Documents for counterparty due diligence.

How to use this pack

The Compliance Pack is intended to support efficient onboarding and periodic refresh by financial counterparties, banks, professional advisors and other parties conducting due diligence on the Company.

Each document below is marked with one of the following statuses:

• Public, freely available; please contact us if a copy is required.
• On Request, provided on request to verified counterparties; standard confidentiality applies.
• Under NDA, provided on request to verified counterparties under a written non-disclosure agreement.

Corporate documents

Documents evidencing the legal existence, registration and constitutional arrangements of Benson Industries Limited.

• Certificate of Incorporation (Hong Kong CR) Issued by the Hong Kong Companies Registry. CR No. 3029464.
  On Request
• Business Registration Certificate Current Business Registration Certificate issued by the Inland Revenue Department. BR No. 72797378.
  On Request
• Latest Annual Return (NAR1) Most recent annual return filed with the Companies Registry.
  On Request
• Articles of Association Constitutional documents of the Company.
  On Request
• Group structure chart Ultimate beneficial ownership and group structure overview.
  Under NDA

Regulatory & compliance

Documents describing the Company’s regulatory status and the design of its compliance programme.

• Regulatory status memorandum Summary of the Company's regulatory status as a private investment company; principal investor only; no public offering.
  On Request
• AML / CFT policy summary Summary of the Company's voluntary AML / CFT framework, FATF-aligned and informed by HKMA and SFC guidance.
  On Request
• Sanctions policy summary The Company's sanctions compliance policy, covering UN, OFAC, EU, UK and Hong Kong regimes.
  On Request
• Conflicts of interest policy summary Policy framework for the identification, escalation and management of conflicts of interest.
  On Request
• Privacy policy Personal data handling under the Personal Data (Privacy) Ordinance (Cap. 486).
  Public
• Wolfsberg CBDDQ (current version) Wolfsberg Group Correspondent Banking Due Diligence Questionnaire, completed and current.
  On Request

Tax & identifiers

Tax documentation and standard institutional identifiers required by financial counterparties.

• Legal Entity Identifier (LEI) certificate ISO 17442 LEI for use in regulated transactions.
  On Request
• CRS self-certification Common Reporting Standard self-certification for tax residency purposes.
  On Request
• Form W-8BEN-E (current) U.S. IRS Form W-8BEN-E in respect of the Company's status for U.S. tax withholding purposes.
  On Request
• Hong Kong tax residency certificate Issued by the Hong Kong Inland Revenue Department.
  On Request
• GIIN (if applicable) Global Intermediary Identification Number under FATCA, where applicable.
  On Request

Financial information

Periodic financial reporting is made available to verified counterparties under confidentiality.

• Audited financial statements (most recent) Latest audited financial statements; available on request to verified counterparties under NDA.
  Under NDA

Policy summaries

The Company maintains a set of written policies that govern its operations and risk management. Summaries of the principal policies are available on request:

• Investment policy and risk appetite framework
• Credit underwriting and approval standards
• Counterparty due diligence and onboarding procedures
• Sanctions, AML and CFT procedures
• Conflicts of interest and personal account dealing
• Information security and acceptable use
• Business continuity and incident management
• Whistleblowing and grievance procedures
• Code of conduct

Requesting additional materials

For documents not listed above, or for verified access to restricted materials, please contact the Compliance Office. Requests should include:

• The requesting institution and the role of the requester;
• The purpose of the request (for example, onboarding, periodic refresh, transaction-specific);
• The form of confidentiality undertaking (if any) the requester is prepared to provide.

For transaction-related enquiries, including borrower introductions and origination opportunities, please instead contact Loading…. For general enquiries, please use Loading….