MIRA INFORM REPORT

Report Date :

21.02.2011

IDENTIFICATION DETAILS

Name :	GCL POLY (SUZHOU) ENERGY LTD.

Registered Office :	Room 1901, 24# Building, Times Square, Huachi Street, Suzhou Industrial Park Zone, Jiangsu Province, 215021 Pr

Country :	China

Date of Incorporation :	23.03.2010

Com. Reg. No.:	320000400004133

Legal Form :	Chinese-Foreign Equity Joint Venture Enterprise

Line of Business :	International Trade

RATING & COMMENTS

MIRA’s Rating :

RATING		STATUS	PROPOSED CREDIT LINE
26-40	B	Capability to overcome financial difficulties seems comparatively below average.	Small

Status :	New Company

Payment Behaviour :	No Complaints

Litigation :	Clear

NOTES :

Any query related to this report can be made on e-mail : infodept@mirainform.com while quoting report number, name and date.

ECGC Country Risk Classification List – June 30, 2010

Country Name

Previous Rating

(01.04.2010)

Current Rating

(30.06.2010)

China

Risk Category	ECGC Classification
Insignificant	A1
Low	A2
Moderate	B1
High	B2
Very High	C1
Restricted	C2
Off-credit	D

Company name & address

GCL POLY (SUZHOU) ENERGY LTD.

room 1901, 24# building, times square, huachi street, suzhou industrial park zone, jiangsu PROVINCE, 215021 PR CHINA

TEL: 86 (0) 512-66967888 FAX: 86 (0) 512-66967712

EXECUTIVE SUMMARY

INCORPORATION DATE : march 23, 2010

REGISTRATION NO. : 320000400004133

REGISTERED LEGAL FORM : Chinese-foreign equity joint venture enterprise

CHIEF EXECUTIVE : MR. zhu gongshan (CHAIRMAN)

STAFF STRENGTH : 80

REGISTERED CAPITAL : CNY 2,000,000,000

BUSINESS LINE : trading

TURNOVER : n/a

EQUITIES : n/a

PAYMENT : AVERAGE

RECOMM. CREDIT RANGE : Moderate amount

MARKET CONDITION : average

FINANCIAL CONDITION : UNDETERMINED

OPERATIONAL TREND : FAIRLY STEADY

GENERAL REPUTATION : AVERAGE

EXCHANGE RATE : CNY 6.58 = USD 1

Adopted abbreviations

ANS - amount not stated

NS - not stated

SC - subject company (the company inquired by you)

NA - not available

CNY - China Yuan Renminbi

SC was registered as a Chinese-foreign equity joint venture enterprise at local Administration for Industry & Commerce (AIC - The official body of issuing and renewing business license) on March 23, 2010.

Company Status: Chinese-foreign equity joint venture enterprise

This form of business in PR China is defined as a legal person. It is a limited co. jointly invested by one or more foreign companies and one or more PR China controlled companies within the territories of PR China according to a certain proportion of capital investment. The investing parties exercise business management, share profits and bear all risks and liabilities of the co. together. The equity joint venture law requires that foreign party contribute not less than 25% of the registered capital, with no maximum. The investing parties are free to agree on method of profit distribution and liabilities bearing according to the proportion of capital investment. Each investing parties contributes funds, tangible assets, technology & etc. The board of directors excises the high authority. The joint venture usually has a limited duration of 10 to 50 years. Enterprise with large investment, long construction periods, low investment returns, introducing of advanced technology & advanced technology products that have good competition position in international market may extend beyond the 50 years limit.

SC’s registered business scope includes investment in the field of foreign enterprises allowed by government; 2. Providing the following services for the invested enterprise according to the written authorization (passed by executive director): A. assisting and acting the invested enterprise to purchase machinery, office equipment, raw materials, components & parts, and sell the products, also provide the after service for the invested enterprise; B. balancing foreign exchange for the invested enterprise under the agreement and supervision of foreign exchange department; C. Providing manufacturing, trading, technology support, staff training, and HR management, etc. D. assisting the invested enterprise to seek loans and provide guarantee; 3. establishing R & D center or department in China to engage in research & development and transfer on new products and high and new technology, and permission of the development, providing related services; 4. providing consulting services for the investor, and related marketing information, investment policies and other consulting services for the related enterprises; 5. wholesale, import and export of polysilicon, silicon, solar cells and modules, photovoltaic materials, solar products and ancillaries.

SC is mainly engaged in international trade.

Mr. Zhu Gongshan has been chairman of SC since 2010.

SC is known to have approx. 80 employees at present.

SC is currently operating at the above stated address, and this address houses its operating office in the industrial zone of Suzhou. Our checks reveal that SC rents the total premise about 500 square meters.

SC is not known to host web site of its own at present.

SC started its normal operation in December of 2010.

No significant events or changes were found during our checks with the local Administration for Industry & Commerce.

MAIN SHAREHOLDERS:

Name % of Shareholding

(Hong Kong) Richmore International Development Limited 25.05

Jiangsu Zhongneng Polysilicon Technology Development Co., Ltd. 43.80

(Hong Kong) GCL Solar Energy Technology Holdings Limited 31.15

HK Richmore International Development Limited:

====================================

Incorporation Date : May 16, 2007

Registration No. : 1133086

Registered Legal Form : Private

Jiangsu Zhongneng Polysilicon Technology Development Co., Ltd.:

=================================================

Address: No. 66 Yangshan Road, Economic Development Zone, Xuzhou, Jiangsu Province

Tel: 86 0516-83152899

HK GCL Solar Energy Technology Holdings Limited:

=======================================

Incorporation Date : November 13, 2006

Registration No. : 1087124

Registered Legal Form : Private

l Chairman:

Mr. Zhu Gongshan, 53 years old with university education. He is currently responsible for the overall management of SC.

