A. Description of the Advisory Firm Incorporated in September 2008 in Hong Kong, HGI is a wholly-owned subsidiary of Harvest Fund Management Co., Ltd (“HFM”). HGI has been registered with the SFC in Hong Kong pursuant to the Hong Kong Securities and Futures Ordinance to conduct the regulated activities of 1) advising on securities (Type 4) and asset management (Type 9) since February 2009, and 2) dealing in securities (Type 1) since November 2010. Our parent company was incorporated in 1999 and is a significant investment firm headquartered in Beijing, China. The owners of HFM are China Credit Trust Co., Ltd, Lixin Investment Co., Ltd and DWS Investments Singapore Limited. More information is available in our Form ADV Part 1. We provide discretionary portfolio management services to our clients, sometimes with the assistance of HFM, serving as the investment adviser to pooled investment vehicles (“funds”) sponsored by other financial firms. We also provide investment advisory services on behalf of sophisticated institutional investors to separately managed accounts. We categorize our services as Fund Advisory and Separate Accounts. We may in future provide portfolio management services to funds sponsored by HFM and may serve certain high net worth individuals. While client investment mandates vary, our investment focus is largely on Asia, in certain cases predominantly on China, with limited amounts of investment in other markets. We may invest client assets across a range of investment classes, but, generally, investment focuses on equity and fixed income securities. We may also invest in derivative instruments, most often for hedging and portfolio management purposes. More information on the strategies we utilize, and the risks often associated with them, can be found in Item 8. Clients or investors should also consult the relevant offering document or investment supervisory agreement for a more complete discussion of risks and investment strategies. In each case, we will provide services to our clients according to an executed Investment Management Agreement detailing client-imposed investment guidelines and, if applicable, restrictions. Client Assets As of December 31, 2019, we manage the following assets: Discretionary Assets (US$'000) US$ 4,154,424 Non-discretionary Assets (US$'000) US$ 80,702 Total US$ 4,235,126 please register to get more info

Fee Schedule We do not currently impose a standard fee upon our clients. Fees are as described in a particular Investment Management Agreement. As a rule, fees can be expected to vary based on factors including the complexity of the mandate, the amount of assets under management, the client’s investment strategy and objective, whether the mandate is discretionary or non-discretionary and other factors. In our sole discretion, we may vary the fee structure for certain large or strategic investors, including affiliates, and for HGI employees. We may also vary the fee structure in connection with promotional efforts or for other business development reasons. A. Timing and Payment of Fees Typically, management fees and performance fees (where applicable) are payable in arrears based upon the market value of the assets at the end of the preceding billing period. The billing period is negotiable depending upon the types of the mandate. Clients are generally billed for their management fees and performance fees (where applicable). The timing of fee payments may be negotiated with each client and typically is set forth in the applicable Investment Management Agreement (for a separate account) or in the relevant fund’s governing documents. Asset-based fees generally are paid monthly, quarterly or semi- annually.

Other methods of payment and calculation may also be available, where appropriate or upon a client’s request. B. Clients are Responsible for Third Party Fees There are other types of fees or expenses clients may pay in connection with our advisory services, such as custodian fees or transaction costs. For example, clients may pay costs such as brokerage commissions, wire transfer fees, and other fees and taxes charged to brokerage accounts and securities transactions, which are unrelated to the fees we charge. please register to get more info

transactions and determining the reasonableness of their compensation (e.g., commissions and/or spreads). C. Prepayment of Fees We collect our fees in arrears. We do not collect our fees in advance. D. Outside Compensation for the Sale of Securities to Clients Neither we nor our employees accept compensation, including sales charges or service fees, from any third-party for the sale of securities or other investment products. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We may have performance-based fee arrangements with certain of our clients from time to time. Performance-based fee arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. These fee arrangements also create an incentive to favor higher fee paying accounts over other accounts in the allocation of investment opportunities. We have designed and implemented procedures to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. ITEM 7 – TYPES OF CLIENTS We may provide services to a variety of client types. Clients include:  Corporations; and  Pooled investment vehicles, including US and non-US public investment companies for retail investors and private investment funds. The relative percentage each client type currently represents is available on our Form ADV Part 1. The actual mix of types of clients may change over time based upon market conditions, business plans and other factors. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Our methods of analysis and investment strategies vary between the three investment universes we cover. Chinese Equities 1.1 OVERVIEW OF INVESTMENT PROCESS 1.1.1 TOP DOWN GAA VIEW Investment Process Framework: TOP DOWN INVESTMENT PROCESS
• The Investment Strategy and Asset Allocation Committee pulls together key investment personnel to generate and research key top down strategic investment ideas – “Macro Overlay”.
• Macro & GAA strategists research on global and local macro themes, discover key market drivers and provide asset allocation view.
• Specialists provide individual asset class insights.
• Quantitative analyst uses various quantitative tools to identify opportunities and risks.
• Portfolio strategies that deviate from market style can result in substantial tracking error
• The committee is responsible for identifying market style
• Style deviation and downside risk of each investment strategies are measured
• Dynamic risk management refers to identifying downside risks of a portfolio strategy associated with market style tilts THE TOP DOWN APPROACH BY GAA 1) Monitor global fund flows, macro policies, market movements for the entire investment universe 2) Direct short to medium term investment views across the HGI investment platform together with the CIO and asset classes specialists FOUR-STEP GAA RESEARCH PROCESS TAA & SAA ASSET ALLOCATION MODEL 1.1.2 BOTTOM UP FUNDAMENTAL RESEARCH We are convinced that over the long term market prices are oriented on “fundamental values”. For this reason, we follow an investment process that is based on our own, in-house, fundamental evaluation of each stock. The investment process can be defined by the following 4 steps: IDEA GENERATION IDEA VERIFICATION IDEA IMPLEMENTATION RISK MANAGEMENT Ideas are generated via our Macro Overlay, fundamental research and quantitative screenings. Our investment universe comprises both core coverage stocks and alpha ideas.
Due-diligence checks are conducted while assumptions are being challenged. Views on stocks are expressed via stock ratings. Target price is measured by the core-CFROI valuation methodology and conventional valuation measures.
We aim to capture all our high conviction quality ideas consistently across all our client portfolios within the risk control parameters and permitted investment guidelines. Investment strategies are tested against style tilts.
Systems and checks are in place to monitor market risk and credit risk as well as build an effective and sound control environment across products and departments.
Investment strategies are tested against style tilts.
(I) Idea Generation – Research is key IDEA POOL INDEX AND NON-INDEX IDEAS COREALPHA BROAD UNIVERSE MACRO OVERLAYFUNDAMENTAL RESEARCHCFROI*

