The Capital Company Hong Kong Limited (the “Company”) is domiciled in Hong Kong.  In Hong Kong, The Company conducts its financial advisory business through The Capital Company Hong Kong Limited, CE. No BIH055, which is licensed and authorized by the Securities and Futures Commission (SFC) to engage in advising on securities and asset management.  Regulated advice and RA4 or RA9 services will be governed by a “Client Advisory Agreement” or “Client Investment Management Agreement.” We conduct our insurance related business in Hong Kong through The Protection Company Hong Kong Limited, which is registered with the Confederation of Insurance Brokers (CIB).  Other Companies in the Group may be licensed for additional activities in Hong Kong or other jurisdictions.


The contents of this document have not been reviewed by the SFC and SFC authorization is not an official recommendation of the Licensed Corporation or its portfolios.  Investment involves risks, including the loss of principal. Past performance is not an indication of future performance. Investors are advised to consider their own investment objectives and circumstances in determining the suitability of an investment in any investment product or portfolio management service. If you are in any doubt, you should seek professional advice, including tax and legal advice. Investors should refer to any relevant prospectus for further details, including product features, risk factors and restrictions on owning and holding a portfolio or the underlying funds and ETFs that compose a portfolio. The information published on The Capital Company Group’s (the “Group”) website is should be used for information purposes and is subject to change.  The None of the information contained in this website constitutes financial or other professional advice in any way. If you require additional information, you should contact appropriate Group personnel.


The historical track record, performance, and related calculations shown in the Company’s fact sheets, strategy sheets, presentations, website and other materials are provided to show you how client accounts have performed in strategies managed by the current Responsible Officers and Partners of the firm.  The Company began offering asset management services at the beginning of 2017, continuing the strategies previously managed by partners at EXS Capital Asia Limited.  The Company manages investment strategies and may at some future date offer investment funds or other investment products to access these strategies. Please read performance related materials carefully and ensure all material queries are answered to your satisfaction prior to investing.


The Capital Company Hong Kong Limited is not registered or authorized to provide financial services in other jurisdictions, including the United States and Australia.  If you require investment or insurance services in the United States or Australia, we will refer you to our affiliates in those jurisdictions.   In China, the information contained in this document does not constitute a public offer of any investment products in the People’s Republic of China (the “PRC”). No investment service or portfolio is being offered or sold directly or indirectly in the PRC to the PRC public. Further, no legal or natural persons of the PRC may directly or indirectly purchase any investment portfolios or any beneficial interest therein without obtaining all prior governmental approvals that are required by the PRC (which includes conducting due approval or registration or filing formalities under the PRC laws), whether statutorily or otherwise. Persons who come into possession of this document are required to observe these restrictions.


This document is for discussion purposes only and is not an offer to sell or the solicitation of an offer to buy securities, insurance or other financial products.   These materials are for distribution only to potential investors who are authorized to receive them and in a jurisdiction where the Company is authorized to do business. No offer to sell (or solicitation of an offer to buy) will be made in any jurisdiction in which such offer or solicitation would be unlawful.


This publication is not, nor is it intended to constitute, an advertisement or expected performance of any investment product and is no guarantee of future returns. This publication is not intended for public use or distribution. The information in this publication was developed using both publicly available and proprietary data that we assumed to be accurate; nevertheless, we accept no liability and offer no guarantee as to its being correct at any time and explicitly disclaim any responsibility arising therefrom. The contents of this publication can be changed without prior notice. The Company expressly disclaims all liability for representations, expressed or implied, contained in, or omissions from the attached information.  In addition, certain of the information contained in this document has been obtained from sources outside of the Capital Company Hong Kong Limited.   No part of this document may be reproduced or shared without the permission of the Company.  Please contact the Company with any questions.

Site Disclaimer

The information published on The Capital Company Group’s (the “Group”) website is should be used for information purposes and is subject to change. The None of the information contained in this website constitutes financial or other professional advice in any way. If you require additional information, you should contact appropriate Group personnel.


While we use reasonable efforts to ensure that the information contained on its website is current and accurate at the date of publication, no warranties are made, either expressed or implied, as to reliability, accuracy or completeness of the information. The Capital Company Group accepts no liability for any loss arising directly or indirectly from the use of or action taken in reliance on such information. No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programs or macros.


Links from this website exist for information only and the Group accepts no responsibility or liability for the information contained on any such site. The existence of a link to another website does not imply or express endorsement of its provider, product or services by The Capital Company Group. For any questions or concerns, please contact us at wealth@capital-company.com or +852-3468-8880.


The Company is not registered or authorized to provide financial services in other jurisdictions, including the United States and Australia. If you require investment or insurance services in the United States or Australia, we will refer you to our affiliates in those jurisdictions. These affiliates are regulated by the Securities and Exchange Commission (SEC) in the USA and the Australian Securities and Investments Commission (ASIC) in Australia and will require separate Engagement Letters and will invoice separately from The Company. The Company may receive referral fees or share expenses with these affiliates as allowed by the appropriate local regulator; however the Company is not responsible for advice or services provided by those affiliates, as we are not authorized in those jurisdictions.

Terms & Conditions

We work to ensure that the Group’s websites operate properly at all times. We make no warranties as to the availability or accessibility of the web site, and (save as otherwise set out in these terms and conditions) we will not be liable for any damages, loss, costs or expenses incurred by you from any lack of availability or accessibility of the web site.


We may use information obtained about you from cookies (files which are sent by us to your computer or other access device) which are created when you visit our site. The type of cookies we use only give us information about which pages you have visited – they do not store any personal information about you. We use the information gathered to help improve your experience of using the site. For any questions or concerns, please contact us at wealth@capital-company.com or +852-3468-8880.


The Capital Company Hong Kong Limited – CE No. BIH055
The Protection Company Hong Kong Limited – Reg No 0442
Lucky Building 23rd Floor, 39 Wellington Street, Central, Hong Kong
Tel: +852-3468-8880
Email: wealth@capital-company.com

Privacy Policy

Update on Use of Personal Data

To comply with the Part VI A under the Personal Data Privacy Amendment (www.pco.org.hk) Ordinance 2012 and other related government ordinances which may apply to privacy, we would like to bring your attention to our privacy policy as stated below.



We collect personal information to open your account(s), to process your transactions and to help us provide a better level of service. We do not sell your personal information to anyone.


We protect the security and confidentiality of the personal information we collect. Our relationship with you is our most important asset. We understand that you have entrusted us with your private financial information, and we do everything we can to maintain that trust.


This Privacy Policy Statement (“Statement”) is in accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (the “Ordinance”). The Statement is intended to notify you what personal data is collected and why, how it will be used, how long we keep the data, what are our security measures and how access requests are to be addressed. “Personal data” means any personally identifying information as more particularly defined in the Ordinance.


Details of our approach to privacy and how your personal information is collected and used are set forth below.


