Conflict of Interest Policy

Effective Date: January 1, 2025

Jinnong Sui Capital is committed to identifying, managing, and disclosing all actual and potential conflicts of interest to ensure investor interests are not compromised.

1. Types of Conflicts

The following are potential conflict-of-interest scenarios in our business:
  • Personal Trading: overlap between employee personal investments and fund holdings
  • Related-Party Transactions: transactions involving affiliated entities (e.g., the manager or its subsidiaries)
  • Soft Commissions: accepting research services or other benefits from counterparties
  • Multiple Roles: the same individual serving multiple funds or clients simultaneously
  • Gifts & Entertainment: accepting favors that may impair independent judgment
  • External Appointments: employees holding positions at external organizations

2. Identification & Disclosure

  • New hires must complete a conflict-of-interest declaration within 30 days of onboarding
  • Existing employees must update their conflict-of-interest declaration annually
  • Any event that may constitute a conflict of interest must be proactively reported within 5 business days
  • Investment decision-makers must pre-clear personal trading plans

3. Management Measures

  • Information Barriers: investment decision-making, trade execution, and settlement functions are strictly segregated
  • Restricted List: the Compliance Department maintains a restricted securities list; relevant personnel are prohibited from trading those securities
  • Independent Approval: related-party transactions require approval from the independent Risk Management Committee
  • Fair Allocation: trading opportunities are allocated fairly based on the best-interest principle for clients
  • Compensation Design: remuneration structures must not incentivize excessive risk-taking or harm to investor interests

4. Disclosure

Conflicts that cannot be adequately managed through internal mechanisms will be clearly and fully disclosed to affected investors. The relevant business may proceed only after obtaining written consent.

5. Oversight & Enforcement

The Compliance Department conducts an independent review of this Policy annually. Violations are handled in accordance with the Code of Ethics.