Compliance

HIGH IMPACT CAPITAL ADVISORS LIMITED

Green Finance Framework

June 2023

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Introduction

High Impact Capital Advisors Ltd. (HICA) recognizes its share of responsibilities in combating climate change and environmental degradation by supporting the transition to a low carbon and sustainable economy. As an impact financial advisor, we are committed to playing our part in addressing this global challenge through our role as a financial intermediary between the economy, the environment and society. We recognize the role we can play in mobilizing the finance needed to promote the transition of the global economy towards low carbon activities.

One of the ways in which HICA can facilitate this transition is by financing green finance instruments (including bonds, loans, commercial paper, and other debt or financing structures) to facilitate capital for low-carbon and environmentally sustainable economic activity.

Inline with best market practice HICA commits to a high standard of transparency for its green financings to enable investors to judge its green credentials. This document sets out the policy and process by which green debt financing instruments supported by us will be invested and managed covering:

· Use of Proceeds

· Project Evaluation and Selection

· Management of Proceeds

· Reporting

· Assurance

This Green Finance Framework is aligned to the International Capital Market Association's Green Bond Principles (2018), which HICA has endorsed.

‍Use of Proceeds

The objective of HICA green financing instruments is to fund projects or assets that: mitigate climate change by reducing emissions; protect ecosystems; or otherwise have a positive environmental impact in support of the UN Sustainable Development Goals. The proceeds of any green financing will be used to finance or re-finance projects or assets with a clear and defined environmental benefit(“Eligible Projects or Assets”).

Eligible Projects or Assets for HICA green financings are:

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Projects not eligible for inclusion in a green financing are those involving coal-fired power, defense, large-scale hydropower, gambling, mining, nuclear energy, oil &gas, palm oil, tobacco, and wood pulp. Eligible financial products include:

· Debt (e.g., bank loans, bonds, bridge loans, mezzanine debt, back leverage, revolvers, corporate debt)

· Equity (e.g., tax, project, corporate)

The proceeds will be used primarily for refinancing of Eligible Projects or Assets, but HICA aims to allocate at least 20% of total proceeds to new financing. HICA aims to allocate the majority of proceeds on the day of issue, and all proceeds will be allocated to projects after 12 months.

The proportion of re-financing vs. financing may be stated in the disclosure documentation, and any projects that may be refinanced may be indicated.

‍Project Evaluation and Selection

The environmental objectives of the green financings may be defined and stated in the disclosure documentation. A list of potential projects and assets will be identified by business teams. The projects will be evaluated according to the following criteria:

1. Financial due diligence

2. Environmental, Social and Governance (ESG) evaluation

· Counter party evaluation

o The evaluation process will consider the counterparty’s project commitment, capacity, and track record for ESG issues as well as the quality of reporting on ESG issues.

o The evaluation will take into account assessments made by selected ESG ratings agencies if appropriate and appropriate industry standards or certification such as the Equator Principles.

o If the counterparty’s business is diversified and includes activities that are not Eligible Projects or Assets, consideration will be given to the counterparty’s whole business and to whether the investment will achieve a substantial positive impact on the environment.

· Asset-level evaluation

o The evaluation will take into account information about environmental and social impacts of individual projects or assets.

3. Impact evaluation

· The environmental benefit of each project or asset will be assessed against science-based climate targets and quantified if feasible. Social impacts will be evaluated to the extent appropriate.

On the basis of the list the final selection of assets funded will be made by a Green Finance Investment Committee comprising senior leadership of HICA.

The Eligible Projects and Assets may be listed and described in the relevant disclosure documentation.

‍Management of Proceeds

Proceeds from green debt financing instruments will be managed by HICA in a portfolio approach. HICA intends to allocate the proceeds from green financing instruments to a portfolio of Eligible Projects or Assets, selected in accordance with the use of proceeds criteria and project evaluation and selection process presented above.

