EFM Investment Capabilities

EFM Asset Management Limited

Our Investment Capability & Strategy EFM Global Financial Services & Technology Fund

July 2020

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EFM Asset Management Limited is licensed with the Securities and Futures Commission (“SFC”) in Hong Kong (CE number BFJ775) Type 9 (Asset Management) regulated activity. The funds offered by EFM are currently not authorised or approved by any regulatory body. EFM does not provide investment advisory services to the public and nothing contained in this document should be construed as an offer of such services. The information you are about to access is available in Hong Kong, available only to, professional investors as defined in the Securities and Futures Ordinance (Cap. 571, the laws of Hong Kong, “the Ordinance”) and its subsidiary legislation, Securities and Futures (Professional Investor) Rules (“PI Rules”). Any resident of Hong Kong in possession of this document hereby certifies that it is a professional investor. The information is also available in the United States, only to “accredited investors”, as defined in Rule 501(a) of Regulation D of the United States Securities Act. Any resident of the United States in possession of this document hereby certifies that it is an accredited investor. By retaining this document, you agree to contact EFM immediately if there is any change in your status as a professional investor or accredited investor, as applicable. You should contact us if you require further information about your status.

Contents EFM Overview Investment Capabilities

5

EFM’s History

6

Corporate Structure

6

Funds Under Management

7

ESG Integration into Portfolio Construction

24

EFM’s Approach to Active Ownership

26

Portfolio Risk Management

26

Managing the Research Process

27

Strategy Capacity: Financial Services and Technology Fund

7

EFM’s Governance and Corporate Structure

8

Firm Ambition and Culture

9

Risk and Compliance Framework

Firm Location

9

Trading 30

Business Operations 29

Business Continuity, IT Infrastructure

Investment Process Investment Philosophy

11

Investment Process

11

Universe Selection and Coverage

12

Analytical and Valuation Techniques

15

Macroeconomic Data

16

Industry and Company Analysis

16

Analysis: Financial Analysis

17

Analysis: Risk Analysis

17

Output: Investment Thesis

19

Output: Expected Rate of Return

19

Output: Risks

20

Environmental, Social and Governance

22

Portfolio Construction

22

Portfolio Construction Parameters

23

and Cyber Security

33

Investment Operations

34

Legal 35 Accounting and Auditing

35

Client Reporting

36

Appendix: Our People in Detail Personnel Structure

38

Bios

39

3

At EFM we are a specialist investment manager focused on the global financial services and technology industries

Global Investment Specialists At EFM, we are a specialist investment manager focussed on the global financial services and technology industry sectors.

Our mission is to provide investors with portfolios of high-quality growth assets across both the financial services and technology sectors. Our focus is dedicated to identifying and investing in the best assets in the listed equity market with the goal of delivering strong absolute returns over an investment cycle.

Our Flagship Fund is the EFM Global Financial Services and Technology Fund (‘FST’) 1. A distinctive view with regard to the Financial Services and Technology sectors The FST fund is focussed on the technologies, innovation methodologies, companies and new services re-shaping the financial services and technology landscape. The accelerating pace of technological change is the most creative force – and also the most destructive – in the financial services ecosystem today. The time that it takes to go from breakthrough technology to mass-market application is collapsing. The divide between incumbents and disruptors is also narrowing. Our proprietary investment universes are clearly defined and focuses on identifying companies that are industry leaders and innovative within these sectors.

Our strategy is highly differentiated compared to typical global equity portfolios and may show relatively low beta against other global equity indices.

2. Unique competitive advantages Together with the breadth of expertise within EFM, we are fortunate to have a broad limited partner network of current investors to draw upon where those investors invariably are either current or former senior executives of financial institutions as well as a number of founders of early stage technology companies. Together, our network enhances our insights into industry.

Our portfolios are managed on a team basis. This allows for every member to benefit from their peers and for clients to be a beneficiary of the firm’s best thinking.

3. Benchmark agnostic EFM believes that an absolute return focussed benchmark is the most appropriate measure against which to evaluate the longterm performance of our strategies. This approach ensures that the focus of portfolio construction remains on delivering

consistent absolute real returns and avoids any risk that the focus might stray towards relative performance against indices that can adversely impact stock selection decisions over the longer term.

We adhere to a strict valuation discipline that aims to achieve a defensive pattern of performance with a long-run objective of outperforming the MSCI World Index. Limiting the portfolio only to stocks that we believe are high quality where we hold a very high level of conviction should provide lower volatility and lower drawdown in down markets than a more general global equity portfolio.

4. Excellence and depth in research Our investment team, along with our limited partner network, has a deep understanding and experience in the Financial Services and Technology industries. Our breadth across the entire spectrum of both industries enables us to better assess the true market value of securities and to identify attractive investment opportunities for our clients. Our investment process ensures that a broad range of evidence is reflected in our ultimate investment decisions.

5. Risk Management Understanding and managing risk is intrinsically linked to our investment process and our approach to portfolio construction. We aim to ensure that the anticipated return more than compensates for the assumed level of risk. Our investment process entails that we are always cognisant of both understanding and managing the relationship between risk and returns as it applies to our portfolio of investments.

Additionally, we have the capabilities to construct tailored portfolio solutions, given specific risk/return outcomes depending on investors’ performance and risk objectives.

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EFM’s History EFM is a specialist investment manager of both publicly listed and private securities established in July 2015+.

EFM’s philosophy is to provide investors with portfolios managed by an experienced team of specialists investing in high quality assets.

EFM’s investment and risk management approach is interwoven within this philosophy with the risk/return relationship being a primary focus.

Corporate Structure

EFM GROUP LTD Incorporated: Cayman islands

EFM ASSET MANAGEMENT

Incorporated: Cayman islands

EFM ASSET MANAGEMENT LTD+

Incorporated: Hong Kong

+

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EFM ASSET MANAGEMENT (SINGAPORE) PRIVATE LTD

Incorporated: Singapore

EFM ASSET MANAGEMENT PTY LTD

Incorporated: Australia

EFM ASSET MANAGEMENT (Canada) LTD

Incorporated: Canada (Alberta)

EFM Asset Management Limited is incorporated in Hong Kong and is regulated and licensed by the Securities and Futures Commission (‘SFC’) of Hong Kong.

Funds Under Management As at 31 July 2020, EFM’s funds under management* (‘FUM’) is as follows:

Total Funds Under Management $326 million Global Listed Equities ($166 million)

$60m

Global Financial Services & Technology Fund

$106m Institutional & Individual Mandates

Private Funds

$160m Private Equity & Venture Capital

* We hold significant co-investment stakes in our funds

Strategy Capacity: Financial Services and Technology Fund As specialists in the financial services and technology sectors, EFM is cognisant of the importance of continually monitoring the investment capacity of our strategies. We believe that capacity is most accurately assessed from the perspective of the underlying liquidity of the portfolio and the ability to implement buy and sell investment decisions with minimal market impact and without compromising investment strategy.

Annual Capacity Assessment Annually we undertake an evaluation of capacity that takes into account changes in EFM’s Assets Under Management (‘AUM’), portfolio holdings and trading attributes over the past year. Specifically, we apply two major tests for evaluating theoretical capacity limits: Test 1: Constrained stock test Test 2: Portfolio liquidity test In our assessment, we also review other factors, namely corporate activity, block trade, the number of stocks held, trading execution liquidity and how they influence capacity.

2020 Update At the start of 2020, using the methodology established in 2016, we estimate that the combined capacity of the EFM Global Financial Services and Technology Fund is between USD$5 billion and USD$10 billion.

As at 31 July 2020, the AUM of FST was USD$60 million. It is evident that capacity is not an issue for this strategy.

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EFM’s Governance and Corporate Structure: EFM’s Executive Management Team oversees the implementation of the strategic direction and long-term sustainability of the firm. Key operating decisions relating to the firm are determined at this level. EFM’s Executive Management Team comprises the following members:

Executive Management Team Jeff Emmanuel

Executive Chairman/Chief Investment Officer

Stuart Smith

Chief Financial & Operating Officer

Directors Alric Lindsay

Director - EFM Global Financial Services & Technology Fund

Martin Warwick

Director - EFM Global Financial Services & Technology Fund

Advisors, Consultants and Country Representatives Brett Paton

Chairman of Senior Advisory Group

Stuart Wills

Senior Advisor

David Harden

Senior Advisor

Robert Jesudason

Senior Advisor

Matthew Hegarty

Director - Strategy & Development

David Singer

Advisor - Sales & Distribution

Russell Keenan

Chief Executive Officer - Canada

EFM’s Investment Team EFM’s Investment Team are first and foremost investment specialists with unique experience derived particularly from within the Financial Services and Technology sectors. The depth and breadth of that experience of EFM’s research effort provides distinct advantages to competitors operating within this space.

