China Suntien Green Energy Corporation Limited(600956)
Continuous risk assessment report on Hebei Construction Investment Group Finance Co., Ltd
(2021)
China Suntien Green Energy Corporation Limited(600956) in accordance with the requirements of self regulatory guidelines for listed companies on Shanghai Stock Exchange No. 5 – transactions and related party transactions, the regular financial statements of the financial company, including balance sheet, income statement and cash flow statement, were obtained and reviewed by checking the financial license, business license of enterprise legal person and other certificates of Hebei Construction Investment Group Finance Co., Ltd. (hereinafter referred to as “financial company”), The business qualification, business and risk status of the financial company are evaluated, and the specific situation is reported as follows:
1、 Basic information of finance company
Finance company is a non bank financial institution established with the approval of Bank Of China Limited(601988) Industry Regulatory Commission. The code of financial license is 00534688, and the unified social credit code of enterprise legal person business license is 91130 Shenzhen Zhenye(Group)Co.Ltd(000006) 165450xj.
The registered capital of the finance company is 2 billion yuan, of which Hebei Construction Investment Group Co., Ltd. contributes 1.2 billion yuan, accounting for 60% of the registered capital; The company contributed 200 million yuan, accounting for 10% of the registered capital Jointo Energy Investment Co.Ltd.Hebei(000600) invested 200 million yuan, accounting for 10% of the registered capital; Hebei Construction Investment Transportation Investment Co., Ltd. invested 200 million yuan, accounting for 10% of the registered capital; Hebei Jiantou Water Investment Co., Ltd. invested 200 million yuan, accounting for 10% of the registered capital. Legal representative: Yuan Yanming, registered address: block a, Yuyuan Plaza, No. 9, Yuhua West Road, Shijiazhuang.
With the approval of the CBRC, the company’s business includes: handling financial and financing consulting, credit assurance and related consulting and agency services for member units; Assist member units to realize the receipt and payment of transaction funds; Approved insurance agency business; Provide guarantee to member units; Handle entrusted loans and entrusted investment between member units; Handle bill acceptance and discount for member companies; Handle the internal transfer settlement between member units and the corresponding settlement and clearing scheme design; Absorbing deposits from member units; Handle loans and financial leases for member units; Underwriting corporate bonds of member units; Securities investment; Engage in interbank lending; Other businesses approved by the CBRC.
2、 Basic information of internal control of finance company
(I) internal control environment
The financial company has a sound corporate governance structure, scientific and standardized management and operation, and has established an organizational structure with reasonable division of labor, clear responsibilities and clear reporting relationship, which provides necessary preconditions for the effectiveness of risk management. The company has set up its organizational structure in accordance with the principle of mutual checks and balances among decision-making system, execution system and supervision and feedback system: the decision-making system includes the shareholders’ meeting, the board of directors and its subordinate Risk Management Committee; The execution system includes the senior management and its subordinate credit review committee, investment and financing Committee and various business functional departments; The supervision and feedback system includes the board of supervisors, the audit committee under the board of directors and the risk management department and audit department directly responsible to the board of directors. It constructs three working procedures and risk prevention and control system with the separation of front office, middle office and back office.
The organization chart is as follows:
Board of directors: responsible for ensuring that the company establishes and implements an adequate and effective internal control system; Examine and approve the overall business strategy and major policies, and regularly inspect and evaluate the implementation; Be responsible for ensuring that the company operates prudently within the framework of laws and policies, clearly setting acceptable risk levels, and ensuring that the senior management takes necessary measures to identify, measure, monitor and control risks; Organization responsible for examination and approval; Be responsible for ensuring that the senior management monitors and evaluates the adequacy and effectiveness of the internal control system.
Board of supervisors: responsible for supervising the board of directors and senior management to improve the internal control system; Be responsible for supervising the board of directors and directors, senior management and senior management to perform internal control duties; Be responsible for requiring directors and senior managers to correct their behaviors that harm the interests of the company and supervising the implementation.
Senior management: responsible for formulating internal control policies and monitoring and evaluating the adequacy and effectiveness of the internal control system; Be responsible for implementing the decisions of the board of directors; Establish procedures and measures for identifying, measuring, monitoring and controlling risks; Be responsible for establishing and improving the internal organization to ensure the effective performance of various responsibilities of internal control.
Risk Management Committee: responsible to the board of directors, it is the highest decision-making body of the company’s comprehensive risk management. Through the formulation and implementation of a series of systems, procedures and methods, it carries out pre prevention and in-process control of risks, coordinates and handles major cross departmental risk management and internal control matters of the company, and reviews the general policies and procedures of the company’s risk management. The daily office of the risk management committee is in the risk management department.
