Initial 28- day moratorium that commences when the

Corporate Voluntary Arrangement documents are lodged with the High Court. During the moratorium, no winding up or judicial management process may be commenced, no right to enforce a security or right of re-entry may be exercised and no other proceedings, execution, distress or other © Rajah & Tann Asia 18

Areas Thailand Malaysia Indonesia Singapore Scope of legal process may be Moratorium commenced or continued against the company or its property.  Judicial Management – During the period between the application being made and either a judicial management order or dismissal of the application being made, the company may not be wound up, no steps may be taken in security and quasi-security enforcement and legal proceedings. Following the granting of the order, in addition to the above, no receiver or manager shall be appointed and no steps shall be taken to transfer any share of the company or alter the status of any member for the duration of the judicial management order.  Conservatorship – Initial moratorium for 12 months which may be extended. No legal proceedings or insolvency processes of any kind can be initiated or continued, no assets may © Rajah & Tann Asia 19

Areas Thailand Malaysia Indonesia Singapore be repossessed, no debts can be set off and no security can be enforced.

Invocation of  Reorganisation – Automatic  Scheme of Arrangement –  PKPU – Automatic on  Judicial Management – Moratorium from the day on which the Not automatic. Granted on application for suspension of Automatic upon application, and Court makes an order the application by company, payments for duration of automatic upon company being accepting the application for member or creditor. PKPU. placed in judicial management. business reorganisation until the expiration of the period  Corporate Voluntary  Scheme of Arrangement – for implementation of the Arrangements – Automatic Automatic 30-day moratorium reorganisation plan, or the upon lodgement of upon application, which may be date on which the Corporate Voluntary extended by the Court. reorganisation plan is Arrangement documents accomplished successfully, with the High Court. or the date on which the  Judicial Management – Court (i) subsequently Automatically comes into dismisses the application for being upon application for business reorganization; (ii) judicial management. disposes of the case; (iii) repeals the order for the  Conservatorship – Automatic reorganization; (iv) cancels upon appointment of the reorganization; or (v) conservator. places the debtor under absolute receivership.

Territorial  Reorganisation - The Thai  Scheme of Arrangement –  PKPU – Local.  Judicial Management – Effect of Courts only exercise Local. generally local. Moratorium jurisdiction over the assets of the debtor that are situated  Corporate Voluntary  Scheme of Arrangement – within Thailand. arrangements – Local. moratorium may restrict acts outside Singapore by persons  Judicial Management - Local.

Areas Thailand Malaysia Indonesia Singapore

 Conservatorship – Local. subject to jurisdiction of Singapore Court.

Rescue  Reorganisation – None.  Scheme of Arrangement –  PKPU – None.  Judicial Management and Financing None. Scheme of Arrangement – Court may order rescue  Corporate Voluntary financing to be given priority Arrangements – None. over preferential and unsecured  Judicial Management – debts, or secured against None. assets as a subordinate, equal or superior charge against  Conservatorship – None. company’s assets.

Approval of  Reorganisation plan must be  Scheme of Arrangement -  PKPU – Approval by simple  Statement of proposals in Plan approved by: Approval by 75% of the total majority in number and at Judicial Management – value of creditors or class of least 2/3 in value of each Approval by simple majority of (1) Creditors: creditors and members, or class of secured and creditors in number and value. Approval by each and class of members present unsecured creditors who o  Scheme of Arrangement – every group of creditors and voting at the court- attend and vote at the Approval by 75% or more in by a majority of the convened class meeting, meeting. either in person or by proxy. value and 50% or more in creditors in the meeting number of creditors in each with an amount of debts  Corporate Voluntary class of creditors, but the Court not less than 2/3 of the Arrangements – Approval by can vary the latter requirement. total debts of the a majority in excess of 50% creditors present and of members and 75% in casting votes at the value of creditors. meeting, either in person or by proxy, or  Judicial Management – Approval by 75% in value of Approval by at least one o creditors whose claims have group of creditors by a been accepted by the majority of the creditors in the meeting of that © Rajah & Tann Asia 21

Areas Thailand Malaysia Indonesia Singapore Approval of group of creditors with judicial manager, present in Plan an amount of debts not person or by proxy. less than 2/3 of that group of creditors  Conservatorship – a present and casting majority in value of the votes at the meeting, secured creditors, present either in person or by and voting, either in person proxy and, upon or by proxy or the Malaysia counting the aggregate Deposit Insurance amount of debts of the Corporation approves the creditors approving the proposal and there are no reorganisation plan at secured creditors of the the meeting of all affected company known to groups of creditors, not the conservator. less than 50% of the amount of debts of the creditors present and casting votes at the meeting; and (2) the Court.