HICA will strive, over time, to achieve a level of allocation for the eligible green project portfolio which matches the balance of net proceeds from its outstanding green financing instruments. Additional eligible green projects will be added to the eligible green project portfolio to the extent required to ensure that the net proceeds from outstanding green financing instruments will be allocated to eligible green projects.

Any unallocated proceeds will be earmarked and held as cash or cash-equivalents pending investment in Eligible Projects or Assets. Any temporary cash-equivalent investments must be consistent with the objectives of the green financing.

‍Reporting

HICA will publish a monitoring report on an annual basis until full allocation. This report will:

· Provide an update of total amount of proceeds allocated to Eligible Projects and Assets.

· State the remaining balance of any unallocated funds.

· Describe the qualitative and where possible, quantitative, indicators of the projects’ environmental impact.

Each annual letter will be reviewed by the HICA Green Finance Investment Committee and verified by an independent assurance provider in advance of publication. Annual letter can be found on the HICA website.

‍Assurance

HICA will engage an independent assurance provider (as approved by the Green Finance Investment Committee) to provide a second party opinion on this green finance framework, and to annually assure the process used in financing of Eligible Projects and Assets in accordance with the framework. The opinion of the assurance provider will be published at HICA website.

Assurance will take place pre-issuance and on an annual basis for the duration that the green financing is outstanding, prior to the publication of the annual letter. Where feasible, HICA will seek certification following the pre- and post-issuance procedures outlined by International Capital Market Association Green Bond Principles.

HIGH IMPACT CAPITAL ADVISORS LIMITED

Conflicts of Interest Policy

June, 2023

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Set out below is a summary of the High Impact Capital Advisors Limited Conflicts of Interest Policy

The High Impact Capital Advisors Limited is established in Hong Kong under the Hong Kong Law with registered office at: 1103/F Space Sun House, 181 Des Voeux Road Central, Sheung Wan, Hong Kong.

Conflicts of Interest

A Conflict of Interest (“Conflict”) is a situation or arrangement where The High Impact Capital Advisors Limited, or a company with which it has an association, (“HICA”) and/or any of its employees is subject to multiple influences, the competition of which might adversely affect decision-making or outcomes in the course of conducting business.

A Conflict can be due to the competition of legitimate influences (such as acting for multiple clients), or the presence of harmful ones (such as personal gain). Because it provides a wide range of services, HICA may from time to time have interests that conflict with its clients’ interests or with the duties that it owes to its clients.

Conflicts can arise between:

1. one client and another (client versus client);
2. HICA and a client (HICA versus client);
3. an employee and a client (employee versus client);
4. an employee and HICA (employee versus HICA); and/or
5. one part of HICA and another (HICA versus HICA).

HICA has established policies and procedures that are designed to identify, and prevent or manage Conflicts.

Conflicts policies are reviewed at least annually. These policies and procedures include arrangements to safeguard the interests of clients.

How HICA deals with Conflicts

HICA’s organizational structures are designed so that behavior that could lead to Conflicts is not incentivized or rewarded.

Where necessary, HICA restricts the flow of information to certain employees in order to protect its clients’ interests. HICA has procedures in place to:

• Identify all types of potential Conflicts that could reasonably arise in the context of its activities;
• Maintain registers of all potential Conflicts identified;
• Prevent or manage Conflicts on an ongoing basis;
• Disclose Conflicts where appropriate; and
• Maintain evidence of all occurrences of Conflicts that cannot be managed.

Identifying Conflicts

Each of HICA’s businesses is required to consider the types of potential Conflict relevant to the specific services and activities they carry out.

For example, potential Conflicts are considered when:

• Developing a new product;
• Establishing or amending any cross-referral, revenue sharing or joint venture arrangements; or
• Transferring businesses, activities or operations (or parts thereof) to another part of the HICA.