Members of our Investment Team have been drawn from a broad range of backgrounds. This ensures a diversity of experience and unique perspectives which is essential to fundamental bottom-up investment analysis.

Collectively our team incorporates a diversity of unique industry experience gained from within corporate finance, debt and equity financing, strategy, private investments as well as mergers and acquisitions. Our team’s breadth of experience and knowledge is a significant point of differentiation which we believe has been a major factor of our ongoing success and the Investment Team has an average of twenty years experience.

As of 30 July 2020, our Investment Team consists of the four of investment analysts/specialists.

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NAME

TITLE

ROLE AT FIRM

Jeff Emmanuel

Chief Investment Officer

Portfolio Manager across all active stragies

Adam Lee

Senior Analyst

Coverage Responsibilties: Global Financials and Fin Tech

Angus Walker

Senior Analyst

Coverage Responsibilities: Global Consumer Tech and Fin Tech

Eileen Deng

Senior Analyst

Coverage Responsibilities: Global Technology

Firm Ambition and Culture As a firm, our goal and ambition is to be recognised as a globally pre-eminent investment manager. To achieve this goal and outcome, EFM is diligently focussed on achieving the following:

Delivering superior investment outcomes for our investors

Exceeding in client service expectations

Creating a highperformance culture

Given our commitment toward fostering and cultivating a high-performance culture, we have: - Formal and clear guidelines with regard to behaviour and attitudes. These shared common values and incorporated into our recruitment processes in order to particularly ensure that all new hires are a good cultural fit.

- Consistent internal communication strategy to ensure that all staff members share in EFM’s milestones and achievements that also serves to facilitate a consistent feedback loop throughout the firm. This is principally achieved by group notifications/chat rooms, regular meetings, offsites and other initiatives.

- Regular dialogue between management and staff to ensure staff engagement and to ensure actionable feedback is followed through.

Firm Location

HEAD OFFICE: Level 19, 2 Shelley Street, Central, Hong Kong.

All members of the EFM Investment Team are in Hong Kong.

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EFM has developed a robust investment process designed to consistently deliver superior returns

Investment Process Investment Philosophy EFM considers itself to be an absolute return manager and hence utilises absolute return benchmarks for our strategies. EFM believes that by using a longer-term fundamental valuation approach when investing in listed markets through the cycle, significant opportunities arise as listed markets misprice assets in the short term. Through investing in listed markets, EFM views both the liquidity and investable opportunity set as greater, further allowing for enhanced returns to investors.

At EFM, we firmly believe that one of our distinct competitive advantages in deploying our strategy is due to EFM’s industry experience, research network and our limited partner network made up of both senior financial services and technology company executives. We believe that our limited partner network provides a strong competitive advantage in this respect as we are well supported with additional thesis validation.

The Global Financial Services and Technology Fund The Financial Services and Technology Fund (‘FST’) is a long-only strategy that seeks to provide investors with long-term capital growth by investing in a diverse range of globally listed securities across a number of different financial services and technology sub-sectors and different geographic regions.

Investment Process For EFM’s actively-managed strategies, the EFM investment process is designed to provide investors with attractive, stable returns within a robust risk-management framework. The investment process to deliver these returns is founded and based upon fundamental research undertaken within a rigorous analytical framework.

The below chart summarises the key components of EFM’s Investment Process.

EFM’s Investment Process

Universe selection and coverage

LEGEND: Inputs Analysis Outputs

Returns

Macro economic data

Analytical/ valuation techniques Financial/risk analysis

Portfolio construction

Risk

Portfolio analysis

Industry and company analysis

Investment thesis

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Investment Universe EFM’s proprietary Investment Universe is used to select securities for the FST Strategy. The universe includes many liquid and highest quality companies identified globally.

The Investment Universe includes companies with the following desirable investment characteristics: - H igh returns on capital with the prospect of future stable financial returns; - S trong market positions in attractive industries; - M oderate financial leverage; and - S ound corporate governance and stewardship.

We believe that the combination of these factors occurs infrequently and is usually the result of decades of investment in brands or technology, industry consolidation, astute capital allocation and innovative product development.

By focussing solely on companies that are industry leaders and innovative within these sectors that we count as our core competency, we strongly believe that it improves our chances of success and to minimise the chances of negative outcomes.

Universe Selection and Coverage

Note: Indicative of financial services and technology landscape, not necessarily of FST investments

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A distinctive view to both the Financial Services and Technology Sectors The financial services and technology sectors are in the early stages of an unprecedented period of evolution and this is being driven by innovation platforms that are re-shaping the global economy. The landscapes of both the technology and financial services sectors are increasingly converging and competitive landscapes are evolving rapidly with barriers to entry collapsing.

Proprietary Investment Universe Based on what we see as the key characteristics for our investment universe, we have created a proprietary investment universe:

UNIVERSE FILTERING Proprietary quant screening of the FST stock universe Liquidity criteria Stock leads from industryspecific research Granular industry insights from private company due diligence

QUALITATIVE RISK ANALYSIS Degree & durability of competitive edge Sector & sub-sector thematic testing Qualitative screen of company, country or industry risk

FUNDAMENTAL ANALYSIS & VALUE RANKING Modelling and valuation derived Total Shareholder Return (‘TSR’) Private company & listed peer engagement Management & site visits

ESG assessment

PORTFOLIO CONSTRUCTION Stocks demonstrating highest TSR of universe at current levels, >15% hurdle Assessment of macroeconomic factors Maximum single stock position <5% of portfoloio NAV

Universe Amendments On a quarterly basis, the composition of the Investment Universe is reviewed. The Investment Team determines decisions on changes to the Investment Universe.

Stocks will be considered for inclusion under the following scenarios: - T hey are new to market, for instance, IPOs or spin-offs and have sufficiently determined valuation upside.

- They

have increased their liquidity. For instance, they have increased in value or the sale of restricted holdings (e.g., government or other major shareholders).

- T hey have changed their business mix and, accordingly, the investment case is more attractive.

Sector and Regional Coverage Each analyst has a set of stock coverage responsibilities. Some analysts also have a sector focus that reflects both their experience and preference to cover particular types of companies. Where an analyst has a particular global sector or industry expertise, this is made use of, although there is no formal coordinator for either a particular industry or sector.

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Coverage Requirements All companies within our Investment Universe are assigned to analysts who are responsible for coverage. To focus our research resources, these are divided into:

Core Companies

Analysts maintain a full financial model for these companies and maintain active coverage.

Watchlist Companies

Analysts monitor company developments and maintain a more simplified financial model and lighter coverage.

Decisions regarding the allocation of companies to the Core and Watchlist are made by the Chief Investment Officer in consultation with the Investment Team and are reviewed quarterly.

A summary of expectations of research produced by analysts on companies under coverage is set out below. Responsibilities for coverage are set based on ‘coverage units’ which is EFM’s method of representing the work required to cover an ‘average’ company.

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SECTION

CORE COMPANIES

WATCHLIST COMPANIES

Investment profile

Always companies and up to date

Updated at least once a year. The same structure as for core companies but more concise. Will contain a justification of why the company is not in the core list

Number of Companies Covered

60%

40%

Stock Report

On initiation and updated at least every year

Not required

Full model

Always complete and up to date

Not required

Simple model

N/A

Yes

Results and Event commentary

Yes. Commentary to focus on aspects of results that affect the investment case

At analyst discretion

Meeting requirement

Able to speak on company at an investment meeting at short notice (max two days)

Able to provide commentary at investment meetings as part of sector reviews

Meetings with management

EFM to meet with company management at least once per year

Not required, meetings when appropriate

Secondary analyst coverage

Nominated analyst to provide backup coverage when company is in the portfolio

Not required

Transfer between core and watch list

Analyst to keep company under review to test if it should be on the watch list

Analyst to keep company under review to test if it should be core or removed from the relevant Investment Universe

Analytical and Valuation Techniques Consistent Qualitative Framework and Information System Investment Profile The ‘Investment Profile’ is the fundamentally most important internal research report that EFM produces on a company. This is a concise analysis and record of the key information that is required for the Portfolio Manager to make decisions with regard to an investment in a company. This report contains a record of the understanding that EFM has developed with regard to a company over time. A summary of the contents of the Investment Profile is set out in the table below.

