Cicc Alpha Investment Management (Usa), Llc

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT AVAILABLE TO THE PUBLIC ON APRIL 13, 2023 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): THE ADVISORY AFFILIATE'S SUBSIDIARIES, CICC QIANHAI DEVELOPMENT (SHENZHEN) FUND MANAGEMENT CO., LTD AND CICC QIANHAI (SHENZHEN) EQUITY INVESTMENT FUND MANAGEMENT CO., LTD, AND THE RELEVANT PRODUCTS UNDER THEIR MANAGEMENT FAILED TO COMPLETE RECTIFICATION AS SCHEDULED, AS WELL AS OVERDRAFT OF CLIENT'S ACCOUNTS RESULTED FROM THE FAILURE OF SYSTEM'S INTERCEPTION OF THE ADVISORY AFFILIATE, WHICH VIOLATED RELEVANT PROVISIONS OF THE REGULATION ON THE SUPERVISION AND ADMINISTRATION OF SECURITIES COMPANIES, THE CSRC BEIJING BUREAU DECIDED TO TAKE THE ADMINISTRATIVE REGULATORY MEASURE OF ORDERING TO TAKE RECTIFICATION MEASURES TO THE ADVISORY AFFILIATE. Status: Final Sanction Detail: NOT APPLICABLE Summary: IN RESPONSE TO THE ADMINISTRATIVE REGULATORY MEASURE, THE ADVISORY AFFILIATE HAS TAKEN THE FOLLOWING RECTIFICATION MEASURES: (1) ACCORDING TO THE REGULATORY REQUIREMENTS, THE ADVISORY AFFILIATE SHALL CONTINUE TO FOLLOW UP AND COMPLETE THE RECTIFICATION OF THE TWO ENTITIES OF CCIC QIANHAI AND THEIR MANAGED PRODUCTS; (2) AFTER THE OCCURRENCE OF OVERDRAFT INCIDENT OF CLIENT'S ACCOUNTS, THE ADVISORY AFFILIATE HAD PROMPTLY ORGANIZED THE TECHNICAL DEPARTMENT TO CONDUCT A COMPREHENSIVE INVESTIGATION FOR THE SYSTEM'S PROBLEM AND HAD RESTORED THE CORRESPONDING DEFECTS IN A TIMELY MANNER AND NOW RECTIFICATION HAS BEEN COMPLETED.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT AVAILABLE TO THE PUBLIC ON APRIL 13, 2023 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): THIS ADVISORY AFFILIATE FAILED TO PERFORM THE DUE DILIGENCE ON CERTAIN MATTERS OF THE UNDERWRITING BUSINESS RELATED TO HUACHEN AUTOMOTIVE GROUP HOLDINGS COMPANY LIMITED ON APPLICATION FOR PUBLIC ISSUANCE OF THE 2019 CORPORATE BONDS AND 2019 1ST TRANCHE BONDS. Status: Final Sanction Detail: NOT APPLICABLE Summary: IN RESPONSE TO THE ADMINISTRATIVE REGULATORY MEASURE, THE ADVISORY AFFILIATE HAS TAKEN THE FOLLOWING RECTIFICATION MEASURES: IT HAS ACTIVELY HANDLED THE RISKS OF DEFAULT ON THIS TRANCHE OF BONDS, IMPROVED THE APPROVAL STANDARDS FOR THOSE BONDS, FOCUSED ON THE ASSESSMENT AND JUDGMENT BEFORE ESTABLISHMENT OF PROJECT, CAREFULLY ESTIMATED THE QUALITY OF THE PROJECTS, REQUIRED THE RESPONSIBLE COMMITTEE TO STRENGTHEN THE AUDIT OF THE PROJECTS, AND EARNESTLY ASSUMED PERFORMANCE RESPONSIBILITIES.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT AVAILABLE TO THE PUBIC ON APRIL 20, 2022 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): ITS ASSET MANAGEMENT BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM, ITS MANAGEMENT, DIRECTORS, EMPLOYEES ETC.) ADOPTED THE COST METHOD IN THE VALUATION OF SOME ASSETS IN THE PRIVATE ASSET MANAGEMENT PLAN, AND THERE WERE INCONSISTENCIES IN VALUATION TECHNIQUES ADOPTED FOR THE SAME INVESTMENT PRODUCTS WITH THE SAME CHARACTERISTICS Status: Final Sanction Detail: NOT APPLICABLE Summary: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT: ITS BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM) COMPLETED THE RECTIFICATION BY ADJUSTING THE VALUATION METHOD AND ADOPTING THE METHOD OF REDUCING SHAREHOLDING WHEN APPROPRIATE; AND AS FOR THE CONSISTENCIES IN VALUATION TECHNIQUES, ADVISORY AFFILIATE UNIFIED VALUATION METHODS AND COMPLETED THE RECTIFICATION FROM THE PERSPECTIVE OF MARKET VALUE MEASUREMENT.