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New Capital Emerging Markets Future Leaders Fund

Marketing Communication

Executive Summary

Key events in market

February saw a reversal of markets as equities repriced Fed rate-hike expectations from 25bps to a possible 50bps on the back of (marginally) stronger inflation data, particularly the producer price index (PPI) and the core personal consumption expenditure (PCE) price index. The best performing markets were Greece, Czech Republic and UAE. Developed markets weathered the downdraft better than emerging.

Key performance & positioning updates

The Fund's benchmark (Solactive Emerging Markets ex China Custom Net Return
USD Index) performance was weaker than global and developed market equities.

Market Update

The breathless start to 2023 quickly reversed. China’s pause was to an extent inevitable – the rally was technically overbought, backward-looking data remained relatively negative (inevitably) and – most concerning – political involvement in the economy seems to be only increasing. This is offset by improving strong guidance and rapidly improving macroeconomic data. Those markets most closely correlated to China – South Africa, -10.7%; South Korea, -10.4%; and Brazil, -8.3% – were noticeably weak. There were some idiosyncratic issues there too: commodities in general were noticeably weaker, with metals particularly the focus – Nickel, Silver and Aluminium all fell more than 10%. Political noise – whilst certainly diminishing – remained above the comfort level in both Brazil and South Africa. And some economic data continued to contract – for example, the Manufacturing Purchasing Managers' Index in South Africa came in at 48.8 vs. 53 previously. From our perspective, there seems to be a steady fundamental improvement in Chinese economic activity, particularly around the consumer which is being explicitly targeted for support by the government. This should underwrite another leg of the China rally for the coming months.

Eastern European markets were the leaders in a tough month. Greece delivered another outstanding month of returns, rising 9.8%. This brings the year to date returns for the market to 23.7%. This is very idiosyncratic in the context of global equities: Greece – from a top down and banking sector perspective – has essentially been restructuring for the past five to ten years. The banking sector is at the heart of the rally: the four core banks are benefitting from significant net interest margin (NIM) tailwinds as their deposit funded franchises benefit from higher lending rates. Greece was upgraded to BB+ by Fitch and they are eying an investment grade sovereign rating, further reducing the cost of funding. This is against a backdrop of several years of loan book clean up and recapitalisations. We have been positive on the market and overweight since the Fund’s launch (28/03/2022) – albeit choosing industrial exposure ahead of financials. Today we see many reasons for the rally to persist – mainly still cheap valuations and improving GDP, which is still well below pre-GFC levels (!). But are mindful of the potential for a pause around the election, in July, which could cause investors to question the investment case as the existing leadership – who have done a fantastic job – may be questioned. Czech Republic's outperformance was driven by the corporate activity of a single utility. GCC domestic growth data remained robust, albeit backward looking, but energy prices – particularly natural gas – weighed on Qatari and Saudi Arabian markets.

In Asia, India suffered continued weakness, falling 5%, as a combination of flows and Adani follow through continued to weigh on sentiment. Adani Enterprises, the group’s flagship business, scrapped its follow-on public offering and have wiped ~US$115bn from the value of Adani companies in the two weeks following Hindenburg Research published their short seller report accusing the conglomerate of stock manipulation and accounting fraud. Reassuringly, the banks – especially the private institutions, where we have exposure – are not indicating material adverse impact from the group. Whilst the details are yet to be seen, we anticipate state banks to be far more exposed.

Latin America broadly experienced a tougher month: Mexican equities fell 0.7%, the best of the lot; Colombia fell 17%, the worst. Year to date Argentina remains the strongest performing regional market, +15%. Economists have been downgrading growth expectations for the region after a robust 2022, when the region expanded almost 4% with strong employment and service sectors, rebounding post the pandemic. The outlook for growth is lower, however, at ~2%. Analysts are pointing to domestic factors – namely higher interest rates which have weighed on business and consumer confidence, seen in slower job creation and spending on goods and services. There has also been political disruption in the region – such as Peru. And external factors, such as weakness at key trading partners (Europe and the US). Weaker commodity prices have also been a headwind in the near term. From our perspective, however, we see the region as a beneficiary of improving Chinese economic activity, with the positive feedback loops on terms of trade; and further upside to domestic growth given that interest rates are likely to be cut in Mexico and Brazil before the full year.