When Potential Conflicts Involve Clients, the Assessment also Takes into Account Whether the Company and/or any employee:

• Is likely to make a financial gain or avoid a financial loss at the expense of any client;
• Has an interest in the outcome of a service provided to a client, or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
• Has a financial or other incentive to favour the interest of one client (or group of clients) over another;
• Carries on the same business as the client; and/or
• Receives or will receive an inducement in relation to a service provided to the client from a person other than the client.

HICA maintains internal registers, documenting and evaluating all identified potential Conflicts. These registers also record the controls in place to prevent or manage each type of Conflict, and are subject to regular oversight and review by HICA senior management. 

Preventing or Managing Conflicts

HICA structures the remuneration, deployment and management of employees in a way that minimizes Conflicts.

Conflicts clearing procedures ensure that, where necessary, potential Conflicts are escalated and managed before HICA is committed to a transaction.

In some cases, HICA will consider declining to act for one of more clients. For example, if:

• A Conflict is too great;
• Confidentiality obligations prevent adequate disclosure (see Disclosure, below); and/or
• Informed consent cannot be obtained, or is an insufficient control to manage a Conflict.

The Managing Partner, is the point of escalation for significant Conflicts, and resolution of cross-business Conflicts brought to its attention. Written reports on the services and activities reflected in the Registers of Conflicts are presented to senior management at least annually.

Disclosure

HICA may make general disclosures to clients about certain types of potential Conflicts, explaining how such Conflicts are managed (for example, through separation of businesses or measures to prevent unauthorised sharing of confidential information) to mitigate the risk of damage to clients’ interests.

However, where HICA has used all reasonable efforts to prevent or manage a Conflict, but the risk of damage to a client interests remains, a specific disclosure about the presence of a Conflict will be made to the client.

Specific disclosures will be made prior to the conclusion of a contract, in a durable medium, and include sufficient detail, taking into account the nature of the client, to enable that client to take an informed decision.

At times, a duty of confidentiality to one client might limit the disclosures that can be made to another.

Employees

HICA requires its employees to apply good judgement and act with integrity, taking all appropriate steps to:

• Avoid personal Conflicts (for example, in their personal account dealings); and
• Proactively escalate personal Conflicts that do arise.

No employee is permitted to advise a client on any matter in which they have a personal interest, nor take commercial decisions on behalf of the Group if those decisions are connected to their personal or external business affairs until steps have been taken to satisfactorily manage the Conflict.

HICA will take all reasonable steps to identify, and prevent or manage, Conflicts of Interest.

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IMPORTANT LEGAL INFORMATION

This publication constitutes marketing material and is not the result of independent financial research. Therefore the legal requirements regarding the independence of financial research do not apply. The information and opinions expressed in this publication were produced by High Impact Capital Advisors, as of the date of writing and are subject to change without notice. This publication is intended for information purposes only and does not constitute an offer, a recommendation or an invitation by, or on behalf of, High Impact Capital Advisors to make any investments. Opinions and comments of the authors reflect their current views, but not necessarily of other High Impact Capital Advisors entities or any other third party. Services and/or products mentioned in this publication may not be suitable for all recipients and may not be available in all countries. In order to be informed about the services and/or products available in such country, please kindly get in touch with High Impact Capital Advisors.

This publication has been prepared without taking account of the objectives, financial situation or needs of any particular investor. Before entering into any transaction, investors should consider the suitability of the transaction to individual circumstances and objectives. Any investment or trading or other decision should only be made by the client after a thorough reading of the relevant product term sheet, subscription agreement, information memorandum, prospectus or other offering document relating to the issue of the securities or other financial instruments. Nothing in this publication constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific investor. High Impact Capital Advisors recommends that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences. Past performance is not a reliable indicator of future results. Performance forecasts are not a reliable indicator of future performance. The investor may not get back the amount invested. Although the information and data herein are obtained from sources believed to be reliable, no representation is made that the information is accurate or complete. High Impact Capital Advisors does not accept liability for any loss arising from the use of this publication. This publication may only be distributed in countries where its distribution is legally permitted. This publication is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) such publications are prohibited.