SECTION

COMMENTARY

Summary

Summary view of the company and when it is appropriate to hold the shares in portfolios.

Investment thesis

This section of the report explicity sets out the factors that make an investment attractive (or not).

Valuation

This section assesses the valuation of the company, providing evidence why it is appropriate.

Profile

The assets that the company currently owns and/or operates, with the key characteristics that EFM considers important.

Risks

The key risks to valuation and a quantification of the impact of those risks should they materialise.

Strategy

What the company states its strategy to be and how we interpret it.

Capital Structure

Commentary on gearing, dividend policy, credit metrics, financing needs.

Ownership

Whether there are any core shareholders and if so how this affects both the company assets and the way in which the company trades.

ESG

Summary of the analysis from EFM's ESG data and view of the risks associated with these issues.

All qualitative and quantitative research is stored in a structured way on both company servers (including cloud). This ensures that: - There is a clear record of EFM’s current and prior research on a company.

- R esearch is commingled with market data and EFM’s own investment data. For instance, charts identifying share price movements along with identification of when research notes were published are readily available.

- R esearch is circulated to those who need it in the Investment Team and is easily accessible and searchable when needed, regardless of location.

Consistent Quantitative Framework Since inception, EFM has used a consistent financial (consolidation) model template to model each of its companies. Analyst’s complete detailed, business unit by business unit, operational models and the template standardises the front-end; the consolidation, valuation and sensitivity/scenario analysis, and back-end; data import/export functions. This approach ensures the use of consistent inputs such as macroeconomic forecasts (see below) and results in more comparable outputs such as valuation metrics calculated utilising consistent methodologies.

The original template was developed at the firm’s inception and has been upgraded over time to provide enhanced functionality and flexibility.

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Macroeconomic Data Integrating consistent macroeconomic forecasts is key to EFM’s investment process as the value of portfolio assets are impacted by macroeconomic factors such as GDP growth, bond yields and inflation.

EFM’s macroeconomic process is designed to have the following characteristics: - Global forecasts of all key variables for all countries in which it invests that are internally consistent.

- Forecasts are sufficiently long-term so that they can be used in long-term cash-flow forecasts for companies.

- Forecasts are updated sufficiently regularly so that they are reflective of reasonable outcomes of the global economy.

- E FM owns the forecasts and doesn’t solely rely on a third party. This generates a better level of engagement with the forecasting process and ensures that EFM ultimately abides by these views, rather than being able to defer to another source.

- Whilst EFM’s team has expertise in macroeconomics, it makes use of insights from leading practitioners.

- T he structured approach to macroeconomics is efficient, allowing EFM to focus on its core value of fundamental company research.

Industry and Company Analysis Investment ideas are developed in-house by EFM’s Investment Team, Senior Advisors and Limited Partner network. Both the depth and breadth of EFM’s research effort provides distinct advantages. EFM’s research process focuses on analysing the underlying assets and not just on the high-level company cash-flows. This means that it is necessary to gain a deep understanding of the specific business environment and the sector nuances where a company operates.

This detailed analysis requires specialised knowledge and draws on the varied experience of the EFM Investment Team and the broader network of its Senior Advisors and Limited Partners. Short-term developments are often well-understood by the market; it is in the understanding and anticipation of longer-term events where EFM’s analysis adds the most value.

Company Analysis This involves meeting with the management of companies in which EFM is considering, or is already, invested. EFM believes that the meeting company’s management is essential in order to gain a deep understanding of the company’s strategy and operations and to test our investment thesis. Contact with companies is through: - Company site visits or conference calls.

- Meetings with senior management.

- Attending company roadshows.

- Meetings at conferences.

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Over 2019 to date our Investment Team, EFM conducted: - Over 200 company visits, asset inspections and meetings with company management.

- 12 overseas research-related trips.

Industry Analysis EFM has established large communication networks with a range of industry contacts, such as governments, industry associations, regulators, suppliers, competitors and other industry stakeholders. This ensures that EFM has the broadest range of evidence from which to form judgments about the future development of the industry and companies within these industries.

Analysis: Financial Analysis EFM’s financial analysis provides it with the ability to compare companies in the most consistent manner possible. EFM has developed a consistent template to model each company in the investable universe since its inception. The financial model template is comprised of three components:

- A standardised ‘front-end’ module to ensure consistent financial information is derived from each model (financial statements, financial ratios, sensitivities, valuations and return calculations).

- A company-specific module with company-specific assumptions (which is often completed via industry templates).

- A standardised ‘back-end’ module to import macroeconomic and other data and export standard outputs into EFM’s centralised ‘company database.’

Alongside financial information, the detailed qualitative industry and company analyses that our Investment Team conducts are also incorporated into the financial models. These models reflect the main business drivers and macroeconomic variables, as well as helping to make appropriate assumptions about the key variables impacting each company.

Scenario Analysis The key output of our financial models is a point estimate of base case and excess return. EFM assesses for forecasting errors by testing alternative forecast scenarios. We typically require an investment case to be validated against a range of bear cases before making an investment. There is a template scenario sheet that is built into our financial models that allows scenarios to be tested on a customised and dynamic basis.

Scenario analysis assists the Analyst in understanding the key drivers of the business and the sensitivity of the valuation to those factors. This helps focus the Analyst’s diligence on those areas that are most impactful on valuation. These assist decision makers in understanding the range of potential outcomes, the breadth of potential returns and appropriate stock weighting. This is particularly useful in evaluating the risk of a company beyond simply looking at its market beta. Companies whose valuation is more sensitive to a range of factors is inherently riskier than those where the valuation remains relatively robust to changing assumptions.

Analysis: Risk Analysis A core part of our investment process is the understanding of risk. This approach to identifying and managing risk is an integral part of many other elements of the process. Below are examples of the key risks that EFM has identified and how we assess and manage risk.

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RISK

ASSESSMENT/MANAGEMENT

Macroeconomic Risk

EFM regularly assesses macroeconomic risk. Guided by this evaluation, the Investment Team incorporate into their analysis in response to the identified marcroeconomic risks.

Additionally, we recognise the importance of macroeconomic factors in the valuation of assets generally. As such, we place significant focus on ensuring that portfolios are constructed using a consistent global macroeconomic forecast data set.

This approach both increases the confidence in underlying valuations and also allows EFM to identify areas of heightened risk and in particular where risks are asymmetric. EFM believes that helping to reduce investor exposure to macro ‘tail’ risks is a key part of the portfolio management responsibilities that its clients expect of it.

EFM also has the capability of running macro scenarios in its models to understand the sensitivity of stock returns to particular macroeconomic outcomes. Lastly, risk is also considered through scenario analysis.

Company-level Risk

Through use of scenario analysis, the impact of alternative scenarios on financial projections and the risk that the expected return will therefore not not meet expectations is assessed and reviewed. This involves examining assumptions around volume growth, pricing and cost trends, regulatory outcomes particularly when there are reviews of price controls and capital investment plans.

Valuation Risk

EFM adopts a variety of approaches to company valuation where we recognise that any changes in the macroeconomic outlook or underlying cash-flow assumptions will change the valuation of a company. In recognising this, we have adopted a consistent model that is utilised by our investment team when analysing all companies. Additionally, all macroeconomic assumptions are fed into the model centrally.

Market Risk

Market volatility and responses to short-term macroeconomic variables will affect the market value of a company. In some cases, market volatility can provide an opportunity for investment. As specialists in our field we are subject to short-term volatility of global equity markets but we aim to minimise this volatility through careful risk management. This is self-evident in our consistently lower volatility relative to peers over the medium and longer-term.

Financial Risk

EFM undertakes detailed independent financial analysis for each company within EFM’s Investment Universe. Companies are modelled asset by asset on a consistent basis so that reported cash-flows can be reconciled against predicted cash-flows. Risks are considered through scenrio analysis and choice of cost of capital.

Strategy/ Governance Risk

As specialists in both the Financial Services and Technology sectors, EFM is able to engage with company management in greater depth and with higher frequency than managers of broader portfolio. In this respect, EFM is more likely to: a) have some influence on management actions, and b) be able to detect potential warning signs before they become apparent to the broader market, such as detecting where management strategy may have started to lose focus, but (hopefully) before it might become value destructive. EFM also finds that management teams and corporate boards are far more incentivised to engage with shareholders that are known to be sophisticated, long-term, absolute and willing to take large positions.