The Capital Company Hong Kong Limited Group Privacy Policy

The Capital Company Hong Kong Limited, The Protection Company Hong Kong Limited and other companies in the Capital Company Group (hereafter the “Group”) privacy policy applies to consumers who are current or former. Throughout the policy, we refer to information that personally identifies you or your accounts as “personal information.”


Our privacy policy is as follows:

1. We do not sell your personal information to anyone.

2. We do not disclose personal information to third parties, unless one of the following limited exceptions applies:


We disclose personal information to companies that help us process or service your transactions or account(s), including companies that print and mail your account statements.


In order to serve you better, we may disclose personal information, such as account and transaction data, to affiliates and other companies we work with on your behalf, including financial institutions. We have contracts with these companies that prohibit them from using your personal information for their own purposes.


We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, resolve consumer disputes, perform credit and authentication checks, or for institutional risk control.

Outside of these exceptions, we will not share your personal information with third parties without your prior approval.


3. We do collect personal information in the normal course of business in order to administer your accounts and serve you better.

We collect information that you provide to us when you open an account or register for one of our services, such as online or branch seminars, or when you accept a promotional offer for product or service offered the Group or one of its affiliates. The information we collect may include name, address, phone number, email address, Social Security or tax file numbers, and information about your interests, investments, and investment experience. We also may collect information from consumer reporting agencies.


When we collect it

Submission by you: This information is collected when you fill out forms including on-line forms, or respond to one of our e-mail notices, provide us with your business card, write to us or give us information orally.


What we do with it

  • Data collected with Application Forms/Registration Forms/Contact Information Forms: We’ll keep track of your address. Other information is gathered so that we can communicate with you.

  • When you ask for a Password: If you’re asked for some information when you apply for a password to secure pages, it’s only used to generate a password and communicate it to you.

  • If you’re interested in Web page Subscriptions: When you subscribe to a page, we use your email address only to send you information, newsletters or correspondence.

  • Information collected by IP Address and by cookies: This information is used by us for broad demographic data, to produce aggregated information about the number and types of visitors to our site and to ensure that we’re delivering the information you want.

Security Measures

All of this material is kept confidential and we will endeavor to protect it from unauthorized or accidental access or processing. We maintain this security by implementing appropriate physical, electronic and managerial means to secure your personal data. Our web servers are protected behind “firewalls” and our systems are monitored from time to time for unauthorized access.


How you can control your information.

You can choose to “opt out” of any electronic mail by clicking the “unsubscribe” button at the bottom of your email or contact us directly.

Should you wish to be removed from our mailing database at any time, or if you feel we have inaccurate or outdated information about you, please contact us. By contacting us you can update information about yourself, opt out of outside mailings, or choose to be removed from the list altogether.


Contacting us

If you have any questions about this Statement, our practices or your dealings with this site, please contact us at +852-3468-8880 or wealth@capital-company.com

Risk Disclosure


We are pleased that you (“you, or “the “Client”) wish to
appoint us, The Capital Company Hong Kong Limited (“the Company” or the
“Manager”), CE. No. BIH055, also known as the Capital Company, to
manage on a discretionary basis various assets (including proceeds of sale thereof
and additional cash deposits) (together, the “Assets”) in a tailored
portfolio (the “Portfolio”) contributed by the Client into a tailored
portfolio management account (the “Account”) operated by a third
party custodian (the “Custodian”) appointed by you.

The financial markets present many different risks of which investors
should be aware prior to investing. It is the policy of the Manager to draw
customer’s attention to those particular risk factors which make certain
investments higher risk and/or more complex than standard investments. Assets
that may be characterized as “riskier” and/or more complex, include
derivatives, forward contracts, options, structured products, hedge funds,
private equity funds, and unlisted investments in emerging markets. If a Client
is a Retail Client, the Company will not include these riskier assets in the
Portfolio. The Company will also not engage in Options trading for Retail
Clients. For any Retail Client, the investment advice would be limited to
mutual funds (excluding hedge funds), exchange traded funds (ETFs) and single
listed stocks.

The product descriptions and the risks disclosed in this document are
illustrative of those faced by your Account, not exhaustive. For example, it
does not deal with risks associated with a particular issuer or counterparty,
your tax exposure, aspects relating to transaction costs, specific country
risks, etc.

While as your discretionary Manager, we will only invest in Assets that
we believe are suitable for you, each Asset in which you invest may have its
own particular risks. This document does not purport to disclose all the risks
which may exist, nor does it purport to provide you with tax or legal advice.
You should therefore ensure that you are able to assess and understand each
Asset and you may wish to consult with independent qualified investment, legal
and tax advisers prior to investing through the Account.

This document forms part of the Investment Management Agreement for the
Account entered between you, the Client, and us, as Manager (the
“Agreement”). Insofar as you wish us to provide you with the service
governed by the Agreement, you confirm that you have received, read and
understood the content of this Risk Disclosure document as it relates to such
service. Terms not otherwise defined in this document, have the meaning
attributed to them in the Agreement. Should you require any further information
or explanation regarding any of the investments or risks referred to in this
document, you should contact the Manager.


Market Risk

The value of investment instruments can be affected by many things
including fluctuations in interest rates, changes in the global/local economy
and political environments, and movements in the price of underlying
securities, etc. Hence, the risks arising from fluctuations in the price of
investment instruments should be drawn to the attention of [clients /investors
and] the Company itself. For some investment products, such as debt securities,
the fluctuation of the prices may not be that material during any single
trading day, if there is no unexpected event being happened. Yet for some
equity stocks, the prices during any single trading day may be rather volatile
due to some market information related to the listed company. Sometimes it is
unavoidable, but by employing some stop-loss mechanism, such risks may be
relieved to a certain extent. The research and analysis for economy, market
environment and products are also helpful in reducing the market risks. Staffs
in charge of portfolio decision making and strategy implementation will assess
the market situation from time to time in order to find out whether there are
unexpected event being happened or will be happened, in order to analyse the
associated risks.

Potential Loss of investment

Investment through an
Account entails a high degree of risk and is suitable only for investors who
fully understand and are capable of bearing the risks of such investment. The
Client should carefully consider the merits and risks of investing in the
Portfolio in accordance with the Investment Guidelines as described in the
Agreement. There can be no assurance that the Account will be able to achieve
its Investment Objective or that investors will receive a return of their
capital. Accordingly, an investment should be made only by those persons who
can sustain a loss for their entire investment. As a non-traditional
investment, Account is suitable only for a limited portion of the Client’s
overall portfolio. The Account does not purport to constitute a complete
investment program, but rather only to serve as a diversification alternative
intended to complement the Client’s other holdings.

Operational risks

The Company has prudent internal controls and
operational procedures in order to minimize the operational risk. All the
employees must strictly comply with the policies and procedures and the Company
has surveillance for compliance. During the operation process, most of the
documents must be reconciled by an authorized person with their signatures. The
Company has a Compliance Officer, who is based in Hong Kong and will oversee
the audit function. Moreover, special review will be initiated where there are
problems in the business. The Company also engages an external auditor and
accounting support staff to assist with overseeing operations and identifying
operational risks. The Company has a Management and Compliance committee who
meets at least quarterly to review all company records, financials, portfolios
and any recommendations related to risk management and operational risk.

