STAFF
DEALING POLICY
Trading officers/account executive
shall identify all discretionary accounts annually at the financial yearend in
March and/or upon request. Trading
officers/account executive shall obtain approvals from director(s) of the
company for operate an outside trading account other than Rosa Securities
Limited. Trading officers/account
executive shall report the trading details of their outside trading accounts,
if any, to the company annually at the financial yearend in March and/or upon
request. Trading of
clients shall have priority over self-trading including account executive and
trading officers. Client codes,
including account executive and trading officers, must be input into trading
system MWS or AMS which are not changeable after execution to guarantee safety
and fairness. Staff trading shall
only be operated under self-name for proper supervision. Speculation is not encouraged for
trading officers. Trading of
trading officers/account executive shall be reviewed by directors. Trading officers and account executive shall
also follow the following trading guidelines
TRADINGS GUIDELINES ¹µû¥æ©ö«ü«n
A. Definitions ©w¸q
l
¡§child of Employee¡¨ means any child of Employee under the age of 18 or
over the age of 18 and under the age of 25 being a dependent of the
Employee. Children of Employee shall
be construed accordingly; ¡§¹µû¤§¤l¤k¡¨«ü¹µû¤§¥ô¦ó¤£¶W¹L¤Q¤K·³©Î¶W¹L¤Q¤K·³¦Ó¤Ö¹L¤G¤Q¤·³¤´¬°¨Ì¾a¹µû¤§¥ô¦ó¤l¤k¡C ¡§¹µû¤§¤l¤kÌ¡¨À³¾Ú¦¹¬ÛÀ³¦a¸àÄÀ¡F
l
¡§associate¡¨ means any person whom an Employee is able to influence as
regards securities dealings and would normally include: - (i) an Employee¡¦s
spouse or children or a member of his immediate household; and (ii) an
immediate member of the Employee¡¦s family or of the family of the Employee¡¦s
spouse. It also means any company,
corporation, association or their business entity which an Employee is able to
influence as regards securities dealings and would normally include an entity
in which: - (i) an Employee or his spouse is interested and which is under his
or his spouse¡¦s (as the case may be) effective control; (ii) an Employee¡¦s
spouse or children or a member of his immediate household whose investment
decisions are taken on the Employee¡¦s advice is interested and which is under
that person¡¦s effective control; and (iii) any person who is an immediate
member of the Employee¡¦s family or of the family of the Employee¡¦s spouse and
whose investment decisions are taken on the Employee¡¦s advice is interested and
