MIRA INFORM REPORT

Report Date :

12.10.2011

IDENTIFICATION DETAILS

Name :	A.C.I. TRADING LIMITED
Registered Office :	Office 202, 8 Stassinos Avenue 1060 Nicosia
Country :	Cyprus
Date of Incorporation :	22.03.2004
Com. Reg. No.:	C146770 Nicosia
Legal Form :	Private Limited Liability Company / International Business Company (IBC)
Line of Business :	Nondurable Goods, NEC (except specialty advertising)

RATING & COMMENTS

MIRA’s Rating :

Ca

RATING		STATUS	PROPOSED CREDIT LINE
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

Status :	Offshore Company
Payment Behaviour :	Unknown
Litigation :	--

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 – March 31^st, 2011

Country Name	Previous Rating (31.12.2010)	Current Rating (31.03.2011)
Cyprus	B1	B1

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

Name & Address

Correct Registered Name:

A.C.I. TRADING LIMITED

Address:

Office 202, 8 Stassinos Avenue 1060 Nicosia CYPRUS

P.O.Box:

22454, 1522

Telephone:

+357-22447866 +357-22751555 357-22-447866

Fax:	+357-22452054 357-22-751200

Email:

centralmail@demaservices.com (corresp. email)

Web:	www.demaservices.com (correspondence website)

Business address:

Office 202, 8 Stassinos Avenue 1060 Nicosia CYPRUS

Payment

PAYMENT HABITS:

No Complaints

Commercial Morality:

Unable to comment Given that the present is an International Business Company - IBC (Offshore Company) and most of its activities are carried out outside Cyprus, coupled with the fact that no further detailed financial information is available, we feel unable to express a safe and reliable opinion on their creditability and commercial morality of the subject.

Financial Strength:

Unable to comment

Legal Status

Legal Form:

Private Limited Liability Company / International Business Company (IBC) (offshore) The term International Business Company came to substitute the term offshore company. Following the latest changes in the Cyprus Tax laws, a Cyprus registered company is taxed at 10% on its net profits provided that the company has management and control in Cyprus. An IBC may be operated from abroad or may have a fully-fledged office in Cyprus.

Registration number and city:

C146770 Nicosia

Registration date:

22.03.2004

National ID: C146770

Company Status

Registration status: 22.03.2004 - registered company
Activity status: 22.03.2004 - Company is active

Principals

Shareholders
Full Name	Personal ID	Function	Nationality	Equity	Address
DEMA NOMINEES LIMITED Registration: No. C59190, 27.12.1993, Nicosia, CYPRUS		Shareholder		50.00% 22,960 Ordinary	Agia Varvara, 55, Grigori Afxentiou Street 2560 Nicosia CYPRUS
DEMA TRUSTEES LIMITED Registration: No. C86654, 09.06.1997, Nicosia, CYPRUS		Shareholder		50.00% 22,960 Ordinary	Agia Varvara, 55, Grigori Afxentiou Street 2560 Nicosia CYPRUS

Management
Full Name	Personal ID	Age	Function	Nationality	Qualification	Experience	Address
DEMA SECRETARIAL LIMITED			Secretary				Archangelos, 24, Agias Varvaras Street Nicosia CYPRUS
Ms. Georgia Georgiou	799211	33	Director	CYPRUS	Non Retrievable.	Also director of ACI.Trading Ltd, Dagmar Enterprises (Overseas) Ltd, Hosier Ventures Ltd, Petra Overseas Container Services Ltd, Kason Ventures Ltd, Dema Secretarial Ltd, Marlin Holdings Ltd, Roosis Holdings Ltd, Klamouria Trading Ltd and many others	42, Nestoros str Nicosia 1026 Kaimakli CYPRUS
Mr. Andreas Mavromatis	502625	56	Director	CYPRUS	Non retrievable	Non retrievable	55,Gregori Afxentiou Street 2560 Nicosia CYPRUS
Mr. Taras Ivashchenko			Director	UKRAINE	Non Retrievable	Non Retrievable	Office 325, 29, Timoshenko Street 04210 Kiev UKRAINE
Ms. Andriani Zevedeou			Director	CYPRUS	Non Retrievable	Non Retrievable	Lakatamia, 4, Voufaventou Street, Office 04 2322 Nicosia CYPRUS

Activities

Activities:

General Traders

Operations:

SIC   main activity   5199 Nondurable Goods, NEC (except specialty advertising)   6799 Investors, NEC (commodity contract trading companies) According to the Article of Associations the current company deals with general trade although this was not confirmed. However the article makes provision for other activities as well. Business Activities General Trading Industry Classifications - NAICS » Wholesale Trade Agents and Brokers NAICS #42512 » Wholesale Trade NAICS #42 » Other Miscellaneous Durable Goods Merchant Wholesalers NAICS #42399 » Apparel, Piece Goods, and Notions Merchant Wholesalers NAICS #4243 » Other Miscellaneous Nondurable Goods Merchant Wholesalers NAICS #42499

Imports

Non Retrievable

Exports

Non Retrievable

Agencies

Non Retrievable

Trade Suppliers

Non Retrievable

Workforce

The company does not maintain offices in Cyprus. At least we did not trace any. Under these circumstances no staff is employed. In such cases, companies utilize staff (2-3 people) from their auditors� or lawyers� offices.