*Cash flow return on investment Fundamental research is another area where we are keenly focused. We view company visits as the core of our investment process because it allows us to evaluate the quality of management properly from both a micro and macro perspective. The focus of sector and stock analysts will be on both qualitative issues (corporate governance, management quality, firm’s overall competitive position and its relative strengths and weaknesses), as well as quantitative issues (return on capital employed, cash flow generation), when evaluating a business. As one of the leading asset managers, Harvest has significant contact with company management, suppliers, clients and competitors as well as maintains regular contacts with key decision- makers in listed companies. This enables us to get access to precious insights of company management and provides us with a firm understanding of the actual underlying drivers of a company’s long-term earnings potential. On average, over 300 companies are visited each year. Our investment universe consists of stocks within the MSCI China Index and other alpha accretive stocks that fit the strategy’s investment objective. During this stage, around 200 stocks are identified. Research Driven Investment Flow Chart STOCK FOCUS LIST SELECTION PROCESS
• We believe that alpha ideas generated by bottom up in depth research work will make our performance to stand out among peers.
• Stock focus list consists those stocks that we have strong conviction on next one to two years’ share price performance hence we can build a sizable position in our portfolio. Candidates could be quality growth companies, deeply undervalued companies with turn around possibility or reform catalysts.
• 2-3% Overweight in portfolio

(II) Idea Verification We take both a qualitative and a quantitative approach in our analysis and put much emphasis on fundamental research. To enhance our fundamental research, we undertake quantitative screening using the HOLT system on a monthly basis as well as use the Linker-Thinker tool to do financial modeling. During this stage, around 150 stocks will be studied in depth and a stock pool (our focus coverage) with both core stock pool and alpha stock pool will be generated:  Core stock pool: includes companies with relatively large market capitalization and good liquidity. It covers about 80% of market capitalization of the MSCI China index.  Alpha stock pool: includes middle to small size companies, companies with emerging importance (sub-sector leaders) and companies with short to mid-term catalysts. The criteria we use include market capitalization higher than USD 100m and daily turnover higher than USD 0.5m. Our central belief is that ultimately cash flow and Cash Flow Return On Investment (CFROI) which will determine share prices over the medium and long term. Therefore, we focus our efforts on identifying superior growth opportunities at reasonable valuations. We use the Linker Thinker tool for valuing securities which allows further analysis on the drivers for liquidity, cash flow return on investment, asset growth and competitive environment. Based on the CFROI concept, this tool analyzes the life cycle of the company in a disciplined manner which distinguishes it from other typical discount cash flow model. Cash Flow and CFROI is our core belief  Ultimately cash flow and Cash Flow Return On Investment (CFROI) will determine share prices over the medium and long term.  The Linder-Thinker tool allows analysis on the drivers for liquidity, cash flow return on investment, asset growth and competitive environment.  The CFROI concept analyzes the life cycle of the company in a disciplined manner. Cash Flow Return On Investment (CFROI) Although CFROI is a primary valuation methodology that we utilize especially for the non-financial sectors, we also believe that no isolated, single valuation approach allows a full understanding of a company. We, therefore, supplement the discounted cash flow analysis with other conventional valuations tools which best suit the nature of the company’s business model, for example, P/E (Price-to-Earnings Ratio) and EV/EBITDA (Enterprise Value to Earnings Before Interest, Taxes, Depreciation and Amortization). Other valuation tools The aforesaid model is utilized for particular sectors including consumer, telecom, Internet, healthcare, utility and industrial, which have relatively steady cash-flow streams. We do not use the model for financial companies (including bank, insurance and property), cyclical stocks (including commodity, airlines and shipping), and conglomerates. For these companies, we utilize other valuation methodologies including P/E (Price-to-Earnings Ratio), P/B (Price-to-Book Ratio), P/EV (Price to Embedded Value), and NAV (Net Asset Value). Focus coverage – Research Output The outputs of our analysis are stock ratings (1, 2, 3, 4 for both short-term and long-term) and recommendations. Below are our stock rating outputs: In our recommendations, we specify investment opinions, horizon, catalysts, target prices (target returns) and potential risk. The rating will be tracked continuously as well as updated once the catalyst plays out, and any fundamental changes such as change of the company’s strategy would trigger a review of the rating. Around 110 stocks are covered in this stage. Rating Analysis
• Conviction rating – The rating (1) Strong Outperform, (2) Outperform, (3) Underperform, and (4) Strong Underperform will be made relative to country benchmark based on time horizon of 12 months.
• Risk-reward target – The companies within the same conviction rating category will be differentiated by the risk-reward target (upside price versus downside price), and a fundamental score.
• Risk adjusted return is our guiding principle – Every unit of risk should be compensated with more units of upside potential. – We prefer a stock with share price of 30% upside and 10% downside than another with 60% upside with 30% downside.
• Fundamental Hexagon score – Weighted by 6 “right” attributes – growth, value, competitiveness, leverage, management/corporate governance and free cash flow. – Lower correlation to the movements in the financial markets. We believe that in times of market volatility, we can look beyond the noise to focus on these attributes. Team work Culture to Drive Performance – high frequency of investment meetings In addition, the following is the small cap selection process: (III) Idea Implementation The functions of research and portfolio management are combined. Our portfolio managers and research analysts are responsible for research and stock selection within their areas of responsibility, while the portfolio managers work as a team in portfolio construction. The key factors for portfolio construction are:  Capturing the highest conviction ideas o Portfolio construction aims to capture all our highest conviction ideas (i.e. Strong Outperform) within the stipulated country and sector limits. o Strong Outperform rating should have an active bet of at least 100-300 bps.  Other signals (risk-reward, fundamental score) o We pick the stocks from the coverage list based on other signals such as risk- reward target and fundamental score. o We do not express a view in the portfolio on a company with a poor management score even if it has a chance of tactical outperformance. o We may be contrarian at times on out-of-favor stocks especially those with good corporate stewardship and attractive risk-reward profile even if there are no specific share price catalysts.  Country and Sector limits o Country and sector limits.
• Country overweight limits to be not more than 5% or 2x the country weighting in the benchmark (whichever is the lower).
• Sector overweight limits to be not more than 8% or 3x the sector weighting in the benchmark (whichever is the lower).  Monetary policy and political-social stability o We emphasize the importance of monetary policy and political-social stability in the Asian markets. Our Investment Strategy and Asset Allocation Committee provide the overlay for our positions in Asian markets.  In general, positions will be sold or reduced if: o Changes to the original investment theme, trend and sentiment occur. o Fundamental situation worsened, specific to companies or sectors. o Unfavorable changes to management, ownership or corporate strategy. o Positive fundamental development is reflected by the share price. o Superior prospects in other countries/sectors/stocks. o Holding exceeds risk budget However, selling is not automatically triggered by these events but need good explanation to maintain positions We review if stock price underperforms the sector and country benchmark by >10% since initiation of position (IV) Risk Management Risk Management The goal of investment risk management is to monitor and analyze the investment risks and ensure timely communication with portfolio managers and senior management. To achieve this goal, the risk management team has dedicated resources to oversee and monitor HGI’s Morningstar Direct and Matlab  HGI RISK MANAGEMENT PROCESS  RISK IDENTIFICATION - Dynamic risk management For a more detailed write-up on risk management, please refer to Section 6 below. 1.2 TRADE MANAGEMENT All trades are processed through our automated Guideline Checking System  Pre-deal checking/warnings  Post deal breach exception report  Our dedicated compliance department monitors guideline compliance with client, regulatory and internal guidelines on an ongoing basis Investment guidelines are coded into the compliance module of the trading system and the Compliance Team is responsible for the pre-trade/post-trade compliance checks. Portfolio managers will be notified of any identified errors and breaches immediately and are required to take remedial actions in accordance with the requirements of the client mandates and regulations, taking the clients’ best interest into consideration. Compliance with investment guidelines is also monitored independently by an automated back-end system. This system monitors trades and portfolios post execution verifying that specific account/fund guidelines, regulatory requirements and risk exposure limits are followed. Exceptions identified through this process are escalated for proper resolution on a timely basis. Asian Equities The investment process can be defined by the following 4 steps: IDEA GENERATION IDEA VERIFICATION IDEA IMPLEMENTATION RISK MANAGEMENT Ideas are generated via our macro and thematic overlays, supply-chain analysis and quantitative screenings. Our investment universe comprises both core coverage stocks and alpha ideas.
Due-diligence checks are conducted while assumptions are being challenged. Views on stocks are expressed via stock ratings. Target price is derived via the core-CFROI valuation methodology or a combination of conventional valuation measures.
We aim to capture all our high conviction quality ideas consistently across all our client portfolios within the risk control parameters and permitted investment guidelines.
Systems and checks are in place to monitor market risk and credit risk as well as build an effective and sound control environment across products and departments.
Investment strategies are tested against style tilts.
(I) Idea Generation The investment universe is made up of stocks within the MSCI AC Asia ex Japan universe and alpha accretive stocks that fit the portfolio’s investment objective. Setting out with the aim to generate key top down strategic investment ideas – “Macro Overlay”, the Investment Strategy and Asset Allocation Committee musters our key investment personnel including the CIO, Macro & Global Asset Allocation (GAA) Strategists, Asset Classes Specialists and Quantitative Analyst. To better illustrate, Macro & GAA Strategists are responsible for the research on global and local macro themes, discovering key market drivers and providing asset allocation views; Asset Classes Specialists are to provide individual asset class insights, while the Quantitative Analyst uses various quantitative tools to identify opportunities and risks. IDEA POOL INDEX AND NON-INDEX IDEAS CORE 150-200 companies ALPHA 100-150 companies BROAD UNIVERSE (approximately 500 companies) MACRO & THEMATIC OVERLAY VALUATIONS CFROI* LIQUIDITY CIO Macro & GAA Strategists Quantitative Analyst Asset Classes Specialists

