Kenneth Raymond Deayton

Swiss Commodity Re Limited is a Hong Kong-registered company controlled by Deayton, operating from the same 6th Floor, Wyndham Place address as Hong Kong Corporate Services Group.² Despite its name, the entity has no Swiss registration; the CRML 424B3 prospectus filing identifies its address as Deayton's corporate services office in Central, Hong Kong.⁴

On November 21, 2025, Swiss Commodity Re entered into an Asset Sale Agreement with Critical Metals Corp, selling 40 kilograms of copper powder described as 99.96% purity in exchange for 1,800,000 CRML ordinary shares at $10 per share, a 40% premium over the then-market price. The transaction closed on December 16, 2025.³ Malcolm Scott Macintyre, identified at the address 22 Faraday Avenue, Rose Bay, NSW 2029, Australia, received a separate allocation of 200,000 shares ($2 million) under the same agreement.³ Macintyre is Managing Director of Capella Capital, a Sydney infrastructure finance firm; his background is in transport and social infrastructure finance at Babcock & Brown and ABN AMRO, with no documented involvement in commodities or metals trading.⁷

The 424B3 prospectus (dated March 4, 2026) discloses that Swiss Commodity Re holds 1.5% of CRML's 122,074,807 outstanding shares, placing it below the 5% threshold that would require Schedule 13D or 13G beneficial ownership filings. There is therefore no SEC reporting mechanism that would disclose subsequent dispositions of these shares.³

Analysis of Deayton's professional background identifies no involvement in commodities trading, metals, mining, materials science, or defense supply chains at any point in his 50-year career.⁸ Hong Kong Corporate Services Group's services -- company formation, WFOEs in China, tax compliance, bookkeeping, payroll, and virtual offices -- are corporate administrative functions, not commodity operations.⁸ No direct connection between Deayton and Tony Sage (CRML's CEO and Executive Chairman) has been identified through overlapping boards, corporate registries, professional networks, or public records. The intermediary who introduced the transaction is unknown.⁹

Deayton began his career at the Hong Kong Inland Revenue Department, where he served for four years before moving to HSBC's head office as a tax consultant for seven years.¹ He then spent fifteen years as a partner at Deloitte Touche Tohmatsu in Hong Kong, specializing in corporate services.¹ After Deloitte, he founded Asian Financial Services Limited, a corporate services firm that was subsequently acquired by TMF Group, a Dutch multinational trust and corporate services provider. He also co-founded The Hong Kong Trust Company Group.¹

In 2001, Deayton established Hong Kong Corporate Services Group (HKCS Group), where he serves as Managing Director and CEO. The firm operates from 6th Floor, Wyndham Place, 40-44 Wyndham Street, Central, Hong Kong, and provides company incorporation, registered office and agent services, tax compliance, bookkeeping, payroll, and Wholly Foreign-Owned Enterprise (WFOE) setup in mainland China.¹ MarketScreener records connect Deayton professionally to Nimble Holdings, HSBC, Deloitte Touche Tohmatsu Hong Kong, Terra Capital PLC, and Asian Property Investments Ltd.¹⁰ His second-degree corporate network through co-directorships extends to Emerson Radio Corp (via Tak Kwong Hon), Sansui Electric Co Ltd, Singamas Container Holdings, CCT Fortis Holdings, and GBA Holdings.¹⁰

The ICIJ Panama Papers database records Deayton as shareholder of Newbury Investment Limited, a British Virgin Islands company incorporated on September 4, 1991, through Mossack Fonseca.⁵ Shareholding records span from September 1997 and August 2002. The registered address for Newbury Investment Limited was Unit F, 7th Floor, CNT Tower, 338 Hennessy Road, Wanchai, Hong Kong. Deayton's personal address in the Panama Papers is listed as Unit F3, Goodview Garden, 24 Stubbs Road, Hong Kong.⁵

Separately, the ICIJ Offshore Leaks database records Deayton as director of Richmond Holdings (BVI) Ltd, incorporated on July 26, 2001, through a different offshore services provider, Portcullis Trustnet (now Portcullis Group). Deayton served as director from July 2001 to April 2003.⁵ These are two distinct BVI entities established through two different service providers -- Mossack Fonseca (Panama Papers) and Portcullis Trustnet (Offshore Leaks) -- with overlapping timelines in the early 2000s.⁵

On May 30, 2016, Deayton was appointed independent non-executive director and chairman of the audit committee of The Grande Holdings Limited (HKEX: 0186, subsequently renamed Nimble Holdings Limited).⁶ The appointment coincided with the company's resumption of trading on the Hong Kong Stock Exchange following a period of provisional liquidation.⁶ Grande Holdings, through its subsidiaries S&T International Distribution Ltd and Grande N.A.K.S. Ltd, held a 72.4% controlling interest in Emerson Radio Corp (NYSE American: MSN), a US consumer electronics company.¹¹

Deayton's tenure ended in December 2017 when the Grande Holdings board was reconstituted under new controlling shareholder Tan Bingzhao.⁶ The audit committee chairmanship during a post-liquidation period placed Deayton in a governance role at a company transitioning through financial distress and change of control -- a role consistent with his CPA credentials and corporate services background.⁶