which is under that person¡¦s effective control; ¡§Ápô¤H¤h¡¨«ü¥ô¦ó¥i³Q¹µû¼vÅT¦³Ãö¨äÃÒ¨éú³¶R½æªº¤H¤h¡A³q±`·|¥]¬A¡G(i) ¹µû¤§°t°¸©Î¤l¤k̩Ψ䪽±µ¦í¤áªº¤@û¡F¤Î(ii) ¹µûª½¨t®aÄݩΨä°t°¸ª½¨t®aÄݤ§¤@¦¨û¡C ¡§Ápô¤H¤h¡¨ ¥ç«ü¥ô¦ó¥i³Q¹µû¼vÅT¦³Ãö¨äÃÒ¨éú³¶R½æªº¤½¥q¡Bªk¹Î¡B¨ó·|¡B©Î¨ä¥L°Ó·~ÓÅé¡A³q±`·|¥]¬A¡G(i)¹µû©Î¨ä°t°¸¾Ö¦³Åv¯q¤Î¸Ó¹µû©Î¨ä°t°¸(µø¦ó±¡§Î¦Ó©w)¦³¹ê½è±±¨îªºÓÅé¡F(ii)¹µû¤§°t°¸©Î¤l¤k̩Ψ䪽±µ¦í¤áªº¤@û(¥Lªº§ë¸ê¨M©w¬OÅ¥±q¹µûªº«ØÄ³«á§@¥Xªº)¾Ö¦³Åv¯q¤Î¦³¹ê½è±±¨îªºÓÅé¡F¤Î(iii)¥ô¦ó¤H¤h¬°¹µûª½¨t®aÄݩΨä°t°¸ª½¨t®aÄݤ§¤@¦¨û(¸Ó¤H¤hªº§ë¸ê¨M©w¬OÅ¥±q¹µûªº«ØÄ³«á§@¥Xªº)¾Ö¦³Åv¯q¤Î¦³¹ê½è±±¨îªºÓÅé¡F
l
¡§exchanges¡¨ means The Stock Exchange of Hong Kong Ltd and any other exchange
on which the Employer trades or will trades; ¡§¥æ©ö©Ò¡¨«ü»´äÁp¦X¥æ©ö©Ò¦³¤½¥q¤Î¥»¤½¥q¦b¤º¶R½æ©Î±N©ó¶R½æªº¥æ©ö©Ò©ÎÃÒ¨éú³¥«³õ¡F
l
¡§firm¡¨ means the Employer and any associated company of the Employer,
associated companies mean any two or more companies or bodies corporate
including Employer, one of which is the holding company of the other or
others; ¡§¥»¤½¥q¡¨«ü¹µ¥D¤Î¥ô¦ó¹µ¥DªºÁpô¤½¥q¡CÁpô¤½¥q«ü¥ô¦ó¨â¶¡©Î¥H¤Wªº¤½¥q©Îªk¤H¹ÎÅé(¥]¬A¹µ¥D¦b¤º)¡A¦Ó¨ä¤¤¤@¶¡¬O¥t¥~¤@¶¡©Î¨ä¥L¤½¥qªº¥À¤½¥q¡F
l
¡§securities¡¨ is as defined in the Securities Ordinance (Cap. 333); ¡§ÃÒ¨éú³¡¨«ü¦p¦bÃÒ¨éú³±ø¨Ò(²Ä¤T¤T¤T³¹)¤ºªº©w¸q¡F
l
¡§commodity" is as defined in the Commodities Trading Ordinance and
all such equivalent products listed or traded on markets outside Hong Kong; and
¡§°Ó«~¡¨«ü¦p¦b°Ó«~±ø¨Ò(²Ä¤G¤¹s³¹)¤ºªº©w¸q¡A¤Î©Ò¦³¦b»´ä´ä¥H¥~ªº¥«³õ¤W¥«©Î¥æ©öªº¦Pµ¥²£«~¡F¤Î
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¡§ controller¡¨
means the highest position on-duty personnel in charge of clients¡¦ trading or
the Manager. ¡§¥DºÞ¡¨«ü¦b·íȤ§³Ì°ªÂ¾¦ì«È¤á¥æ©ö¥Nªí©Î¤½¥q¸g²z¡C
B. Employee or associate shall not deal in any security with
respect to: (a) which the firm has in the course of or in connection with its
business, (b) or the Employee has in the course of or in connection with his
employment or dealing on behalf of the Firm; information (i) which is not generally available to
he public and holders of the security concerned (ii) and if the information were so available would likely
bring about a material change in the market price of the security
concerned. (Such information
includes knowledge of outstanding or probable orders in the security
concerned.) Y¦³¥H¤U±¡§Î¯A¤Î¬YÃÒ¨é¡A¹µû©ÎÁpô¤Hµ¥«h¤£¯à¶R½æ¸ÓÃÒ¨éú³¡G(a) ¥»¤½¥q¦b¶i¦æ¨ä·~°È¹Lµ{¤¤©Î»P¨ä·~°È¦³Ãö³s¦Ó±o¨ì¡F(b)©Î¸Ó¹µû¦b¤u§@¤W©Î»P¨ä¤u§@¦³Ãö³s©Î¥N¥»¤½¥q§@¥æ©ö¦Ó±o¨ì¦p¤Uªº¸ê®Æ¡G (i)¤½²³»P¦³ÃöÃÒ¨éú³«ù¦³¤H¤£¯à´¶¹MÀò±oªº¸ê®Æ (ii)¤ÎY¸Ó¸ê®Æ¥i³Q´¶¹MÀò±o¡A«Ü¥i¯à¦³¥O¦³ÃöÃÒ¨éú³ªº¥«»ù¦³«¤jÂàöÜ¡C(¸Óµ¥¸ê®Æ¥]¬A¦³ÃöÃÒ¨éú³¥¼§¹¦¨ªº¶R½æ«ü¥Ü©Î¥i¯à¦³¶R½æ«ü¥Üªº®ø®§¡C)
C.
