Item 5: Performance-Based Fees......................................................................................... 4 Item 6: Types of Clients ....................................................................................................... 4 Item 7: Methods of Analysis, Investment Strategies and Risk of Loss ................................. 5 Item 8: Disciplinary Information .......................................................................................... 8 Item 9: Other Financial Industry Activities and Affiliations .................................................. 8 Item 10: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................ 8 Item 11: Brokerage Practices ............................................................................................... 9 Item 12: Review of Accounts ............................................................................................. 10 Item 13: Client Referrals and Other Compensation ........................................................... 11 Item 14: Custody ............................................................................................................... 11 Item 15: Investment Discretion ........................................................................................ 11 Item 16: Voting Client Securities....................................................................................... 11 Item 17: Financial Information ......................................................................................... 12 Item 2: Material Changes This is Synergy Fund Management Group Limited’s brochure filing for the 2022 annual amendment. Item 3: Advisory Business Our Firm Synergy Fund Management Group Limited (“Synergy”, “we” or the “Firm”) is a company limited by shares incorporated in Hong Kong on January 25, 2010. Synergy is licensed by the Securities and Futures Commission in Hong Kong to conduct Type 4 (Advising on Securities)

and Type 9 (Asset Management) activities. As of Dec 31, 2022, Synergy has provided investment advisory services to Synergy Asia Market Neutral Master Fund (“SAMNMF”), Synergy Asia Market Neutral Fund (“SAMNF”), Synergy Asia Master Fund (“SAMF”), Synergy Asia Feeder Fund (“SAFF”), Synergy Global Market Neutral Master Fund (“SGMNMF”), Synergy Global Market Neutral Feeder Fund (“SGMNFF”) and Synergy Global Fund (“SGF”) (collectively, the “Funds”), each a privately pooled investment vehicle incorporated in the Cayman Islands as exempted companies with limited liability (the “Fund” ). The Funds are exempted from registration under the Investment Company Act of 1940. Synergy also manages separately managed accounts (each an “SMA”) and provides advisory service to clients. Principal Owners Synergy is 100% owned and controlled by LAU Sau Han, Eliza, who holds Synergy ownership via ABDE & Associates Limited. Client Types Synergy serves as an Investment Adviser to the Funds, which are exempted from registration under the Investment Company Act of 1940, and provides advisory and discretionary services to other exempt funds, clients, and/or SMAs. Types of Services Offered Synergy provides investment advisory services to the Funds, clients and SMAs (“Investors”) in accordance with the investment objectives described in the Funds’ offering documents or investment mandates as amended and supplemented from time to time (“Offering Materials”). Investors may impose restrictions on investing in certain securities or types of securities by virtue of letter agreements or other similar agreements (“Side Letters”) providing different rights and benefits. As of 31 December 2022, Synergy managed approximately US$ 617M of regulatory assets on a discretionary basis (excluding SMA assets).
The fees applicable to the Funds are set forth in detail in the Funds’ Offering Materials; with respect to all share classes, the Firm receives an annual management fee ranging up to 1.25% per annum in respect of the net asset value (“NAV”) of the Funds (“Management Fee”). The Management Fee is payable monthly in arrears The Funds pay for its organizational expenses as well as all costs related to its investments, including but not limited to, accounting, auditing, tax preparation, legal, administration and applicable transaction costs. The management fees applicable to the clients with SMAs are agreed with clients in the Investment Management Agreements (“IMAs”) The clients with SMAs will incur all investment expenses related to trading or dealing in the assets of the SMAs including custodial fees, brokerage commissions, clearing fees, transfer or stamp taxes, and other transaction costs.