Cram-Down  Despite objections, the Court  Scheme of Arrangement –  PKPU – The Court can order  Statement of proposals in is empowered to approve the There are no cram-down cram down if (a) the Judicial Management – No.

reorganisation plan if the procedures prescribed. proposed composition plan  Scheme of Arrangement – Yes, requirements under the law has been proposed and are met.  Corporate Voluntary approved based on the Court can order cram-down Arrangements – There are required voting (as above) where requisite approval has  The reorganisation plan no cram-down procedures been given by at least one class threshold; and (b) the plan approved by the Court shall prescribed. has been ratified by the of creditors, and there is one or bind the creditors entitled to more dissenting class, provided Court. apply for the repayment of  Judicial Management – (i) the requisite approval There are no cram-down debt in the business  Secured creditors whose threshold is reached for all procedures prescribed. reorganization and the claims have been verified creditors as a whole; (ii)there is creditors entitled to receive © Rajah & Tann Asia 22

Areas Thailand Malaysia Indonesia Singapore

Cram-Down the repayment of debt under  Conservatorship – There are and voted against the no unfair discrimination; and (iii) the business reorganization. no cram-down procedures composition plan in the scheme is fair and equitable. prescribed. creditors' meeting would not be bound by the Court- approved composition plan and will be compensated for the loan or the security value (whichever is lower).

Approval of  None.  Scheme of Arrangement –  PKPU – None.  Judicial Management - Plan without None. Statement of proposals in Creditors’ Judicial Management – requires  Corporate Voluntary a creditors' meeting Meeting arrangements – None.  Scheme of Arrangement – Yes,  Judicial Management – possible under a prepack None. scheme.  Conservatorship – Yes, but only where there are no secured creditors.

KEY CONTACTS

Sim Kwan Kiat Dr. Min Thein T +65 6232 0436 T: +959 7304 0763 E [email protected] E: [email protected]

Wilson Zhu Chester Toh T +65 6232 0490 T +65 6232 0220 E [email protected] E [email protected]

Sheila Ng U Kyaw Swa Myint T +65 6232 0590 T: +959 7304 0763 E [email protected] E: [email protected]

Heng Chhay T: +855 23 963 112/113 Ben Yap E: [email protected] T: +632 894 0377 to 79 E: [email protected]

Vladi Miguel Lazaro Ibrahim Assegaf T: +632 894 0377 to 79 T: +62 21 2555 7825 E: [email protected] E: [email protected]

Ahmad Maulana T: +62 21 2555 7816 E: [email protected]

Lee Hock Chye Pakpoom Suntornvipat T: +60 3 2273 1919 T: +66 2 656 1991 E: [email protected] E: [email protected]

John Mathew Dr. Quang Chau T: +60 3 2273 1919 T: +84 28 3821 2382 E: [email protected] E: [email protected]

Heng Yee Keat Logan Leung T: +60 3 2273 1919 T: +84 28 3821 2382 E: [email protected] E: [email protected]

OUR REGIONAL OFFICES

Rajah & Tann Singapore LLP Christopher & Lee Ong T +65 6535 3600 T +60 3 2273 1919 F +65 6225 9630 F +60 3 2273 8310 sg.rajahtannasia.com www.christopherleeong.com

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Assegaf Hamzah & Partners R&T Asia (Thailand) Limited T +66 2 656 1991 Jakarta Office F +66 2 656 0833 T +62 21 2555 7800 th.rajahtannasia.com F +62 21 2555 7899

Surabaya Office T +62 31 5116 4550 Rajah & Tann LCT Lawyers F +62 31 5116 4560 www.ahp.id Ho Chi Minh City Office T +84 28 3821 2382 F +84 28 3520 8206

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