Employee or associate shall not deal in the following securities: - ¹µû©ÎÁpô¤Hµ¥«h¤£¯à§@¥H¤UÃÒ¨éú³ªº¶R½æ¡G
(i)
a security of
the Firm or any of its subsidiaries and any other securities with which the
Firm is closely connected as determined by the Firm for a period of 6 weeks
prior to the announcement of the interim or final financial report of the Firm
or any of the aforesaid subsidiaries except with the prior approval of the
Firm; °£«D¦³¥»¤½¥q¨Æ¥ý§åã¡A¦b¥»¤½¥q©Î¥ô¦ó¨äªþÄݤ½¥q¤½§G¨ä¤¤´Á©Î¥½´Á°]¬F³ø§i«e¤»¬P´Á´Á¶¡¡A§@¥»¤½¥q©Î¨äªþÄݤ½¥qªºÃÒ¨éú³¶R½æ¡A¤Î§@»P¥»¤½¥q¦³±K¤ÁÃö«Y(ÀH¥»¤½¥q¨M©w)ªº¥ô¦óÃÒ¨éú³¶R½æ¡F
(ii)
a security of an
offeree company during the offer period of a take-over where the Firm is acting
as a corporate finance adviser or involved in the take-over in any way; ´£¥X¦¬ÁÊ´Á¶¡ªº³Q¦¬Áʤ½¥qªºÃÒ¨é¡A¦Ó¥»¤½¥q§@¬°¸Ó¤½¥qªº¤½¥q°]°ÈÅU°Ý©Î¥H¥ô¦ó§Î¦¡»P¸Ó¦¬Áʦ³Ãö³s¡F
(iii)
a security which is
related to a publicly listed company which is also a client of the Firm;
or »P¤@¶¡¤½¶}¤W¥«¤½¥q¦³³sô¥ç¬°¥»¤½¥q«È¤áªºÃÒ¨é¡F©Î
(iv)
a security in which
a client of the Firm is dealing or where orders are being solicited either by
written research or spoken communication by the Firm. ¥»¤½¥q«È¤á¥¿¦b§@¥æ©öªºÃÒ¨é¡A©Î¨ä¶R½æ«ü¥Ü¬O±q¥»¤½¥qªº®Ñ±¬ã¨s©Î¤fÀYÁpµ¸©Ò°ÂÅó¦Ó¨ÓªºÃÒ¨é¡C
D.
Employee or associate shall not sell a security within 60 days of the
first official date of dealings in such security was acquired in any offer for
sale in which the Firm was involved.
¹µû©ÎÁpô¤Hµ¥¤£¥i¦b¥¿¦¡¥æ©öº¤é«áªº¤»¤Q¤Ñ¤º°â½æ¥ô¦ó¥»¤½¥q¦³°Ñ»Pªº¥X°âÁܽФ¤Àò±oªº¥ô¦óÃÒ¨é¡C
E.
Employee or associate shall not knowingly deal directly for his or its
own account with a client of the Firm.
¹µû©ÎÁpô¤Hµ¥¤£¯à¦³·N¦a¬°¥»¨½ã¤áª½±µ»P¥»¤½¥qªº«È¤á¶R½æ¡C
F.
Employee or associate shall not deal against the interests of the Firm
in any security in which the Firm makes a market and all dealings in such
security require the prior approval of the Firm. ¹µû©ÎÁpô¤Hµ¥¤£¯à¦b¥»¤½¥q¬°¬Y¤@ÃÒ¨éú³¨î³y¥«³õ®É¡A¥H¬Û¹ï¥»¤½¥q§Q¯q§@¶R½æ¡A¤Î©Ò¦³¦¹µ¥ÃÒ¨éú³ªº¶R½æ»Ýn±o¨ì¥»¤½¥qªº¨Æ¥ý§åã¡C
G.
Employee or associate shall not purchase, sell or otherwise deal,
directly or indirectly, in any security that is the subject of research and/or recommendation
by the Firm 3 weeks before and after the issue of the relevant research, report
or recommendation. ¦bµo©ñ¦³Ãö¬ã¨s¡B³ø§i©Î«ØÄ³¤T¬P´Á¤§«e¤Î¤§«á¡A¹µû©ÎÁpô¤Hµ¥¤£¯àª½±µ©Î¶¡±µ¦a¶R¡B½æ©Î¥H¥ô¦ó¤è¦¡¶R½æ¥ô¦ó¤@°¦¬°¥»¤½¥q¬ã¨s¤Î/©Î«ØÄ³¥DÃDªºÃÒ¨éú³¡C
H.