General trading risks

All investments
present a risk of loss of capital. The Manager’s investment program may utilise
such sophisticated investment techniques as option transactions, margin
transactions, short sales and contracts for differences, which practices can,
in certain circumstances, multiply the adverse impact to which the Portfolio
may otherwise be subject. No guarantee or representation is made that the
Manager’s investment program will be successful.

General economic conditions

The success of any
investment activity is affected by general economic conditions, which may
affect the level and volatility of prices as well as the liquidity of the
markets. The prices of many securities and derivative instruments are highly
volatile. The price movements of the instruments which will be acquired for the
Portfolio are influenced by, among other things, interest rates, changing
supply and demand relationships, the trade, fiscal, monetary and exchange
control programs and policies of governments, and national and international
political and economic events. For example, in light of the recent financial
turmoil, regulators in various jurisdictions have imposed restrictions on short
selling which includes in some jurisdictions a ban on naked short sales. The
profitability of the Portfolio could be adversely affected by a worsening of
general economic conditions globally or in certain individual markets. Factors
such as interest rates, inflation, investor sentiment, the availability and cost
of credit, the liquidity of the global financial markets and the level and
volatility of equity prices could significantly affect the profitability level
of the Portfolio. For example:

an economic downturn or significantly higher interest rates could adversely
affect the credit quality of the Assets comprised in the Portfolio;

a market downturn or worsening of the economy could cause the Portfolio
to incur substantial losses; and

a market downturn would be likely to lead to a decline in the volume of
transactions that the Portfolio executes for its Clients and, therefore lead to
a decline in the income it receives.

Governments from time
to time intervene, directly and by regulation, in certain markets, particularly
those in currencies and interest rates, disrupting strategies focusing on these
sectors. On the other hand, certain strategies are “long” volatility, and their
profit potential is severely diminished or eliminated in settled market
conditions. Unexpected changes (in either direction) in the volatility or
liquidity of the markets could cause significant losses.

Effect of Governmental Policy and Regulation

The Portfolio’s
investments can be affected by the fiscal or other policies and other actions
of various governmental and regulatory authorities in Hong Kong, mainland
China, and elsewhere. Areas where changes could have an impact include:

the monetary, interest rate and other policies of central banks and
regulatory authorities;

general changes in government or regulatory policy that may significantly
influence investor decisions in particular markets in which the Account

general changes in the regulatory requirements, for example, prudential
rules relating to the capital adequacy framework and rules designed to promote
financial stability and increase depositor protection;

changes in competition and pricing environments;

further developments in the financial reporting environment; and

expropriation, nationalisation, confiscation of assets and changes in
legislation relating to foreign ownership.

Each strategy
selected will be unlikely to achieve its objectives under certain market
conditions, conditions which may prevail for substantial periods of time after
the Account begins operating or allocates assets to a particular strategy.


The following sets
out some of the risk factors associated with the Investment Guidelines.

Success of Portfolio

The performance of
the Portfolio will depend on the success of the Investment Guidelines.
Exploitation of the Investment Guidelines involves uncertainty. No assurance
can be given that suitable investment opportunities in which to deploy all of
the Account’s capital will be located. A reduction in the volatility and
pricing inefficiency of the markets in which the Manager will seek to invest,
as well as other market factors, will reduce the scope for the Manager’s
investment strategies. The Manager may employ certain strategies that depend
upon the reliability and accuracy of the Manager’s analytical investment
processes. To the extent such investment processes (or the assumptions
underlying them) do not prove to be correct, the Portfolio may not perform as anticipated,
which could result in substantial losses.

Distressed investing

The Portfolio may be
invested in securities and private claims and obligations of entities that are
experiencing significant financial or business difficulties. The Portfolio may lose
all or a substantial portion of its investment in such distressed companies or
may be required to accept cash or securities with a market value of less than
the initial investment. One of the risks of investing in distressed entities is
the difficulty of obtaining information as to the true condition of such
issuers. Distressed company investments may also be adversely affected by state
and federal laws relating to fraudulent conveyances, voidable preferences,
lender liability and a court’s discretionary power to disallow, subordinate or
disenfranchise particular claims. The market prices of such securities are also
subject to erratic changes and above-average price volatility, and the spread
between the bid and offer prices of such securities may be greater than
normally expected.

Investments in undervalued securities

The Portfolio may be
invested in securities that the Manager believes to be undervalued. The
identification of investment opportunities in undervalued securities is a
difficult task, and there are no assurances that such opportunities will be
successfully recognised or acquired. While investments in undervalued
securities offer the opportunity for above-average capital appreciation, these
investments involve a high degree of financial risk and can result in
substantial losses. Returns generated from the Portfolio’s investments may not
adequately compensate for the business and financial risks assumed. In
addition, such securities may need to be held in the Account for a substantial
period of time before realising their anticipated value. During this period, a
portion of the Portfolio capital would be committed to the securities
purchased, thus possibly preventing the Manager from investing in other

Portfolio Concentration

Subject always to the
Investment Restrictions, it is possible that the Manager might take substantial
positions in the same or related markets at or about the same time, reducing
the Portfolio’s diversification and increasing risk.

Limitations on Hedging Techniques

The Manager will
seek to employ various hedging techniques to reduce systematic and unsystematic
risks. A substantial risk remains, nonetheless, that such techniques will not
always be available or available at a reasonable cost and when available, will
not always be effective in limiting losses.


Generally, we do not
recommend that leverage is used. However, where requested by the Client,
certain forms of leverage may be used. Leverage must be provided by the
Custodian and the Custodian may impose their own limitations or restrictions on
the use of Leverage.

Financial leverage
includes buying securities on margin. In addition to direct borrowings from
banks, the Manager may employ strategies that include the use of financial
leverage, such as the use of options, and other derivative securities, or other
forms of leverage or credit. The Manager may also engage in short sales. While
leverage presents opportunities for increasing total return, it has the effect
of potentially increasing losses as well. Accordingly, any event which
adversely affects the value of a Portfolio investment would be magnified to the
extent leverage is employed in relation to the Portfolio. The cumulative effect
of the use of leverage in a market that moves adversely to a leveraged
investment could result in a substantial loss, which would be greater than if
leverage were not used.

The risk of loss in
financing a transaction by deposit of collateral is significant. The Client may
sustain losses in excess of the cash and any other Assets deposited as
collateral with. Market conditions may make it impossible to execute contingent
orders, such as “stop-loss” or “stop-limit” orders. The
Client may be called upon at short notice to make additional margin deposits or
interest payments. If the required margin deposits or interest payments are not
made within the prescribed time, the collateral may be liquidated without the
Client’s consent. Moreover, the Client will remain liable for any resulting
deficit in its account and interest charged on its account. The Client should
therefore carefully consider whether such a financing arrangement is suitable
in light of its own financial position and investment objectives.