Fund Performance & Positioning

February showed disappointing absolute numbers but solid relative performance. We kept fund positioning conservative. Of our sector allocations, the overweight to Consumer Staples and underweights in Financials and Materials were the biggest contributors. Our zero allocation to Real Estate, overweight Communication Services and Health Care exposures were the relative detractors.

In the Consumer Staples sector Cencosud, Wal-Mart de Mexico and Femsa were the positive contributors. Cencosud enjoyed a robust month on little news, after some sell side upgrades at the end of January. They highlighted the characteristics we like about the business, namely its robust business model, demonstrated in resilient growth (~7% organic top line growth CAGR (compound annual growth rate) over the last five years); geographic diversification – with a core in Chile and the Andean region, but also meaningful exposure in Brazil and now North America after their acquisition of The Fresh Market; and cheap rated self-help: consensus earnings has the company on 7x 2023 P/E with a 29% forward free cash flow yield. Wal-Mart de Mexico reported solid results with a cautious outlook given the operating environment (like their parent) and rising personnel costs (leading to greater investment drive in automation). They positively surprised with a higher dividend. Femsa, the Mexican conglomerate, was a particularly satisfying contribution given we have been actively engaging management on specific capital allocation and ESG improvements. They own 14% of Heineken, the largest Mexican Coca Cola bottling business, and Oxxo, the leading Latin American convenience store chain. They published the conclusions from their strategic review, which involved executing a large portion of what we had requested in our detailed presentation. Whilst perhaps light on details as of yet, the stock reacted positively. We are meeting management at the beginning of March.

Financials suffered a weaker month in general, with risk off and some macro downgrades, which is perhaps unsurprising given that NIM expansion is broadly priced in. Emirates NBD is our preferred bank in the UAE which delivered a solid month. Whilst not the most exciting holding in the portfolio, it offers skewed exposure to the fastest growing Emirate (Dubai) at a discount to its local peers. We added a new financials position in South Africa, taking advantage of the macro headwinds. Discovery is an insurance company we have been following closely for the past six years. They have two core businesses – Life and Health insurance businesses in the UK and South Africa – and several new, fast-growing opportunities such as their global Vitality franchise and digital initiatives (e.g. digital bank). We have always considered this to be one of the most dynamic insurance companies globally – leveraging a data advantage (lifestyle tracking) to create a cost and pricing advantage. Today, crucially, their core businesses have stabilised with higher rates and they are reducing their spending on new, loss making projects. Additionally, Discovery’s Chinese Vitality partner is Ping An – the biggest local player. After a few years of disappointments from both the core and new business investments (taking too long), we hope to see some inflection in top line growth and a stable capital base driving returns on investment higher. One small example of our confidence in this renewed capital discipline is Amplify, Discovery’s insuretech joint venture with AIA (another Asian Vitality partner), which was wholly funded by their partner. Whilst small, it indicates the power of their platform and relationships.

Within Materials, our underweight worked well in the month given the commodity price action and China’s pullback. APL Apollo was the biggest positive contributor. Despite the Adani headlines, Indian budget announcements in February underlined infrastructure as a core focus of their growth strategy. APL Apollo is positioned within the steel tubes segment benefitting from broad based construction; and should see mix shift as premiumisation kicks in – particularly as a result of previous acquisition of a galvanised pipes business. Their results exceeded expectations at the beginning of the month – with particularly strong sales.