EFM’s strategy for engaging with its portfolio companies is two-fold: 1. Regularly meet with senior management from portfolio companies to determine the strategy of management to account and/or apply pressure where EFM believes that strategy is not aligned with investors interests; and 2. Meet with the boards of portfolio companies and clearly communicate the interests of EFM’s clients and its views on strategy, governance and remuneration.

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Leverage Risk

For each company we analyse, EFM evaluates the appropriateness of debt. Our Investment Team runs stress test scenarios to evaluate whether the company would be materially impacted by changes in the debt market. We also test whether temporary cash-flow impacts, for instance, the impact of a recession on revenue volumes, could potentially lead to a lock-up or default on its debt.

We do not believe that our clients are seeking material exposure to movements in the international financing markets and therefore we will generally not take large positions in companies that are heavily exposed to large re-financing events or who are dependent upon favourable lending conditions to outperform. High leverage is reflected in a higher cost of equity and in turn a higher EFM required return.

Structural Complexity Risk

To further manage and reduce risks, EFM has a preference for stocks with more simplified ownership structures and with experienced management teams. EFM will, therefore, generally prefer investments with the following characteristics: Established management with long-track records Full-ownership of underlying real asset Aligned shareholder bases - avoidance of large family holdings or large non-aligned shareholders.

High complexity is reflected through a higher required return.

Environmental, Social and Governance (â&#x20AC;&#x2DC;ESGâ&#x20AC;&#x2122;) Risk

EFM uses a third-party service providers of ESG scores for portfolio companies and report that highlighting issues of concerns pertaining to each company. Analysts assess this information and supplement with their own research to consider risks to EFM as a shareholder. Risk is considered through a higher EFM required return through an explicity adjustment.

Output: Investment Thesis The most important research report that EFM produces is the Investment Profile. This is a concise analysis and record of the key information that is required for the members of the Investment Team to make investment decisions regarding companies. A key component of this document is the Investment Thesis that explicitly sets out the factors that make an investment either attractive or not.

Output: Expected Rate of Return The EFM Expected Return (EFMER) is determined by fundamental, bottom-up research based on forecasts of dividends and capital growth over a five-year holding period. In the short-term, there may be deviations between current market valuations and our view of the fair value given future developments in the industry, the prevailing macro environment and the company. EFMâ&#x20AC;&#x2122;s approach reflects the assumptions that these distortions will be normalised over five years.

Whilst the use of an internal rate of return (IRR) is common amongst investors, the use of the EFM Expected Rate of Return after adjusting for inflation and other factors, is less common. EFM uses the Expected Rate of Return as it allows appropriate comparisons between companies with different inflation environments and other macroeconomic factors. Over time exchange rates are likely to adjust to reflect Purchasing Power Parity, in other words, a country with high inflation is likely to experience a depreciation of its currency compared to other countries that are experiencing lower inflation. Comparing against real IRRs, therefore provides a more accurate comparison of expected returns.

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Output: Risks EFM’s cost of equity is determined using CAPM. However, some risks are not captured within the CAPM framework. Explicit adjustments are made to calculate the required return and to reflect these risks. EFM adjusts for three additional risks.

1. Liquidity Less liquid stocks are more expensive to both enter and to exit. EFM, therefore requires a higher return when considering buying shares in these companies. The measure is based on an industry standard ‘transaction cost analysis’ generally utilised by trading desks.

CALCULATION AND RANGE Liquidity is calculated as the implicit cost of trading the position, including the average daily volume of a security (‘ADV’), the volatility of the stock and making an adjustment for the size of the holding in the strategy. The current strategy’s funds under management are used in the calculation.

2. Portfolio Manager Comfort tock-specific risks (positive or negative) that the Portfolio Manager believes are not being accurately reflected in the current CAPM S derived cost of equity and liquidity is adjusted through a Portfolio Manager (‘PM’) Comfort score. The PM Comfort adjustment, if required, will be for: - Corporate governance.

- Minority alignment of interests.

- Management.

- Structural complexity.

- The short-term regulatory, or other stock-specific issues.

CALCULATION AND RANGE The PM Comfort score is not quantitatively calculated but overlays the portfolio manager’s experience into the construction of the portfolio.

Key features of this risk adjustment: - The range of scores is unlimited but generally varies from +2.0% to -2.0%.

- The default PM Comfort score for a security within the EFM universe is zero with adjustments up or down used sparingly.

- D ue to the qualitative nature of the score, the commentary is provided on why a positive or negative PM Comfort score has been assigned.

20

We believe a distinct competitive advantage is the utilisation of our limited partner network comprising senior financial services and technology company executives

Environmental, Social and Governance (‘ESG’) A rigorous assessment of ESG issues is made in EFM’s Investment Process as they can materially impact risk and cash-flows over a company’s investment horizon (for more detail regarding ESG integration into our Investment Process please see ‘ESG Integration into Portfolio Construction’ in the Portfolio Construction section).

Portfolio Construction Actively-Managed Bottom-up (80% of Investment Process): At a stock selection level, the Investment Team and Portfolio Manager seek to balance both risk and return in order to achieve the total return with the lowest level of assumed risk.

Top down (20% of Investment Process): At a portfolio construction level, the Portfolio Manager applies an assessment of portfolio positioning against guidelines and macroeconomic narrative.

List of companies ranked by Excess Return

Strategy specific Portfolio Construction Parameters

Investment Team and Portfolio Manager review list of companies, ranks preferred stocks and proposes portfolio changes

Portfolio Manager makes final decisions on adjustments to the portfolio weighting (including adding new stocks or exiting positions)

Final portfolio decisions communicated to the EFM traders for execution

Macroeconomic outlook and risks

Excess Return Ranking The primary quantitative tool in EFM’s portfolio construction is the Excess Return, on which EFM’s stock ranking system is based.

Excess Return = Real Expected Return – Real Required Return Our actively-managed approach comprises a range of companies that exhibit different risk-return profiles. In order to achieve the best risk/return trade-off from the portfolio, the highest stock-weightings will be assigned to the stocks exhibiting the highest potential excess returns. In the EFM process, therefore, excess returns are related to a stock ranking system. Stocks are ranked from 1 – 4 and maximum stock limits are set based on these rankings.

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Portfolio Construction Parameters Portfolio Risk is managed by guideline limits on the portfolio’s exposure to stock positions, asset maturities, sectors, regions and cash positions. The aim of these limits is to ensure that the risk for the overall portfolio is managed whilst at the same time providing the Portfolio Manager with the scope to both weigh-up and balance the range of investment opportunities.

One method that the Investment Team employs to manage portfolio risk is through guideline limits on the exposure to stock positions, asset maturities, sectors and regions. The aim of these limits is to ensure that risk for the overall portfolio is managed whilst at the same time providing the Investment Team with the scope to balance between a range of investment opportunities.

Importantly, the weights are set at the asset level and not by the categorisation of the company in databases or by the location of the listing. This ensures that the weights genuinely reflect portfolio risk.

1. Stock Positions The primary quantitative tool in EFM’s portfolio construction is the Excess Return on which EFM’s stock ranking system is based.

Excess Return = Real Expected Return – Real Required Return To achieve the best risk/return trade-off from the portfolio, the highest stock weightings will be in the stocks with the highest excess returns. EFM, therefore, provide stocks with a ranking from 1 through to 4, with maximum stock limits set based on these rankings.

EXCESS RETURN

MAXIMUM STOCK WEIGHTING

Rank 1

3+%

6%

Rank 2

2-3%

5%

Rank 3

1-2%

4%

Rank 4

<1%

3%

2. Regional Exposure Limits The FST strategy does seek regional diversification whilst adhering to certain regional limits.

UK/EUROPE (Developed)

NORTH AMERICA (Developed)

ASIA/PACIFIC (Developed)

DEVELOPING

0-50%

0-75%

0-30%

0-30%

Consideration of Total Returns Benchmark: total return of 10-15% per annum over a market cycle (rolling five-year periods).

In constructing the portfolio, the Investment Team seeks to balance the risk and return to achieve the benchmark total return for the lowest possible risk. The portfolio only comprises stocks where risk, expected return and the potential for excess returns have all been thoroughly assessed and valued.

23

Liquidity Score The primary measure of liquidity often used by the market is the Average Daily Volume (‘ADV’) of shares traded on stock exchanges.