HIGH IMPACT CAPITAL ADVISORS LIMITED

Environmental, Social and Governance Policy Statement

June, 2023

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ESG Policy

High Impact Capital Advisors Limited is established in Hong Kong under the Hong Kong Law with registered address at: 1103/F Space Sun House, 181 Des Voeux Road Central, Sheung Wan, Hong Kong. Acting upon our fiduciary role as a responsible financial advisor, we are committed to helping clients create profits alongside positive social and environmental impact.

We believe investing in environmental, social and governance (ESG) will help ignite faster progress toward the United Nation 17 Sustainable Development Goals (SDGs), and create long-lasting socioeconomic impact for millions of people worldwide. We aim to incorporate ESG criteria across the entire business value chain of the Firm. Given the diversity of client objectives and requirements, we provide tailored approaches to different types of ESG strategies that would enhance our clients’ profits whiling creating broader benefits for society as a whole.

Mission and Strategy 

Our mission is to finance small companies in making social and environmental impact that matters to the world. Our investment strategy focuses on providing non-bank financial institutions (NBFI) who seek to raise direct private debt and private equity financing with social and green capitals. 

We believe that only an active investment approach delivers the full benefits of ESG to our clients. Our combination of integrated ESG research with a robust market access improves the risk profile of our advices, and steers clients toward greater and more sustainable long-term profitability.

Social capital means providing small businesses and individuals proprietors with access to affordable financial products and services that meet their needs –transactions, payments, savings, credit and insurance – delivered in a responsible and sustainable way, a.k.a. Inclusive Finance

Green capital means financing unsubsidized energy efficiency and renewable energy projects for small businesses and individual proprietors that generate significant energy savings and reduce greenhouse gas emissions by 20% per annum.

In line with our clients’ interests, we continuously improve the process of integrating our all-encompassing ESG approach into our financial advices and contribute to the development of best practices for the ESG community.

Social and green finances help ignite faster progress toward the United Nations 17 Sustainable Development Goals (SDGs), and create long-lasting socioeconomic impact for millions of people worldwide. Evidence is overwhelming that the widespread adoption of social and green finances helped lift people out of poverty between (SDG 1); make investments that result in higher incomes (SDG 2), empower women gaining more control over their finances and greater economic opportunity (SDG 5); access working capital to grow and create new jobs (SDG 8); and enable adoption of affordable and efficient modern energy (SGD 7 and 13). 

ESG Integration Approach

In order to make a meaningful impact, we are committed to, and actively engaged in, applying ESG throughout our entire financial advisory activities.

The cornerstone of our approach is that our dedicated ESG research works hand in hand with our clients. Dialogue between the ESG research and our clients facilitates a wider understanding of specific ESG risks and opportunities at a thematic level.

Our ESG research delivers on (i) ESG risk analysis including material impact potentially on the risk of specific companies; (ii) Best-in-Class ESG ratings model and analysis; (iii) thematic research on the ESG sector frameworks, monitor and highlight emerging ESG risks, and identify long-term trends within or across sectors that provide ESG opportunities or may present ESG risks.

ESG Engagement

We collaboratively participate within the ESG communities around the world, and actively make use of our thought leadership through targeted engagements on select ESG issues. We aim for a holistic engagement approach in seeking dialogues on ESG opportunities and inherent risks among peer groups. By communicating the material impact of ESG issues with our clients, we strive to accelerate board base adoption of ESG while protecting the interests of our clients.

ESG Service Capabilities

All our services aim to deliver a competitive performance and benefit from our ESG risk and return perspective. For clients aiming to achieve a positive environmental and social effect or a pre-defined impact as part of their investment objectives, we offer dedicated impact strategies. For clients aiming to reflect a value-based view, we are able to provide such concepts, for example through exclusion lists.