The Manager is to a
certain extent restricted as to the percentage of the Assets that are invested
in any particular instrument or market in order to optimise the risk-reward
profile of the Portfolio. To the extent, the Manager concentrates the Portfolio
investments in a particular issuer, security or market sector, the Portfolio
investments will become more susceptible to fluctuations in value resulting
from adverse economic or business conditions affecting that particular issuer,
security or market.

Emerging markets

The Manager will
invest the Portfolio into emerging markets. Such investments involve risk
factors and special considerations which may not be typically associated with
more developed markets. Political or economic change and instability may be
more likely to occur and have a greater effect on such creditors. Adverse
government policies or actions, taxation, restrictions on foreign investment
and on currency convertibility and repatriation, currency fluctuations and
other developments in the laws and regulations of emerging countries, including
expropriation, nationalisation, temporary or continuing freeze of assets or
confiscation could result in loss to the Portfolio. The legal infrastructure
and accounting, auditing and reporting standards in emerging markets may not
provide the same degree of investor information or protection as would
generally apply to creditors in more major markets.

Liquidity of investments

The Manager may make
investments for the Portfolio in markets that are volatile and which may become
illiquid. Accordingly, it may be impossible (in the event of trading halts or
daily price fluctuation limits on the markets traded or otherwise) or expensive
for the Manager to liquidate positions against which the market is moving. Alternatively,
it may not be possible in certain circumstances for a position to be initiated
or liquidated promptly (in the event of insufficient trading activity in the
relevant market or otherwise).

3.10      Foreign exchange risks

A large portion of
the Portfolio may be invested in financial instruments denominated in
currencies other than the currency of the Account and in other financial
instruments, the price of which is calculated with reference to currencies
other than the currency of the Account. The Portfolio, however, will be valued
in the currency of the Account as agreed between you and the Custodian. The
Portfolio may also be invested in currencies or financial instruments seeking a
foreign exchange exposure. To the extent that such exposure is unhedged, the
value of the Assets will fluctuate with exchange rates as well as with price
changes of the Portfolio’s investments in the various local markets. Foreign
exchange rates can fluctuate considerably, exposing the Portfolio to
significant financial losses.

Interest rate risks

The Manager may make
investments that are exposed to interest rate risks. To the extent prevailing
interest rates change, to a larger extent or in a different way than
anticipated by the Manager, the Portfolio could suffer significant financial
losses. Increases in interest rates may also affect the Portfolio’s borrowings,
having a negative impact on the Portfolio’s profitability.

3.12       Transactions in other jurisdictions

Transactions on
markets in other jurisdictions, including markets formally linked to a domestic
market, may create exposure to additional risk. Such markets may be subject to
regulation which may offer different or diminished investor protection. The
Client should familiarise itself with any relevant rules. The local regulatory
authority will be unable to compel the enforcement of the rules of regulatory
authorities or markets in other jurisdictions where the transactions have been
effected. The Manager may use securities, including stocks, bonds and exchange
traded funds that listed on exchanges in other jurisdictions and are
unauthorized for SFC purposes.

3.13       Trading facilities

Electronic trading
facilities are supported by computer-based component systems for the
order-routing, execution, matching, registration or clearing of trades. As with
all facilities and systems, they are vulnerable to temporary disruption or
failure. The Client’s ability to recover certain losses may be subject to
limits on liability imposed by the system provider, the market, the clearing
house and/or participant firms. Such limits may vary.

3.14       Electronic trading

The Company will not
employ its own electronic trading system. Where the Company uses third party’s
systems as part of its electronic trading, it will perform appropriate due
diligence on such systems; and keep records of its design and development and
modifications; and the relevant agreements with the third party in place, in
particular, release of system R&D information to the relevant regulator,
and technical support/training to users. Trading on an electronic trading
system may differ from trading on other more conventional trading systems and/or
platforms. Transactions on an electronic trading system, will create exposure
to risks associated with the system including the failure of hardware and
software. The result of any system failure may be that the order is either not
executed as instructed or is not executed at all.

3.15       Off-exchange transactions

In some
jurisdictions, and only then in restricted circumstances, parties are permitted
to effect off-exchange transactions. Such parties may be acting as a
counterparty to the transaction. It may be difficult or impossible to liquidate
an existing position, to assess the value, to determine a fair price or to
assess the exposure to risk. For these reasons, these transactions may involve
increased risks. Off-exchange transactions may be less regulated or subject to
a separate regulatory regime. The Client should familiarise itself with
applicable rules and attendant risks.


The following sets
out some of the risk factors associated with the investments made for the


Equities invested in
by the Portfolio may involve substantial risks and may be subject to wide and
sudden fluctuations in market value, with a resulting fluctuation in the amount
of profits and losses. The price of a security may move up or down, and may
become valueless. It is likely that losses will be incurred rather than profit
made as a result of buying and selling securities. Privately placed securities
and other illiquid securities held for the Account may be difficult to sell, be
saleable only at a substantial discount or upon registration with a regulator,
and present valuation difficulties.

Trading Options

The Company does not utilize
Options strategies in most Portfolios. Trading options by the Portfolio may
involve substantial risks. Market conditions may make it impossible to execute
such orders. In some circumstances, losses may be in excess of the initial
margin. Placing contingent orders, such as “stop-loss” or
“stop-limit” orders, will not necessarily avoid loss. Market
conditions may make it impossible to execute such orders.

The purchaser of
options may offset or exercise the options or allow the options to expire. The
exercise of an option results either in a cash settlement or in the purchaser
acquiring or delivering the underlying interest. If the purchased option
expires worthless, the Client will suffer a total loss of the investment which
will consist of the option premium plus transaction costs. The possibility that
deep-out-of the money options become profitable is ordinarily remote.

The Client may be
called upon at short notice to deposit additional margin funds. If the required
funds are not provided within the prescribed time, the Client’s position may be
liquidated. The Client will remain liable for any resulting deficit in its
account. Strategies using combinations of positions, such as “spread”
or “straddle” positions may be as risky as taking simple
“long” or “short” positions.

Selling (“writing” or
“granting”) an option generally entails considerably greater risk than
purchasing options. Although the premium received by the seller is fixed, the
seller may sustain a loss well in excess of that amount. The seller will be
liable for additional margin to maintain the position if the market moves

The seller will also
be exposed to the risk of the purchaser exercising the option and the seller
will be obligated to either settle the option in cash or to acquire or deliver
the underlying interest.

Market conditions
(e.g. illiquidity) and/or the operation of the rules of certain markets (e.g.
the suspension of trading in any contract or contract month because of price
limits or “circuit breakers”) may increase the risk of loss by making it
difficult or impossible to effect transactions or liquidate/offset positions.
Where options have been sold, this may increase the risk of loss. Further,
normal pricing relationships between the underlying interest and the futures,
and the underlying interest and the option may not exist. This can occur when,
for example, the futures contract underlying the option is subject to price
limits while the option is not.

