Operational manual and Internal Control Procedure in relation to trading of securities for a financial brokerage.

Objective of the Operations and Internal Control Procedural Manual

The operations manual serves the following objectives:

1) It serves as official company procedures in connection with daily operations to control the activities and safeguard its assets.

2) It serves to satisfy Regulator and relevant requirements.

3) It serves as a control tool to instruct and inform company staff uniformly.

From time to time, the Compliance Division and the Responsible Officer may issue updates or supplements and update to this Manual. Such updates and supplements are to be physically maintained with the Manual and are to be incorporated by reference as part of this Manual when issued. However, there may be instances where it would be inappropriate for the procedures or guidelines contained herein to be followed. In any such case the Responsible Officer/Division Officer is responsible for with the particular transaction must agree the revised procedures to be followed with the Executive Director / Responsible Officer or the Compliance Officer. The Compliance Division must keep written record of any agreed variation.

Section 1: INTRODUCTION

Objective of the Operations and internal control procedural Manual

Section 2: FINANCIAL RESOURCES RULES

Minimum Liquid Capital Requirement

Chapter 3: JOB DESCRIPTIONS & ACCOUNTABILITY

Responsible parties

Job Description

Section 4: ANTI-MONEY LAUNDERING/ANTI-TERRORISM

Relevant Legislation

Money Laundering

Stages of money laundering

Definition of terrorist financing

Section 5: IDENTIFICATION OF YOUR CLIENTS

New Client

Origination of client’s instructions

Section 6: INDIVIDUAL/CORPORATE CLIENT

ACCOUNT OPENING DOCUMENTS-SECURITIES CASH

AND MARGIN

Sales Team Structure

Registration and Capabilities

Client Account Opening

Professional Investors

Amendments to account opening documents

Closure of Accounts

Section 7: TRADING AND CREDIT LIMIT POLICY - CASH AND MARGIN

Trading Limit

Sales Credit Policy

Section 8: ORDER HANDLING AND DEALING

Diligence

Client’s Order Handling Procedures

Future Dealing Procedures

Through Account Executive

Direct to Dealing Department

Access to Dealing Room

Branch Office's dealing procedures

Internet Trading System for clients

Client Priority

Trading Errors

Records Maintaining

Section 9: EMPLOYEE DEALING POLICY

To whom this policy applies

Objectives

Scope of this policy

Mandatory Rules

General Restrictions

Penalties for Non compliance

Section 10: FUTURES MARGIN LENDING POLICY

Prudent Banking borrowing

Margin Call Policy

Margin Calls

Position Limits

Margin Call Procedures

Section 11: FUTURES SETTLEMENT OPERATION

On Trade date

On T + 1

On T + 2

Cash settlement

Funds withdrawals from Clients’ accounts

Clients Deposits

Clients Withdrawal

Section 12: FUTURES RECONCILIATION

Daily Reconciliation

Monthly Reconciliation

Section 13: BANK AND TRUST ACCOUNTS RECONCILIATION

Section 14: CONTINGENCY POLICY

Section 15: HANDLING COMPLAINTS

How to use this Document?

This document should be carefully read by the respective financial institutions.

This template may be used upon the Operational manual and Internal Control Procedure in relation to trading of securities for a financial brokerage.

This is in accordance with SFC and HKMA regulations.