Exclusion Lists

We aim to avoid reputational risks for our clients. We publish an exclusion list that aims to provide clients with clarity and transparency on investments. 

Climate Risk Statement

We believe that material ESG factors such as climate risk may impact the future performance of investment. We consider climate risk an important long-term risk factor to be considered as part of investment decision making.

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IMPORTANT LEGAL INFORMATION

This publication constitutes marketing material and is not the result of independent financial research. Therefore the legal requirements regarding the independence of financial research do not apply. The information and opinions expressed in this publication were produced by High Impact Capital Advisors, as of the date of writing and are subject to change without notice. This publication is intended for information purposes only and does not constitute an offer, a recommendation or an invitation by, or on behalf of, High Impact Capital Advisors to make any investments. Opinions and comments of the authors reflect their current views, but not necessarily of other High Impact Capital Advisors entities or any other third party. Services and/or products mentioned in this publication may not be suitable for all recipients and may not be available in all countries. In order to be informed about the services and/or products available in such country, please kindly get in touch with High Impact Capital Advisors.

This publication has been prepared without taking account of the objectives, financial situation or needs of any particular investor. Before entering into any transaction, investors should consider the suitability of the transaction to individual circumstances and objectives. Any investment or trading or other decision should only be made by the client after a thorough reading of the relevant product term sheet, subscription agreement, information memorandum, prospectus or other offering document relating to the issue of the securities or other financial instruments. Nothing in this publication constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific investor. High Impact Capital Advisors recommends that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences. Past performance is not a reliable indicator of future results. Performance forecasts are not a reliable indicator of future performance. The investor may not get back the amount invested. Although the information and data herein are obtained from sources believed to be reliable, no representation is made that the information is accurate or complete. High Impact Capital Advisors does not accept liability for any loss arising from the use of this publication. This publication may only be distributed in countries where its distribution is legally permitted. This publication is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) such publications are prohibited.

HIGH IMPACT CAPITAL ADVISORS LIMITED

Statement of Anti Money Laundering (AML) and Counter Terrorist Financing (CTF) Policies and Principles

June, 2023

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High Impact Capital Advisors Ltd. (HICA) is committed to implementing minimum control standards across all jurisdictions for which it operates.

HICA established a Anti-Money Laundering Policy (“AML Policy”) for this purpose. The objective of the AML Policy is to identify and appropriately manage money laundering risks identified by HICA. This is achieved by establishing and implementing appropriate processes, systems and controls to protect HICA, its customers, shareholders, employees, and the communities it serves from money laundering. The AML Policy sets out the minimum control standards to all HICA entities and employees, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.

The AML Policy is informed by applicable laws, regulations, regulatory guidance and best practice from Hong Kong. In cases where material differences exist between the rules and regulations of Hong Kong and other authorities or countries, the AML Policy adopts the highest standard; while acknowledging the primacy of local law.

The Policy includes:

• The appointment of a Money Laundering Reporting Officer (“MLRO”) or alternative position as required by local regulation
• Minimum Customer Due Diligence (“CDD”) requirements, incorporating Customer Identification and Verification (“ID&V”) and Know Your Customer (“KYC”) principles
• Conducting enhanced due diligence (“EDD”) on customers assessed as higher risk; such as Politically Exposed Persons (“PEPs”) in senior positions, their relatives and close associates
• Establishing processes and systems designed to monitor customer transactions for the purpose of identifying suspicious activity
• The investigation and subsequent reporting of suspicious activity to the appropriate regulatory and/or law enforcement bodies
• Mandated regular AML training of employees and contractors
• The prohibition of the following products, services and customer types:
  - Anonymous accounts or numbered accounts or customers seeking to maintain an account in an obviously fictitious name
  - Shell banks, i.e. banks with no physical presence or staff
  - Hold Mail, i.e. where the customer has instructed all documentation related to the account are to be held on their behalf until collection
  - Payable-through-accounts, i.e. HICA does not allow domestic or foreign bank customers to provide payable-through-accounts to their customers on their HSBC accounts
• Mandated regular independent testing by second line assurance function and third line audit function; and
• Any relevant additional local requirements