Investment ideas are often generated via our thematic overlays and supply-chain analysis. We perform quantitative screening using cash-flow return on investment (CFROI) and liquidity filter – daily turnover (minimum of USD1.0 million). We regard CFROI as a critical parameter in screening out companies with consistently poor cash flow for a prolonged period. For thematic overlays, we conduct regular brain-storming sessions to identify and discuss structural as well as tactical themes namely, China Influence and Domestic Uncorrelated.  In relation to China Influence, we believe that China will exert rising influence on other Asian economies and evaluate the impact of Scarcity, Liquidity and Policy themes on specific sectors such as material, energy, financial and consumer discretionary. We seek companies which can favorably benefit from the positive influence of China while avoiding those which may or will be negatively affected by China.  In relation to Domestic Domination, we observe the social and political dynamics within the markets in Asia outside of China and broadly categorise domestic domination opportunities as follows:- - Consumption – for example Things that will prevail, not affected by internet like tourism, entertainment, logistics, healthcare, fitness - Innovation (Supply Chain) – for example, localized internet application, global supply chain - Inequality – regional differences among different countries A significant amount of our time is also spent interacting with companies in various industries to generate useful on the ground insights. Robust supply-chain analysis is widely performed whenever possible especially in the highly contested sectors such as technology, industrial and material. (II) Idea Verification We verify our investment ideas through fundamental and financial due-diligence. We aim to streamline our investment universe further into a focus coverage list. Our coverage is derived from MSCI AC Asia ex Japan universe and the resulting focus coverage will comprise of both core stocks and alpha stocks. Core stocks are typically large-cap representative stocks within the respective country MSCI indexes. Alpha accretive names are companies which are either non-index e.g. newly listed companies or lowly represented in the indices. Target price, fundamental score and conviction ratings are generated during the idea verification process. Our stock research focuses on our down-to-earth due-diligence at the corporate level. We ascertain our understanding of the business model (risk and rewards), competitive advantages and growth profile (secular or cyclical). Corporate interactions enable us to verify our financial assumptions, and qualitative facts and whenever possible, we also cross-check our findings with its customers, suppliers and competitors. Our conviction in a company may move in tandem with the level of our supply-chain analysis. Our portfolio managers and analysts interact at least once a quarter with the management of companies in which we are invested by way of on-site company visits, off-site meetings and conferences. We generate a target price from our internal financial assumptions of a company. Our investment style and process is based on the central belief that it is cash-flow and cash-flow return on investment (CFROI) which will ultimately determine share prices over the medium and long term. With this in mind, we focus our efforts on identifying superior growth opportunities at reasonable valuations. CFROI is the primary valuation methodology which we utilize especially for non-financial sectors. Reality checks are performed by making references to other conventional valuations like P/E, and EV/EBITDA. For specific sectors like financials, we evaluate banks and insurance companies based on the Gordon Growth Model (ROE-g/COE- g) implied P/B valuation and we value real estate companies based on RNAV (Revalued Net Asset Value). Often, we may have situations where we produce a probability weighted target price (best case, base case and worst case). Risk aversion is our guiding principle i.e. every unit of risk should be compensated with more units of upside potential. This means that we would prefer a stock with share price of 30% upside and 10% downside compared to one with 60% upside with 30% downside. We view that the fundamental score has a lower correlation to the movements in the financial markets and we believe that in times of market volatilities, we can look beyond the noises to focus on these attributes. In the times of crisis or bear market cycles, it is not uncommon that the valuation of “good” and “bad” companies will converge. Management quality is the most important attribute we value in a company and we will not invest in companies which have corporate governance or credibility issues. We encapsulate the importance of management quality in our fundamental score. We do not express a view in the portfolio on a company with a poor management score even if it may have a chance of tactical outperformance. We may be contrarian at times on out-of-favor stocks especially those with good corporate stewardship and attractive risk-reward profile even if there are no specific share price catalysts. Our Fundamental Hexagon Score is weighted by 6 “right” attributes – growth, value, competitiveness, leverage, management/corporate governance and free cash flow. The conviction rating (Strong Outperform, Outperform, Underperform, Strong Underperform) in relation to a stock is made relative to the country benchmark and based on a particular time horizon. We focus on effective communication within the investment team. We have weekly research meetings for stocks to be presented by each analyst. All the relevant portfolio managers will attend the meeting and assumptions will be challenged. Company visit and corporate results update notes will also be circulated via the HGI Investment Group email system. All reports will be posted on the Harvest’s internal Sharepoint system. The investment reports will cover the following key areas:-  Growth – the growth profile of the company (high or steady)  Value – valuation of the company versus its normalized mean or peers  Competitiveness – company’s edge in face of competition  Leverage – balance sheet strength  Management/Corporate Governance – track record of management  Free cash flow – ability to generate cash flow (III) Idea Implementation The actual portfolio is constructed based on the inputs of the focus coverage, macro and thematic/sector overlay, risk control parameters as well as specific investment objectives and restrictions. Our portfolio construction process aims to capture all our highest conviction ideas (i.e. Strong Outperform) within the stipulated country and sector limits. We implement all the stocks with “Strong Outperform” rating with an active bet of between 100 to 300 bps in the portfolio. We do differentiate stocks within the “Outperform” category by making reference to risk-reward target and fundamental scores. In terms of country and sector deviation limits, the country deviation limit should not be more than 5% or 2 times the country weighting in the benchmark (whichever is the lower) while the sector deviation limit should not be more than 8% or 3 times the sector weighting in the benchmark (whichever is the lower). We do emphasize the importance of monetary policy and political-social stability in the Asian markets and intervene in our market allocation during extreme market conditions especially in times of rising political and social risks. We have a well-rounded fundamental research-driven approach, with a team of bottom-up analysis focuses on sector & company research and a team of top-down strategist focuses on global macro and market trend analysis. Our core beliefs
• Macro trends and theme/policy determine investment returns
• Focused, but in-depth, coverage is key for opportunities discovery
• Teamwork is the only means to deliver superior and consistent results Our investment process
• Based on a team approach, within and across asset classes, to drive investment performance
• Identify, test and control risk before implementation We invest in the merits of companies, capturing the best high conviction ideas In general, positions will be sold or reduced if:  Changes to the original investment theme, trend and sentiment occur  Fundamental situation worsened – specific to companies or sectors  Unfavorable changes in management, ownership or corporate strategy  Positive fundamental development is reflected by the share price  Superior prospects in other countries/sectors/stocks  Holding exceeds risk budget (IV) Risk Management Risk Management The goal of investment risk management is to monitor and analyze the investment risks and ensure timely communication with portfolio managers and senior management. To achieve this goal, the risk management team has dedicated resources to oversee and monitor HGI’s Morningstar Direct and Matlab For a more detailed write-up on risk management, please refer to Section 6 below. Trade Management All trades are processed through our automated Guideline Checking System  Pre-deal checking/warnings  Post deal breach exception report  Our dedicated compliance department monitors guideline compliance with client, regulatory and internal guidelines on an ongoing basis Investment guidelines are coded into the compliance module of the trading system and the Compliance Team is responsible for the pre-trade/post-trade compliance checks. Portfolio managers will be notified of any identified errors and breaches immediately and are required to take remedial actions in accordance with the requirements of the client mandates and regulations, taking the clients’ best interest into consideration. Compliance with investment guidelines is also monitored independently by an automated back-end system. This system monitors trades and portfolios post execution verifying that specific account/fund guidelines, regulatory requirements and risk exposure limits are followed. Exceptions identified through this process are escalated for proper resolution on a timely basis. Dynamic risk management This refers to identifying the downside risks of our portfolio strategies, particularly with regard to the prevailing market style tilts. To this end, Risk Manager is obliged to analyze the investment styles of our portfolios, which can be categorized into value, growth, quality, momentum, cyclical, defensive, etc. Concomitantly, the Investment Strategy and Asset Allocation Committee is responsible for identifying /forecasting the market investment style(s) going forward. Then, our portfolios are tested against the identified /forecast market style(s), and we will keep monitoring our deviation from the forecast market styles – which may result in large tracking errors – and decide whether strategy fine-tuning is needed, and make certain that our portfolios have followed the guidelines on stock and sector limits issued by the Committee based on their top down views. Other than that, Risk Manager also provides disciplines based on the liquidity risk control perspective. Overall, we strongly believe that the constant interaction between the Investment Strategy and Asset Allocation Committee, Risk Manager and Portfolio Managers can lead to a cross-fertilization of ideas – the mixing of the top-down and bottom-up views to produce a more desirable result – and consequently style deviation and the downside risks of our investment portfolios can be measured and the strategies to be fine-tuned, helping us to contain the market style risks. Style Factor Analysis Calculate Portfolio Style Exposure (Powered by Barra) Calculate Style deviation and downside risk (Powered by Barra) Investment strategy fine tuning Enhanced Alpha Generation Fixed Income Our investment process pursues a combined approach between top-down and bottom-up approaches. In the top-down approach, economic data on a global, regional and local basis are taken into consideration (e.g. economic growth, monetary and fiscal policies and interest rate cycles) to identify longer-term macro trends and current themes which are likely to impact markets. Central to our bottom-up approach is a proprietary internal rating process which was developed using Moody’s rating as a reference, which then incorporated our sector views and strategies from the top-down approach. Investment Process All Harvest’s investment professionals, including both the onshore investment teams from HFM and the offshore investment teams from HGI, share a centralized research platform to promote effective communication and information exchange. The research platform encompasses a common report database and email distribution list covering asset-class strategies, macro- economics, industry (weekly monthly, quarterly, and annually) and company-specific research and update. Our portfolio construction is based on a combination of top-down and bottom-up approaches. The top-down asset and sector allocation decisions are based on the macro views from our Global Asset Allocation (GAA) team. GAA, PMs and investment analysts hold monthly meeting to discuss the major macro trends, global fund flow, and the resulting asset and sector allocation. Our bottom-up fundamental research includes in-depth industry and company analysis as well as credit specific issues, including quality of cash flow generation, liquidity analysis, peer comparison, capital structure and covenant analysis as well as potential rating uplift from government ownership or strong sponsor. We will then incorporate RV (relative value) analysis before making the final investment decision. At a given time, we have about 80-100 investment holdings in our portfolio. In addition, we keep about 20 credits in a watch list. Decision to add/remove or overweight/underweight a particular credit depends on our top-down strategy as well as the bottom-up credit and RV analysis described above. We aim to keep a diversified portfolio with no more than 3-5% per investment grade issuer and 2% per high-yield issuer depending on our investment mandates. Finally, we also incorporate the following considerations in the portfolio construction process:  Guidelines or restrictions and compliance requirements of the given investment mandates;  Liquidity constraints on the position. Macro- Economics Fundamentals Analyse global economic trends and government policies, with consistent long term and short term views Fixed Income Analysis & Recommendations Duration/Yield curve Spreads Currency Industry Analysis Company Analysis RV/Peer Comp Risk & Liquidity Monitoring EPRF Data / Flow Data Fixed Income Research Fundamental Analysis & Value Assessment Strategic GAA View Long-Term GlobalView Long-term view on global marco and major asset classes trends Short-Term Tactical Strategy
•Short-term global marco and market trends
•Fund positioning and fund flows
•Discover investment opportunities GAA View Tactical GAA View Input for GAA View Generation Global Asset Classes View Equity Analysis & Recommendations Return on capital (CFROI) Asset growth Discount rate Life-cycle fade rate Industry Analysis Risk & Liquidity Monitoring Fund Flow Data Equity Research

