Risk Assessment: APSLEY GROUP INTERNATIONAL LTD

1. Risk Rating: MEDIUM

Justification: While the company demonstrated strong liquidity and asset growth through its last detailed filing period (2017), the significant data gap since then—combined with conflicting ownership disclosures and a material business pivot—creates substantial uncertainty. The company appears solvent based on historical data, but current financial position cannot be reliably assessed.

2. Key Concerns

i. Significant Financial Data Staleness

The most recent detailed financial figures available are for the year ending 31 October 2017—approximately 7 years old. While the company has filed confirmation statements up to November 2025 and accounts appear current (last made up to 31 December 2024, next due September 2026), no recent balance sheet data is accessible. This creates an unacceptable level of uncertainty regarding the current solvency and liquidity position of the business.

ii. Conflicting Persons with Significant Control (PSC) Disclosures

The PSC register presents ownership percentages that cannot reconcile mathematically: - Spotlight Sports Group Limited: >75% shares and voting rights - Centurycomm Limited: 50-75% shares and voting rights - Mr Apperley: 25-50% shares and voting rights - Mr Prosser: 25-50% shares and voting rights

The minimum total would exceed 175%, which is impossible. This suggests either: stale PSC entries not yet updated following ownership changes, complex share class structures with different voting rights, or administrative errors. The ownership structure requires immediate clarification.

iii. Material Composition of Debtors and Creditor Concentration

In the 2017 accounts, "other debtors" of £399,209 constituted 91% of total debtors (£437,354). Only £38,145 represented trade debtors. The nature of these "other debtors" is not disclosed and could represent intercompany balances, loans, or items of uncertain recoverability. Similarly, taxation and social security liabilities of £251,219 represented 65% of total creditors, which warrants examination of whether this reflects profitability or deferred obligations.

3. Positive Indicators

i. Strong Historical Liquidity and Solvency

As of October 2017, the company held £1,230,840 in cash against total current liabilities of £386,238—a cash coverage ratio of approximately 3.2:1. Net current assets were £1,281,956 with no long-term liabilities reported. The company appeared well-capitalized with minimal solvency risk at that time.

ii. Consistent Growth Trajectory

The financial history demonstrates sustained growth: - Total assets grew from £76,847 (2014) to £1,668,194 (2017) - Shareholders' funds grew from £23,796 (2014) to £1,281,956 (2017) - Cash increased from £37,491 (2014) to £1,230,840 (2017)

This trajectory suggests a viable and expanding business during the period covered.

iii. Regulatory Compliance

The company is Active, not in liquidation, and filings are current with no overdue items. No director disqualification records are noted. The accounts category has been updated to "Audit Exemption Subsidiary," and the accounting reference date appears to have shifted from October to December, suggesting ongoing corporate activity and administrative maintenance.

4. Due Diligence Notes

a. Obtain Current Financial Statements

Request the most recent filed accounts directly from the company or their auditors. The 7-year data gap makes any investment decision based on 2017 figures imprudent. Specifically request accounts for years ending December 2019 onwards.

b. Clarify PSC Structure

Investigate the PSC register discrepancy as a priority. Determine whether Spotlight Sports Group Limited and Centurycomm Limited are related entities, whether share classes carry different rights, and what the actual beneficial ownership structure is. Spotlight Sports Group appears to be a listed company (formerly Daily Fantasy Sports Group plc), which may provide additional disclosure.

c. Intercompany Relationships and "Other Debtors"

As an "Audit Exemption Subsidiary," this entity is part of a larger group. Investigate the nature of the £399,209 in other debtors—whether these represent intercompany receivables, loans to directors/related parties, or other items. Assess whether these balances are recoverable and whether they create dependency on group entities.

d. Business Model Following Name Change

The company traded as "BETTING INVESTMENTS LIMITED" until January 2017, then rebranded to APSLEY GROUP INTERNATIONAL LTD. The SIC code is 73110 (Advertising agencies). Investigate whether this reflects a genuine business pivot or merely a corporate rebranding, and assess the current revenue model and client base.

e. Related Party Transactions

Given the subsidiary status and multiple corporate PSCs, examine the extent of related party transactions, intercompany pricing, and whether the company's financial position is dependent on group funding arrangements or transfer pricing.

f. Change in Accounting Reference Date

The accounting reference date appears to have changed from 31 October to 31 December. Investigate whether this aligns with a group restructuring or acquisition, and whether comparative periods are affected.