The absence of an
underlying reference price may make it difficult to judge “fair
value”. The Client is advised to study and understand options before
trading and carefully consider whether such trading is suitable in the light of
its own financial position and investment objectives. The Client should inform
itself of exercise and expiration procedures for options and its rights and
obligations upon exercise or expiry.

Margin Trading

Leverage utilized in Margin Trading must be
provided by the Custodian and the Custodian may impose their own limitations or
restrictions on the use of Margin or Leverage.  The Manager does not provide any form of
margin or securities lending. The risk of loss in financing a transaction by
deposit of collateral is significant. You may sustain losses in excess of your
cash and any other assets deposited as collateral with the licensed or
registered person. Market conditions may make it impossible to execute
contingent orders, such as “stop-loss” or “stop-limit”
orders. You may be called upon at short notice to make additional margin
deposits or interest payments. If the required margin deposits or interest
payments are not made within the prescribed time, your collateral may be
liquidated without your consent. Moreover, you will remain liable for any
resulting deficit in your account and interest charged on your account. You
should therefore carefully consider whether such a financing arrangement is
suitable in light of your own financial position and investment objectives.


The Manager may use
derivatives, such as options. Substantial risks are also involved in borrowing
and lending against derivatives. Derivatives prices can be volatile, market
movements are difficult to predict and financing sources and related interest
rates are subject to rapid change. One or more markets may move against the
derivatives positions held for the Account, thereby causing substantial losses.
Many of these instruments are not traded on exchanges but rather through an
informal network of banks and dealers who have no obligation to make markets in
them and can apply essentially discretionary margin and credit requirements
(and thus in effect force the Manager to close out positions for the
Portfolio). In addition, some derivatives carry the additional risk of failure
to perform by the counterparty to the transaction. Many unforeseeable events,
such as a change of government policies, can have profound effects on interest
and exchange rates, which in turn can have large and sudden effects on prices
of derivative instruments.

Forward contracts

The Manager (acting
as agent on behalf of the Client) may enter into forward contracts and options
thereon, which are not traded on exchanges and are not standardised. Rather,
banks and dealers act as principals in these markets, negotiating each
transaction on an individual basis. Forward and “cash” trading is
substantially unregulated; there is no limitation on daily price movements and
speculative position limits are not applicable. The counterparties who deal in
the forward markets are not required to continue to make markets in the
currencies or commodities they trade and these markets can experience periods
of illiquidity, sometimes of significant duration. There have been periods
during which certain participants in these markets have refused to quote prices
for certain currencies or commodities or have quoted prices with an unusually
wide spread between the price at which they were prepared to buy and that at
which they were prepared to sell.

Disruptions can occur
in any market traded by the Manager due to unusually high trading volume,
political intervention or other factors. The imposition of controls by
governmental authorities might also limit such forward trading to less than
that which the Manager would otherwise recommend, to the possible detriment of
the Portfolio. Market illiquidity or disruption could result in major losses to
the Portfolio.


The Manager may buy
and sell options for the Portfolio, and there are various risks inherent in
such trading. For example, the seller (writer) of a covered call option (e.g.
the writer has a long position in the underlying security) assumes the risk of
a decline in the market price of the underlying security to a level below the
purchase price of the security, less the premium received on the call option.
The writer of a covered call option also gives up the opportunity for gain on
the underlying security above the exercise price of the call.

The writer of an
uncovered call option assumes the risk of a theoretically unlimited increase in
the market price of the underlying security above the exercise price of the
option. The buyer of a call option assumes the risk of losing the premium
invested in the option. The seller (writer) of a covered put option (e.g. the
writer has a short position in the underlying security) assumes the risk of an
increase in the market price of the underlying security above the sales price
(in establishing the short position) of the underlying security plus the
premium received, and gives up the opportunity for gain on the underlying
security below the exercise price of the option less the premium received on
the put option. The seller of an uncovered put option assumes the risk of a
decline in the market price of the underlying security below the exercise price
of the option. The buyer of a put option assumes the risk of losing the premium
it paid to purchase the put option. The options markets have the authority to
prohibit the exercise of particular options, which if imposed when trading in
the option has also been halted, would lock holders and writers of that option
into their positions until one of the two restrictions has been lifted.

Hedge Fund Risks

Some hedge funds often engage in leveraging, short-selling and other speculative
investment practices that involve a high degree of risk, can be illiquid, are
not required to provide periodic pricing or valuation to investors, are not
subject to the same regulatory requirements as other mutual funds or collective
investment schemes, often charge high fees, and in many cases the underlying
investments are not transparent and are known only to the investment manager.

Past performance of any fund is not necessarily indicative of future
results. The Client should only commit risk capital to a fund investment. Hedge
funds are alternative investment products and are not for everyone as they
entail risks that are different from more traditional investments. An
investment in such a fund is not intended to be a complete investment programme
for any investor and the Client should carefully consider whether an investment
in the hedge fund is suitable in the light of the Client’s own circumstances,
financial resources and entire investment programme.

A Client who wishes to invest in such funds should be aware that:

(a)         Funds are speculative
and may use leverage and as a result the Client’s returns may be volatile.

(b)         With respect to single
manager funds the fund’s manager has total trading authority. The use of a
single manager could mean a lack of diversification and higher risk. With
respect to fund of funds, the fund’s manager has complete discretion to invest
in various sub-funds without disclosure thereof to the Client. Because of this
lack of transparency, there is no way for the Client to monitor the specific
investments made by the fund or to know whether the sub-fund investments are
consistent with the fund’s historic investment philosophy or risk levels.
Investors are not always informed about planned strategies, and changes to them
or of changes to portfolio managers. Hedge funds are not subject to any
disclosure requirements.

(c)         Unlike traditional
collective investments, hedge funds have limited liquidity and may generally
only be redeemed at restricted times, such as once a month, quarterly or even
only annually. Similarly, investors can normally only invest in a hedge fund at
specific times. There are generally long notice periods for redemptions and
long lock-up periods (during which investors are obliged to leave their capital
in the fund).

(d)         There is no secondary
market for the interests. Transfers of interests are subject to limitations.
The fund’s manager may deny a request to transfer if it determines that the
transfer may result in adverse legal or tax consequences for the fund.

(e)         Delays may occur, and
unfavorable prices may result, when settling buy and sell orders for hedge fund
units. There is no guarantee that investors will be able to enforce their

(f)          Hedge fund managers
are not generally required to be licensed by any authority and are largely
unregulated. In particular, hedge funds are not subject to the numerous
investor protection regulations that apply to authorized collective
investments. These include rules on liquidity, redemption of fund units at any
time, avoiding conflicts of interest, fair prices for fund units, disclosure
and limitations on borrowing.