However, the transaction costs associated with a particular trade are impacted by a number of other variables, including how the stock trades (by larger blocks or many smaller parcels), the bid-ask spread, the volatility of the stock’s home market and the volatility of the stock relative to its market. As a result, EFM has developed an ‘Adjusted ADV’ using an adjusted ADV estimate, EFM attaches a liquidity score to each company. There are three possible liquidity scores:

RANKING

LIQUIDITY

EXPLANATION

H (High)

Adjusted ADV > USD$10 million

Where a position can be entered or exited with low transaction costs

M (Medium)

Adjusted ADV of USD$2 million to 10 million

Where a position's entry or exit will take a few days with a medium level of transaction costs

L (Low)

Adjusted ADV of less than USD$2 million or a market capitalisation of less than USD$500 million

Where liquidity is too low for the company to be considered by EFM

ESG Integration into Portfolio Construction As a signatory to the UN PRI, EFM believes that Environmental, Social and Governance (‘ESG’) factors are an important aspect of any company’s performance. Since inception, we have integrated the consideration of ESG issues within our Investment Process and we have in turn approached the ownership of equity in companies from a long-term perspective and sustainability-driven approach.

1.ESG Integration into Fundamental Research Entrenched into EFM’s Investment Process are the following considerations that affect or impact the valuations placed on each company: - U se of third-party providers: At EFM, we use third-party providers that produce ESG scores and reports on companies within our investment universe. Often time various data sources are employed directly into our investment analysis; this assists our Investment Team to make better-informed decisions regarding ESG risks and opportunities.

- C ash-flow forecasts: Where appropriate, EFM incorporates environment and other ESG factors into our cashflow forecasts for all revenues, expenses and capital expenditure.

- R equired Return: The expected rate of return for each security that captures Corporate Governance as well as Environment and Social Factors.

- C ompany Engagement: An integral component of EFM’s fundamental, bottom-up research is meeting with company management to test existing investment theses and convictions. EFM is in regular, active discussion with company management as well as with key industry participants (regulators) on governance.

Ultimately, our evaluation of a company’s prospective Excess Return is amplified or diminished due to stronger or weaker governance standards; sensitivity ranges are wider due to uncertain environmental regulation and social issues such as labour costs.

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2. ESG Integration into Portfolio Construction In the construction of EFMâ&#x20AC;&#x2122;s portfolios, we screen out stocks that pose potentially material ESG issues.

Additionally, ESG is considered at the time of portfolio construction when it is relevant. Whilst considering potential investments and stock selection, the EFM Investment Team refers to the valuation as well as the risks and opportunities identified by the Investment Team.

Below are a list of ESG factors assessed by EFMâ&#x20AC;&#x2122;s Investment Team:

CORPORATE GOVERNANCE

ENVIRONMENTAL RISK AND OPPORTUNITIES

SOCIAL RISK ASSESSMENT

Structure of the board, executive management and key reporting lines

The sustainability of key resource inputs

Political and regulatory support for investments and company operations in general

Quality or personnel and their historical track records

Harmful and toxic by-products

Injury rates compared to peers

Alignment of internal and external stakeholders, including remuneration practices and other incentives

Emission of carbon dioxide, sulphur dioxide, nitrous oxides and particulates

Turnover of key staff

Disclosure of asset company operations and financial performance (enough detail to assess and value each material operating entity)

Exposure to carbon taxes and Emission Trading Schemes

Public perception of company activities

Conflicts of interest between majority owners, management and minority shareholders

Extent of recycling, re-use and waste minimisation

The use of child labour and exploitative work practices

Impact on natural water flows The extent of risk management policies and their implementation

Cost of environmenal compliance Planning and approval processes for new projects

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EFM’s Approach to Active Ownership Of the three ESG factors, corporate governance tends to have the most significant impact on company performance and provides the greatest scope for value destruction.

EFM is an active participant in corporate governance matters that arise as a result of investments in securities. At EFM, we think of ‘active ownership’ as the supporting of good governance in companies and other assets and seeking to achieve change where we believe that governance is poor or less than ideal.

On behalf of our investors, we perform our active ownership duties in two main ways: 1. Voting at Company Meetings For all securities for which EFM is authorised to vote, upon receipt of notice of a meeting, the Investment Team reviews the resolution to be put to the meeting and determines EFM’s position. Where voting discretion is left to EFM, EFM’s view will be reflected in any proxy record.

2. Engagement with Company Management and Industry Participants When EFM becomes a shareholder in a company, we expect to be so for some years and the relationship with the Company’s board is an important part of the process. EFM’s investment team engages with company management on ESG and related issues in regular meeting and conversations with key management personnel. These discussions also seek to provide feedback to companies regarding: - C orporate strategy encouragement to consider long-term value creation and long-term risk management including ESG issues.

- C apital management and structure.

- E xecutive remuneration and incentive schemes, ensuring that executive remuneration is both appropriate for the company and those incentives are aligned with long-term shareholders.

Portfolio Risk Management At EFM, understanding and managing risk is interwoven throughout our investment process and in our approach to portfolio construction. In the construction of our Investable Universe, for instance, risk is managed by excluding companies which display characteristics that are undesirable to an investor. Additionally, in our analysis of individual companies, we use scenario analysis to assess the financial consequences of a range of probable outcomes and the likelihood of such outcomes is carefully considered (for more detail see ‘Risk Analysis’ within the Investment Process section).

EFM recognises that risk management is crucial to maintaining consistent investment performance over time. We acknowledge that ultimately exposure to some risk is required to meet return objectives. It is our detailed risk analysis that provides our Investment Team and the Portfolio Manager with the confidence to take calculated risks when making portfolio decisions.

Additionally, our risk assessment and models incorporate the following into our overall risk management process: 1. T o identify the systemic factors that the portfolio is exposed to and to the extent of those exposures (as measured by the beta); 2. To forecast the total level of portfolio risk (i.e., portfolio volatility); 3. To make better risk-return decisions by comparing the marginal contribution to risk of a security to the portfolio and the return from that security as determined by our own valuation calculations; and 4. To conduct scenario testing enabling the assessment of how potential shocks can affect the portfolio.

26

Managing the Research Process EFMâ&#x20AC;&#x2122;s Investment Team and the CIO manage the Investment Process and the overall investment performance across all strategies.

Each member of the Investment Team has an average of more than twenty (20) years of relevant experience that makes it a highly experienced leadership team.

Analyst Responsibilities Analysts have defined responsibilities for maintaining coverage of the companies that they have been allocated. This means that they are required to have up to date models and investment profiles, are commenting on news-flow and monitoring share prices. Analysts must highlight when the stocks under their coverage look attractive and should be considered for inclusion in portfolios and when valuation signals for existing portfolio stocks indicate the Investment Team and Portfolio Manager should review the current size of holdings.

Meeting Schedule EFM has an established meeting cycle that is designed to ensure appropriate communication between the members of the Investment Team.

There is a weekly meeting cycle, designed to ensure an orderly process of communication of events and analysis and for appropriate decisions on the prioritisation of research. The cycle commences with the â&#x20AC;&#x2DC;Portfolio Assessmentâ&#x20AC;&#x2122; meeting and concludes with the two weekly research meetings.

In addition to the above, the investment team meets on a quarterly basis to ensure that: - P erformance and research are reviewed with a strategic perspective.

- T he most appropriate macroeconomic and market data is being used.

- A ppropriate consideration is being given to emerging themes.

27

Identification and management of risk is an integral part of our business and investment processes

Business Operations EFM’s Risk Management process is designed to ensure that we identify risks, priortise those risks that we deem require mitigation and develop plans and actions to ensure that these risks are sufficiently mitigated.

They key elements of our Risk Management framework are: 1. Identification of business risk through conducting annual risk assessment reviews 2. Understanding the impact of these risks, prioritising the risk and developing action plans to prioritise risk mitigation 3. Tracking the progress of the mitigation plans to ensure prioritised risks are mitigated to the extent necessary

Risk and Compliance Framework EFM’s Risk and Compliance Framework comprises policies and procedures designed to meet EFM’s obligations, client requirements and best practices.

The framework is tested on an ongoing basis to ensure that EFM is acting in accordance with each policy as well as ensuring that the Risk and Compliance function continues to operate to a best practice level and responds to both local and international regulatory changes.

EFM’s staff receive regular training throughout the year on the policies, facilitated by the Chief Compliance Officer, Chief Financial Officer/ Chief Operating Officer and EFM’s third-party compliance firm, Duff and Phelps.