Outlook

Our core outlook has not changed much in the month, although we are marginally more bullish on certain segments of the world and more cautious on others. Broadly, this is likely to be another choppy year but we still see structural tailwinds for Emerging Markets and headwinds for developed peers. Indeed, we were perhaps surprised at developed market resilience in the face of what is likely to be a change in policy. Our sense is that the transmission mechanism in the US particularly – and to an extent in Europe – is far slower than previous cycles given that corporates are not highly levered and most mortgages are fixed long (some for 30 years). Countries like Sweden, and to an extent the UK, are likely to see a far swifter reckoning from higher rates as mortgage repricing creates problems in property markets. After a pause for a month, China seems well set for another leg up – particularly with a government so focused on consumption – and early signs that the Chinese property sector is recapitalising shows that the economy is getting back on its feet.

In terms of positioning we did two main things this month. We are continuing to reduce the number of holdings and are consolidating around names where we have greater conviction. Having started the year with 55 positions we now have 50, exiting lower conviction ideas (e.g. Cisarua) or those that don’t meaningfully diversify our tracking error. There is more to do here and the higher number of companies was a function of wanting to be diversified during 2022’s difficult market. Ideally we would like to have 40-45 positions. We also increased our exposure to companies benefitting from secular tailwinds.

We are also mindful that 2023 is likely to be another year of volatility: we aim to be disciplined in taking profits and adding to those names we like that have underperformed. In Latin America, Brazil is still selling off after the election. We have been 4% underweight but are closing that gradually as the market acclimatises to Lula, who – despite the rhetoric – has only done what he said he would do. We continue to characterise local investors as extremely bearish on local equities – with some sympathy: given there is a bias (we speak to investors, professionals and management teams, many of whom are disappointed Bolsonaro voters) and locals can invest in local currency bonds at 13-14%, guaranteed for 5 years. Foreigners, as indicated by flows, have lately caught up with locals and February saw the first change in net inflows since almost January 2022. For us this a first sign of capitulation. We see room for locals to be positively surprised by Lula (soft signals have been encouraging, such as ministers calming the market verbally, or Petrobras paying their dividend) and the market has meaningfully reset 2023 growth expectations. Brazil remains extremely cheap – even when adjusting for discounted commodity sectors – and whilst we may not be at the bottom we have our shortlist of ideas. Conversely, Mexico is in the grip of a nearshoring bull-market and whilst we are happy to ride this, we are cautious about adding to the most sensitive names.

In Asia we continue bias towards those companies benefitting from China reopening and are taking selected advantage of Indian weakness. That has meant adding to Taiwan and South Korea – particularly early cycle names – and adding to infrastructure exposed names in India. We have cut exposure to Indonesia, taking advantage of the recent rally.

CEEMEA remains disparate. We have slightly reduced some positions in Saudi Arabia where we have seen deteriorating fundamentals or have relatively low conviction. Conversely we had added to names we particularly like – such as Nahdi Medical. We are seeing more attractive entry points for some Polish names with structural tailwinds. Whilst we are constructive on the energy complex this year we are mindful of conflict between the slow down in US activity and recovery in Chinese demand (albeit lagging, given inventories, as noted in previous months). In the short term, the US is a larger consumer of oil, and likely to win this struggle. Longer term, the supply side should win.

Disclaimer

For professional clients, qualified investors and accredited investors only. The value of investments and the income derived from them can fall as well as rise, your capital is at risk. Note: Past performance is not a guide to the future. Returns may increase or decrease as a result of currency fluctuations.

Performance contribution is gross of fees, all other performance shown is net of fees and expenses. Please refer to the Prospectus for further information on this Fund and prior to any subscription. All data sourced New Capital, EFGAM, Bloomberg, as at title date, unless otherwise stated.

Issued in the UK by EFG Asset Management (UK) Limited which is authorised and regulated by the Financial Conduct Authority (FCA Registration No. 536771). Registered No: 7389746. Registered address: Park House, 116 Park Street, London W1K 6AP. Telephone: +44 (0)20 7491 9111.

This document is a marketing communication and does not constitute an offer to sell, solicit or buy any investment product or service, and is not intended to be a final representation of the terms and conditions of any product or service. The investments mentioned in this document may not be suitable for all recipients and you should seek professional advice if you are in doubt. Clients should obtain legal/taxation advice suitable to their particular circumstances. This document may not be reproduced or disclosed (in whole or in part) to any other person without our prior written permission. Although information in this document has been obtained from sources believed to be reliable, EFGAM does not represent or warrant its accuracy, and such information may be incomplete or condensed. All estimates and opinions in this document constitute our judgment as of the date of the document and may be subject to change without notice.