Where dealing in a security is not prohibited by these guidelines, the
following dealings in such securities shall be done ONLY through the Firm in
accordance with these guidelines:
·í¬YÃÒ¨éú³ªº¶R½æ¤£¦b¦¹«ü«n¸T¨î¤§¤º¡A¸ÓÃÒ¨éú³ªº¤U¦C¶R½æ¥u¯à®Ú¾Ú¦¹«ü«n³z¹L¥»¤½¥q¶i¦æ:
(a)
by Employee or associate; ¹µû©ÎÁpô¤Hµ¥ªº¶R½æ¡F
(b)
by any trust (regardless of who the beneficiary may be) where Employee
or associate is a trustee and takes part in investment decisions; ¥ô¦ó«H°Uªº¶R½æ¡A¦ÓµL½×¨ü¯q¤H¬°½Ö¡A¹µû©ÎÁpô¤Hµ¥¬°¸Ó«H°Uªº¤@¨ü°U¤H¤Î°Ñ»P§@§ë¸ê¨M©w¡F
(c)
by any trust where Employee or associate is a beneficiary and takes
part in investment decisions; ¥ô¦ó«H°Uªº¶R½æ¡A¦Ó¹µû©ÎÁpô¤Hµ¥¬°¸Ó«H°Uªº¤@¨ü¯q¤H¤Î°Ñ»P§@§ë¸ê¨M©w¡F
(d)
by any company where Employee or associate has sufficient shareholding
to control or influence the company, its board or the conduct of the company¡¦s
business; ¥ô¦ó¤½¥qªº¶R½æ¡A¦Ó¹µû©ÎÁpô¤Hµ¥¦³¨¬°÷«ùªÑ¶q¥h±±¨î©Î¼vÅT¸Ó¤½¥q¡B¸Ó¸³¨Æ§½¡B©Î¸Ó¤½¥qªº·~°È¹B§@¡F
(e)
applications for new issues by Employee or associate; or ¹µû©ÎÁpô¤Hµ¥ªº·sµo¦æÃÒ¨éú³¥Ó½Ð¡F©Î
(f)
any other dealings in which Employee plays a part in the investment
decision either for friends, relatives or family investment vehicles or where
an employee may directly or indirectly receive any economic benefit. ¥ô¦ó¨ä¥L¶R½æ¡A¦Ó¦³¸Óµ¥¶R½æ¤¤¡A¹µû°Ñ»P¬°ªB¤Í¡B¿ËÄݩήaÄݧë¸ê¤u¨ã©Ò§@ªº§ë¸ê¨M©w¡A©Î±q¸Óµ¥¶R½æ¤¤¹µû¥iª½±µ©Î¶¡±µ¦a¦¬¨ú¥ô¦ó¸gÀÙ§Q¯q¡C
I
All dealings by Employee, associate or by any trust as mentioned in paragraph
H above (¡§Dealings¡¨) must be effected inthe name of the employee, the relevant
associate or trust (as the case may be).