IMPORTANT LEGAL INFORMATION

This publication constitutes marketing material and is not the result of independent financial research. Therefore the legal requirements regarding the independence of financial research do not apply. The information and opinions expressed in this publication were produced by High Impact Capital Advisors, as of the date of writing and are subject to change without notice. This publication is intended for information purposes only and does not constitute an offer, a recommendation or an invitation by, or on behalf of, High Impact Capital Advisors to make any investments. Opinions and comments of the authors reflect their current views, but not necessarily of other High Impact Capital Advisors entities or any other third party. Services and/or products mentioned in this publication may not be suitable for all recipients and may not be available in all countries. In order to be informed about the services and/or products available in such country, please kindly get in touch with High Impact Capital Advisors.

This publication has been prepared without taking account of the objectives, financial situation or needs of any particular investor. Before entering into any transaction, investors should consider the suitability of the transaction to individual circumstances and objectives. Any investment or trading or other decision should only be made by the client after a thorough reading of the relevant product term sheet, subscription agreement, information memorandum, prospectus or other offering document relating to the issue of the securities or other financial instruments. Nothing in this publication constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific investor. High Impact Capital Advisors recommends that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences. Past performance is not a reliable indicator of future results. Performance forecasts are not a reliable indicator of future performance. The investor may not get back the amount invested. Although the information and data herein are obtained from sources believed to be reliable, no representation is made that the information is accurate or complete. High Impact Capital Advisors does not accept liability for any loss arising from the use of this publication. This publication may only be distributed in countries where its distribution is legally permitted. This publication is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) such publications are prohibited.

HIGH IMPACT CAPITAL ADVISORS LIMITED

Business Continuity Plan

June, 2023

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HIGH IMPACT CAPITAL ADVISORS LIMITED

Business Continuity Plan

Background

A business continuity plan will enable the firm to continue its business in the event of a significant business disruption or, in the alternative, conduct an orderly wind-down of operations.

In this Policy document, clients of High Impact Capital Advisors Limited (HICA) will find information on HICA commitment to these obligations and highlights of our Business Continuity Plan.

HICA Business Continuity Plan

Effective business continuity measures are critical for any business entity. HICA is committed to protecting its staff and ensuring the continuity of critical businesses and functions in order to protect the HICA franchise, mitigate risk, safeguard revenues and sustain both a stable business and customer confidence. The development, implementation, testing and maintenance of an effective global Business Continuity and Disaster Recovery plan are required to sustain these objectives.

To further our commitment in the event of a significant business disruption, as well as meet all regulatory requirements, HICA’s infrastructure includes a Business Continuity Management (“BCM”) team that is an integral part of HICA's normal business operations. BCM plans, tests, and manages crises concerning business lines and functions’ relocation and recovery.

Ten Critical Components

Our plans to ensure business continuity address the ten key areas:

1. Data back-up and recovery (hard copy and electronic) – identification of the location of primary books and records (hard copy and electronic) and the location of back-up books and records (hard copy and electronic). In addition, the Company must be prepared to describe how they back up data, as well as how they will recover data in the event of a significant business disruption.
2. All mission critical systems – systems that are necessary, depending on the nature of a member's business, to ensure prompt and accurate processing of transactions, including, but not limited to, order taking, order entry, execution, comparison, allocation, settlement of transactions, the maintenance of customer accounts, access to customer accounts and the delivery of funds and securities.
3. Financial and operational assessments – written procedures that allow the Company to identify changes in its operational, financial, and credit risk exposures. Operational risk focuses on the Company's ability to maintain communications with customers and to retrieve key activity records through its "mission critical systems." Financial risk relates to the Company's ability to continue to generate revenue and to retain or obtain adequate financing. Firms may also face credit risk, which would also hinder the ability of the Company’s counter-parties to fulfil their obligations.
4. Alternate communications between customers and the Company – alternate means of communications that a firm will use to communicate with its customers in the event of a significant business disruption.
5. Alternate communications between firm and its employees – alternate means of communications that a firm will use to communicate with its employees in the event of a significant business disruption.
6. Alternate physical location of employees – alternate locations must be designated for employees, including key personnel that have been identified to assist in the resumption of business operations.
7. Critical business constituents, banks, and counter-party impact – effect a significant business disruption will have on the Company’s relationship with its critical business constituents, banks, and counter-parties, and how it will deal with those impacts.
8. Regulatory reporting if required – available means the Company can use to continue its compliance with regulatory reporting requirements.
9. Communications with regulators if required – communication with regulators through whatever means are still available, including the designation of business continuity plan contacts with regulators to assist in these communications.
10. Providing customers prompt access to their information – measures the Company will use to make customer records available to customers in the event of a significant business disruption.

HICA has long maintained business continuity and disaster recovery plans to ensure robust operations through times of crisis. HICA has established its emergency team to quickly address changing circumstances, including monitoring compliance with applicable internal policies.

We recognize that our services are critical to our customers' success, and that this depends first and foremost on the health of our employees. In line with recommendations from the World Health Organization, and local authorities, we have taken steps to reduce our exposure to infection and to limit HICA personnel from potentially contracting or spreading COVID-19.

We will continue to update this policy as this situation evolves.

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IMPORTANT LEGAL INFORMATION

This publication constitutes marketing material and is not the result of independent financial research. Therefore the legal requirements regarding the independence of financial research do not apply. The information and opinions expressed in this publication were produced by High Impact Capital Advisors, as of the date of writing and are subject to change without notice. This publication is intended for information purposes only and does not constitute an offer, a recommendation or an invitation by, or on behalf of, High Impact Capital Advisors to make any investments. Opinions and comments of the authors reflect their current views, but not necessarily of other High Impact Capital Advisors entities or any other third party. Services and/or products mentioned in this publication may not be suitable for all recipients and may not be available in all countries. In order to be informed about the services and/or products available in such country, please kindly get in touch with High Impact Capital Advisors.

This publication has been prepared without taking account of the objectives, financial situation or needs of any particular investor. Before entering into any transaction, investors should consider the suitability of the transaction to individual circumstances and objectives. Any investment or trading or other decision should only be made by the client after a thorough reading of the relevant product term sheet, subscription agreement, information memorandum, prospectus or other offering document relating to the issue of the securities or other financial instruments. Nothing in this publication constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific investor. High Impact Capital Advisors recommends that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences. Past performance is not a reliable indicator of future results. Performance forecasts are not a reliable indicator of future performance. The investor may not get back the amount invested. Although the information and data herein are obtained from sources believed to be reliable, no representation is made that the information is accurate or complete. High Impact Capital Advisors does not accept liability for any loss arising from the use of this publication. This publication may only be distributed in countries where its distribution is legally permitted. This publication is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) such publications are prohibited.

HIGH IMPACT CAPITAL ADVISORS LIMITED

Data Privacy and Security Policy

June, 2023

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How Your Information is Used

In accordance with Hong Kong data protection laws (as amended, updated or replaced from time to time), the General Data Protection Regulation (EU) 2016/679 and laws applicable to the processing of personal data (together, the “Data Protection Laws”), the High Impact Capital Advisors Limited (“the Company”), acting as “data controller” within the meaning of the Data Protection Laws, hereby informs prospective investors and clients of the Company (together, “the Customers”) that personal data provided by each Customer to the Company (“Personal Data”, as defined in paragraph (b), below) will be collected, recorded, stored, adapted, disclosed, transferred or otherwise processed, by electronic means or otherwise, for the following purposes (each a “Processing Purpose”):

