Investment Code: I Code

The Company recognizes our core responsibility to maintain and create investment value that provides long-term benefits for our customers under acceptable risk exposure and investment policies. We will conduct a thorough Fundamental Analysis of potential assets and effectively monitor the investments, social and environmental responsibilities, and ESG performance of Investee Companies.

2.1 Organization Structure

The Company has a team of specialists in investment management, marketing, operational support, and risk management. Each department has clearly defined job scopes and operates under separate chains of command.

Roles and Responsibilities

2.1.1) The investment management department is under the command of the Chief Investment Officer. The team is responsible for managing mutual funds and private funds in accordance with the Securities and Exchange Commission’s (SEC) issuance of product governance guidelines and is obliged to report to the Board of Directors.

The investment management department will not take part in making investment decisions pertaining to the benefit of the Company. This is to prevent any possible conflict of interest.

2.1.2) The Investment Committee (IC) is responsible for determining policies, direction of the Company, and investment strategies, as well as monitoring and assessing the funds to ensure they adhere to the investment policies.

2.1.3) The investment management department will keep the clients’ best interests in mind and monitor the investments, social and environmental responsibilities, and ESG performance of Investee Companies to ensure there are no misconducts in asset trading.

2.1.4) The investment management department is responsible for monitoring the Investee Companies to ensure they have good social and environmental governance.

2.1.5) The investment management department shall communicate with clients and adopt best practices for the entire duration of the investment, as well as disclose the investment code to all related parties.

2.1.6) The operational support and risk management teams are responsible for ensuring all processes are in accordance with the SEC’s standards and must report directly to the Audit Committee.

Managing Conflicts of Interest

2.2.1) The Company adopts a robust policy aimed at preventing conflicts of interests and establishing systems and controls that allow them to identify, minimize, and properly manage such conflicts should they arise.

• Proprietary Trading – The Company has investment guidelines set by the accounting department, which has no access to confidential fund data or information about the investment management chain of command.
• Staff Dealing Rules – Employees who are interested in trading must submit a buying request to the Company’s asset trading department.
• Cross Departmental Recruitment – The Company does not allow recruiting staff from other departments to work in the investment management team. For other cross departmental recruitments, a written consent form must be agreed upon by the managers of both departments, with the condition that the recruitment shall not cause any conflicts of interest.
• Churning – Fund managers will not trade excessively, and must carefully conduct the trade with the fund’s best interests in mind.
• Soft Commission – The Company is allowed to accept soft commission arising from transactions with third parties. The soft commission must be disclosed to the investor in accordance with the SEC’s regulations.
• Transactions with Related Parties – Cross-fund transactions are allowed, provided that the prices are appropriate and that the trade is in accordance with the SEC’s guidelines.

2.2.2) The Company has allocated separate space for the investment management team. The area can only be accessed by team members through fingerprint scanning.

2.2.3) The Company provides training programs so employees can effectively carry out the policies.

2.2.4) The Company has certain measures to track, control, and inspect every business process. It also has procedures in place for informing misconduct and penalties for policy violation.

2.2.5) The Company encourages communication with service providers to identify conflicts of interest, and has measures to manage and mitigate the impact of the conflict.

2.2.6) The Company regularly revises the suitability of policies and work processes.

3.1) The investment management team should have in place processes and procedures for active ongoing monitoring of the performance of Investee Companies to ensure that they become promptly aware of factors relevant to the value of the Investee Companies. Such procedures include creating asset analysis reports, monitoring the Investee Companies’ business performance, and reviewing the asset reports when there are significant changes in the market or government regulations.

3.2) The investment management team should take into consideration the commitment of Investee Companies to ESG principles, including corporate governance, and social and environmental responsibility.

3.3) The investment management team will actively monitor the performance of Investee Companies commensurate with the nature of their investments in order to become promptly aware of factors relevant to the value of the Investee Companies and the investments. Such monitoring should include news and research analysis, engagement with the Board of Directors and the Executives of the Investee Companies, and voting rights at the Investee Companies’ Annual General Meeting.

3.4) In the event that Investee Companies are found to have failed to comply with the Corporate Governance Code or ESG principles, or other risk factors that may affect the value of the Investee Companies and the durable return on investments have been identified, the Company’s investment management team will gather all the information and present their findings to the Investment Committee.

4.1) The Company has developed a policy with guidelines that indicate when and how to apply enhanced monitoring of and engagement with the Investee Companies in the event regular monitoring measures under Principle 3 are deemed insufficient to resolve risk factors identified. Early intervention by Institutional Investors should assist in preserving and restoring the value of investment in the relevant Investee Companies.

4.2) Events that warrant enhanced monitoring by Institutional Investors include investment value concerns resulting from:

• 4.2.1) Corporate strategies, business performance, and risk management
• 4.2.2) The Investee Company’s implementation of corporate governance principles
• 4.2.3) The Investee Company’s approach to social responsibilities and environmental governance principles

4.3) For additional procedures, the investment management team will progressively escalate their actions as deemed necessary, including by:

• 4.3.1) Formally notifying the Board of Directors

• 4.3.2) Engaging with the Chairman, Board of Directors, or other independent directors
• 4.3.3) Disclosing information to the public before the Annual General Meeting takes place
• 4.3.4) Notifying the Investee Companies of the Company’s voting decision prior to the Annual General Meeting and subsequently exercising voting rights at the relevant meetings
• 4.3.5) Requesting that the matters of concern identified be added to the agenda for the Annual General Meeting, which include removing or appointing Directors or Executives

4.4) In the event when the Company has obtained access to non-public information that may affect the price of the Investee Company’s securities, the Company shall implement measures to protect the confidentiality of such non-public price-sensitive information and to prevent the use of such information in violation of applicable laws

5.1) The Company has established clear policies and guidelines about voting rights, which have been approved by the Board of Director.

5.2) Disclosing the guidelines about exercising voting rights to investors should be done in accordance with the SEC’s regulations.

5.3) The Company should disclose the use of proxy voting or voting advisory services. The disclosure should include scope of proxy or advisory services used, names of the service providers, and statistics of votes exercised using advisory services.

6.1) The Company believes collaboration with other investors and stakeholders may be the most effective way to resolve concerns about business or ESG performance identified by the Institutional Investors. We have established a policy that indicates the circumstances in which the Investee Companies should seek and participate in formal or informal collective engagement.

6.2) The collective engagement must comply with applicable laws and regulations.

7.1) The investment management team will maintain effective record-keeping systems and keep records of how they discharge their investment duties and stewardship responsibilities in accordance with the Principles set out in this I Code. There will be mechanisms in place to ensure that information disclosed to clients and the public is accurate, complete, and not misleading.

7.2) The Company shall publicly disclose the Investment Governance Policy, procedures, and the level of compliance with the Policy and the Principles set out in the I Code through various channels, including the Company’s annual report or website.

7.3) The Company shall revise and improve the policies set out in this I Code biennially, or in accordance with the SEC’s new or changing regulations.