©Ò¦³¦b¥H¤W²ÄH¬q´£¤Îªº¹µû¡BÁpô¤Hµ¥©Î¥ô¦ó«H°U©Ò§@ªº¶R½æ(¡§©Òz¶R½æ¡¨)¤@©wn¥H¹µû¡B¦³ÃöÁpô¤Hµ¥©Î«H°Uªº¦W¸q(µø¦óºØ±¡§Î¦Ó©w)¶i¦æ¡C
J
Employee¡¦s Dealings orders shall be entered into the trading system of
the Firm or the Exchange. ¹µû©Ò¦³©Òz¶R½æ«ü¥Ü¥²¶·¿é¤J¥»¤½¥q©Î¥æ©ö©Òªº¥æ©ö¨t²Î¡C
K
When the Firm executes a Dealing for Employee, he shall be treated as
if he were a client of the Firm and his rights and obligations shall be the
same as those of the clients of the Firm except at the Firm¡¦s discretion, (a) the brokerage and/or the Firm¡¦s
charges related to the Dealings may be at a reduced rate but subject to the
Rules of the Exchange; and
(b) dealing for a client of the Firm or for the Firm itself shall always
have priority over the Dealings particularly in terms of the most favourable
dealt prices and the order of allocation in the event of a partially filled
order. ·í¥»¤½¥q¬°¹µû°õ¦æ©Òz¶R½æ¡A¥²¶·§â¹µûµø§@¥»¤½¥q«È¤á¹ï«Ý¡A¦Ó¹µûªºÅv§Q©M¸q°È¡A°£¤Uz¥~¡A¥²¶·»P¥»¤½¥qªº«È¤áªºÅv§Q©M¸q°È¬Û¦P: (a) ±©©ó¥æ©ö©Ò³W«h¡A¥»¤½¥q¦³°u±¡Åv´î§C¸g¬ö¦þª÷¤Î/©Î¥»¤½¥q»P©Òz¶R½æ¦³Ãöªº¶O¥Î¡F¤Î (b) ¥»¤½¥q«È¤á©Î¥»¤½¥qªº¶R½æ¥Ã»·¤ñ©Òz¶R½æ¦³Àu¥ýÅv¡A¤×¨ä¬O¥H³ÌÀu´f¥æ©ö»ù¤Î¦b³¡¥÷§¹¦¨«ü¥Üªº±¡§Î¤U¤À°tªº¦¸§Ç¨Ó»¡¡C
L
All Dealings shall be confined to transactions, which are reasonable
within the means of Employee or associate or trust (as the case may be) or the
agreed credit facility from the firm.
¥þ³¡©Òz¶R½æ¥²¶·©ó¹µû¡BÁpô¤Hµ¥©Î«H°U(µø¦óºØ±¡§Î¦Ó©w)ªº¦X²z¯à¤O©Î»P¥»¤½¥q¤w¦³¨óijªº«H¥Î¦w±Æªº½d³ò¤º¶R½æ¡C
M
All Dealings by Employee must be limited to reasonable levels having
regard to his work commitments to the Firm as well as his financial
position. ¹µûªº©Ò¦³¶R½æ¥²¶·³W©ó¦Ò¼{¨ì¨ä»P¥»¤½¥q¤u§@¥÷¶q¤Î¨ä¸gÀÙª¬ªpªº¦X²zµ{«×¤º¡C
N
Where it is found that any of these guidelines has been breached, the
Firm shall have the right to reverse any Dealing which is subject to these
guidelines, with or without notice to Employee or associate and at the Employee¡¦s
cost and expense, or the cost and expense of the associate and any profit will
be retained by the Firm for its own use if subsequent investigation justifies
such retention, provided any reversal of Dealing under this paragraph is
reasonable in the circumstances. ·íµoı¹H¤Ï¦¹´£«ü«nªº¥ô¦ó¤@±ø¡AµL½×¦³§_³qª¾¹µû©Î¸ÓÁpô¤Hµ¥¡A¥»¤½¥q±N¦³Åv±À½¥ô¦ó³Q¦¹«ü«n©Ò³Wªº©Òz¶R½æ¡A¤Î·|¥Ñ¹µû©Î¸ÓÁpô¤Hµ¥t³d¶O¥Î»P¤ä¥X¡F¤ÎY¨ä«á½Õ¬dÃÒ©ú¥»¤½¥q«O¯d¥ô¦ó§Q¼í§@¬°¨p¥Î¬O¥¿·íªº¸Ü¡A¥»¤½¥q·|§@¥X¸Óµ¥«O¯d¡A¦ý±À½¸Ó©Òz¶R½æ¥u¯à¦b¦X²z±¡§Î¤U¤~¥i¶i¦æ¡C
O
Any new client introduced by Employee shall be approved by the Firm/the
controller prior to trading. ¥ô¦ó¹µû¤¶²Ðªº·s«È¤á¦b¶i¦æ¶R½æ«e¡A¥²¶·¥Ñ¥»¤½¥q/¥DºÞ§åã¡C
P
The burden of proving compliance with these guidelines is on the
Employee concerned and if in any doubt, employee is advised to consult the
Firm/the controller before undertaking any Dealing. ÃÒ©ú¦³¿í¦u¦¹«ü«nªº³d¥ô¦b¹µû¨¤W¡AY¦³¥ô¦óºÃ°Ý¡A¦b¦¹ÄU³ë¹µû¦b¶i¦æ¥ô¦ó¶R½æ«e»P¥»¤½¥q/¥DºÞ¬d¸ß¡C
Q
