Effective Date:  January 1^st, 2024

At Capital Asset Management (Hong Kong) (“the Company”), we are committed to maintaining the highest standards of professionalism, integrity, and service excellence. This policy outlines the principles, rules, and guidelines that govern our operations and interactions with employees, clients, and stakeholders.

1. Scope

This policy applies to all employees, contractors, and representatives of Capital Asset Management, as well as any clients or third parties interacting with the Company.

2. Code of Conduct

All employees are expected to:

• Act with honesty, integrity, and transparency in all business dealings.

• Treat clients, colleagues, and stakeholders with respect and professionalism.

• Maintain confidentiality and safeguard sensitive information.

• Adhere to applicable laws, regulations, and company standards.

Violations of this Code of Conduct may result in disciplinary action, up to and including termination of employment or engagement.

3. Equal Opportunity and Non-Discrimination

We are an equal opportunity employer. Discrimination or harassment on the basis of race, color, religion, gender, age, national origin, disability, or any other protected status is strictly prohibited.

4. Confidentiality and Data Protection

All employees must:

• Protect client and company information from unauthorized access or disclosure.

• Comply with applicable data protection regulations, including Hong Kong’s PDPO and other relevant international standards.

• Report any data breaches or security incidents immediately.

Failure to comply may result in disciplinary action and potential legal consequences.

5. Conflict of Interest

Employees must avoid situations where personal interests conflict with their duties to the Company.

• Disclose any potential conflicts of interest to management immediately.

• Refrain from engaging in activities or relationships that could compromise professional judgment.

6. Anti-Bribery and Corruption

The Company has a zero-tolerance policy for bribery and corruption.

• Employees and representatives must not offer, accept, or solicit bribes or any form of improper payment.

• Any suspected incidents must be reported to the Compliance Officer immediately.

7. Workplace Safety and Health

Capital Asset Management is committed to providing a safe and healthy work environment.

• Employees must adhere to safety protocols and report any hazards promptly.

• The Company conducts regular risk assessments to mitigate workplace risks.

8. Use of Company Resources

Company resources, including technology, equipment, and time, must be used responsibly and for legitimate business purposes.

• Unauthorized personal use of company resources is prohibited.

• Employees must comply with IT and cybersecurity policies to protect the integrity of company systems.

9. Client Relations

Our clients are at the core of our business.

• Employees must provide accurate information, professional advice, and exceptional service.

• Complaints or disputes must be handled promptly and escalated to management when necessary.

10. Environmental Responsibility

The Company strives to minimize its environmental footprint by:

• Encouraging sustainable practices, such as paperless operations.

• Complying with environmental regulations.

11. Reporting Violations

Employees and stakeholders are encouraged to report violations of this policy or any unethical behavior without fear of retaliation. Reports can be made to:

• Compliance Officer:  compliance@capassethk.com

• Anonymous Reporting Hotline:  +852-8197-5025

12. Policy Amendments

This policy may be updated periodically to reflect changes in regulations or company operations. All updates will be communicated to employees and posted on our internal portal.

13. Acknowledgment

All employees must acknowledge receipt and understanding of this policy upon onboarding and whenever significant updates are made.

For further questions or clarifications regarding this policy, please contact:

• Email:  policy@capassethk.com

• Phone:  +852-8197-5025

• Mailing Address:  Suite 3408B, Gloucester Tower, The Landmark, 11 Pedder Street, Central, Hong Kong.