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS SEMI-ANNUAL REPORT AVAILABLE TO THE PUBLIC ON SEPTEMBER 9, 2022 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): ITS FICC DEPARTMENT (OPTION BUSINESS NOT RELATED TO THE REPORTING ADVISORY FIRM, ITS MANAGEMENT, DIRECTORS, EMPLOYEES ETC.) ENGAGED A NON-PROFESSIONAL INVESTOR AS THE COUNTERPARTY TO AN OVER-THE-COUNTER OPTION CONTRACT. Status: Final Sanction Detail: NOT APPLICABLE Summary: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS SEMI ANNUAL REPORT: ITS FICC DEPARTMENT COMPLETED A SELF-EXAMINATION ON EXISTING OTC OPTION CUSTOMERS AND RECTIFICATION REQUIRING ALL CUSTOMERS TO MEET ELIGIBILITY STANDARD.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT AVAILABLE TO THE PUBLIC ON APRIL 20, 2022 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): ITS BROKER-DEALER BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM, ITS MANAGEMENT, DIRECTORS, EMPLOYEES ETC.) FAILED TO PERFORM CERTAIN CUSTOMER ID AND SUBMIT REPORTS ON CERTAIN LARGE-VALUE TRANSACTIONS OR SUSPICIOUS TRANSACTIONS Status: Final Sanction Detail: NOT APPLICABLE Summary: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT: ITS BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM) COMPLETED THE RECTIFICATION AND RELEVANT RESPONSIBLE PERSONNEL HAD PAID THE PENALTIES.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS SEMI-ANNUAL REPORT AVAILABLE TO THE PUBLIC ON SEPTEMBER 9, 2022 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): ITS SUBSIDIARY TIANJIN JIACHENG INVESTMENT MANAGEMENT CO. LTD FAILED TO LIQUIDATE REDUNDANT SPECIAL PURPOSE VEHICLES (SPVS) WITHIN THE REQUIRED PERIOD BY CSRC AND AMEND CERTAIN ARTICLES OF ASSOCIATION OF SPVS IN ACCORDANCE WITH REGULATORY MEASURES. Status: Final Sanction Detail: NOT APPLICABLE Summary: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS SEMI ANNUAL REPORT: ITS SUBSIDIARY TIANJINJIACHENG INVESTMENT MANAGEMENT CO., LTD AND REDUNDANT SPVS WERE LIQUIDATED AS REQUIRED AND CERTAIN ARTICLES OF ASSOCIATION OF SPVS WERE AMENDED AS REQUIRED.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT AVAILABLE TO THE PUBLIC ON APRIL 20, 2022 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): ITS INVESTMENT BANKING BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM, ITS MANAGEMENT, DIRECTORS, EMPLOYEES ETC.) AS A SPONSOR IN CONNECTION WITH A COMPANY'S APPLICATION OF LISTING ON THE STAR MARKET, FAILED TO PERFORM THE DUE DILIGENCE TO CONDUCT SUFFICIENT VERIFICATION PROCEDURES AS TO THE ISSUER'S CHARACTERISTICS OF SCIENTIFIC AND TECHNOLOGICAL INNOVATION, AND ISSUED CONCLUSIVE OPINIONS ,MAINLY RELYING ON EXPLANATORY DOCUMENTS PROVIDED BY THE ISSUER, SO THAT RELEVANT PROCEDURES ADOPTED AND THE EVIDENCE OBTAINED WERE NOT SUFFICIENT TO SUPPORT DISCLOSED INFORMATION AND FAILED TO PROVIDE A COMPLETE AND ACCURATE ASSESSMENT OF THE ISSUER'S CHARACTERISTICS OF SCIENTIFIC AND TECHNOLOGICAL INNOVATION. Status: Final Sanction Detail: NOT APPLICABLE Summary: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT: ITS BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM) REINFORCED THE INTERNAL CONTROL AND AUDIT, ENHANCE THE CONTROL OF PROJECT RISKS, IMPROVE THE LEARNING OF POLICIES AND DUE DILIGENCE, AND PAY ATTENTION TO NEGATIVE PUBLIC OPINIONS.