1. to enable and deliver the Company’s services, including (without limitation) the facilitation, communication and payment by and to the Company, and generally to enable and give advice to the Customers of the Company;
2. to carry out or to facilitate the carrying out with respect to the Customers’ credit, money laundering, due diligence and conflict checks for the purposes of fraud, money laundering, financial crime prevention and tax identification laws (including FATCA and the international Common Reporting Standard, and applicable antimoney laundering laws), and generally to enable the Company to comply with its legal obligations arising in connection therewith;
3. to facilitate the provision to the Company of services by its service providers, including (without limitation) the authorization or confirmation of billing transactions and payments by and to the Company;
4. to facilitate the operational support and development necessary to the Company’s investment advisory objectives and strategies with respect to its advisory services, including (without limitation) the Company’s risk management processes, and the services provided to the Company by third-party service providers;
5. in relation to any litigation, disputes or contentious matter in which the Company is involved;
6. to comply with legal and regulatory requests made to the Company anywhere in the world;
7. to facilitate reporting, including (without limitation) transaction reporting to, and audits by, national and international regulatory, enforcement or exchange bodies, and tax authorities, and the compliance by the Company with court orders associated therewith;
8. for the Monitoring Purposes defined and specified in paragraph (e) below; and
9. for direct marketing purposes specified in paragraph (f) below. The Company will not collect Personal Data without a valid legal ground. Accordingly, the Company will only process and use Personal Data:
   
   a. if necessary, to enter into, to execute or to carry out a contract with each Customer for the services required by the Customers (as described in Processing Purposes 1 above);
   b. if necessary, for the Company’s legitimate interests, provided in each case that such interests are not overridden by the privacy interests of impacted individuals. The Company’s legitimate interests are described in the Processing Purposes 2, 3, 4, 5, 6 and 7, above;
   c. to exercise and defend the Company’s legal rights anywhere in the world as described in Processing Purpose 5 above;
   d. if necessary, to comply with legal obligations, (including any legal or regulatory guidance, codes or opinions), applicable to the Company anywhere in the world as described in Processing Purposes 2, 5 and 6 above; and 
   e. if necessary, for the performance of a task carried out in the public interest as described in Processing Purposes 2, 3, 4, 5 and 6.

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IMPORTANT LEGAL INFORMATION

This publication constitutes marketing material and is not the result of independent financial research. Therefore the legal requirements regarding the independence of financial research do not apply. The information and opinions expressed in this publication were produced by High Impact Capital Advisors, as of the date of writing and are subject to change without notice. This publication is intended for information purposes only and does not constitute an offer, a recommendation or an invitation by, or on behalf of, High Impact Capital Advisors to make any investments. Opinions and comments of the authors reflect their current views, but not necessarily of other High Impact Capital Advisors entities or any other third party. Services and/or products mentioned in this publication may not be suitable for all recipients and may not be available in all countries. In order to be informed about the services and/or products available in such country, please kindly get in touch with High Impact Capital Advisors.

This publication has been prepared without taking account of the objectives, financial situation or needs of any particular investor. Before entering into any transaction, investors should consider the suitability of the transaction to individual circumstances and objectives. Any investment or trading or other decision should only be made by the client after a thorough reading of the relevant product term sheet, subscription agreement, information memorandum, prospectus or other offering document relating to the issue of the securities or other financial instruments. Nothing in this publication constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific investor. High Impact Capital Advisors recommends that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences. Past performance is not a reliable indicator of future results. Performance forecasts are not a reliable indicator of future performance. The investor may not get back the amount invested. Although the information and data herein are obtained from sources believed to be reliable, no representation is made that the information is accurate or complete. High Impact Capital Advisors does not accept liability for any loss arising from the use of this publication. This publication may only be distributed in countries where its distribution is legally permitted. This publication is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) such publications are prohibited.