Since these rules do not apply to hedge funds, they can use much more
leverage than traditional authorized funds, and engage in complex investment
transactions that are not permitted for traditional collective investments. A
hedge fund is allowed to adopt aggressive strategies, including the widespread
use of short selling, leverage, swaps, arbitrage, derivatives and programme
trading. Their investment strategies are often highly complex and very lacking
in transparency. The investor will often receive little or no information about
changes of strategy that may lead to a significant increase in risk, or receive
such information only at a late stage.

As part of their investment strategy, hedge funds can also use
derivatives such as futures, options and swaps that may be listed on an
exchange but do not have to be. These instruments may be subject to significant
price volatility, resulting in a high risk of loss for the fund. The low
margins typically required to build up a position in such instruments mean that
high levels of borrowing can be used. Depending on the instrument, a relatively
small change in the price of the contract can therefore lead to a large profit
or loss in comparison with the capital lodged as collateral and hence to
further, unforeseeable losses that can exceed any margin cover.

Synthetic Exchange-Traded Funds (ETFs) and
Related Products

The principal
objectives of ETFs are to track the performance of an underlying index or group
of assets. ETFs may carry additional risks which derive from the nature of the
product and which may not be immediately obvious to the investor. In
particular, although this is not intended to be a definitive disclosure of all
possible risks, the Client should consider the following risks which may be
inherent in the nature of ETFs:

Market risk: Investors are exposed to the political, economic, currency
and other risks related to the synthetic ETF’s underlying index.

Counterparty risk: Where a synthetic ETF invests in derivatives to
replicate the index performance, investors are exposed to the credit risk of
the counterparties who issued the derivatives, in addition to the risks
relating to the index. Further, potential contagion and concentration risks of
the derivative issuers should be taken into account (e.g. since derivative
issuers are predominantly international financial institutions, the failure of
one derivative counterparty of a synthetic ETF may have a “knock-on”
effect on other derivative counterparties of the synthetic ETF). Some synthetic
ETFs have collateral to reduce the counterparty risk, but there may be a risk
that the market value of the collateral has fallen substantially when the
synthetic ETF seeks to realize the collateral.

Liquidity risk: A higher liquidity risk is involved if a synthetic ETF
involves derivatives which do not have an active secondary market. Wider
bid-offer spreads in the price of the derivatives may result in losses.

Tracking error: There may be disparity between the performance of the
synthetic ETF and the performance of the underlying index due to, for instance,
failure of the tracking strategy, currency differences, fees and expenses.

Trading at a discount or premium: Where the index/market that the
synthetic ETF tracks is subject to restricted access, the efficiency in unit
creation or redemption to keep the price of the synthetic ETF in line with its
net asset value (“NAV”) may be disrupted, causing the synthetic ETF
to trade at a higher premium or discount to its NAV. Investors who buy a
synthetic ETF at a premium may not be able to recover the premium in the event
of termination.

Growth Enterprise Market Stocks

Growth Enterprise
Market (“GEM”) stocks involve a high investment risk. In particular,
companies may list on GEM with neither a track record of profitability nor any
obligation to forecast future profitability. GEM stocks may be very volatile
and illiquid. The Client should make the decision to enter into the Agreement
only after due and careful consideration. The greater risk profile and other
characteristics of GEM mean that it is a market more suited to professional and
other sophisticated investors. Currently information on GEM stocks may only be
found on the internet website operated by The Stock Exchange of Hong Kong
Limited. GEM companies are usually not required to issue paid announcements in
gazetted newspapers. The Client is advised to seek independent professional
advice if you are uncertain of or have not understood any aspect of the nature
and risks involved in trading of GEM stocks.

4.10      NASDAQ-AMEX Securities

The securities under
the Nasdaq-Amex Pilot Program (“PP”) are aimed at sophisticated
investors. The Client should become familiarised with the PP before trading in
the PP securities and should be aware that the PP securities are not regulated
as a primary or secondary listing on the Main Board or the GEM of The Stock
Exchange of Hong Kong Limited.

4.11       Structured securities

The risks associated
with structured finance transactions and obligations may be subject to
prepayment risk, credit risk, liquidity risk, market risk, structural risk,
legal risk and interest rate risk (which may depend upon any associated hedge
agreement providing for the exchange of interest accruing on the security being
repackaged into interest stated to be payable on the trust certificates or
similar securities). In addition, the performance of a structured finance
obligation will be affected by a variety of factors, including the level and
timing of payments and recoveries on and the characteristics of the underlying
repackaged securities, remoteness of those assets from the originator or
transferor and the adequacy of and ability to realise upon any related

4.12       Competition

The investment
industry is extremely competitive and involves a high degree of risk. The
Manager will compete with firms, including many of the larger investment and
commercial banking firms, which may have substantially greater financial
resources and research staff.


The following are
some of the risks associated with the Manager and other service providers to
the Account.

Operating History

The success of the
Portfolio is significantly dependent upon the expertise of the management team.
While the key professionals of the Manager have considerable investment
experience, the Manager itself has a relatively short history of managing
accounts. Any future unavailability of their services to the Account could have
a material adverse impact on the Portfolio’s performance.

Counterparty risk

To the extent that
contracts for investment will be entered into between the Client (acting
through the agency of the Manager) and a market counterparty as principal (and
not as agent), the Portfolio is exposed to the risk that the market
counterparty may, in an insolvency or similar event, be unable to meet its
contractual obligations to the Client.

Because certain
purchases, sales, financing arrangements (including the lending of portfolio
securities) and derivative instruments in which the Manager will engage for the
Portfolio are not traded on an exchange but are instead traded between
counterparties based on contractual relationships, the Client is subject to the
risk that a counterparty will not perform its obligations under the related
contracts. Although the Client intends to enter into transactions only with
counterparties which have been approved by the Manager (acting as agent on behalf
of the Client) under the aspects of creditworthiness, and will pursue its
remedies under any such contracts, there can be no assurance that a
counterparty will not default and that the Portfolio will not sustain a loss on
a transaction as a result.

System Risks

The Manager relies to
a significant extent on computer systems and software and other service
providers to develop and execute investment strategies, analyse investment
opportunities, price the Portfolio’s assets, execute and settle trades, and conducting
risk and operational controls. Such systems and software may be subject to
errors, defects, interruptions or failure. In the event of such malfunction,
the Portfolio may incur significant losses to the extent its or its service
providers’ ability to evaluate, make, hold, monitor, or dispose of investments,
or to monitor risks and operations is affected. The Manager may not be in a
position to verify the accuracy of the operation or results of the systems used
by it or other service providers and may rely on erroneous computations or
data, causing losses to the Portfolio. The Manager and other service providers
are generally not liable to the Portfolio for such system malfunction unless
caused by their own gross negligence, wilful default or fraud.