Description Of Premises

Address:	Office 202, 8 Stassinos Avenue 1060 Nicosia CYPRUS
Type of premises:	Premises
Type of ownership:	shared
Address:	Agia Varvara, 55, Gregori Afxentiou Street 2560 Nicosia CYPRUS
Type of premises:	Registered Address

Headquarters:

Please note that we have not been able to trace offices of the company in Cyprus. The address given above is that of the company's Official Correspondence Address, Dema Services Limited. Correspondence: Dema Services Limited, 8 Stasinou Street, Photiades Business Center, 3rd floor, office 301, 1522 Nicosia, Cyprus, Tel: 357 22751555.

Bankers

RAIFFEISEN ZENTRAL BANK OSTERREICH AKTIENGESELL SCHAFT
STADTPARK, VIENNA


Account number is not disclosed.

Press

No press / media available at present.

Auditors / Accountants

Non Retrievable

Share Capital

Registered capital:	USD 50,000.00 since 01.01.2008
Number of Ordinary:	50,000
Value per share of Ordinary:	USD 1.00
Issued capital:	USD 45,920.00 since 01.01.2008
Number of Ordinary:	45920
Value per share of Ordinary:	USD 1.00
Paid-up capital:	USD 45,920.00 since 01.01.2008

Charges

10.05.2005

Charge

USD 27,000,000.00

in f/o:Raiffeisen zentralbank oesterreich aktiengesellschaft

Finance

Please note that the latest financial details have not been released to us. The latest financial details are not available at the file of the company at the Official Companies Registry House; as the law provides for all companies. Further financial details are not available from other public sources.

Financial accounts are available at the Department of Registrar of Companies, provided that the company has submitted the compulsory accounts.

The annual general meeting of a company is convened within eighteen months of the date of its registration. Forty two days later the company should file its first annual return with the Registrar of Companies. Once a year, the annual return must be submitted. This should be done within fifteen months from the previous annual return, without disregarding the calendar year (sections 118, 120 and 125 cap. 113).

All Cypriot Companies, whether local or international, must maintain accurate books of accounts, which should reflect the true and correct position of their conduct, as well as give adequate explanation of their operations.

The Cypriot Company Law, which is closely modeled on its English counterpart, entails that company accounts must comprise of the following:

- Directors' report.

- Auditor's report.

- Financial statements as prescribed by International Financial Reporting Standards (IFRS) and consolidated Financial Statements in case of parent companies (unless specifically exempted).

Audited financial statements and an Income Tax Return are required for all companies, even companies with no taxable income and/or dormant companies.

Registered Branches (in Cyprus) of foreign companies are not legally bound to compile full separate branch accounts however when taxed on the island, are obliged to do so for income tax purposes.

Additionally they have to submit accounts of the main company, translated into Greek, to the Department of Registrar of Companies.

Partnerships are exempt from any requirement to prepare audited accounts, but they are legally bound to keep proper books of account which must be available for scrutiny by individual partners.

GENERAL COMMENTS

MAIN SOURCES OF INFORMATION - FOR THIS REPORT

i. Visited Official Companies’ Registry

ii. Interview with Company / Correspondence

iii. Desk Research

iv. Search through Internet Subscription Databases (Business Information)

v. Specialized Media Search Global & Local

vi. Search through internet Social Networks

vii. Infocredit Negative Record Database

viii. Relationship/Directorship Search through Infocredit Database

The present is an International Business Company - IBC (ex - Offshore Company) registered in Cyprus on 22.03.2004. According to the article of association the company is involved in general trade. However, this information was not confirmed. Of Course the article makes provision of other activities as well. We have the impression that this is an International Business Company.

IBC companies, being covered by the law of confidentiality, may use nominee shareholders that hold the shares in trust for beneficial owners. Until recently beneficial owners were made known only to the Central Bank of the Republic of Cyprus that used to grant the permission for the company’s registration in Cyprus. After Cyprus accession in the EU this practice changed. Beneficial owners of an IBC are now known to the Lawyers and / or Auditors that undertake the registration of such companies in Cyprus.

In the past IBC’s (ex offshore companies & offshore branches) used to be benefited from a corporation tax rate on their profits of 4.25%. However, according to new tax legislation which has been in effect as of 1st January 2003, there is no longer a distinction between local companies and International Business Companies (IBC’s) and thus, the net profits of all companies registered in Cyprus are taxed at the rate of 10%.

Further more, in the past the law required the IBC’s (ex offshore companies & offshore branches), beneficial owners to be non-Cypriot residents and the business activities to be carried out, outside Cyprus only. Currently, this law has changed. IBC entities may have activities worldwide, including Cyprus. However, in order for an IBC entity to have activities locally, their Memorandum and Articles of Association should provide for that. Most of the IBC entities that were registered before the change of the law have already proceeded with the amendments in their Memorandum and Articles of Association.

We were not able to trace any offices for the company in question in Cyprus, however we contacted the company's correspondence Dema Services Limited where the official declined to release any information such as if the company is an IBC or not and if they maintain offices of their own in Cyprus, due to the confidentiality policy owed to their clients. For this reason, a questionnaire was placed in order to be forwarded to the subject but there has been no response yet.

Please note that the information included in the report was obtained from the Official Companies’ Registrar.

A check against our records revealed that no negative payment incidents against Subject Company, such as unpaid invoices, dishonored cheques and utility bills, bankruptcies exist etc.

Contact information

Telephone number:	357 22 447866	Company Correspondence
Fax number:	357 22 751200

FOREIGN EXCHANGE RATES

Currency	Unit	Indian Rupees
US Dollar	1	Rs.49.03
UK Pound	1	Rs.76.60
Euro	1	Rs.66.80

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
--	NB	New Business	--

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.