The Firm/the controller will review all Dealings daily and has he right
to require any transaction to be reversed under paragraph N above where there
is any possibility that such transaction to contrary to the interests of any of
its clients or in breach of any of these guidelines. In such event, the employee concerned will have to make good
any shortfall or loss to the parties involved unless the employee concerned is
able to establish that he did not know or could not have reasonably known of
the possibility that such Dealing would likely be contrary to the interests of
any of the Firm¡¦s clients or be in breach of any of these guidelines. ¥»¤½¥q/¥DºÞ·|¨C¤é¼f®Ö©Ò¦³¹µû©Òz¶R½æ¡A¤ÎY¦³Ãö¶R½æ¥i¯à»P¥»¤½¥q¥ô¦ó«È¤áªº§Q¯q¦³¬Û¹ï±¡§Î©Î¹H¤Ï¦¹«ü«nªº¥ô¦ó¤@±ø¡A¥»¤½¥q¦³Åv®Ú¾Ú¥H¤W²ÄN¬qn¨D±N¸Ó¶R½æ±À½¡C¦b¸Ó±¡ªp¤U¡A°£«D¹µû¯à°÷µý¹ê¥L·í®É¨Ã¤£ª¾¹D©Î¤£¯à¦X²z¦aª¾¹D¸Óµ¥¶R½æ¦³¥i¯à»P¥»¤½¥q¥ô¦ó«È¤áªº§Q¯q¦³¬Û¹ï±¡§Î©Î¹Hªð¦¹«ü«nªº¥ô¦ó¤@±øªº¥i¯à©Ê¡A¹µû±N»Ý¸É½à¦³²o³s¤H¤hªº¥ô¦ó¤£¨¬©Î·l¥¢¡C
R
Employee cannot enter into any transaction if he knows or should
reasonable have known that the transaction is likely to be detrimental to have
an adverse effect on the interests of the Firm or any of the Firm¡¦s clients or
cause or counsel an associate or another person or entity to enter into such
transaction. Y¹µûª¾¹D©ÎÀ³¸Ó¦X²z¦aª¾¹D¬Y¶µ¶R½æ«Ü¦³¥i¯à¹ï¥»¤½¥q©Î¥ô¦ó«È¤áªº§Q¯q¦³·l©Î¦³¤£¨}¼vÅT¡A«h¹µû¤£¯à¶i¦æ¥ô¦ó¸Óµ¥¶R½æ¡A©Î«P¨Ï©Îö¨ÏÁpô¤Hµ¥©Î¥t¤@¤H¤h©ÎÓÅé¶i¦æ¸Óµ¥¶R½æ¡C
S
Employee shall always execute clients¡¦ and house orders with priority
to Employee¡¦s and spouse¡¦s order(s).
As to prevent disputes, if there are order(s) with the same stock placed
within the same minutes and at the same price to the same trader (may be the
employee himself) from Employee or spouse and Clients or house, clients¡¦ and/or
house orders shall always have the priority no matter which is/are placed
first. If Employee is in breach,
the Firm may cancel or reverse any relevant Dealing in favor to the client(s)
or house, except written acceptance(s) from client(s) or the firm is/are
obtained. All cost or loss
result from the cancellation or revision is to be borne by the employee. ¹µû¥²¶·¦b¥ô¦ó±¡ªp¤U¥ý³B²z«È¤á¤Î¤½¥q¤§¶R½æ«ü¥Ü¡CY¦³¥ô¦ó«È¤á/¤½¥q¤Î¹µû/¨ä°t°¸¤§¦PªÑ¥÷¡B¦P»ù¡B¦P¤ÀÄÁ¡B©ó¦P¤@¥æ©öû(©ÎÀç·~°Ó¥»¤H)¸¨½L¤§¶R½æ«ü¥Ü¡A¤£½×½Ö«ü¥Ü¥ý³B²z¡A¥ý³B²z¤§¶R½æ«ü¥Ü¥²¶·Âk©ó«È¤á©Î/¤Î¤½¥q¡CY¹µû¹H¤Ï¦¹«ü¤Þ¡A°£±o¨ì«È¤á©Î¤½¥q®Ñ±¦P·N¥~¡A¥»¤½¥q·|°ò©ó«È¤á©Î¤½¥q¤§§Q¯qºM®ø©Î±À½¥ô¦ó¦³Ãö©Òz¶R½æ¡A¶O¥Î¤Î©Ò¦³·l¥¢¨Ã¥Ñ¹µût³d¡C
T
Employee shall, upon becoming aware of any fact which he knows or
reasonable believes may constitute a breach of any laws, any Rules or
Regulations of the Exchange or any other applicable rules or regulations,
immediately report the same to the Firm/the controller and to the
Exchange. ¹µû¥²¶·¦bª¾¾å¥ô¦ó¥Lª¾¹D¡A©Î¦X²z¦a¬Û«H¥iºc¦¨¹H¤Ï¥ô¦óªk¨Ò¡B¥ô¦ó¥æ©ö©Ò³W«h©Î³W¨Ò©Î¥ô¦ó¾A¥Îªº³W«h©Î³W¨Òªº¨Æ±¡«á¡A¥ß§Y¦V¥»¤½¥q/¥DºÞ¤Î¥æ©ö©Ò³ø§i¦³Ãö¨Æ±¡¡C
U