Risk Control Framework

No risk control
system is fail-safe, and no assurance can be given that the risk control
framework designed and maintained by the Manager will achieve its objective
Although all theories and valuation models applied are constantly challenged to
ensure that the original thesis is correct they may, if proven wrong, not be as
quickly discarded as to hinder materially adverse effects of such theories and

Reliance on information from Custodian and
third parties

In order to value the
Assets of the Portfolio, the Manager will rely on information provided by the
Custodian or outside parties, and such persons may provide inaccurate,
incomplete, not current or otherwise unreliable information. To the extent the
information received by the Manager is inaccurate or unreliable, the valuation
of the Portfolio and its Assets may be inaccurate and cause losses to the
Portfolio and the Client.

Assets received or held outside of Hong Kong

Assets received or
held by the Custodian or other intermediaries outside Hong Kong are subject to
the applicable laws and regulations of the relevant overseas jurisdiction which
may be different from the Securities and Futures Ordinance (Cap.571) and the
rules made thereunder. Consequently, such Assets may not enjoy the same
protection as that conferred on client assets received or held in Hong Kong.

Suspension of Trading

Securities exchanges
typically have the right to suspend or limit trading in any instrument traded
on the exchanges. A suspension could render it impossible for the Manager to
liquidate positions and thereby expose the Portfolio to losses.

Misconduct of service providers

Misconduct of the
employees of the Manager, the Custodian, the prime broker and other service
providers could cause significant losses to the Portfolio, including the
unauthorised entering into transactions, the failure to comply with operational
and risk procedures, the use of sensitive information for personal trading
activities, the non-compliance with applicable law or regulations, and the
concealing of the foregoing, and may result in reputational damage, litigation,
business disruption and/or financial losses to the Portfolio, for which the
relevant service provider may not be liable at all or only to a limited extent.

Repledging Securities Collateral

There is a risk in
providing the Manager with a standing authority that allows it to apply the
Account’s securities or securities collateral pursuant to a securities
borrowing and lending agreement, repledge any Assets’ collateral for financial
accommodation or deposit the securities collateral as collateral for the
discharge and satisfaction of its settlement obligations and liabilities.

If your securities or
securities collateral are received or held by a Hong Kong-based Custodian, the
above arrangement is allowed only if the Client consents in writing to the
standing authority. Moreover, unless you are a professional investor, your
authority must specify the period for which it is current and be limited to not
more than 12 months. If you are a professional investor, these restrictions do
not apply.

Additionally, your
authority may be deemed to be renewed (i.e. without your written consent) if
the Manager issues you a reminder at least 14 days prior to the expiry of the
authority, and you do not object to such deemed renewal before the expiry date
of your then existing authority.

You are not required
by any law to sign this authority. However, your authorisation may be required,
for example, to facilitate margin lending to you or to allow your securities or
securities collateral to be lent to or deposited as collateral with third
parties. The Manager will explain to you the purposes for which one of these
authorisations is required.

If you sign such
authorisation and your securities or securities collateral are lent to or
deposited with third parties, those third parties will have a lien or charge on
your securities or securities collateral. Although the Manager is responsible
to you for securities or securities collateral lent or deposited under your
authority, a default by it could result in the loss of your securities or
securities collateral.

A cash account not
involving securities borrowing and lending is available from most Custodians.
If you do not require margin facilities or do not wish your securities or
securities collateral to be lent or pledged, do not sign the above authority
and ask your Custodian to open this type of cash account.

5.10      Institutional risks

Institutions, such as
brokerage firms or banks, may have custody of the Assets for the Client. These
assets will often be registered in a “street name”, not in the name
of the Client or Custodian. Bankruptcy or fraud at one of these institutions
could impair the operational capabilities or the capital position of the

Absence of regulation

The Manager itself is
not licensed with any regulatory body other than as a Licensed Corporation with
the Securities and Futures Commission in Hong Kong.

The Account may be
subject to the Investment Management Fee, the Performance Fee and certain other
fixed and contingent costs payable irrespective of profitability. Such fees
costs and expenses will adversely affect the Net Asset Value and are not
subject to regulation or review by any regulatory body.

5.12       Potential conflicts of interest

The Manager does not
and does not intend to utilize a Performance Fee structure in portfolios.  Prospective investors should note that where
a Performance Fee is payable:

the fact that the Performance Fee is payable only in respect of increases
in the value of the Assets may create an incentive for the Manager to make or
recommend investments that are riskier or more speculative than would be the
case if it were compensated solely based on a flat percentage of capital; and

the Manager may receive increased compensation because the Performance
Fee (if any) will be calculated on a basis which includes unrealised
appreciation as well as realised gains.

In addition, Assets
that are not admitted to official listing on any stock exchange or dealt on any
other recognised exchange, or, assets admitted to official listing on any stock
exchange or dealt on any other recognised exchange whose last available price
is, in the opinion of the Manager, not representative of their fair market value,
will be valued based on the reasonably foreseeable sales price determined
prudently and in good faith by or under procedures established by the Manager
(after consultation with the Custodian).

5.13       Commission and other charges

The Company does not
intend to accept commissions, rebates, soft commissions or retrocessions. The
Company intends to only accept fees directly from the Client.

Commission, fees and
other charges for which the Client will be liable will affect your Net Asset
Value and ultimately the Client’s profit (if any) or loss. Any receipt by the
Manager of cash or money rebates (including soft commission) from brokers or
dealers in respect of transactions for the Account may be retained by the
Manager only if fully disclosed to the Client.
The Client should familiarise itself with all fees and other charges for
which it is liable or that will be paid to the Manager and the Custodian.



There are certain tax
risk factors associated with entering into this Agreement and any decision to
enter into this Agreement should be made only after consultation with a
qualified independent tax adviser. The Manager will not provide tax advice.

Legal investment risks

Many of the laws that
govern private and foreign investment, securities transactions and other
contractual relationships in certain countries in which the Portfolio will be
invested are new and largely untested. As a result, the Portfolio may be
subject to a number of unusual risks, including inadequate investor protection,
contradictory legislation, incomplete, unclear and changing laws, ignorance or
breaches of regulations on the part of other market participants, lack of
established or effective avenues for legal redress, lack of standard practices
and confidentiality customs characteristic of developed markets and lack of
enforcement of existing regulations. Furthermore, it may be difficult to obtain
and enforce a judgment in certain countries in which Assets are invested. There
can be no assurance that this difficulty in protecting and enforcing rights
will not have a material adverse effect on the investment made for the

In addition, the
income and gains of the Portfolio may be subject to withholding taxes imposed
by foreign governments for which the Client may not receive a full foreign tax

Terrorist Action and Cyber Crime

There is a risk of
terrorist attacks around the world causing significant loss of life and
property damage and disruptions in global markets. Economic and diplomatic
sanctions may be in place or imposed on certain states and military action may
be commenced. The impact of such events is unclear, but could have a material
effect on general economic conditions and market liquidity. Cyber Crime is a
risk. The Company maintains a Cybersecurity policy to attempt to prevent Cyber
Crime. Cyber Crime can create significant personal and business losses for
affected businesses and systems.