Audit Committee: responsible to the board of directors, it is the guidance and decision-making body of the company’s audit and internal control. It is responsible for supervising and reviewing the soundness of the design and effectiveness of the implementation of the company’s internal control system, putting forward suggestions on the establishment of the company’s audit and supervision system, guiding the development of audit and audit work, and determining the responsibility of the company’s operation post risk matters. The daily office of the audit committee is in the audit department.
Credit audit committee: responsible to the general manager and make approval decisions on relevant working systems and procedures of credit business; Make approval decisions on the credit business and other businesses declared by the credit business department; Final approval of asset classification results; Approve and make decisions on the responsibility identification of non-performing assets; Make decisions on the management and disposal of non-performing assets. The credit audit committee is composed of the deputy general manager of the company, the manager of the risk management department, the manager of the capital settlement department, the manager of the planning and finance department and the manager of the comprehensive management department. The daily office is in the risk management department.
The investment and financing committee is the decision-making body of investment and financing business under the leadership of the general manager of the company, which performs the role of review and restriction on the company’s inter-bank business and securities investment business, and controls the risk of inter-bank business.
Business department: the company’s business departments (credit business department, capital operation Department, capital settlement department, planning and finance department and comprehensive management department) include most of the company’s assets and businesses. They directly face all kinds of risks in their daily work and are the front line of the company’s risk management. Each business department undertakes the following risk management responsibilities:
1. Implement the basic process of risk management within the scope of responsibilities of the Department to integrate risk management into daily management and business work;
2. Study and put forward the judgment criteria or judgment mechanism of major decisions, major risks, major events and important business processes of the Department;
3. Study and put forward the risk assessment report related to the business of the Department;
4. Participate in cross functional risk management;
5. Do a good job in cultivating risk management culture;
Risk management department: it is the specific executive department of relevant decisions of the risk management committee and the Department that leads and coordinates the risk management work of various departments of the company. Its main responsibilities are to formulate the company’s risk management policies and systems, supervise and prompt the risks of various business activities of the company, organize and implement the inspection of the implementation of early warning, monitoring, analysis and internal control systems of various risks, and write risk assessment reports; Organize the research and review of the company’s rules and regulations and operation processes, and review the customer credit rating evaluation methods and standards; Organize the implementation of asset risk classification and identification and authenticity inspection, and organize the management and disposal of transferred non-performing assets; Manage the general legal affairs of the company; Be responsible for the daily affairs of the risk management committee and the credit audit committee, conduct preliminary review of the meeting materials, and track and monitor the implementation of relevant matters.
Audit department: it is a department independent of the business level and management level, which is responsible for monitoring the company’s internal control. Its main responsibility is to carry out audit review, carry out comprehensive audit, inspection and supervision of all departments, posts and businesses, including daily business audit and special audit, and report to the board of directors and the board of supervisors on a regular basis; Be responsible for the company’s compliance management, organize compliance inspection and prepare inspection report, and monitor the rectification of each department.
(II) risk identification and assessment
The implementation of the internal control of the finance company is organized by the risk management department and supervised by the audit department. Within the scope of their responsibilities, various departments and institutions formulate their own different risk control systems, standardized operating procedures, operating standards and risk prevention measures according to the different characteristics of various businesses, mainly including credit risk, operational risk, liquidity risk and information system risk. The responsibilities of various departments are separated and supervised each other, Predict, evaluate and control various risks in self operation.
(III) internal control measures
The risk control of the finance company focuses on the credit risk and operational risk in credit business such as credit, loan and bill, capital security and operational risk in settlement business, corporate liquidity risk and computer information system risk. The following measures shall be taken for risk control of key businesses: inspection of functional departments, behavior control such as statistical statements and special reports, physical control such as physical custody and regular inventory, approval and authorization, separation of incompatible positions, etc. The above measures can be carried out alone or in combination.
1. Authorization management
According to the relevant requirements of the basic norms of internal control, the authorization management measures are formulated to standardize the management of business authorization, expense authorization and transaction authorization. The authorization of the company is in the form of letter of authorization, which defines the scope and authority of each post to handle business and matters. Managers at all levels exercise their powers and assume responsibilities in strict accordance with the scope of authorization. The company implements the collective decision-making approval or joint signing system for major businesses and matters. No individual may make decisions alone or change collective decisions without authorization.
The implementation of the authorization system improves the company’s external adaptability and decision-making efficiency, fully mobilizes the enthusiasm of work at all levels, and can effectively prevent internal control risks.
