MIRA INFORM REPORT

Report Date :

14.05.2011

IDENTIFICATION DETAILS

Name :	STEELCO PACIFIC TRADING LTD.
Registered Office :	42/F., China Online Centre, 333 Lockhart Road, Wanchai
Country :	Hong Kong
Date of Incorporation :	13.04.2004
Com. Reg. No.:	34518871
Legal Form :	Private Limited Company
Line of Business :	Importer and Exporter of all kinds of iron and steel materials.

RATING & COMMENTS

MIRA’s Rating :

Ba

RATING		STATUS	PROPOSED CREDIT LINE
41-55	Ba	Overall operation is considered normal. Capable to meet normal commitments.	Satisfactory

Status :	Satisfactory
Payment Behaviour :	Regular
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 – December 31, 2010

Country Name	Previous Rating (30.09.2010)	Current Rating (31.12.2010)
Hong Kong	a2	a2

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

Company name

STEELCO PACIFIC TRADING LTD.

company address

42/F., China Online Centre, 333 Lockhart Road, Wanchai, Hong Kong.

PHONE: 2893 1099, 2893 7305, 3657 5352

FAX: 2893 1399

E-MAIL: donald@spt.com.hk

MANAGEMENT

Managing Director: Mr. Au Chun Keung, Donald

SUMMARY

Incorporated on: 13th April, 2004.

Organization: Private Limited Company.

Capital: Nominal: HK$6,000,000.00

Issued: HK$6,000,000.00

Business Category: Steel Product Trader.

Employees: 15.

Main Dealing Banker: Fortis Bank, Hong Kong Branch.

Banking Relation: Satisfactory.

company ADDRESS

Registered Head Office:-

42/F., China Online Centre, 333 Lockhart Road, Wanchai, Hong Kong.

Holding Company:-

Steelco Holding Ltd., British Virgin Islands.

Affiliated Company:-

Steelco Pacific Trading DMCC, Dubai, UAE.

BUSINESS REGISTRATION NUMBER

34518871

COMPANY FILE NUMBER

0894684

MANAGEMENT

Managing Director: Mr. Au Chun Keung, Donald

CAPITAL

Nominal Share Capital: HK$6,000,000.00 (Divided into 6,000,000 shares of HK$1.00 each)

Issued Share Capital: HK$6,000,000.00

SHAREHOLDER

(As per registry dated 13-04-2010)

Name	No. of shares
Steelco Holding Ltd. Palm Grove House, P.O. Box 438, Road Town, Tortola, British Virgin Islands.	6,000,000 =======

DIRECTOR

(As per registry dated 13-04-2010)

Name (Nationality)	Address
AU Chun Keung	13/F., The Primrose, 38 Rose Street, Yau Yat Chuen, Kowloon Tong, Kowloon, Hong Kong.

SECRETARY

(As per registry dated 13-04-2010)

Name	Address
FONG Shiu Man, David	Flat D, 2/F., Block 5, Beverly Garden, Tseung Kwan O, New Territories, Hong Kong.

HISTORY

The subject was incorporated on 13th April, 2004 as a private limited liability company under the Hong Kong Companies Ordinance.

Originally the subject was registered under the name of Gold Loyal Investment Ltd., name changed to the present style on 15th March, 2005.

Last time the subject was located at Room 3502, 35/F., China Online Centre, 333 Lockhart Road, Wanchai, Hong Kong, moved to 42/F. of the same building with effect from 28th September, 2009.

Apart from these, neither material change nor amendment has been ever traced and noted.

OPERATIONS

Activities: Importer and Exporter.

Lines: All kinds of iron and steel materials.

Employees: 15.

Commodities Imported: China, Russia, India, etc.

Markets: China, other Asian countries, Europe, etc.

Terms/Sales: As per contracted.

Terms/Buying: Various terms.

MEMBERSHIP

The Hong Kong General Chamber of Commerce, Hong Kong.

[Membership No. HKS0901]

FINANCIAL INFORMATION

Nominal Share Capital: HK$6,000,000.00 (Divided into 6,000,000 shares of HK$1.00 each)

Issued Share Capital: HK$6,000,000.00

Mortgage or Charge (since September 2008): (See attachment)

Profit or Loss: Making a small profit every year.

Condition: Keeping in a satisfactory manner.

Facilities: Making active use of general banking facilities.

Payment: Met obligations on time.

Commercial Morality: Satisfactory.

Bankers:-

Fortis Bank, Hong Kong Branch.

BNP Paribas S.A., Hong Kong.

Standing: Normal.