Working Experience(s):

From 2010 to present Working in SC as chairman, also working in GCL-Poly Energy Holdings Limited as CEO.

l General Manager:

Mr. Shu Hua, ID# 320602196210222072, 49 years old with university education. He is currently responsible for the daily management of SC.

Working Experience(s):

From 2010 to present Working in SC as general manager, also working in GCL-Poly Energy Holdings Limited as vice CEO.

SC is mainly engaged in international trade.

SC started its normal operation in December of 2010.

SC’s products mainly include: silicon.

SC sources its materials 40% from domestic market, and 60% from overseas market. SC sells 30% of its products in domestic market, and 70% to overseas market, mainly Southeast Asian market.

The buying terms of SC include T/T, L/C and Credit of 30-60 days. The payment terms of SC include T/T, L/C and Credit of 30-60 days.

*Major Customer:

=============

Hyundai Heavy Industries Co.

*Major Supplier:

============

Jiangsu GCL Silicon Material Technology Development Co., Ltd.

SC is known to have 7 subsidiaries at present, and the following are the major ones.

· Jiangsu GCL Silicon Material. Technology Development Co., Ltd.

· Changzhou GCL Photovoltaic Technology Co., Ltd.

Etc.

GCL-Poly Energy Holdings Limited.

===========================

Date of Registration: 12-JUL-2007

Place of Incorporation: Cayman Islands

Company Status: Listed

Active Status: Live

Hong Kong Headquarters Address: Unit 1703B-1706, Level 17, International Commerce Centre, 1 Austin Road West, Kowloon, Hong Kong

Tel.: (852) 2526 8368

Fax: (852) 2526 7638

E-mail: info@gcl-poly.com.hk

Website: http://www.gcl-poly.com.hk

Overall payment appraisal :

( ) Excellent ( ) Good (X) Average ( ) Fair ( ) Poor ( ) Not yet determined

The appraisal serves as a reference to reveal SC's payments habits and ability to pay. It is based on the 3 weighed factors: Trade payment experience (through current enquiry with SC's suppliers), our delinquent payment and our debt collection record concerning SC.

Trade payment experience : A trade enquiry currently conducted with SC's supplier(s) reveal the following:

Supplier A

Products sold: silicon

Date account opened: Since 2010

Line of credit: N/A

Terms: 30-60 days

Average monthly sales: N/A

Current balance: N/A

Rating Key : 3

Any Special Comments: _______________________________________

Payment record keys :

1 = Prompt : Payment made before the credit period expires

2 = As agreed terms : Payment made upon due date

3 = Slightly slow but acceptable : Payment made 5 to 20 days beyond agreed terms

4 = Slow : Payment made 16 to 45 days beyond agreed terms

5 = Poor : Payment made over 45 days beyond agreed terms

6 = No comment : Account is newly opened & record is not yet established

Note : In some instances, payment beyond terms can be the result of disputes over merchandise, lost invoices, disputed accounts & etc.

Delinquent payment record : None in our database.

Debt collection record : No overdue amount owed by SC was placed to us for collection within the last 6 years.

Agricultural Bank of China

AC# 550101048005698

Relationship: Normal.

SC was established in 2010, so its financial reports are not available at present.

SC is considered medium-sized in its line with a short development history. Due to lack of financial statements, we are unable to determine the maximum credit limit for SC. Taking into consideration of SC’s favorable background and market future, we would rate SC as an average credit risk company.

FOREIGN EXCHANGE RATES

Currency	Unit	Indian Rupees
US Dollar	1	Rs.45.18
UK Pound	1	Rs.73.04
Euro	1	Rs.61.43

RATING EXPLANATIONS

RATING		STATUS	PROPOSED CREDIT LINE
>86	Aaa	Possesses an extremely sound financial base with the strongest capability for timely payment of interest and principal sums	Unlimited
71-85	Aa	Possesses adequate working capital. No caution needed for credit transaction. It has above average (strong) capability for payment of interest and principal sums	Large
56-70	A	Financial & operational base are regarded healthy. General unfavourable factors will not cause fatal effect. Satisfactory capability for payment of interest and principal sums	Fairly Large
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory
26-40	B	Capability to overcome financial difficulties seems comparatively below average.	Small
11-25	Ca	Adverse factors are apparent. Repayment of interest and principal sums in default or expected to be in default upon maturity	Limited with full security
<10	C	Absolute credit risk exists. Caution needed to be exercised	Credit not recommended

This score serves as a reference to assess SC’s credit risk and to set the amount of credit to be extended. It is calculated from a composite of weighted scores obtained from each of the major sections of this report. The assessed factors and their relative weights (as indicated through %) are as follows:

Financial condition (40%) Ownership background (20%) Payment record (10%)

Credit history (10%) Market trend (10%) Operational size (10%)

PRIVATE & CONFIDENTIAL : This information is provided to you at your request, you having employed MIPL for such purpose. You will use the information as aid only in determining the propriety of giving credit and generally as an aid to your business and for no other purpose. You will hold the information in strict confidence, and shall not reveal it or make it known to the subject persons, firms or corporations or to any other. MIPL does not warrant the correctness of the information as you hold it free of any liability whatsoever. You will be liable to and indemnify MIPL for any loss, damage or expense, occasioned by your breach or non observance of any one, or more of these conditions

This report is issued at your request without any risk and responsibility on the part of MIRA INFORM PRIVATE LIMITED (MIPL) or its officials.