Sector Strategy We utilize outputs from macro team across different industry sectors / groups to conduct in- depth analysis for each industry, and identify opportunities across industry. We employ different valuation tools / analytical framework for different industries, and we only use one that best suit the nature of the company’s business. We analyze business cycle across industries; it helps us identify opportunities amid cyclical fluctuations of the economy over medium term. Interest Rate Strategy Within interest rate strategies, the Fixed Income Investment Team seeks opportunities from duration and slope management of interest rate risk, and relative value opportunities. Our primary approach to interest rate risk management is to take strategic positions based on our fair value forecasts. However, where we believe we have a good understanding of the short- term factors, we will take tactical positions. i) Strategic positions are implemented when market prices do not reflect fair value based on our fundamental medium to long term economic views. The deviation of the central scenario Risk Identification and Monitoring Portfolio Strategy Formation Integrated Top-Down and Bottom-Up Investment Approach GAA fundamental & systematic Asset class research Idea Generation Implementation Monitoring forecast from current market pricing dictates sign and size of strategic duration/slope positions relative to benchmark. ii) Tactical positions are implemented when we have a strong conviction on short-term price movements, usually driven by technical factors such as market momentum, funds flow and individual data releases. These positions are undertaken on a discretionary basis. In general, interest rate positions are predominantly strategic in nature. Forecasts of fair value bond yields are formulated having regard to domestic macroeconomic factors and idiosyncratic capital market developments and flows. These are consistent with the global economic, monetary policy and capital market themes identified in concurrent strategy sessions. A deviation of the forecasts from the market pricing will dictate the sign and size of the strategic local market duration position. Interest rate positions will need to be adjusted for access and liquidity constraints. Currency Strategy GAA team identifies fundamental, technical and behavioral factors which drive currency value in the short to medium term. Themes identified in global and regional macro analysis form the basis for our currency outlook. The global factor analysis approach is modified to ensure that the most relevant drivers in each regional currency are considered. The team prepares currency forecasts that incorporate not only the themes from our global and regional macro analysis, but also the assessment of medium-term currency valuations within the region with considerations of macroeconomic, policy, and capital flow developments as relevant. Deviations from our medium or long-term forecasts are used to identify potential investment opportunities. Credit Strategy The development of credit strategies is a combination of top-down and bottom-up analysis. The evaluation results from both analysis have a direct input into sector allocation and credit selection at the portfolio construction stage. Top-down evaluation: We identify longer-term trends and current themes likely to impact markets during the investment period. Analysis of economic, credit and market-specific factors both globally and regionally allows us to determine how much credit to allocate to the portfolio. We leverage the resources of our Macro Strategists and Credit Team in Beijing, and our regional investment teams within HGI, to determine the key drivers of global, regional and local credit markets. Bottom-up evaluation: Central to our bottom-up credit evaluation, is a proprietary internal rating process. In undertaking credit analysis, we utilize the resources of our onshore and offshore research teams. Research Process The research matrix is one of our most important processes within our investment practice as this provides us the most valuable information in order to capture the market opportunities. We have designed multi-faceted system linked to all research groups. Three main groups contribute to the research process, namely the Macro Team, Strategy Team, and the Credit Team:

