You are advised to read Shenwan Hongyuan Research (H.K.) Limited's policy on Chinese Walls, confidential and inside information, and conflicts of interest (the “Policy”) as set out herein. This Policy provides minimum standards within Shenwan Hongyuan Research (H.K.) Limited to ensure that clients' and Shenwan Hongyuan Research (H.K.) Limited's data is properly dealt with and that clients are treated fairly in accordance with applicable laws and regulations.

Shenwan Hongyuan Research (H.K.) Limited endeavours to make effort to ensure that its employees understand the general ethical standards and adhere to comply with all applicable laws and regulations.

2.1 General

Shenwan Hongyuan Research (H.K.) Limited has established policies, procedures and arrangements, including physical arrangements, (collectively "Chinese Walls") designed to manage and safekeep confidential and inside information and prevent unauthorized spread and misuse of such information.

Chinese Walls function as a tool to separate areas that have access to inside information ("Insider Areas") from those who do not have such access ("Public Areas"). In other words, they are designed to serve as an effective system of functional barriers to prevent the inappropriate or unauthorized communication of information that may be confidential or price sensitive between one business activity and another business activity. Chinese Walls are also designed as a means of managing conflicts of interest.

The Policy on Chinese Walls prohibits employees in an Insider Area from communicating any confidential or inside information to employees in Public Areas, subject to limited exceptions approved by Shenwan Hongyuan Research (H.K.) Limited.

The policy also ensures that employees of Shenwan Hongyuan Research (H.K.) Limited within a Chinese Wall have a responsibility to ensure the Chinese Wall is not breached deliberately or inadvertently. Any reported breaches of the Chinese Walls will be dealt with as soon as reasonably practicable by Shenwan Hongyuan Research (H.K.) Limited.

The establishment of Chinese Walls does not suggest or imply free circulation of materials, confidential and inside information within Insider Areas. Circulation of such is on a 'need-to-know' basis.

Information of listed issuers is only considered public when it is made public either by the listed issuers or by a third party having the authority to do so.

2.2 Permanent Insiders

Certain employees of Shenwan Hongyuan Research (H.K.) Limited have by their function access to information from departments that are separated by Chinese Walls. In other words, they are considered as 'above the wall'. Another group of employees have the ability to transcend the Chinese Walls by their roles. Both groups of employees are referred to as "Permanent Insiders". Shenwan Hongyuan Research (H.K.) Limited will keep the number of Permanent Insiders to a minimum, document the list of Permanent Insiders and review the list from time to time and as necessary.

Permanent Insiders are restricted to carry out personal investment activities that accurately reflect their enhanced access to inside information. Permanent Insiders also bear the responsibility to ensure that inside information is not spread from Insider Areas to Public Areas.

Shenwan Hongyuan Research (H.K.) Limited have policy to ensure that all employees understand that they should treat confidential information as confidential and exercise due care when accessing, using, handling, storing and disposing of confidential information whether obtained from those with whom Shenwan Hongyuan Research (H.K.) Limited does business or from within Shenwan Hongyuan Research (H.K.) Limited. All such information is restricted for use for its intended purpose and must not be used for any other use or benefit.

Confidential information must be circulated on a strict 'need-to-know' basis and for a specified purpose only. Disclosure of confidential information is strictly prohibited and unless for the purpose of complying with applicable laws and regulations.

All policies regarding confidential information above apply also to Inside Information.

Shenwan Hongyuan Research (H.K.) Limited will ensure that employees handle Inside Information properly. This includes informing relevant departments of their receipt of inside information and erecting Chinese Walls where employees have regular access to inside information.

Where Chinese Walls arrangements are in place employees working within an Insider Area are prohibited from communicating any Confidential or Inside Information to employees in Public Areas without the prior approval of their local Compliance Officer.

Many jurisdictions prohibit insider trading and arrangement of trades in securities with Inside Information. Shenwan Hongyuan Research (H.K.) Limited will ensure that policies and/or procedures are in place designed to monitor insider trading or improper trading based on inside information. Furthermore, employees are explained to avoid passing along any inside information expressly or by way of making a recommendation for the purchase or sale of such securities based upon inside information. Both prohibitions reflect local laws and regulations on these topics.

Shenwan Hongyuan Research (H.K.) Limited will ensure that its employees will avoid acting or giving the appearance of acting in the presence of a conflict of interest. When a conflict of interest does exist, the employee shall report such conflict and keep it in record. Employees of Shenwan Hongyuan Research (H.K.) Limited also have a duty to ensure that Shenwan Hongyuan Research (H.K.) Limited should not unfairly place its interests above those of its Clients.

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