UBO Disclosure Policy

UBO Disclosure Policy Fundamentals

Veligera Capital OÜ conducts comprehensive Due Diligence on all counterparties, as well as prospective and investment partners to ensure complete transparency and clarity regarding Ultimate Beneficial Owners (UBOs). We strictly adhere to our UBO Disclosure Policy, which mandates absolute clarity and verifiable information about UBOs before entering into any business transactions. Furthermore, all counterparties are required to obtain a valid Legal Entity Identifier (LEI code) as a prerequisite for any business engagement. If there is any uncertainty or lack of transparency regarding UBOs or if an LEI code is not provided, we do not proceed with the partnership or transaction under any circumstances.

At a bare minimum, we need to know at least 76% of the legal entity ownership structure to the natural person(s).

Example

Suppose the legal entity is owned by two (2) other legal entities, e.g., company A and company B, each holding 50% of the shares. Then, we will need to know the ownership structure of companies A and B, and so on, until we reach the Ultimate Beneficial Owner(s), who must always be a natural person(s).

If both entities (Company A and Company B) are owned by other legal entities, the responsible person will be required to reveal their ownership structure as well.