Yes. A Promoter group is relationship-based definition rather than one with direct shareholding.
Even if no shares a held, the relationship does very much exist insofar as potential for conflicts of interest arises.
Entities should therefore be considered in the Promoter category directly as a related party for RPT compliances even if not holding any share(s) in the listed entity but are merely a part of the Promoter Group category.
Affinisio(RPT) automatically and intelligently describes these relationships across all levels with in-built multi-level tracking and tracing..
