A. BUSINESS DESCRIPTION / OWNERSHIP – CAMHK was established in September 2008 as a
wholly owned subsidiary of China Asset Management Co. Ltd. (“ChinaAMC”) to strategically develop
ChinaAMC’s offshore business and investment capabilities.
ChinaAMC was established in April 1998 as one of the first nation-wide fund management companies
in the People’s Republic of China (“China”). As of December 31, 2023, ChinaAMC is one of the largest
fund management company in terms of mutual fund assets under management in China. ChinaAMC
provides investment management and advisory services to both retail and institutional clients.
B. TYPES OF ADVISORY SERVICES OFFERED –CAMHK provides services to U.S.-based
registered investment companies, including exchange-traded funds (“ETFs”). CAMHK also provides
discretionary investment management, investment advisory and related support services to a wide-
range of non-U.S. clients, including pension and profit-sharing plans, pooled investment vehicles and
corporations.
In performing advisory services, CAMHK is authorized to utilize the talents of investment
professionals of affiliated investment advisory firms to manage a particular strategy or product. In
keeping with applicable regulatory guidance, each such affiliate has entered into a Memorandum of
Understanding (“MOU”) with CAMHK through which the affiliate is considered a “Participating
Affiliate” of CAMHK as that term is used in relief granted by the staff of the SEC. This allows CAMHK,
as a U.S. registered investment adviser, to use the resources of non-U.S. affiliates, i.e., Participating
Affiliates, to render portfolio management, research or trading services to clients
of CAMHK.
The arrangement with Participating Affiliates positions CAMHK to offer investment management
styles and strategies that it otherwise may not manage under the framework of U.S. regulations. In
partnering with affiliates, CAMHK offers management and related services to U.S. clients provided by
investment management personnel associated with Participating Affiliates, who are viewed as best
positioned to provide the expertise required to manage a particular strategy or product. Investment
professionals of a Participating Affiliate are authorized to render substantially similar portfolio
management research or trading services to their own advisory clients and the performance achieved
may be better or worse than that achieved on behalf of CAMHK clients.
In addition to its registration with the SEC, CAMHK is licensed and regulated by the Securities and
Futures Commission in Hong Kong to carry on regulated activities of the following types:
• Type 1 (dealing in securities – distribution of unit trusts)
• Type 4 (advising on securities)
• Type 9 (asset management) in Hong Kong
C. TAILORING ADVISORY SERVICES TO INDIVIDUAL NEEDS OF CLIENT
The goals and objectives for each client are documented in investment management agreements/
advisory agreements. Clients can impose restrictions on investing in certain securities or types of
securities.
D. CAMHK’s ASSETS UNDER MANAGEMENT — As of December 31, 2023, CAMHK had
CAMHK – ADV 2A – pg . 2
$7,166,417,121 (USD) in assets under management.
U. S. Dollar Amount
Discretionary: $6,709,507,899
Non-Discretionary: $456,909,222
Total: $7,166,417,121
CAMHK – ADV 2A – pg . 3