2. Fund management
In accordance with the measures for the administration of enterprise group financial companies and the relevant provisions of the people’s Bank of China and the Bank Of China Limited(601988) Industry Regulatory Commission, the finance company has formulated the measures for the administration of capital plans, the deposit business management system, the settlement business management system, the internal account management measures, the online banking system operation management measures, the liquidity risk management measures and other business management measures Business operation process, so that first of all, the business risk is controlled through the operation specifications and control standards specified in the procedures and processes.
(1) In terms of fund plan management, the company formulates the fund plan management measures according to the centralized fund management measures of Hebei Construction Investment Group Co., Ltd., and ensures the safety, efficiency and liquidity of the company’s funds through the formulation and implementation of fund plan management in accordance with the principles of unified dispatching, coordinated management, positive balance and benefit priority.
(2) In terms of deposit business of member units, the company strictly follows the principles of equality, voluntariness, fairness and good faith to ensure the safety of funds of member units and safeguard the legitimate rights and interests of all parties. (3) In terms of transfer settlement business, member companies open settlement accounts in the company, and realize fund settlement by logging in to the company’s settlement platform and submitting instructions online, so as to strictly ensure the safety, quickness and smoothness of settlement, and have high data security at the same time.
3. Accounting business control
The finance company establishes and implements standardized accounting procedures in accordance with the accounting law of the people’s Republic of China, accounting standards for business enterprises and other relevant national laws and regulations and the Interim Measures for accounting of Hebei Construction Investment Group Co., Ltd. The company has established an independent financial and accounting department to ensure that the accounting department and accounting personnel can handle accounting business legally and in compliance. The company has defined the authority of the accounting department and accounting personnel. The accounting personnel shall handle relevant businesses within their respective authority. Those beyond the authority must be authorized before handling. The principle of separation of duties and mutual restriction shall be implemented in the setting of settlement and accounting posts of the company. It is strictly prohibited for one person to concurrently hold incompatible posts or complete the business operation of the whole process of settlement and accounting alone. The company regularly checks the accounting books with the physical objects, funds and relevant materials to ensure the consistency of the relevant contents between the actual accounts, account data, accounts, account certificates, accounts and account tables.
In accordance with the principles of specially assigned person management, mutual restraint, appropriate approval and strict registration, the finance company strengthens the management of contracts, bills, seals and keys. Seals and bills are kept and used separately. Important contracts and bills have special measures such as serial number control, cancellation control, blank voucher control and collection registration control. When the accounting personnel change, the supervision procedures shall be strictly implemented, and the handover procedures shall be handled with the receiver under the supervision of the supervisor.
4. Credit business control
The loan object of the finance company is limited to the member units of Hebei Construction Investment Group. According to the different characteristics of various businesses, the company has formulated comprehensive credit management measures, self operated loan business management measures, customer credit rating management measures and bill acceptance business management measures, standardized various business operation processes of the company, and established a complete credit management system before, during and after loan.
(1) Establish a credit management system with clear division of labor, clear responsibilities and mutual constraints, so as to achieve the separation of loan approval and hierarchical approval.
The finance company determines the review procedure and approval authority according to the loan scale, type, term and guarantee conditions, and reviews and approves the loan in strict accordance with the procedure and authority.
The finance company has established and improved the credit department and credit post responsibility system, and the post setting of the credit department should be reasonable and clear. Loan investigation and evaluation personnel are responsible for loan investigation and evaluation, and bear the responsibility for investigation errors and inaccurate evaluation; Loan reviewers are responsible for the review of loan risks and bear the responsibility for review errors; Loan issuing personnel are responsible for the inspection and collection of loans, and bear the responsibility for inspection errors and ineffective collection.
The finance company establishes a credit audit committee as the decision-making body of credit business. The credit and loan applications approved by the credit business department shall be submitted to the credit audit committee for approval after the risk management department issues risk opinions.
The credit review committee is responsible for the review of credit and loans. The committee’s deliberation and voting shall follow the principles of collective deliberation, explicit expression of opinions and majority approval, and all opinions shall be recorded and archived.
(2) Prevent the high concentration of single customer risk, prevent the issuance of related party loans and human loans in violation of credit principles, and prevent the illegal investment of credit funds in high-risk areas and illegal activities. (3) Post loan management: the credit business department is responsible for the monitoring and management of the loan purpose, interest collection, overdue loans and extended loans of the loan, and the post loan inspection of the security and recoverability of the loan.
The finance company has established an asset risk classification system to standardize the recognition standards and procedures of asset quality. It is strictly prohibited to cover up the real situation of non-performing assets and ensure the authenticity of asset quality.
(4) Establish customer management information files, and comprehensively and intensively grasp the customer’s credit level, operation and financial status and compensation