If Employee is in breach, or attempts to do any act or omits to act
which would result in a breach of any of these guidelines, the employee will be
subject to disciplinary action by the Firm which may include cancellation or
reversal of any relevant Dealing with costs to be borne by the employee and any
loss borne by the employee, any gain or profit made or realized by the employee
to be disposed of as the Firm may direct, summary dismissal and reporting of
the matter to the Exchange and the Securities and Futures Commission. Y¹µû¹H¤Ï©Î¸Õ¹Ï§@¥X¥ô¦ó¦æ°Ê¦Ó·|¤ÞP¹H¤Ï¦¹«ü«nªº¥ô¦ó¤@±ø¡A¥»¤½¥q·|¹ï¹µû±Ä¨ú¬ö«ß¦æ°Ê¡A¬ö«ß¦æ°Ê¥i¥]¬AºM®ø©Î±À½¥ô¦ó¦³Ãö©Òz¶R½æ¡A¨Ã¥Ñ¹µût³d¶O¥Î¤Î©Ò¦³·l¥¢¡A¥ô¦ó¹µû±o¨ì©Î§é²{ªº±o¯q©Î§Q¼í¥i¥Ñ¥»¤½¥qÀH·N¦a¤À°t¡A§Y®É¸Ñ¹µ¡A¤Î¦V¥æ©ö©Ò©MÃÒ¨éú³¤Î´Á³f¨Æ°ÈºÊ¹î©eû·|³ø§i¸Óµ¥¨Æ¥ó¡C
V
Any breach of these guidelines involving securities or circumstances
set out in paragraphs B-G of these guidelines will normally result in summary
dismissal and reporting of the matter to the Exchange and the Securities and
Futures Commission. ¥ô¦ó¹H¤Ï¦¹«ü«n¦Ó²o¯A¨ìÃÒ¨éú³©Î¦¹«ü«n¤º²ÄB¦ÜG¬q©Òz±¡ªp¡A³q±`·|¦³§Y®É¸Ñ¹µ¤Î±N¨Æ¥ó³ø§i¦Ü¥æ©ö©Ò©MÃÒ¨é¤Î´Á³f¨Æ°ÈºÊ¹î©eû·|ªº«áªG¡C
W
If Employee believes that strict application of any of these guidelines
may give rise to difficulty in his circumstances, the employee may make written
application to the Firm/the controller for exemption from any particular
guideline(s) with supporting reasons and appropriate documentation. Such application shall be considered by
the Firm/the controller on a case-by-case basis. Õ¹µû¬Û«HÄY®æ°õ¦æ¦¹«ü«nªº¥ô¦ó¤@±ø·|¦]¨ä³B¹Ò³y¦¨§xÃø¡A«h¹µû¥i¦V¥»¤½¥q/¥DºÞ®Ñ±¥Ó½ÐÁŧK¹ï¨äÀ³¥Î¥ô¦ó¤@±ø«ü«n¡A¨Ã´£¨Ñ¤ä«ù²z¥Ñ¤Î¾A·í¤å¥ó¡C¸Óµ¥¥Ó½Ð·|¥Ñ¥»¤½¥q/¥DºÞ¥HÓ§O°ò¦³B²z¡C
X
Employees may arrange to have their investments managed on a fully
discretionary basis by an independent investment manager. However a written application should still
be made to the Firm/the controller for any exemption from these guidelines. ¹µû¥i¦w±Æ¨ä§ë¸ê¥Ñ¿W¥ß§ë¸ê¸g²z¥H¥þÅv¥N²z°ò¦³B²z¡A¦ý¤´À³¦V¥»¤½¥q/¥DºÞ®Ñ±¥Ó½ÐÁŧK¹ï¨äÀ³¥Î¦¹«ü«n¡C
AML POLICY
Based on the latest Anti
Money Laundering regulations in Hong Kong, Rosa Securities Limited has a responsibility and a
commitment to actively prevent money laundering and funding terrorist
activities. To fulfill this goal we have adopted internal policies,
procedures and controls to identify the true identity of
the client. We verify client identity through documentary evidence and
the client shall produce the following documents and statements for account
opening:
(a)
original Hong Kong Identity Card, passport or equivalent
(b) copy of
Hong Kong Identity Card, passport or equivalent for records
(c) a valid
address proof from recognized entity(ies), and
(d) a
self-named bank account details (also for settlement purpose)
And also all trades are
closely monitored by director, currently David Da Rosa, includes but not
limited to the following guidelines.