Macro Research The starting point of our research process is an analysis of the macroeconomic environment which is undertaken by the Macro Team. Data is gathered from multiple parties such as government agencies, industry associations, and external resources platform. The team will then conduct macro analysis on global and regional economic growth and money supply figures, based on domestic macroeconomic factors and idiosyncratic capital market developments and flows. Interest rate forecast, currency forecast, and inflation forecast will be executed in order to provide both long and short-term market outlook to the rest of the team. Note that all research information are uploaded to our Knowledge Management (KM) System which ensures communication for information exchange among teams. Industry Theme Analysis The Strategy Team will utilize the comprehensive analytic outputs from our macro team, to conduct a second layer of thematic analysis and sensitivity analysis in relation to different industries, duration positioning and asset sectors (e.g. HY vs IG, straight bonds vs CB). Here, a Top-down Approach will be applied leveraging on our specialized expertise in each area, and close collaboration between onshore and offshore teams. Information extracted from industry databases and inputs from industry experts as well as sell-side strategists are also factored into review. We also strive to combine quantitative analysis and fundamental research to form an integrated systematic approach to better understand and respond to risk factors without behavioral bias. The last stage is a sector life cycle analysis from which the investment strategy will be determined. Micro Research Once the investment strategy has been developed, the Credit Team will perform a credit analysis through a Bottom-up evaluation process utilizing resources of both our onshore and offshore research teams. During this phase, a massive amount of data on each potential investment will be analyzed. This includes the industry trends and risks, business position, financial profile, liquidity and cash flow analysis, covenants analysis, and valuation of the possible investments. The result provides a clear picture of the valuable names which will be included in the investment universe and will be considered during the portfolio construction stage. Back to list 1.3 PORTFOLIO MONITORING The credit monitoring and risk management process are also conducted throughout the investment process. It is crucial to keep track of the credit rating and risk figures of the securities in order to keep our investments within the portfolio investment constraints. The credit monitoring is an on-going process and will be performed by the Credit Team. For risk management, a pre-deal and post-deal check will be conducted. On an ongoing basis the Risk Management Department access and monitor portfolio risk (mainly liquidity and counterparty risks) according to changing market situations. Risk Management teams are also responsible for monitoring and producing portfolio risk analysis report. The goal of investment risk management is to monitor and analyze the investment risks and ensure timely communication with portfolio managers and senior management about the investment risk. To achieve this goal, the Risk Management team has dedicated resources to oversee and monitor HGI’s investment risk. Key risks and performance systems are BarraOne, FactSet, Bloomberg, Morningstar Direct and Matlab. Compliance is also responsible for daily monitoring of the investment process. 1.4 SELL-DISCIPLINE The sell-discipline operates within our investment process. In general, positions will be sold or reduced if:  Fundamental - Changes to the original investment theme, trend and sentiment occur - Fundamental situation worsened – specific to macroeconomics - Unfavorable changes to credit of corporate bonds, market liquidity and supply and demand shocks - Positive fundamental development is reflected by the price  Opportunity Cost - Superior prospects in other sectors/bonds  Risk control - Holding exceeds the maximum risk budget While selling any position is not automatically triggered by these events, good explanations will be required to maintain the positions.
ETF Investment Strategy (I) Portfolio Construction: The fund’s investment management process is relatively simple and fully represents the degree of diversification that the index embodies. However, various market specific factors and circumstances may result in differences in the fund’s portfolio and the index composition from time to time. These factors include: the effect of subscriptions and redemptions, underlying stock weight adjustments, legal restrictions on investment shares, transaction costs, stock dividend distribution, share allotment and issuance of new shares. The requirement to purchase stocks in lots as well as other restrictions can also cause the portfolio to lag or be biased to an extent, especially when the target index has a large number of the constituents – in that case, the frequency of adjustment and time delay can be an important factor. In addition, when stocks have been suspended for a prolonged period of time or delisted, a full replication strategy will inevitably face situations where its return will deviate from the index and therefore ultimately cause tracking error. (II) Portfolio Rebalancing: The fund utilizes the full replication strategy to track the MSCI China A index performance efficiently. On a daily basis, the fund manager verifies the underlying stock holdings’ weights with MSCI and rebalances the portfolio according to the day’s net flow. The investment team utilizes Harvest’s passive investment system to monitor not only the average daily tracking error but also the accumulated tracking difference as well. The investment team closely tracks any corporate actions of the underlying stocks and takes corresponding actions. The reasons for rebalancing can be categorized as follows:  Change in index constituents The index provider reviews the index on a regular basis, which may result in additions, deletions, and changes in the index constituents. The implementation of changes from periodical review results is in February, May, August and November respectively. All changes will be pre-announced before the effective date. Historically, the average percentage change in number of constituents for the MSCI China A Index was 28.9% for 2010 to 2011 while the average turnover for the same period was 13.1%. The fund manager will analyze the potential weighting changes for the portfolio holdings. In case of weighting change for one typical stock, the fund manager will consider a number of factors to achieve the target weighting prior to the effective date, including the 3-month average trading volume, the significance of the index component and potential trading impact. The fund manager can also decide the trading strategy, for example in the case of illiquid stock, the fund manager might split the order into several trading days before the effective date, and get to the target weight incrementally.  To minimize tracking error On a daily basis, the fund manager is updated with the tracking error analysis of the fund. Under different market condition, the fund manager may set the corresponding alert level, for example daily tracking error above 50bps or annualized tracking error above 3%, the fund manager will look into the attribution analysis of the tracking error then decide whether to adjust the portfolio holdings accordingly, usually the attribution could include dividends received, trading P&L, positioning variance from the index weights, and cash drag, e.g. if portfolio variance arises, sector overweight/underweight comparing to underlying index over 2%, the fund manager would initiate the portfolio rebalancing to minimize the deviation.  Adjust cash portion in the portfolio The fund applies a full replication strategy to track the underlying index. The fund will maintain a relatively low level of cash in order to effectively track the index. When cash level reaches above 1% or below 0.2% in the portfolio, the fund manager could initiate the portfolio rebalancing to adjust the asset allocation. Back to list

