Effective Date: January 1, 2025
Jinnong Sui Capital and its managed funds are committed to conducting business with the highest ethical standards. This Code of Ethics establishes behavioral benchmarks for all employees, management, and partners, ensuring every decision prioritizes investor interests.
All personnel must adhere to the principle of good faith. Fraud, misrepresentation, or misleading statements in any form are strictly prohibited. All investment advice, product communications, and client interactions must be truthful, accurate, and complete.
All personnel must proactively disclose any actual or potential conflicts of interest, including but not limited to personal investments, external business interests, and familial relationships involving counterparties. See the Conflict of Interest Policy for details.
The use of material non-public information for personal trading or its disclosure to others is strictly prohibited. All employees must comply with trade reporting requirements and are subject to compliance review.
No gifts, hospitality, or other benefits that may influence—or appear to influence—business decisions may be accepted. The value of any single gift accepted must not exceed RMB 500 and must be reported to the Compliance Department.
Any person who becomes aware of conduct violating this Code may report it through confidential channels to the Compliance Department. The firm strictly prohibits retaliation of any kind against good-faith whistleblowers.
Violations of this Code will result in disciplinary action, including but not limited to warnings, suspension, termination of employment, and referral to regulatory authorities in serious cases.
This Code is reviewed annually by the Compliance Committee under the Board of Directors.