China Hainan Rubber Industry Group Co.Ltd(601118)
Risk assessment report on financial services provided by Hainan Nongken Group Finance Co., Ltd. for the company in 2021
1、 Basic information of Hainan Nongken Group Finance Co., Ltd
Hainan Nongken Group Finance Co., Ltd. (hereinafter referred to as “Nongken finance company”) was jointly invested and established by Hainan Nongken Investment Holding Group Co., Ltd. and China Hainan Rubber Industry Group Co.Ltd(601118) (hereinafter referred to as “the company” or “the company”) on December 15, 2011. It is a non bank financial institution approved by Bank Of China Limited(601988) Insurance Regulatory Commission. The code of financial license institution is l0140a24600001.
The registered capital of Nongken finance company is RMB 500 million, of which Hainan Nongken Investment Holding Group Co., Ltd. contributes RMB 40 million and holds 80%; The company invested 100 million yuan and held 20% of the shares.
The current legal representative of Nongken finance company is Deng Wenjie, the unified social credit code of business license of enterprise legal person is 9146 Shenzhen Seg Co.Ltd(000058) 393623×5, and the registered address is 23 / F, Haiken international finance 2020 center, No. 115 Binhai Avenue, Haikou City, Hainan Province.
Business scope of Nongken finance company: handling financial and financing consulting, credit visa and related consulting and agency business 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; Engage in interbank lending; Investment in marketable securities (excluding investment in the secondary stock market); Buyer’s credit for products of member units; Underwriting corporate bonds of member units (general business projects are operated independently, and licensed business projects are operated with relevant licenses or approval documents).
2、 Internal control of Nongken finance company
(I) control environment
1. Governance structure
In accordance with the provisions of the articles of association, Nongken finance company has established the board of shareholders, the board of directors and the board of supervisors, and implemented the general manager responsibility system under the leadership of the board of directors. We have formulated the rules of procedure of the shareholders’ meeting, the rules of procedure of the board of directors, the rules of procedure of the board of supervisors, the measures for the supervision and management of the board of directors over the senior management, and the governance structure of the rules of procedure and mutual checks and balances of the general manager’s office.
The board of shareholders, the board of directors and supervisors shall hold meetings regularly to perform their duties in accordance with the rules of procedure and decision-making procedures. Risk control committee, credit review committee and investment and Financing Review Committee were established, and the management measures for risk control committee, management measures for credit review committee, management measures for investment and Financing Review Committee and risk management measures were established.
Board of directors: responsible for formulating overall business strategy and major policies to ensure the establishment of a comprehensive 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, and ensure that the senior management takes necessary measures to identify, measure, monitor and control risks.
Board of supervisors: responsible for supervising the board of directors and senior management to improve the risk management system; Be responsible for supervising the board of directors and directors, management and senior management to perform risk control responsibilities; Be responsible for requiring directors, chairman and senior managers to correct their behaviors that harm the interests of the company and supervise the implementation.
Risk control committee: responsible to the board of directors, it is the highest decision-making body for comprehensive risk management, coordinates and handles cross departmental major risk management and internal control matters, and reviews the general policies and procedures of risk management. Audit Committee: responsible to the board of directors, mainly responsible for the communication, supervision and verification of internal and external audit of the company.
Credit review committee: it is responsible to the general manager and makes approval decisions on the relevant working systems and procedures of credit business and the development of credit business and other businesses; Final approval of asset classification results; Make decisions on the responsibility identification of non-performing assets and the management and disposal of non-performing assets.
Investment and Financing Review Committee: responsible to the general manager and make approval decisions on investment and financing business according to relevant provisions of investment and financing management system; Make decisions on the disposal of investment and financing products with risks.
2. Organization setting and distribution of rights and responsibilities
Nongken finance company has set up functional departments such as settlement business department, credit business department, investment business department, planning and finance department, comprehensive management department, information technology department, risk management department and audit department, and formulated settlement business management measures, settlement business emergency budget, loan business management measures and credit management measures, as well as department responsibilities A series of rules and regulations such as post setting and staffing management measures have established an effective management system that can cover major business areas and major matters.
