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Terms of Service

Last updated: 2 June 2025

The platform is operated by AA Capital Limited (“we”, “AA Capital” or “Company”), an asset management company licensed with the Securities and Futures Commission (CE no. BJI417) to carry on business in Type 4 (advising on securities) and Type 9 (asset management) regulated activities in Hong Kong under the Securities and Futures Ordinance (Cap. 571) (“SFO”). AA Capital is an alternative investment platform at www.aacapitalhk.com which provides professional investors (which includes Professional Investors as defined under the Securities and Futures Ordinance of Hong Kong or the respective local jurisdictions, as defined under relevant local regulations from time to time) access to top tier alternative investment funds (the “Site”). This webpage has not been reviewed by the Securities and Futures Commission.

Only professional investors (“Investors”), as defined here, could access the Site and the services offered by the Site and the Company. Investors must understand the risk of investing in such asset classes, including no protection of the principals and illiquidity. Investors may also receive confidential information and must commit to certain confidentiality obligations.

By using the Site, including by simply viewing the Content on it, you are agreeing that you, and each person you allow to access the Site through your account, will abide by the terms of these Terms of Service (the “Agreement”), which is set forth in its entirety below. This Agreement is between the Company and you, and it governs your access to and use of the services, websites, and applications offered by the Company (the “Services”). Your access to and use of the Services are conditioned on your acceptance of and compliance with this Agreement.

The Site is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) the publication or availability of the Site is prohibited. Persons in respect of whom such prohibitions apply must not access the Site. For more information, see Section XII(1) (Availability of Services).

Capitalized terms used herein are defined in Section XIV (Definitions) of this Agreement.

You would qualify to invest with AA Capital if you meet certain criteria, including but not exclusive to sufficient prior investment experiences and minimum net worth benchmarked to the definition of professional investors in Hong Kong SAR under SFO or the respective local jurisdictions. Each investor is required to represent that they comply with the applicable regulations and laws upon registration on AA Capital platform. Furthermore, you agree and knowledge that AA Capital may from time to time request from you supportive documentation demonstrating your status as professional investors. You may lose your access to the website and/ or the investments if you fail to respond to AA Capital’s reasonable requests. You must make your own assessment regarding regulatory requirements as may be applied to your activities on the Site.

This Website and any information contained herein has not been reviewed by Hong Kong Securities and Futures Commission or any other regulatory authority, and is made available by AA Capital Limited (hereafter “AA Capital”) for Professional Investors’ general information only and not for any other purpose. For the avoidance of doubt, the term “Professional Investor” refers to and covers Professional Investors as defined under the Securities and Futures Ordinance of Hong Kong or other relevant respective local jurisdictions. The Viewer proclaims himself/herself as a Professional Investor by continuing to access the Website. The Viewer agrees that this website shall be used solely as reference, or for informational use and not for any other purposes, commercial or otherwise. AA Capital is an asset management company licensed with the Securities and Futures Commission (CE no. BJI417) to carry on business in Type 4 (advising on securities) and Type 9 (asset management) regulated activities in Hong Kong under the Securities and Futures Ordinance (Cap. 571). The information contained in this website is not intended and shall not be used or construed as an offer to sell, or a solicitation of any offer to buy, securities of any fund or other investment product in any jurisdiction. The information contained herein is qualified in its entirety by the terms applicable to the investment funds as set out in its constitutive and offering documents (“Fund Documents”) and should be read together with such Fund Documents. Neither AA Capital nor any of its officers, directors, agents and employees makes any warranty, express or implied, of any kind related to the adequacy, accuracy or completeness of any information on this site or the use of information on this site. The information in this Website is not intended and should be construed as investment, tax, legal, financial or other advice. AA Capital holds exclusive and rightful ownership of the intellectual and proprietary rights to all opinions, concepts, ideas, work products, and the like, related to or as a result of the General Information and contents in this Website.

Privacy Policy

Last Updated: 2 June 2025

The Privacy Policy provides specific details of how AA Capital Limited and its employees (“AA Capital”, “we”, “us” or “our”) treat any Personal Data you provide us when you visit the AA Capital website (“Site”) and use the services provided to you at the Site. AA Capital is committed to protecting your privacy information in accordance with applicable laws and regulation, including without limitation to the Hong Kong Personal Data (Privacy) Ordinance (Cap 486) as amended from time to time.

“Personal Data” has its respective meaning given in the Hong Kong SAR or other relevant jurisdiction data protection legislation, as the context may require, and includes any information relating to an identifiable individual (such as name, address, date of birth or economic information).