Compliance Testing The Risk and Compliance team conduct compliance monitoring throughout the year. Monitoring is completed by in-depth reviews of specific subjects. The reviews involve interviewing staff, testing of system data, policy and procedure analysis and current market conditions.

Results of the testing, including any identified exceptions are reported to the Board and the Risk and Compliance Committee.

Investment Compliance The EFM Risk and Compliance team provide specialist mandate investment compliance oversight. This investment compliance framework includes detailed mandate and product guidelines addressing all client, regulatory and EFM investment restrictions. All restrictions are monitored via both Enfusion Integrata/Northern Trust systems on both a pre and post-trade basis as outlined in the ‘Trade Flow and Investment Compliance’ section of this document. Any exceptions identified are investigated and escalated to senior management within the business.

Incident Reporting All incidents and breaches are recorded on the EFM Breach and Incident Register.

Incidents are detected via Risk and Compliance testing, management oversight and staff reporting. All incidents are reported via the Incident Register to Senior Management, the board and clients or regulators as required.

29

Trading EFM’s trading team consists of traders who oversee the execution of our stock and foreign exchange (‘FX’) trading. EFM’s traders liaise with brokers as well as with self-directed execution (‘DMA’) and block trading facilities, to execute the buy and sell orders triggered by the CIO. On a periodic basis, liquidity analysis is included in the wider Transaction Cost Analysis review that is part of the bi-annual Best Execution Review. Longer term liquidity analysis is performed on portfolio holdings as part of the annual capacity analysis paper. Liquidity analysis is also performed at least quarterly (days to redeem the portfolio). Liquidity is also explicitly accounted for in the implied trade cost estimate that forms part of the required rate of return in the investment making decision process.

At a trading level, liquidity is monitored on a granular level taking advantage of various liquidity sources across multiple venues on the trading desk, including high touch brokers, block desks, dark pools, buy-side crossing networks and via electronic execution providers.

These opportunities are fed back on a proactive basis to the Investment Team on watch list stocks.

Order and Execution Management Systems EFM utilises the Enfusion Integrata trading platform for equities order creation, execution and investment compliance and the Northern Trust platform for FX trades. For equities, this provides the ability for both traders to view on-going trades across all regions, completed trades and trades that are currently being executed in the market.

Enfusion Integrata contains all the underlying EFM account equity, cash and FX positions and is where all trades are generated. The compliance module contains all mandate, fund and regulator related investment restrictions on an account by account basis and is maintained by the EFM Compliance team. Enfusion Integrata connects to equity brokers via FIX (electronic routing) and electronically receives all fills and execution data to maintain transparency and operational risk management. All order sent to brokers are electronically acknowledged when accepted, amended and completed. Trades are booked from Enfusion Integrata with the trading marching process managed by the Investment Operations team. There is an audit function within the system that tracks each orders lifecycle, from generation, amendment, routing, execution and booking and relevant EFM persons and brokers.

EFM utilises Northern Trust for all fund administration services. Once the trades have been matched, settlement instructions are sent by Northern Trust via SWIFT message to Northern Trust for inclusion in the daily transactional and valuation reporting files.

Trade lifecycle and approval process

3

EFM

6

NORTHERN TRUST/ CUSTODIAN

4

7

2

5

1

BROKERS

1

Trade instructions are sent to broker for execution via Enfusion Integrata (Equity – trader, pre-trade compliance)

2

Broker confirmation is returned to EFM via Enfusion Integrata

3

Contract is matched by Northern Trust and EFM Operations Team

4

Swift messages are sent to Northern Trust

5

Northern Trust reconciles custodial and prime broker records to own records

6

Northern Trust calculates the NAV and transaction position reports are sent via secure portal from Northern Trust to EFM

7

30

Post-trade compliance completed by EFM: - Check security pricing - Mandate constraints - Daily holdings (Equity and FFX) and cash reconciliation.

All equity orders arise from the Portfolio Manager. These orders are tested on a pre-trade basis against the investment compliance rules engine within Enfusion Integrata and once passed or approved, they are released through to the trading team and into Enfusion Integrata.

The responsibility for approval of orders, where there is an investment compliance flag, is with the Investment Compliance team who are independent. Once executed the traders book out the trades which then flow through to the trade matching system and managed by the Investment Operations team. If there is a trade that is partially filled, the orders will be allocated pro-rata to its original amount.

Compliance module The compliance module in the Enfusion Integrata and Northern Trust systems contains all the investment restrictions and guidelines in clients Investment Management Agreements (‘IMAs’), legislation and relevant fund documentation All of these rules and guidelines are translated and captured within both Enfusion Integrata and Northern Trust for both time-of-trade compliance and daily compliance monitoring (post-trade). All compliance rules are documented in a fund template and then set up in Enfusion Integrata and reviewed by the Chief Financial Officer/Chief Operating Officer.

Pre-Trade Compliance When an order is set-up EFM’s Compliance module runs a pre-trade compliance check. The process is designed to determine whether the proposed trade, when taken with all other current and proposed trades, will result in a breach of the investment guidelines for any of the accounts. If a constraint is potentially breached, the system will log the potential breach and depending on the level of authorisation required, the following must occur:

- A warning where the Chief Investment Officer can override – a note is required to be added to explain the decision that also creates and audit trail.

- A soft-stop that requires approval from the Compliance Committee that cannot subsequently be overridden by the traders.

- A hard-stop that cannot be overridden.

Only after the pre-trade compliance check is completed does the order get released for execution by the trader.

A further compliance check is made by the system when the order is routed to a broker for execution. This check is a further update on the compliance requirements for changes that many have occurred between the order creation and the actual routing for execution.

Post-Trade Compliance EFM’s Operations and Compliance team generates a daily report that is reviewed daily by the Investment and Operations teams. All warnings are communicated to the Chief Investment Officer and traders via email and all breaches are investigated with the external Investment Administrator (Northern Trust) to ascertain their validity. A valid breach would be escalated to the Chief Financial Officer/ Chief Operating Officer.

31

Broker Selection EFM uses a mix of global brokers, local brokers, Direct Market Access (‘DMA’) execution only providers and Block matching venues to encourage an environment favourable to lowering both implicit and explicit transaction costs.

All brokers are subject to a standard rate card for execution and tack on rates. The rate card is subject to review on an on-going basis.

Best Execution Obtaining the best price (implicit transaction costs) and lowest commission (explicit transaction costs) for an order in the relevant market at the time, for transactions of the kind and size concerned, is ordinarily the starting point in determining best execution for a fund.

This involves decision making around broker selection, venue selection, execution style and aggressiveness in order to achieve the best price in the prevailing market conditions. All of these decisions involve consideration on several inter-related factors, included the size of the order, urgency interacting with natural flow, IOIs and dark pools, market microstructure, latency and algorithm suites.

Transaction Cost Analysis (‘TCA’) is utilised on a pre, real-time and post-trade basis to monitor the indirect costs of trades versus a variety of benchmark and factors.

EFM is committed to ensuring best execution by undertaking an independent quarterly broker review scrutinising a random sample of EFM executed trades for the period for broker quality, taking into account consideration the above factors and ensuring that conflicts of interest do not arise. This independent review is conducted by EFM’s Risk and Compliance team.

32

Business Continuity, IT Infrastructure and Cyber Security Business Continuity Planning EFM’s Business Continuity Planning (‘BCP’) is designed to enable us to recover the critical business processes that support the business in a timely manner. In a full-scale outage, the time to recover critical systems range from instant failover (Trading via Enfusion Integrata, Bloomberg Anywhere on laptop or mobile device) to around four hours (email and file servers, etc.).

The key elements of BCP include:

- Identifying the infrastructure and resources required to enable EFM to continue to operate at a minimum acceptable level in various disaster scenarios.

- Developing practical recovery plans that describe how EFM will continue to achieve its objectives should potential disruptions occur.

- Testing the BCP plans regularly.

- Ensuring all staff understand their roles and responsibilities in the event of a disruption.

IT Infrastructure and Environment EFM has an outsourcing partnership with an external provider, Velocity Technology Limited (‘Velocity’), to provide Information Technology (‘IT’) infrastructure and support services.

Velocity specialises in outsourced IT services for the financial industry. Velocity has over 100 clients in the financial industry including boutique asset managers, hedge funds, brokers and investment banking firms. Velocity maintains equipment in two data centres located in both Cyberport and Tseung Kwan to offer private cloud services and remote Disaster Recovery (‘DR’) services to clients.

Velocity employs 114 full-time staff including 94 engineers. Additionally, Velocity is a member of the Alternative Investment Management Association (‘AIMA’).