Legal and regulatory risks

The regulation of the
international currencies, securities, credit and derivatives markets has
undergone substantial change in recent years, and such change is expected to
continue for the foreseeable future. The effect of regulatory change on the
Portfolio, while impossible to predict, could be substantial and adverse.


Risk and consequence of being treated as a
Professional Investor (PI)

The Manager does not
treat most Clients as PIs.  For Clients
who elect to be treated as a PI, please refer to the Professional Investor
Assessment for the new Professional Investor details and requirements as well
as the extract of section 15.4 and 15.5 of the revised Code of Conduct for
persons registered with the SFC. If the Company solicits the sale of or
recommendation for any financial product to a Client (who is not a CPI or IPI),
including the Company’s RA9 discretionary portfolio asset management service,
the financial product (or discretionary portfolio) must be reasonably suitable
for the Client having regard to the Client’s financial situation, investment
experience and investment objectives. No other provision of this agreement or
any other document the Company asks a Client to sign and no statement made by
the Company or any of its Representatives may ask a Client derogates from this

Risk of providing an authority to hold mail
or to direct mail to third parties

If you provide the Manager with the authority
to hold mail or to direct mail to third parties, it is your responsibility to
promptly collect in person all contract notes and statements of your account
and review them in detail to ensure that any anomalies or mistakes can be
detected in a timely fashion.

Personal Data Privacy Ordinance

Pursuant to the
Personal Data (Privacy) Ordinance (the “Ordinance”), the following information
is provided to you in connection with your dealings with and provision of data
or information to the Capital Company Limited or its subsidiaries and
affiliates from time to time (“the Capital Company”).   In addition, please also review the sections
in your CMA on FATCA, GDRP and CRS, as these pieces of global legislation have
an impact on our agreement and the required data retention and record keeping.

Please be aware that
this Personal Information Collection Statement (the “Statement”) replaces any
notice or statement of similar nature that may have been provided to you
previously. The Capital Company is committed to maintaining your personal data
in accordance with the requirements of the Ordinance and will take all
reasonable steps to ensure that your personal data is kept secure against
unauthorized access, loss, disclosure and destruction.

From time to time, it is necessary for clients and various other
individuals (“data subjects”) to supply the Capital Company with data in
connection with various matters, and it is generally not obligatory for a data
subject to provide personal data to the Capital Company.

Although provision of personal data is not obligatory, failure to supply
such data may result in the Capital Company being unable to continue services
to clients and various other individuals or comply with any laws or guidelines
issued by regulatory or other authorities.

Data relating to the data subjects are collected or received by the
Capital Company from time to time in the ordinary course of the Capital
Company’ relationship with them, for example, when data subjects attend
seminar/events or generally communicate verbally or in writing by data subjects
with the Capital Company.

The purposes for which data relating to a data subject may be used will
vary depending on the nature of the data subject’s relationship with the
Capital Company. They may comprise any or all of the following purposes:

the processing of applications for an account with and/or other
financial services provided by the Capital Company;

enabling the Capital Company to ensure the daily operation of the
services provided to the data subjects;

researching, designing and launching financial, investment, securities
services or related products for data subjects’ use;

promoting and marketing services and products subject to your exercise
of the opt-out right (please see further details in paragraphs (e) & (k)

providing alerts, newsletter and investment education materials
requested/signed up by the data subjects;

meeting the disclosure and compliance requirements under any laws or
regulatory requirements applicable to the Capital Company or any of its
affiliates in Hong Kong or elsewhere from time to time;

complying with any law binding or applying to the Capital Company within
or outside of Hong Kong;

any purpose related to the administration of the products offered by the
Capital Company or the data subject’s participation therein; and

purposes directly related or incidental to the above, including seeking
professional advices.

Use of Data in Direct Marketing: The Capital Company may use the data
subject’s data in direct marketing and the Capital Company requires the data
subject’s consent (which includes an indication of no objection) for that
purpose. In this connection, please note that:

the name, contact details, products and services portfolio information,
transaction pattern and behavior, financial background and demographic data of
the data subject held by the Capital Company from time to time may be used by
the Capital Company in direct marketing;

the following classes of services, products and subjects may be marketed
in direct marketing: (1) financial, investment, securities and related services
and products; (2) reward, loyalty or privileges programs, promotional offers
and related services; and (3) invitations to financial and investment

Data collected may be maintained for such period as may be required
under applicable laws or as otherwise needed to fulfil any of the purposes set
out in paragraph (d) above.

Data held by the Capital Company relating to a data subject will be kept
confidential but the Capital Company may provide such information to the
following parties whether inside or outside Hong Kong for the purposes set out
in paragraph (d):

the Capital Company’ group companies;

the service providers of the Capital Company including the registrar,
transfer agent, the custodian, administrative service agent, distributors,
securities and investment service providers and the auditor of each products
offered by the Capital Company;

any agent, contractor or third party service provider who provides
administrative, research, design, launch, telecommunications, printing, letter
shopping, mailing, computer, payment, securities clearing and settlement or
other services to the Capital Company in connection with the operation of its

the intermediaries of the Capital Company including third party
financial institutions (e.g. banks, independent financial advisors, insurers),
third party product issuers, correspondent banks which may handle or process
payment to/from data subjects;

the employees, officers, directors and agents of the Capital Company;

any other party (including but not limited to, any regulatory
authorities, governmental authorities, tax, law enforcement authorities)
entitled thereto by law or regulation.

Under the Ordinance, any individual has the right:

to check whether the Company holds data about him or her, and of access
to such data;

to require the Capital Company to correct any data relating to him or her
which is inaccurate;

to ascertain the Capital Company’ policies and practices in relation to
data and to be informed of the kind of personal data held by the Capital
Company; and

to object to the use of his/her personal data for marketing purposes and
the Capital Company shall not use his/her personal data for marketing purposes
after he/she communicates his/her objection to the Capital Company.

In accordance with the terms of the Ordinance, the Capital Company has
the right to charge a reasonable fee for the processing of any data access

Nothing in this Statement shall limit the rights of the data subject
under the Ordinance.

You may exercise your opt-out right by notifying the Company if you wish
to object to the use of your personal data for direct marketing purposes. The
person to whom such objections, requests for access to data, correction of data
or for information regarding policies and practices and kinds of data is the
Compliance Officer on duty at the Capital Company in writing as noted below.

Any further questions about the Risk Disclosure Document, the CMA, and the Investor Risk Profile and
any other matters should be directed in writing to the Capital Company Compliance
Officer in writing at the address below or on email at jessica@capital-company.com.
Clients are requested to make any material queries in writing to the Compliance
Officer to document the query and ensure appropriate resolution and write to:


The Capital Company Hong Kong Limited

Attention: The Compliance Officer

Lucky Building, 23rd

39 Wellington Street


Hong Kong