The audit department is independent of the business level and the operation management level. It is responsible for implementing comprehensive audit, inspection and supervision of all departments, posts and businesses, tracking the rectification, and directly reporting to the board of directors. It has strong independence.
The organizational structure of Nongken finance company is as follows:
Board of directors
Audit committee risk control committee
general manager
Investment and credit review committee
Deputy General Manager
Comprehensive management settlement business credit investment plan financial risk management audit investment business information technology 3. Human resources
The agricultural reclamation finance company has formulated the management measures for personnel recruitment and the management measures for employee assessment and leave
And the measures for handling employees’ violations of rules and regulations, which are used to standardize employees’ daily behavior and ensure the success of work
Ability to take responsibility. And formulated the performance management measures and established the employee performance appraisal management system.
4. Corporate culture
Nongken finance company attaches importance to the construction of corporate culture and carries out various forms of activities to carry out core values and social
Responsibility education, risk management training, strengthening risk awareness, ensuring safety and achieving annual strategic objectives.
（2） Risk assessment
The risk management organization of Nongken finance company is composed of the board of directors, the risk control committee under the board of directors
Senior management, credit review committee, investment and Financing Review Committee, audit department and business functional departments
Door composition.
The board of directors and risk control committee are risk decision-making bodies, senior management and their subordinates
The review committee, the investment and Financing Review Committee and all business functional departments are risk executing agencies, including the board of supervisors and the audit committee
The audit committee and the audit department are risk supervision institutions.
Nongken finance company has formulated risk management measures, risk isolation system, authorization management measures
Risk management systems such as business operation risk control management measures and asset quality five level classification management measures
Define the responsibilities of each department and organization and post responsibilities, and establish the emergency response plan and conclusion
The emergency plan has been established and the emergency management system has been fully defined.
At present, the main risks faced by Nongken financial company are operational risk, liquidity risk and credit risk.
Operational risk refers to the risk of loss caused by imperfect or problematic internal procedures, personnel and systems or external events. For this reason, Nongken finance company has established operational risk management measures to specify the operating procedures of account management, deposit business, settlement business, credit business, investment business, interbank business and intermediary business in detail; Liquidity risk refers to the risk of capital shortage when fulfilling the obligation of settlement by delivering cash or other financial assets. For this, Nongken finance company has formulated the measures for capital position management to strengthen capital position management and establish a liquidity risk index early warning mechanism. Information system risk refers to the failure to timely and accurately collect and transmit information related to business risks and ensure effective communication of information among departments and levels. In this regard, Nongken finance company has established a major event reporting mechanism and a smooth and effective information communication and reporting system. The management measures for the safe use of computers and the management measures for the use of software have been formulated, which stipulates that the person in charge of information technology shall carry out regular inspection, exchange and training activities.
(III) control activities
1. Fund settlement business control
Nongken finance company has formulated and improved business management measures such as settlement business management measures, deposit business management measures, fund plan management measures, fund approval management measures, interbank business management measures and budget management measures, clarified the operation norms and control standards of fund planning, settlement and deposit business, and effectively controlled business risks. It is stipulated that the funds shall be uniformly dispatched and the positions shall be centralized. On the premise of meeting the normal operation, priority shall be given to ensuring the settlement capital needs of group member units and the loan needs of member units.
(1) In terms of fund management, Nongken financial company strictly abides by the asset liability management requirements of the measures for the management of enterprise group financial companies, and ensures the safety of funds by formulating and implementing a series of internal control systems such as fund budget, settlement and risk control management.
(2) In terms of deposit business, member units shall follow the principles of equality, voluntariness, fairness and good faith, handle current, notice, fixed-term and other deposit businesses consistent with the bank for member units within the authority of the people’s Bank of China and the CBRC, and fully protect the deposit interests of member units.