This is overseen by EFM’s Chief Financial Officer/Chief Operating Officer in conjunction with the Director of Business Development. The following describes EFM’s IT Infrastructure:

- EFM’s infrastructure environment is a Microsoft solution consisting of minimal on-premises hardware and data centre hosted servers and majority infrastructure. Dual broadband links to the hosting environment provide high-speed access with seamless link redundancy.

- All services in the server and networking environment have full redundancy, allowing EFM to sustain a full-loss of any one piece of equipment in the environment whilst continuing to work normally.

- Network security is maintained with Cisco firewalls, email scanning and antivirus and a tipping point intrusion prevention system (‘IPS’).

- In addition to active directory usernames and passwords, remote users authenticate with a number of different applications.

33

Systems Recovery and Data Protection Velocity provides EFM with a cloud-based disaster recovery solution hosted in data centres located at both Cyberport and Tseung Kwan.

Servers are backed up remotely (in the data centres) on a schedule between every one hour and twenty-four hours depending on the sensitivity of the data being stored. These local images are replicated in real time to a secondary data centre. In the case of a complete loss disaster situation, these images can be started at the secondary data centre allowing access to all IT services.

Systems Environment EFM uses best in class vendor systems for both functionality and connectivity. Systems include Enfusion Integrata and Bloomberg for order management and execution services. Northern Trust is used to match all trades. All systems utilise Financial Information Exchange (‘FIX’) and SWIFT messaging to ensure an environment that is highly integrated and automated. This allows EFM to achieve a high level of straight-through processing (over 98% of all transactions) across all of the brokers, custodians and FX counterparties across global markets where EFM operates. EFM also utilises Northern Trust to provide a robust platform for conducting portfolio analysis and to meet our client and fund reporting requirements. Northern Trust receives daily updates of all positions via an electronic feed from Enfusion.

Cyber Security Stuart Smith, (CFO/COO) and Matthew Hegarty, (Director – Business Development) are responsible for overseeing the EFM Cyber Security program in conjunction with Velocity. This covers controls, testing and training. One of the co-founders of Velocity, Stuart Sanders, has over 20 years experience in Cyber Security and is highly experienced in all areas of network security.

We are constantly monitoring and engaging with experts in the field to test the strength of EFM’s cybersecurity controls.

Investment Operations – Middle and Back Office The majority of EFM’s investment administration functions are outsourced to Northern Trust:

EFM utilises Northern Trust's portfolio platform

34

EQUITY SETTLEMENTS

FOREIGN EXCHANGE (FX) SETTLEMENT

EFM uses Northern Trust for trade matching equity transactions. SWIFT messages are fed from the system to both third party custodians and to EFM's Investment Administrator. Physical settlement is undertaken directly by third party custodian and their local agent.

All failing trades are reported directly to EFM by the custodian on the day of settlements for EFM to followup and resolve.

EFM uses GTSS to trade, match and settle all FX transactions. GTSS will automatically send swift messages for trade confirmation (MT304) and net settlement confirmation (MT202/MT210) direct to our custodian and investment administrator once trade are matched. Physical settlement is undertaken directly by the third party custodian and their local agent.

Investment Reconciliation Investment reconciliation occurs daily with Northern Trust. All reconciliation items are communicated to EFM daily by Northern Trust.

EFM reviews this report daily and follow-up on any outstanding breaks.

Monthly, a full NAV reconciliation (holdings, price, market values, cash, outstanding items, accrued income, fees, etc. is undertaken and received from Enfusion Integrata and this is then reviewed by the EFM Investment Operations team.

EFM Daily Reconciliation EFM Investment Operations team matches all trades in Enfusion Integrata on a daily basis. Any discrepancies identified with GTSS/the broker as the record of truth and EFM/Northern Trustâ&#x20AC;&#x2122;s records are updated accordingly.

Share Pricing EFM engages Northern Trust to provide share pricing services. Northern Trust may use automated systems in the calculation of net asset value and share prices. Pricing is calculated on a daily basis and shares are forward priced.

EFM reviews the Northern Trust Security Pricing policy to ensure that pricing processes are appropriate and EFM will recommend changes as required. These policies address share pricing matters including entry and exit prices, in-specie transfers, etc.

Legal EFM retains external counsel. Additionally, external counsel is also retained on matters of foreign law, that is legal obligations or implications for the business in jurisdictions other than just Hong Kong or on matters in relation to which specialist legal expertise is required.

Law firms currently retained by EFM Cayman Islands

Maples Group

Hong Kong

Clifford Chance

Canada

Osler, Hoskin & Harcourt LLP

Australia

PMC Legal, King & Wood Mallesons

Tax Advisors Hong Kong

PricewaterhouseCoopers

Singapore

PricewaterhouseCoopers

Australia

KPMG

Insurance EFM maintains appropriate insurance coverage. A copy of EFMâ&#x20AC;&#x2122;s current insurance certificate of currency is available upon request.

Accounting and Auditing All EFM fund annual accounts are prepared by the accountancy firm Doran & Minehane with the assistance of Northern Trust and are subject to an external audit. PwC has been engaged to complete this audit.

35

Client Servicing and Reporting EFM prides itself on the quality of our client relationships. We work with our clients to ensure that they are fully informed and have access to senior management and investment personnel on a regular basis as and when required.

The scope of services provided to clients includes access to the Investment Team, regular portfolio reporting and fund commentary, market outlook assessments including asset class valuation analysis and access to EFMâ&#x20AC;&#x2122;s thought leadership and thematic papers.

EFM uses Northern Trustâ&#x20AC;&#x2122;s reporting suite for client reporting as well as for detailed performance analysis. Northern Trustâ&#x20AC;&#x2122;s system is a broad-based financial analysis system that is able to capture both market and portfolio data. Reporting tools within Northern Trust have enabled the establishment of standard client reporting templates that are automatically populated on a periodic basis.

Generally EFM provides monthly and quarterly factsheets and updates for our funds. These reports contain a range of information:

Performance figures over various time horizons

Portfolio characteristics and statistics

Top 5 holdings by percentage weighting

Commentary of portfolio performance, positioning and outlook

Detailed commentary on a portfolio holding or thematic

36

We are committed to fostering and cultivating a high performance investment culture

Appendix

Personnel Structure

Jeff Emmanuel

Martin Warwick

Founder & CIO

Non-Executive Director Australia & Hong Kong

Stuart Smith

Investment Team

Chief Financial & Operating Officer

Adam Lee

Angela Poon

Senior Analyst

Finance & Operations Manager

Angus Walker

Gladys Ho

Senior Analyst

Office Manager

Eileen Deng

Senior Analyst

38

Sales & Distribution

Senior Advisory Group

Appendix

Bios Jeff Emmanuel EXECUTIVE CHAIRMAN, CHIEF INVESTMENT OFFICER

BIO

Jeff founded EFM in 2016 and is the Chief Investment Officer. Jeff has over 30 years’ experience in financial markets. Prior roles have included Vice-Chairman of Investment Banking for Citigroup (HK), Head of Equities for UBS Australia (Sydney) and a leading research FIG analyst in Australia (12 years). Jeff is a Chartered Accountant, a member of FINSIA and holds an MBA from Melbourne University and a Bachelor of Economics from Monash University.

COMMENCED WITH EFM

May 2014

CAREER HISTORY

2011–2013

Citigroup, Vice Chairman of Investment Banking APAC

2002–2011

UBS AG:

2010-2011 Managing Director of APAC Financial Institutions Group, UBS AG

2008-2010 Head of Equities, UBS Australasia

2002-2008 Head of Australian FIG Research, UBS Australasia

2000–2002

Merrill Lynch Australia, Head of Australian FIG Research

1998–2000

ABN Amro, Head of Australian FIG Research

1996–1998

HSBC Securities, Head of Australian FIG Research

2014

Paper 1: Fundamentals of Securities and Futures Regulation

Paper 6: Regulation of Asset Management, Securities and Futures

Commission of Hong Kong

1995

Master of Business Administration, Melbourne University

1991

Diploma Course Securities Institute (Australia)

1987

Bachelor of Economics, Monash University

EDUCATION

39

Appendix

Adam Lee SENIOR ANALYST

BIO

Adam joined EFM in 2018 as a member of the research team. Prior to EFM, Adam was the Senior Regional Banks Analyst for Asia-Pacific at UBS, based in Hong Kong.

