Stewardship

The order of interests is clear

Principle 1

The Company places investors' interests above those of the Company and its officers and employees, and does not favor or discriminate against any investor without reasonable grounds.

Our standards for handling conflicts of interest are public

Principle 2

Our conflict-of-interest prevention policy, information barriers between departments, and employee training are operated according to disclosed standards.

We consistently monitor the companies we invest in

Principles 3 and 4

We periodically review the financial matters of investee companies and, in the course of engagement, comply with the relevant laws, including the prohibition on the use of material non-public information.

Voting and activities are recorded

Principles 5 and 6

We record and manage our voting and stewardship activities and may report them to investors.

Responsible persons are designated

Principle 7

We designate the persons responsible for and in charge of fulfilling our stewardship responsibilities and list them on this page, and we operate the Compliance Officer and the Compliance Team as an independent compliance organization.

Principle1. Establishment and Disclosure of a Stewardship Policy

Institutional investors, as fiduciaries managing and operating the assets of others such as clients and beneficiaries, must establish and disclose a clear policy to faithfully fulfill their responsibilities.

[Implementation Plan]

• The Company places investors' interests above the interests of the Company and its officers and employees.
• The Company treats the interests of all investors equally and does not favor or discriminate against any particular investor without reasonable grounds.
• The Company faithfully fulfills its duty of care as a prudent manager in accordance with relevant laws and regulations, fund agreements, and internal regulations.
• The Company discloses this policy through its website and other channels.
• The Company discloses its management philosophy, corporate history, and founding background through its website.

Principle2. Establishment and Disclosure of a Conflict-of-Interest Prevention Policy

In the course of fulfilling its responsibilities as a fiduciary, an institutional investor must establish and disclose an effective and clear policy on how to resolve conflicts of interest that it actually faces or may potentially face.

[Implementation Plan]

• To resolve conflicts of interest that may arise in the course of fulfilling its stewardship responsibilities, the Company establishes and complies with internal control standards and conflict-of-interest prevention regulations.
• The Company appoints a Compliance Officer independent of the investment division to continuously review and supervise the potential for conflicts of interest.
• Where the possibility of a conflict of interest is recognized, the Company notifies the relevant investor in advance and proceeds with the transaction only after taking the necessary measures to ensure there is no issue with investor protection.
• The Company discloses this conflict-of-interest prevention policy through its website and other channels.
• The Company operates information barriers (Chinese Walls) between departments to fundamentally and structurally block the possibility of conflicts of interest.
• To raise awareness of the importance of conflict-of-interest prevention, the Company conducts related training for its officers and employees at least once a year.

Principle3. Periodic Monitoring of Investee Companies

Institutional investors must periodically monitor investee companies so as to enhance their medium- to long-term value and thereby preserve and increase the value of the invested assets.

[Implementation Plan]

• The Company establishes and operates an internal system for periodically monitoring the financial matters of investee companies.
• Where the monitoring results are deemed necessary to enhance the medium- to long-term value of an investee company, the Company may carry out additional engagement activities.
• Periodic monitoring may be conducted through various means, including company visits, review of disclosure materials, and use of research reports.

Principle4. Establishment of Internal Guidelines for Carrying Out Stewardship Activities

While aiming to build consensus with investee companies, institutional investors must, where necessary, establish internal guidelines on the timing, procedures, and methods for carrying out activities to fulfill their stewardship responsibilities.

[Implementation Plan]

• The Company establishes internal guidelines on the timing, procedures, and methods of its stewardship activities and carries out its activities accordingly.
• In the course of its stewardship activities, the Company strictly complies with relevant laws and regulations, including the FSCMA provisions prohibiting the use of undisclosed material information, and does not seek improper gains by using the inside information of investee companies.

Principle5. Establishment and Disclosure of a Voting Policy and Disclosure of Voting Records

Institutional investors must establish and disclose a voting policy that includes guidelines, procedures, and detailed criteria for the faithful exercise of voting rights, and must also disclose the specific details of, and reasons for, their voting so that the appropriateness of the exercise can be assessed.

[Implementation Plan]

• The Company adopts as a basic principle that voting rights are exercised with the interests of investors as the foremost priority.
• The Company may establish and disclose “Voting Guidelines” setting out the criteria and procedures for exercising voting rights.
• The Company records and manages its voting records and may report them to investors upon request.
• The Company establishes and operates guidelines on the exercise of voting rights and may, where necessary, refer to the opinions of external proxy advisory firms. However, the final decision rests with the Company's own responsibility and judgment.

Principle6. Periodic Reporting on Voting and Stewardship Activities

Institutional investors must periodically report to their clients and beneficiaries on their voting and stewardship activities.

[Implementation Plan]

• The Company records and manages its voting records and the status of its stewardship activities.
• The Company may report the status of its stewardship activities to investors at least once a year.
• However, where necessary, the Company may keep certain information undisclosed, taking into account the impact that disclosure of such information may have on investors' interests and corporate value.
• As a general private fund, the Company is not obligated to make public disclosures; nevertheless, it may report to investors and endeavors to maintain the transparency of its stewardship activities to the greatest extent possible.

Principle7. Securing the Capabilities and Expertise to Fulfill Stewardship Responsibilities

Institutional investors must possess the capabilities and expertise necessary to actively and effectively fulfill their stewardship responsibilities.

[Implementation Plan]

• The Company designates the specialized personnel (those in charge) necessary to fulfill its stewardship responsibilities and specifies the responsible persons and persons in charge in its documentation (including names and contact information).
• The Company establishes and operates an independent compliance organization, including a Compliance Officer and a Compliance Team.