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT AVAILABLE TO THE PUBLIC ON APRIL 20, 2022 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN A POSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIES LAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSING INFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THE MOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): ITS INVESTMENT BANKING BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM, ITS MANAGEMENT, DIRECTORS, EMPLOYEES ETC.) AS A SPONSOR IN CONNECTION WITH IPO FAILED TO PERFORM THE DUE DILIGENCE TO PROCURE THE ISSUER TO CLEAN UP RELEVANT VAM AGREEMENT, AND FULFILL DISCLOSURE OBLIGATIONS IN ACCORDANCE WITH REGULATORY REQUIREMENTS AND DID NOT ISSUE SPECIAL VERIFICATION OPINIONS PROACTIVELY ON WHETHER SUCH VAM AGREEMENTS COMPLY WITH RELEVANT REGULATORY REQUIREMENTS. Status: Final Sanction Detail: NOT APPLICABLE Summary: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORT: ITS INVESTMENT BANKING BUSINESS (NOT RELATED TO THE REPORTING ADVISORY FIRM) HAS CONDUCTED A COMPREHENSIVE SELF-EXAMINATION OF VAM AGREEMENTS IN ALL EXISTING IPO PROJECTS AND HAS PROMPTLY CARRIED OUT A SPECIAL CASE AND WARNING EDUCATION FOR ALL INVESTMENT BANKING PROFESSIONALS. THE LEGAL COMPLIANCE HAS SENT THE COMPLIANCE REMINDER ON IMPROVING QUALITY OF SPONSOR PRACTICES TO THE INVESTMENT BANKING DEPARTMENT. THE INVESTMENT BANKING DEPARTMENT TOOK SERIOUS PUNITIVE MEASURES AGAINST RELEVANT RESPONSIBLE PERSONS

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORTAVAILABLE TO THE PUBLIC ON MARCH 28, 2024 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN APOSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIESLAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSINGINFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THEMOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): DUE TO NON-COMPLIANCE BY THE ADVISORY AFFILIATE'S SUBSIDIARY, CICC FUTURES CO., LTD. ("CICC FUTURES"), WITH THE REGULATIONS ON STAFFING AND THE OCCURRENCE OF CYBERSECURITY INCIDENCES, WHICH WERE FOUND TO BE IN VIOLATION OF RELEVANT CHINESE REGULATIONS, CSRC QINGHAI BUREAU TOOK DISCIPLINARY ACTION OF A WARNING LETTER AGAINST CICC QIANHAI EQUITY. Status: Final Sanction Detail: NOT APPLICABLE Summary: IN RESPONSE TO THIS DISCIPLINARY ACTION, CICC FUTURES HAS ACTIVELY IMPLEMENTED THE CORRECTIVE ACTIONS, STRENGTHENED STAFFING, INFORMATION TECHNOLOGY GOVERNANCE AND SYSTEM MONITORING CAPABILITIES, AND FURTHER IMPROVED THE ABILITY TO RESPOND AND HANDLE CYBERSECURITY INCIDENTS, AND HAS SUBMITTED THE CORRECTIVE ACTION REPORTS TO THE REGULATORY AGENCIES.