(a)
(Country/geographic risk)
Special attention shall be put on clients from countries where
corruption is widespread.
(b)
(Customer/Product risk)
Clients, not familiar to the AE/staff, may be questioned about their
source of fund and occupation and try to determine whether he performs a political
and/or public function during the account opening interview. Simple internet search on newly opened
accounts and search at world compliance (www.worldcompliance.com) if required. Although cash is generally not accepted
for settlement, special attention shall be put on clients who do so. Special attention shall be put on
company with low issued capital.
(c)
Customer due diligence (CDD) measures shall be applied on politically
exposed persons (PEP) on high risk customers from above mentioned risk-based
approach includes obtaining senior management approval and appropriate measures
to ascertain the source of funds, which may be varied from case to case.
(d)
Enhanced due diligence (EDD).
Customer must be physically present for identification purposes.
(e)
Enhanced due diligence (EDD).
If customer has a correspondent banking relationship with us, then
additional measures shall be applied, includes but not limited to the
following: gather sufficient information such as reputation, AML controls of
the corporate client, obtaining senior management approval and providing additional
documents upon request.
(f)
For Corporate Clients (opened after 3/2012), the following procedures
shall be done:
(i)
No foreign company shall be accepted
(ii)
Certificate of Incorporation, Annual Return (AR1), Board Resolution, ID
copy of all directors & Authorized Signatures, Memorandum & Articles of
Association (M&A), Business Registration Certificate (BR), ID copy of all
shareholders holding 10% of the voting rights (low-risk company approved by senior
management exempted), ID copy of any important person to the company (including
any person with Power of Attorney (POA)
(iii)
Company search through at company registry web site
(www.icris.cr.gov.hk)
(iv)
Identity card of
(g) Suspicious
transaction(s), includes but not limited to the trades of PEP, (for example
inconsistent trading behavior, cash deposit over $1,000,000 & request for
issuing payments in favor of 3rd party) shall be reported to Money
Laundry Responsible Officer (MLRO) which will be in-depth investigated and all
account documents will be reviewed.
The said transaction may be reported to Joint Financial Intelligence
Unit (JFIU) and Financial Service and the Treasurer Bureau, if necessary.
(h) All
circulars regarding PEPs issued by SFC will be reviewed and checked against RSL
client database.
(i) All
trading records, including suspicious trades, are well kept according to SFC
requirement.
MONEY LAUNDRY GUIDELINES
i.
Client shall not deposit any cash
for more than 10,000 dollars and/or present any third-party cheque to us, and/or deposit money from any third party in whatsoever ways to any
accounts with us for margin, settlement and/or custody
purposes;
ii.
In case of deposit as described in 11 (i) with us, client may be required to provide written documents from a qualified
solicitors registered in Hong Kong verifying that the
said client own the said sum of money and both the qualified solicitors and the said client may be required to indemnify and keep us indemnify against any damages, losses and claims from me/us and/or any
other third party. The said client shall bare full cost in preparing such guarantee and
indemnity. We reserve the right to retain the said sum of
money at our absolute discretion. And
iii.
Client shall only give us money withdrawal instructions payable in the
said client¡¦s name.