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Ethical Management

Simone Investment Managers Co., Ltd.
Simone asset management businesses to comply with the basic principles of ethical thinking.

Chapter 1. Introduction

As employees of an asset management company that handles a variety of investment vehicles on behalf of clients, we must diligently fulfill our responsibilities and obligations to safeguard our clients’ interests while also helping to contribute to the growth of the capital markets and the nation’s overall economic improvement.
In order to attain these goals, we pledge to practice the following.

Chapter 2. Code of Ethics

1. We have a fiduciary duty to administer and manage client assets responsibly and do our best to safeguard and augment their interests.
2. Each employee must continuously strive to maintain and improve his or her abilities as an asset management specialist.
3. We must take all investment management actions prudently and maintain both independence of mind and objectivity in our judgments.
4. We must not conduct any unfair transaction that could harm the health of the capital markets and the soundness of our clients’ assets.
5. We must observe and uphold all applicable laws and regulations governing the management of our clients’ assets and maintain the utmost integrity.
6. We must take reasonable steps to avoid any conflicts of interest between our clients’ interests and company’s interests or among any particular group of clients.
7. We must not take advantage of nonpublic information obtained in the course of performing our duties for our own interests or the interests of any third party.

Chapter 3. Standards of Conduct

Ⅰ. Safeguarding Client Assets (Duty of Care and Fidelity)
1. When managing client assets, we must diligently perform our duties in a manner that we believe ensures the best interests of our clients, and do so with the greatest possible care that a prudent person of the same position shall generally exhibit in a similar situation
2. Any employee who designs and sets up a fund must thoroughly understand the potential client’s preferences, tolerance for risk, investment objectives, and any other relevant information so as to create the most suitable product.
3. Any employee in charge of investment management must meet the specific investment objectives and strategies given to clients with the greatest possible care. He/she must have a reasonable basis for making any decision concerning asset selection, allocation and investment analysis, and implement prudent hedging policies (i.e. diversification, etc.) for proper risk management.
4. The internal control department must establish an internal control system that meets the company’s standards and, in investment management and other works, implement risk management and compliance which adheres to normal practices.
5. When performing our duties, we must treat all clients fairly, and place the clients’ interests before our company’s interests, and our company’s interests before our own based on the policy governing conflicts of interests.

Ⅱ. Professional Conduct
1. With proper support from the company, each employee must always continue to self-educate to fully understand the knowledge and skills required to perform as a competent asset manager. Each must do their individual best to improve their expertise to fulfill assignments.
2. We must perform our responsibilities with reasonable judgment based on proper research and analysis, and maintain proper records to prove compliance and economic rationality for the actions we have taken.
3. Each employee must perform their individual responsibilities with proper professional care and make fair and objective judgments.

Ⅲ. Independence
1. We must take investment management actions with utmost care, prudent judgment and a policy to avoid conflicts of interests to deliver and maintain independence and objectivity.
2. We must not accept any performance fees, gifts or entertainment unless permitted by applicable laws and regulations.

Ⅳ. Avoidance of Unfair Transactions
1. We must not engage in practices designed to artificially inflate trading volume or distort prices of financial investment products with the intent to take improper advantage of capital market participants.
2. When managing client assets, we must not execute any transactions with any interested party unless they are in full compliance with applicable laws and regulations.
3. When having made an investment decision or considering an investment that could affect the value of a financial investment product or other investable assets, we must not execute our own trades or recommend such trades to a 3rd party prior to client transactions of the same asset.
4. We must not replace 3rd party assets in an investment vehicle with client assets.
5. We must not conduct short-term trades of financial investment products to inflate commissions for an affiliated company or acquire the remainder of a financial investment product the part of which an affiliated company had already purchased.
6. We must not trade any financial investment product at an artificially distorted, unfair price.
7. We must not trade any financial investment product at an unfair price with a significant gap to general market conditions.
8. We must not trade or take actions to trade any financial investment product with the intent to serve specific purposes of the company and its related parties.

Ⅴ. Compliance with the Law
1. We must fully understand and uphold all applicable laws and regulations.
2. We must not deliberately engage in or aid or abet any violations of applicable laws and regulations.
3. When identifying any suspected violation of any applicable law or regulation in the course of performing our duties, we must immediately report it to the internal authority and ensure adequate internal controls are in place to prevent deviations and illegal acts in advance.