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORTAVAILABLE TO THE PUBLIC ON MARCH 28, 2024 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN APOSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIESLAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSINGINFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THEMOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): THE ADVISORY AFFILIATE, IN ITS CAPACITY AS TRUSTEE OF A CERTAIN BOND, FAILED TO PERFORM ITS DUTIES DILIGENTLY AND CAUSED A MAJOR IMPACT ON THE MARKET, AND THUS VIOLATED RELEVANT CHINESE REGULATIONS ON CORPORATE BONDS ISSUANCE AND TRADING. CSRC GUANGDONG BUREAU TOOK DISCIPLINARY ACTION OF A SUPERVISORY INTERVIEW WITH THE ADVISORY AFFILIATE. Status: Final Sanction Detail: NOT APPLICABLE Summary: IN RESPONSE TO THIS DISCIPLINARY ACTION, THE ADVISORY AFFILIATE HAS TAKEN THE FOLLOWING CORRECTIVE MEASURES: IT HAS ACTIVELY IMPLEMENTED THE CORRECTIVE ACTIONS, COMPREHENSIVELY STRENGTHENED THE QUALITY CONTROL OF INVESTMENT BANKING PRACTICES, FORMULATED AND IMPLEMENTED POLICIES TO ADDRESS MATERIAL QUALITY ISSUES, ISSUED MANAGEMENT REQUIREMENTS TO IMPROVE DOCUMENT QUALITY AND ELIMINATE MANAGEMENT LOOPHOLES; CONTINUED TO IMPROVE THE "THREE LINES OF DEFENSE" INTERNAL CONTROL MECHANISMS AND FOCUSED ON COMPREHENSIVE PROFESSIONAL QUALITY, CULTIVATED AND IMPROVED THE STANDARDIZATION OF DUE DILIGENCE, INFORMATION DISCLOSURE, CONTINUOUS SUPERVISION AND OTHER ASPECTS OF INVESTMENT BANKING, CONSOLIDATED THE RESPONSIBILITIES OF EACH LINK OF THE THREE LINES OF DEFENSE, AND IMPROVED THE INDUSTRY. THE ADVISORY AFFILIATE HAS ALSO ESTABLISHED AN EVALUATION MECHANISM FOR THE PROFESSIONAL QUALITY OF SERVICE PERSONNEL AND HAS SUBMITTED A CORRECTIVE ACTION REPORT TO THE REGULATORY AGENCY.

Allegations: ADVISORY AFFILIATE IS A PUBLICLY LISTED COMPANY IN HONGKONG AND ACCORDING TO ITS ANNUAL REPORTAVAILABLE TO THE PUBLIC ON MARCH 28, 2024 (THE REPORTING ADVISORY FIRM AND ADVISORY AFFILIATE ARE NOT IN APOSITION TO SHARE ANY NON-PUBLIC INFORMATION IN ORDER TO AVOID ANY VIOLATION OF THE RELEVANT SECURITIESLAWS APPLICABLE TO THE ADVISORY AFFILIATE AND TO AVOID CREATING ANY MARKET DISRUPTION FROM DISCLOSINGINFORMATION THAT IS NOT PART OF THE PUBLICLY AVAILABLE INFORMATION. FURTHER, FINANCIAL REPORTS ARE THEMOST RELIABLE AND ACCURATE PUBLIC SOURCES OF INFORMATION TO DESCRIBE THIS REGULATORY ACTION): THE ADVISORY AFFILIATE'S SUBSIDIARY, CICC QIANHAI (SHENZHEN) PRIVATE EQUITY FUND MANAGEMENT CO., LTD ("CICC QIANHAI EQUITY"), PROVIDED DISGUISED GUARANTEED RETURN OF CAPITAL AND GUARANTEED RETURN ON INVESTMENT TO THE INVESTORS AND FAILED TO PERFORM DUE DILIGENCE, AND THUS VIOLATED THE RELEVANT CHINESE REGULATIONS. THE SECURITIES INVESTMENT FUND INDUSTRY ASSOCIATION OF CHINA TOOK THE DISCIPLINARY ACTION OF PUBLIC CENSURE AGAINST CICC QIANHAI EQUITY. Status: Final Sanction Detail: NOT APPLICABLE Summary: IN RESPONSE TO THIS DISCIPLINARY ACTION, THE ADVISORY AFFILIATE HAS ESTABLISHED A SPECIAL WORKING GROUP TO PROMOTE THE CORRECTIVE ACTIONS OF CICC QIANHAI EQUITY, ACTIVELY IMPLEMENTED THE CORRECTIVE ACTIONS, AND REPORTED THE PROGRESS TO THE REGULATORY AGENCIES IN A TIMELY MANNER.