Kapital Leasing Compliance Policy is based on a crystal clear principle – the reputation is a key asset!
We consider Complience as more than just administrative procedure; we are carrying out a background check on all our counterparties.
We developed our Policy based on Basel II, FATF and Securities Regulations.
We see it as a way to minimise the possibility of Kapital Leasing becoming a party to money laundering, fraud, financial or economic crime etc.
‘KYC’, knowing our customers means acquiring and monitoring of relevant documents to verify the identity of our prospects, understanding the customer's business - including the source of wealth and the purpose of transactions.
This process is called Customer Due Diligence (questionnaires attached). It means 3 simple steps:
Identification and verification; monitoring; acceptance or rejection of the counterparty.
Due Diligence Questionnaire
- Full legal name and principal place of business.
- History of incorporation.
- What is the source of Capital and Income.
- Group structure and detailed management structure.
- Percentage of common equity held by senior management.
- UBO and shareholders holding more that 5%.
- Is it publicly listed company (what exchange)?
- Breakdown of sales by product and geographic region.
- Brand recognition.
- Core rivals, their market shares.
- Industry’s entry barriers.
- Government regulation and compliance (rights, permits, certificates, licenses etc.).
- Selling terms per customer category.
- Buyers’ concentration; possibility of finding alternative buyers and markets.
- Suppliers purchase and delivery terms.
- Supplier concentration, possibility for substitution, breakdown of import and local resources.
- Current auditors; changes of auditors, if any; usual time of publication of audited financial statements.
- Existence of the tax pledge, last tax inspection’s outcome.
- Availability of the internal audit function within the company.
- Pricing system, including internal transfer pricing.
- Analysis of the company’s cost of sales between fixed and variable costs.
- Foreign exchange risk: currency of receivables vs. currency of payables.
- Is the budgeting process formalized and actual vs. budget analysis regularly undertaken?
- Capital base of the company; planned capital increases.
- Dividend policy and history of dividend payments.
- Policy for setting and updating counterparty limits on the customers.
- Criteria for the selection of regional distributors and dealers.
- Description of the production process, cyclical nature, capacity utilization.
- Logistic company responsible for transportation of raw materials and finished products.
- Name of the insurer(s).
- Detail on storage facilities used (owned/rented, insured).
- Current and historic number of employees.
Attachments
1. An excerpt from the Register showing current shareholders with a stake > 5%.
2. List of consolidated and unconsolidated subsidiaries.
3. Audited or company prepared financial statements over the last 3 financial years, plus explanation of
- related party balance sheet and income statement items
- off balance sheet commitments issued/receive
- breakdown of fixed asses by category including estimated useful lives, average age and scrap value by category
- breakdown of investments by type and purpose
- breakdown of inventory by type, age, and location
- breakdown of receivables by customer, age; detail on overdue and doubtful receivables
- detail on export VAT repayable
- list of bank accounts
- list of bank loans: name of the lender, purpose of the loan, principal amount, amortization schedule, start and maturity date of the loan, current outstanding, past-due amounts, covenants of the loan agreements, collateral given.
5. Detail on insurance policies held by the company: insurer, tenor, type of insurance cover, amount insure
End of Questionnaire
Print version