1.5 PORTFOLIO MONITORING AND CONTROL The ETF’s investment management process is relatively simple and fully represents the degree of diversification that the index embodies. However, various market specific factors and circumstances may result in differences in the ETF’s portfolio and the index composition from time to time. These factors include: the effect of subscriptions and redemptions, underlying stock weight adjustments, legal restrictions on investment shares, transaction costs, stock dividend distribution, share allotment and issuance of new shares. The requirement to purchase stocks in lots as well as other restrictions can also cause the portfolio to lag or be biased to an extent, especially when the target index has a large number of the constituents – in that case the frequency of adjustment and time delay can be an important factor. In addition, when stocks have been suspended for a prolonged period of time or delisted, a full replication strategy will inevitably face situations where its return will deviate from the index and therefore ultimately cause tracking error. On a daily basis, the fund manager is updated with the tracking error analysis of the fund. Under different market condition, the fund manager may set the corresponding alert level, for example daily tracking error above 50bps or annualized tracking error above 3%, the fund manager will look into the attribution analysis of the tracking error then decide whether to adjust the portfolio holdings accordingly, usually the attribution could include dividends received, trading P&L, positioning variance from the index weights, and cash drag, e.g. if portfolio variance arises, sector overweight/underweight comparing to underlying index over 2%, the fund manager would initiate the portfolio rebalancing to minimize the deviation.