Prior to that he worked as a research analyst covering Banks and Diversified Financial Institutions in Australia. He has over 10 years’ of experience in financial markets and holds a Bachelor of Engineering (Bioinformatics) with Honours (Class 1) and Bachelor of Commerce from the University of NSW, Australia.

COMMENCED WITH EFM

July 2018

CAREER HISTORY

EDUCATION

40

2016–2018

UBS Institutional Equities Research, Hong Kong

Senior Regional Banks Analyst, Asia-Pacific

Lead Analyst, Hong Kong Banks

2007–2016

UBS Institutional Equities Research, Sydney, Australia

2012 – 2016 Lead Analyst, Australian Diversified Financials

2009 – 2016 Analyst, Australian Banks

2007 – 2008 Associate, Australian Healthcare & Biotech

2006–2007

UBS Investment Banking, Sydney, Australia

2003–2008

Bachelor of Engineering (Bioinformatics) with Honours Class 1

Bachelor of Commerce (Finance/Accounting) – University of NSW, Sydney, Australia

2006

International Program, Queen’s School of Business

Queen’s University, Kingston, ON, Canada

Appendix

Angus Walker SENIOR ANALYST

BIO

Angus joined EFM in 2016 as a member of the research team. Prior to EFM, Angus worked in the Group Strategy and International Strategy teams for Commonwealth Bank based out of both Sydney and Hong Kong. His experience includes developing and implementing a digital banking strategy targeted in frontier markets including both Asia and Sub-Saharan Africa. Angus holds a Bachelor of Commerce (Finance, International Business) from the University of Sydney, Australia.

COMMENCED WITH EFM

April 2016

CAREER HISTORY

EDUCATION

2016–present

EFM Asset Management

Senior Financial Analyst

2011–2016

Commonwealth Bank of Australia

2015–2016

Strategy Analyst

2013–2015

Analyst – Group Strategy

2011–2012

Institutional Equities Support Manager

2009–2011

Angus holds a Bachelor of Commerce (Finance, International Business)

from the University of Sydney, Australia.

41

Appendix

Eileen Deng SENIOR ANALYST

BIO

Eileen joined EFM as a senior analyst in 2020. Eileen has 10 years’ experience in financial markets. Prior to joining EFM, Eileen was a Vice President in Deutsche Bank (HK) focusing on China TMT research. Eileen is a Certified Public Accountant, a member of HKICPA. Eileen holds a Master of Finance and a Bachelor of Business Administration in Accounting and Finance from The University of Hong Kong.

COMMENCED WITH EFM

March 2020

CAREER HISTORY

2013–2020

Deutsche Bank AG (HK):

2017–2020

Vice President, China TMT research

2015–2017

Associate, China TMT research

2013–2015

Analyst, China TMT research

2011–2012

Rongying Capital Management, Analyst

2009–2011

Deloitte Touche Tohmatsu, Associate Audit

2012–2013

Master of Finance, The University of Hong Kong

2006–2009

Bachelor of Business Administration in Accounting and Finance,

The University of Hong Kong

EDUCATION

42

Appendix

Stuart Smith CHIEF FINANCIAL & OPERATING OFFICER

BIO

Stuart joined EFM in 2018 as Chief Financial Officer and previously worked as an advisor to EFM since its inception. Stuart is a Chartered Accountant with over 30 years’ experience in the Finance Industry having worked in investment banking, public accounting and other senior executive roles (CFO, MD, NED) with both private and publicly listed resource companies. Stuart was also a highly rated Equity Analyst and led Merrill Lynch’s Asia Pacific Oil & Gas research team. Stuart holds a Bachelor of Commerce and a Post Grad Diploma of Finance from Melbourne University.

COMMENCED WITH EFM

May 2018

CAREER HISTORY

2014–2018

Executive Director–Finance, Lion Energy Ltd (ASX listed)

2011–2017

Chief Financial Officer, Ephindo Energy Pte Ltd

2008–2011

Triton Group, CFO and Executive Director

2009–2011

Kulczyk Oil Ventures Inc., Non Executive Director

2005–2008

Merrill Lynch Singapore, Head of Pac-Rim Oil & Gas Research

1998–2005

Merrill Lynch Aust, Head of Aust Oil & Gas and Utilities Rsch

1996–1998

HSBC Securities Aust, Analyst

1992–1996

ANZ Securities, Assistant Analyst then Analyst

1988–1992

Deloitte Touche Tohmatsu, Senior Auditor

1991–1993

University of Melbourne, Post Graduate Diploma in Finance

1990–1991

Institute of Chartered Accountants (ANZ), Professional Year

1986–1988

University of Melbourne, Batchelor of Commerce

1982–1985

Melbourne Grammar School, Higher School Certificate

1980–1981

Maryborough High School

EDUCATION

43

Appendix

Matthew Hegarty DIRECTOR – STRATEGY & DEVELOPMENT

BIO

Matthew joined EFM in 2018 as the Director of Business Development, leveraging over 18 years’ of experience across investment research and fund distribution. Prior to EFM, Matt’s experience includes Director positions at GW Capital and Mosaic Partners along with senior investment research roles at Antipodes Global Partners, Perennial Investment Partners and Global Value Investors. Matt holds a Bachelor of Arts and Bachelor of Laws from Macquarie University with Distinction.

COMMENCED WITH EFM

May 2018

CAREER HISTORY

2018–present EFM Asset Management Limited, Director–Business Development 2016–2017

GW Capital Pty Limited, Director

2014–2016

Antipodes Global Partners Limited, Senior Analyst

2013–2014

Perennial International Limited, Senior Analyst

2012–2013

Mosaic Partners Pty Limited/Mosaic (Beijing)

Fund Management Company Limited, Director

2005–2011

Global Value Investors Limited, Senior Analyst

2003–2005

Commonwealth Bank of Australia, Deal Manager–Corporate Finance

2000–2002

KGrind Pty Limited, In-house Counsel

1997–1999

EDUCATION

44

Blackstone Chambers

1996–2000

Macquarie University, Bachelor of Arts/Bachelor of Laws

1986–1994

St. Andrew’s Cathedral School, Higher School Certificate

Appendix

Russell Keenan CEO - CANADA

BIO

Russell joined EFM in 2018 and has more than 25 years experience in Investment Management, Finance & Strategy. Prior to joining EFM, Russell spent 2 years working in the Commonwealth Bank of Australia’s International Financial Services division in Hong Kong and 13 years in Deutsche Bank AG’s Equity Markets business in Australia & Asia. Russell holds an MBA from Melbourne University, a Graduate Diploma in Applied Finance (FINSIA) and a Bachelor of Business (Federation University).

COMMENCED WITH EFM

June 2019

CAREER HISTORY

EDUCATION

2017–2019

Commonwealth Bank of Australia–International Financial Services,

General Manager–Strategy & Business Development

2004–2017

Deutsche Bank AG, Director–Regional Research Sales

2003–2004

Foodland Associated Ltd, Corporate Strategy Manager

2001–2002

Avery Dennison (Jackstadt GmbH), Market Manager for Australia & New Zealand

1994–2001

Amcor Ltd, Various Sales & Marketing and Strategic Development roles

2019

Canadian Securities Course, CSI

2019

Partners, Directors & Senior Officers Course, CSI

2000–2002

Master of Business Administration (MBA), Melbourne Business School

1994–1996

Graduate Diploma in Applied Finance & Investment, Securities Institute of Australia

1991–1993

Bachelor of Business (Bbus), Federation University

45

Appendix

David Singer SALES & DISTRIBUTION - AUSTRALIA

BIO

David joined EFM in 2018 and has over 25 years experience in financial markets. Prior to EFM David worked for 16 years at UBS Securities Australia Limited where he retired in 2018 as a Managing-Director and Head of Sales Trading. David also previously has worked at Merrill Lynch Australia and Burdett, Buckeridge and Young. David is a fellow of FINSIA and a member of The Australian Institute of Company Directors and holds a Bachelor of Commerce from the University of NSW.

COMMENCED WITH EFM

July 2019

CAREER HISTORY

2002–2018

UBS Securities Australia Limited. Managing Director, Head of Sales Trading

1999–2002

Merrill Lynch Australia Limited. Vice President- Equity sales trading

1994–1999

Burdett, Buckeridge and Young. Senior equity sales

2019

Member of Australian Institute of Company Directors

2005

Fellow of the Securities institute of Australia

1994

University of New South Wales B. Comm

1988

Newington College

EDUCATION

46

EFM Asset Management Ltd