Professional Investor Notice

Last Updated: 2 June 2025

We refer to the account opened or to be opened with AA Capital Limited (“AA Capital”, “We”, “Us”).

The Securities and Futures Commission (“SFC”) has imposed certain rules and restrictions in dealing with investors in Hong Kong. Generally, an investor will be covered by certain requirements and protections under the Securities and Futures Ordinance (Cap. 571D) (“SFO”), which, however, will be relaxed if a customer is categorized as a Professional Investor as defined by the SFO.

For the purposes of this Notice, the term “Professional Investor” shall carry the meaning including “Professional Investor” as defined under the SFO.

Hong Kong

You are regarded as a Professional Investor in Hong Kong if you are:-

1.an individual having a portfolio of liquid assets (including but not limited to cash, deposits, securities) more than HKD 8 million at the date of registration. The portfolio provided may be in the form of: -
1.a portfolio of your own account;
2.a portfolio on a joint account with the your spouse or child(ren);
3.your share of a portfolio on a joint account with one or more persons other than the your spouse or child(ren) where a written agreement is provided;
4.a portfolio of a corporation which, on the registration date, has its principal business the holding of investments and is wholly owned by the individual;
2.a trust corporation having been entrusted under one or more trusts with total assets of not less than HKD 40 million at the date of registration;
3.a corporation having a portfolio of not less than HKD 8 million or total assets of not less than HKD 40 million at the relevant date;
4.a corporation which, at the date of registration, has as its principal business the holding of investments and is wholly owned by any one or more of the persons falling within the definition of professional investors mentioned above, or wholly owns a corporation referred to above; or
5.a partnership having a portfolio of not less than HKD 8 million or total asset of not less than HKD 40 million at the date of registration.

We may require additional information from you if the need arises. If your portfolio does hold assets that are not in the required type of currency under the respective jurisdiction, we will assess its equivalent value at the date of registration.

We may also be required to verify your position as a Professional Investor by requesting any one or more of the following documents, including but not limited to: -

1.Your most recent audited financial statement prepared within 16 months before the registration date in respect of your individual portfolio or corporation;
2.Any one or more of the following documents issued or submitted within 12 months before the registration date:
1.a statement of account or a certificate issued by a bank/custodian;
2.a certificate issued by an auditor or a certified public accountant;
3.a public filing submitted by or on behalf of your corporation;

As a result of this Professional Investor categorization, we may offer you certain investment opportunities which are only available to a Professional Investor. However, we are not required to fulfill certain requirements under the Code of Conduct for Persons Licensed by or Registered with the Securities and Futures Commission and certain other regulations implemented in Hong Kong.

AA Capital will not be required to:-

(a)provide you with information about our business or the identity and status of our employees or others acting on our behalf with whom you may have contact.
(b)confirm to you promptly the essential features of a transaction after effecting a transaction for you.
(c)provide you with any contract notes, statements of account or receipts under the Hong Kong Securities and Futures (Contract Notes, Statements of Account and Receipts) Rules where such would otherwise be required, unless you instruct us to do so.
(d)if AA Capital deal through the Stock Exchange of Hong Kong in securities admitted to trading on the Exchange under the NASDAQ – Anex Pilot Program, AA Capital is not required to provide you with documentation about the Program.

Although we have no regulatory duty to provide you with the above-mentioned information (a) to (d), we may continue to send you the contract notes and statements of account until further notice, and to provide you with other information upon request to the best of our capabilities.

If you have any doubt about any aspect of this notice or have other questions, please do not hesitate to contact us by the following means: -

(I) Email at info@aacapitalhk.com;

(II) Writing using this address:

AA Capital Limited

21/F., Queen’s Road Centre, Queen’s Road Central, Hong Kong

Attn: Head of Legal & Compliance

You have the right to withdraw from being treated as a Professional Investor at any time in respect of any investment products or markets or any part thereof by giving written notice to us not less than fourteen (14) business days prior to the proposed effective date of the withdrawal. Please inform us in writing immediately if you find yourself no longer within the definition of Professional Investor within the meaning of Section 3 of the Securities and Futures (Professional Investor) Rules.

Please note that you will be deemed to have confirmed, acknowledged and agreed to these terms by your continuing operation of your account(s) with us after the date of this letter and our acceptance of your continuing operation of your account(s) and your placing of orders with us and/ or subscribing in any of funds managed by or advised by us, hereafter shall be subject to and on these terms.

This notice and any dispute arising from this notice shall be interpreted and governed by the laws of Hong Kong Special Administrative Region of the People's Republic of China (“Hong Kong”).

THIS PROFESSIONAL INVESTOR NOTICE WAS LAST UPDATED ON 2 JUNE 2025.

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