Asia Frontier The investment process can be defined by the following 4 steps: IDEA GENERATION IDEA VERIFICATION IDEA IMPLEMENTATION RISK MANAGEMENT Ideas are generated via our macro and thematic overlays, supply-chain analysis and quantitative screenings. Our investment universe comprises both core coverage stocks and alpha ideas. Due-diligence checks are conducted while assumptions are being challenged. Views on stocks are expressed via stock ratings. Target price is derived via the core-CFROI valuation methodology or a combination of conventional valuation measures.
We aim to capture all our high conviction quality ideas consistently across all our client portfolios within the risk control parameters and permitted investment guidelines. Systems and checks are in place to monitor market risk and credit risk as well as build an effective and sound control environment across products and departments. Investment strategies are tested against style tilts. (I) Idea Generation The investment universe is made up of stocks which have exposure to the frontier markets and will benefit from the long-term secular growth trends in these markets.  Direct frontier markets - companies listed on the Asia frontier markets stock exchanges which include Bangladesh, Kazakhstan, Mongolia, Sri Lanka and Vietnam. These markets were selected with the following considerations: - Fundamental Macro Analysis - Political Stability - Accessibility to Global Investors  Liquid proxies - companies listed in developed or emerging markets with operations, assets or investments and or with revenue generated in these markets. This may allow inclusion of a wider universe of less directly accessible frontier markets such as Indochina (e.g. Laos, Cambodia) and Central Asia (Turkmenistan) Investment vehicles include companies listed in established exchanges such as Hong Kong, India, Singapore, Korea and Taiwan, as well as ADR/GDR and companies listed in the United Kingdom and the United States. Companies listed in China benefiting from the rapid growth of western Chinese provinces - Inner Mongolia, Tibet, Xinjiang & Yunnan - “Western China Frontier” markets. These companies are largely listed in China A-share market. P-notes on China A share will be used. Investment ideas are often generated via our thematic overlays and supply-chain analysis. We perform quantitative screening using Cash-Flow Return on Investment (CFROI) and liquidity filter – daily turnover (minimum of USD0.5 million). We regard CFROI as a critical parameter in screening out companies with consistently poor cash flow for a prolonged period. Setting out with the aim to generate key top down strategic investment ideas – “Macro Overlay”, the Investment Strategy and Asset Allocation Committee musters our key investment personnel including the CIO, Macro & Global Asset Allocation (GAA) Strategists, Asset Classes Specialists and Quantitative Analyst. To better illustrate, Macro & GAA Strategists are responsible for the research on global and local macro themes, discovering key market drivers and providing asset allocation views; Asset Classes Specialists are to provide individual asset class insights, while the Quantitative Analyst uses various quantitative tools to identify opportunities and risks. CIO Macro & GAA Strategists Quantitative Analyst Asset Classes Specialists

For thematic overlays, we have brainstorming session to identify and discuss both structural as well as tactical China-influence and Domestic Asia Frontier themes. For China-influence themes, we have viewed the Chinese influence of Scarcity, Liquidity and Policy on the specific sectors such as material, energy, industrial. We are seeking companies which can favorably benefit from the positive influence of China while avoiding those which may or will be negatively affected by China. We observe the social and political dynamics within the Domestic Asia Frontier markets outside of China. We invest a significant amount of our time interacting with companies in various industries. Robust supply-chain analysis is widely performed whenever possible especially in the highly contested sectors such as technology, industrial and material. (II) Idea Verification We verify our investment ideas through fundamental and financial due-diligence. We aim to further streamline our investment universe into a focus coverage list. Our focus coverage will comprise of both core stocks and alpha stocks. Core stocks are typically large-cap representative stocks within the respective country indexes. Alpha accretive names are companies which are either non-index e.g. newly listed companies or lowly represented in the indices. Target price, fundamental score and conviction ratings are generated during the idea verification process. Our stock research focuses on our down-to-earth due-diligence at the corporate level. We ascertain our understanding of the business model (risk and rewards), competitive advantages and growth profile (secular or cyclical). Corporate interactions enable us to verify our financial assumptions, and qualitative facts and whenever possible, we also cross-check our findings with its customers, suppliers and competitors. Our conviction in a company may move in tandem with the level of our supply-chain analysis. Our portfolio managers and analysts maintain at least once a quarter interactions with the management of companies we invested by way of on-site company visits, off-site meetings and conferences. We generate a target price from our internal financial assumptions of a company. Our investment style and process is based on the central belief that it is ultimately cash-flow and cash-flow return on investment (CFROI) which will ultimately determine share prices over the medium and long term. With this in mind, we focus our efforts on identifying superior growth opportunities at reasonable valuations. CFROI is the primary valuation methodology which we utilize especially for non-financial sectors. Reality checks are performed by making references to other conventional valuations like P/E, and EV/EBITDA. For specific sectors like financials, we evaluate banks and insurance companies based on the Gordon Growth Model (ROE-g/COE-g) implied P/B valuation and we value real estate companies based on RNAV (Revalued Net Asset Value). Often, we may have situations where we produce a probability weighted target price (best case, base case and worst case). Risk aversion is our guiding principle i.e. every unit of risk should be compensated with more units of upside potential. This means that we would prefer a stock with share price of 30% upside and 10% downside compared to one with 60% upside with 30% downside. We view that fundamental score has a lower correlation to the movements in the financial markets and we believe that in times of market volatilities, we can look beyond the noises to focus on these attributes. In the times of crisis or bear market cycles, it is not uncommon that the valuation of “good” and “bad” companies will converge. Management quality is the most important attribute we value in a company and we will not invest in companies which have corporate governance or credibility issues. We encapsulate the importance of management quality in our fundamental score. We do not express a view in the portfolio on a company with a poor management score even if it may have a chance of tactical outperformance. We may be contrarian at times on out-of-favor stocks especially those with good corporate stewardship and attractive risk-reward profile even if there are no specific share price catalysts. Our fundamental score is weighted by 3 “right” attributes:  Right theme (20%) – China influence and or domestic Asia  Right business (40%) - Business model, competitive advantages and growth profile (secular or cyclical)  Right management (40%) – Corporate governance, track-record, interests alignment (e.g. share ownership) The conviction rating (Strong Outperform, Outperform, Underperform, Strong Underperform) in relation to a stock is made relative to the country benchmark and based on a specific time horizon. We focus on effective communication within the investment team. We have weekly research meetings for stocks to be presented by each analyst. All the relevant portfolio managers will attend the meeting and assumptions will be challenged. Company visit and corporate results update notes will also be circulated via the HGI Investment Group email system. All reports will be posted on the Harvest’s internal KM (Knowledge Management) system. Idea Implementation The actual portfolio is constructed based on the inputs of the focus coverage, macro and thematic/sector overlay, risk control parameters as well as specific investment objectives and restrictions. Our portfolio construction process aims to capture all our highest conviction ideas (i.e. Strong Outperform) within the stipulated country and sector limits. We implement all the stocks with “Strong Outperform” rating with an active bet of between 100 to 300 bps in the portfolio. We do differentiate stocks within the “Outperform” category by making reference to risk-reward target and fundamental scores. Market allocation is often a residual function of our stock selection process. This is a benchmark aware fund. We do emphasize the importance of monetary policy and political-social stability in the Asian markets and intervene in our market allocation during extreme market conditions especially in times of rising political and social risks. Our investment process is largely macro-aware rather than macro-driven. Top-down factors play a secondary role in our investment decision-making process, but are reviewed formally, at the very least, on a monthly frequency, to maintain consistency with our overall investment view of the markets and sectors. Our market specialist will run the macro scorecard in 4 core areas – Growth – Macro GDP and Earnings growth as well as the drivers Valuation – Market and sector valuations Currency and Liquidity Policy and Management – Social and political stability The macroeconomic environment, political factors and currency views are incorporated into the portfolio control process and may lead to refinement of the country allocation results suggested by “bottom-up” criteria. In general, positions will be sold or reduced if:  Changes to the original investment theme, trend and sentiment occur  Fundamental situation worsened – specific to companies or sectors  Unfavorable changes in management, ownership or corporate strategy  Positive fundamental development is reflected in the share price  Superior prospects in other countries/sectors/stocks  Holding exceeds risk budget