(3) In terms of capital accounting, we have standardized accounting in accordance with the requirements of accounting standards, formulated financial management measures and financial expenditure management measures, and standardized financial management and capital expenditure procedures. The post management responsibilities of the financial department are set, and the settlement and accounting posts are set according to the principle of separation of duties and mutual restriction. 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.
2. Credit business control
In accordance with the measures for the administration of enterprise group financial companies and the relevant provisions of Bank Of China Limited(601988) industry supervision and Administration Commission and the people’s Bank of China, Nongken finance company has formulated a number of business systems and operating procedures, such as the measures for the administration of credit extension, the measures for the Administration of credit rating, the measures for the administration of self operated loans, the measures for the administration of bill acceptance business, the measures for the administration of bill discount business and the measures for the administration of guarantee business, It constitutes a comprehensive system covering credit business.
(1) Strict approval
The main control activities of the agricultural reclamation finance company in issuing loans include: the borrower submits the loan application data – the preliminary review of the credit officer – on-site investigation, completing the preliminary risk assessment, checking the credit situation – the manager of the credit department – the accounting of the capital position of the settlement department – the risk department – the deputy general manager in charge – the loan review committee – the approval of the general manager – the loan of the settlement department. All departments, institutions and posts have reasonable division of labor, clear responsibilities and mutual constraints, which can better control the loan risk.
In the loan business, the credit department is responsible for investigating errors and inaccurate evaluation, and the risk management department is responsible for independent credit review and whole process risk monitoring. The loan review committee shall review the customer’s credit rating, credit line, asset classification and other matters within its authority, and make collective decisions according to the principle of authorization management and separation of loan review. The final decision must be approved by more than two-thirds (including) of all members of the loan review committee before it becomes effective. (2) Post loan management and five level classification
Nongken finance company has formulated the five level classification management measures for asset quality according to the regulations, which stipulates that the post loan inspection report shall be made for working capital loans on a quarterly basis, the post loan inspection report shall be made for medium and long-term loans on a semi annual basis, the loan maturity notice shall be sent to the borrower 15 days before the loan maturity, and the risk management personnel shall monitor the quality of credit assets and the implementation of post loan inspection.
3. Investment business control
The company has formulated the financial management rules for investment products and strictly implemented the financial management rules of the enterprise group in accordance with the measures for the prudent management of securities investment (Trial).
4. Audit control
Nongken finance company implements the internal audit supervision system. The audit department is a department under the board of directors. It has formulated relatively complete internal audit methods and operating procedures such as internal audit management measures, audit work management measures and accountability. In addition to daily performing the function of internal audit supervision, it regularly carries out the audit of the work of each business department every year. In 2021, the Audit Department of Nongken finance company audited the credit business department, investment business department, planning and finance department, investment business department, risk management department, information technology department, settlement business department and comprehensive management department, issued audit reports and tracked the rectification of each department.
5. Information system control
The agricultural reclamation finance company has established an effective information system to collect, analyze, transmit and feed back all kinds of information to improve the effectiveness and timeliness of decision-making. It has also formulated rules and regulations such as the management measures for the safe use of computers, the management measures for computer software, the management measures for digital certificates and passwords of online settlement and the management measures for computer rooms. At present, the information system of Nongken finance company mainly includes information modules such as system management, customer management, capital settlement, credit management, bill management, online banking system, bank enterprise interface, statement management, leader query and so on, Realize the linkage between fund transfer, credit, deposit and other related business data.
(IV) overall evaluation of internal control
The governance structure of agricultural reclamation financial company is complete, the internal control system is sound, and the implementation is standardized and effective. In terms of fund management, it has better controlled the risk of fund security and ensured the liquidity of funds; Credit business has established a comprehensive pre credit investigation, loan review and post loan risk control system, which can effectively control the risk of loans.