GENERAL

Steelco Pacific Trading Ltd. is a wholly-owned subsidiary of Steelco Holding Ltd. [Steelco] which is a BVI-registered firm. Formerly, the holding company of the subject was Group China Investments Ltd. which was also a BVI-registered firm. Group China Investments Ltd. transferred all its shares to Steelco on 15th July, 2009.

The only director of the subject is Mr. Au Chun Keung who is a Hong Kong merchant.

The subject has been established in Hong Kong since April 2005. It is trading in iron and steel products and materials. It has set up representative offices in China (Beijing, Tangshan, Shanghai and Guangzhou), Singapore and Dubai of the United Arab Emirates.

The principal activities of the subject are steel trading and acting as an agent for selling steel products. Its markets are China, the Philippines, Singapore, Thailand, India, Spain, Portugal and Italy. It has got business partners in Taiwan, Malaysia, Vietnam, etc. It also has got joint ventures in Europe and America.

The subject sold over 500,000 tonnes of steel products in 2006. The steel products included steel slab, billets, wire rods, seamless pipes, cobble plates, cold rolled strips/coils, hot rolled sheet/coils/plates. In 2007, the subject sold prepainted galvanized, GI coils, ship plates, and bulb flats.

Its Dubai office was opened in May 2007. The Dubai office concentrates on selling quality products such as tubes for oil, gas and petrochemical industry. The subject’s heavy plate sales are currently in excess of 30,000 tonnes per month. In addition, the subject also carries hot-dip galvanised and pre‑painted coils, wire rod and other products. Business is improving.

By the end of 2010, the subject predicts it would have been sold at least 3 million tonnes of iron and steel in the Asia Pacific Region. Currently, it is selling large quantities of Chinese shipbuilding plate to Singapore, and is actively selling Chinese materials to the Philippines, Thailand and Vietnam.

The subject also acts as the Asian sales agent for Steelco Mediterranean Trading, whose annual sales of Russian material, including slab and flat products from NLMK and raw materials from Altai Koks and Stoilinskiy GOK, totalling 2.5 to 3.0 million tonnes annually.

The business of the subject keeps on improving. It has had close business ties with a number of large iron and steel mills in China, such as Baoshan Iron and Steel Group in Shanghai, Tangshan Iron & Steel Co. Ltd. in Tangshan, Guangzhou Iron and Steel Co. and Beijing Iron and Steel Co., which are in Guangzhou and Beijing respectively.

The history of the subject in Hong Kong is over six years and five months.

On the whole, consider it good for normal business engagements.

COURT CASES: None per our.

MORTGAGE OR CHARGE

(Since September 2008)

Date	Particulars	Amount
09-09-2008	Instrument: General Security Agreement Relating to Goods Property: As a continuing security for the payment or discharge to the Bank on demand of all moneys obligations and liabilities Mortgagee: Fortis Bank, Hong Kong Branch.	To secure all obligations and liabilities
09-09-2008	Instrument: General Letter of Pledge Property: (a) all bills of exchange, promissory notes and other negotiable instruments of any description and all bills of lading, warrants, delivery orders, wharfingers’ or other warehouses keepers’ warrants or receipts, policies and certificates of insurance and all other documents of title to, or other documents relating to produce and goods; and (b) all produce and goods Mortgagee: Fortis Bank, Hong Kong Branch.	To secure all obligations and liabilities
23-09-2009	Instrument: Account Charge Property: As beneficial owner, charges and agrees to charge the deposit and all its right, title and interest in the deposit (account number 803577-3159 and 803577-3165) Mortgagee: Fortis Bank, Hong Kong Branch.	Secured Liabilities
08-03-2010	Instrument: Security Memorandum (First Party) Property: The Company hereby assigns and agrees to assign absolutely and unconditionally to the Bank all its right, title and interest in and to each Receivable as continuing security for the payment or discharge of the Secured Liabilities Mortgagee: Fortis Bank (Nederland) N.V., Singapore.	All indebtedness, obligations and liabilities
16-07-2010	Instrument: Transfer of Security executed by Fortis Bank [Transferor], BNP Paribas S.A. [Transferree] and Steelco Pacific Trading Ltd. [Transfer] Property: The Transferor as chargee assigns and transfers to the Transferee all the right, title, benefit, power and interest of the Transferor of and in the Assets and the Security and all appurtenances thereto Mortgagee: BNP Paribas S.A., Hong Kong.	(i) the Secured Debt and (ii) the payment by the Transferee to the Transferor of any amount

FOREIGN EXCHANGE RATES

Currency	Unit	Indian Rupees
US Dollar	1	Rs.44.91
UK Pound	1	Rs.73.06
Euro	1	Rs.64.03

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.