(III) Risk Management Risk Management The goal of investment risk management is to monitor and analyze the investment risks and ensure timely communication with portfolio managers and senior management. To achieve this goal, the risk management team has dedicated resources to oversee and monitor HGI’s Morningstar Direct and Matlab For a more detailed write-up on risk management, please refer to Section 6 below. Trade Management All trades are processed through our automated Guideline Checking System  Pre-deal checking/warnings  Post deal breach exception report  Our dedicated compliance department monitors guideline compliance with client, regulatory and internal guidelines on an ongoing basis Investment guidelines are coded into the compliance module of the trading system. Compliance Team is responsible for the pre-trade/post-trade compliance checking. Portfolio managers will be notified of any identified errors and breaches immediately and are required to take remedial actions in accordance with the requirements of the client mandates and regulations, taking the clients’ best interest into consideration.  Compliance with investment guidelines is also monitored independently by an automated back-end system. This system monitors trades and portfolios post execution verifying that specific account/fund guidelines, regulatory requirements and risk exposure limits are followed. Exceptions identified through this process are escalated for proper resolution on a timely basis. Dynamic risk management This refers to identifying the downside risks of our portfolio strategies, particularly with regard to the prevailing market style tilts. To this end, Risk Manager is obliged to analyze the investment styles of our portfolios, which can be categorized into value, growth, quality, momentum, cyclical, defensive, etc. Concomitantly, the Investment Strategy and Asset Allocation Committee is responsible for identifying /forecasting the market investment style(s) going forward. Then, our portfolios are tested against the identified /forecast market style(s), and we will keep monitoring our deviation from the forecast market styles – which may result in large tracking errors – and decide whether strategy fine-tuning is needed, and make certain that our portfolios have followed the guidelines on stock and sector limits issued by the Committee based on their top down views. Other than that, Risk Manager also provides disciplines based on the liquidity risk control perspective. Overall, we strongly believe that the constant interaction between the Investment Strategy and Asset Allocation Committee, Risk Manager and Portfolio Managers can lead to a cross-fertilization of ideas – the mixing of the top-down and bottom-up views to produce a more desirable result – and consequently style deviation and the downside risks of our investment portfolios can be measured and the strategies to be fine-tuned, helping us to contain the market style risks.

GLOBAL ASSET ALLOCATION

We have a disciplined investment process in place yet maintain flexibility in terms of risk allocation among various elements. We believe both beta and alpha are important potential return sources of a total return portfolio. Depending on market environment, there may be bigger or smaller opportunity set in one vs. the othe please register to get more info

A. Frequency of Reviews Depending on the nature of an institutional client's portfolio, the client's own monitoring capabilities, the type of advice and the arrangements made with the client, HGI's frequency of client account reviews ranges from daily to quarterly. The level of review may encompass the client's portfolio, a section of the portfolio or a specific transaction or investment. Additional reviews may be triggered by changes in the investment objectives or guidelines of a particular client or specific arrangements with particular clients. The frequency, depth, and nature of reviews are often determined by negotiation with individual clients pursuant to the terms of each client's written Investment Management Agreement or by the mandate selected by the client and the particular needs of each client. Reviews are typically conducted by portfolio management personnel. B. Written Reports Clients typically receive a performance statistics report and a performance attribution report. Clients typically also receive an investment management summary including portfolio review and market outlook based on an agreed upon set of procedures. please register to get more info

We have entered into contractual arrangements with firms that may solicit clients for us. The arrangements are made in writing pursuant to Rule 206(4)-3 of the Advisers Act. This requires, among other things, that such solicitors comply with requirements of the Rule and other applicable law, as well as fulfill their contractual obligations with us. The solicitor must, at the time of his solicitation, provide the client with a copy of Part 2 of our Form ADV. The solicitor must also provide the client with a separate document describing the solicitation arrangement, disclosing any affiliation between us and the solicitor, the compensation for solicitation, and whether advisory fees for solicited clients are higher than those for other clients due to compensation paid to the solicitor. please register to get more info

We do not maintain physical possession of the funds or securities of any client. Each of our clients has entered into an agreement with a brokerage firm or commercial bank that serves as custodian of the funds and/or securities held by each such fund. All US clients will receive statements of account holdings from their custodian not less than quarterly. Additionally, we will provide US clients with account balance and activity details upon request. We urge all US clients to review carefully statements from the custodian and compare the custodial records to the reports that we provide them. please register to get more info

We may be retained to manage client accounts on a discretionary or non-discretionary basis. In cases where we have investment discretion, we determine, within a client’s specified investment objectives and guidelines, which securities are bought or sold, the total amount of securities to be bought or sold, and in most cases, the broker or dealer through which the securities are to be bought or sold and the commission rates to be paid, all without further consultation with the client. In exercising our investment discretion, we are guided by the investment management agreement that is established at the inception of the adviser-client relationship (along with any amendments to the agreement). please register to get more info

Pursuant to our proxy voting policies and procedures, we take steps to see that proxies are voted on securities held in client accounts where authority to vote proxies has not been expressly reserved to the client in the investment management agreement or other documentation. If we vote proxies, it is our aim to see that proxies are voted in the best interest of our clients. As an alternative to giving us discretion to vote proxies, clients may provide us with their own written proxy voting guidelines or their own policies, procedures or directions regarding the voting of a proxy or proxies. Such guidelines or directions must be in writing and delivered to us sufficiently in advance to vote the proxies as directed. Clients may obtain information about how their securities were voted upon request by contacting us at our main office at the address given above. Upon request, clients may also obtain from us a copy of our proxy voting policies and procedures. please register to get more info

We do not have any adverse financial information to disclose. The management of HGI believes that we are financially sound. please register to get more info