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Any information quoted relating to the New Capital UCITS Fund plc is merely a brief summary of key aspects of the Fund.  More complete information on the fund can be found in the prospectus, the simplified prospectus or key investor information document, and the most recent audited annual report and the most recent semi-annual report.

These documents constitute the sole binding basis for the purchase of fund units. Copies of these documents are available free of charge in the United Kingdom at EFG Asset Management (UK) Limited (“EFGAM”), Park House, 116 Park Street, London W1K 6AP, United Kingdom. Copies of these documents are available free of charge in Germany at the offices of the German information agent, HSBC Trinkaus & Burkhardt AG, Königsallee 21/23, 40212 Düsseldorf, Germany. Copies of these documents are available free of charge in France from the French centralizing agent, Societe Generale, 29, boulevard Haussmann – 75009 Paris, France. Copies of these documents are available free of charge from the Swiss Representative: CACEIS (Switzerland) SA, Route de Signy 35, CH-1260 Nyon, Switzerland. Paying Agent: EFG Bank SA. 24 Quai du Seujet, CH-1211, Geneva 2, Switzerland.

Copies of these documents are available free of charge in Luxembourg at the offices of the Luxembourg paying agent, HSBC Securities Services (Luxembourg) S.A., 16 boulevard d’Avranches, L-1160 Luxembourg, R.C.S. Luxembourg, B28531. Copies of these documents are available in the local languages as per the above and from www.newcapitalfunds.com. A summary of investor rights is available at: https://www.efgam.com/newcapitalfunds/Summary-Investor-Rights.html.

Country of origin of the collective investment scheme: Ireland

Investment products may be subject to investment risks, involving but not limited to, currency exchange and market risks, fluctuations in value, liquidity risk and, where applicable, possible loss of principal invested.

In the European Union, this Document is issued by KBA Investments Limited (“KBA”). KBA Investments Limited is licensed in terms of the Investment Services Act (Cap 370) as an Investment Firm and is regulated by the Malta Financial Services Authority (Authorisation ID KIL2-IF-16174). In the European Union, this Document is available to Professional Investors only (as defined under Annex II to Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU).

KBA Investments Limited
Licensed in terms of the Investment Services Act (Cap 370) as an Investment Firm and is regulated by the Malta Financial Services Authority (Authorisation ID KIL2-IF-16174). KBA Investments Limited is a sub-distributor in certain countries in the European Union for EFG Asset Management (UK) Limited. For the full list of EU countries, please visit the https://www.mfsa.mt/financial-services-register/ . Registered Office: Trident Park, Notabile Gardens, No 2 - Level 3, Zone 2, Central Business District, Birkirkara, Malta. Registered in Malta No. C97015

Prospectus/Key Investor Information
A copy of the English version of the prospectus of the Fund and the key investor information document relating to the Fund is available on www.newcapital.com and may also be obtained from EFG Asset Management (UK) Limited. Where required under national rules, the key investor information document/the key information document will also be available in the local language of the relevant EEA Member State.

Hyperlink to Summary of Investor Rights
A summary of investor rights associated with an investment in the Fund shall be available in English from www.newcapital.com.

Termination of marketing arrangements
A decision may be taken at any time to terminate the arrangements made for the marketing of the Fund in any EEA Member State in which it is currently marketed. In such circumstances, Shareholders in the affected EEA Member State will be notified of this decision and will be provided with the opportunity to redeem their shareholding in the Fund free of any charges or deductions for at least 30 working days from the date of such notification.
Issued in the United Kingdom by EFGAM which is authorised and regulated by the Financial Conduct Authority. Registered number: 7389736. Registered address: EFG Asset Management (UK) Limited, Park House, 116 Park Street, London W1K 6AP, United Kingdom.

France
Investors should note that, relative to the expectations of the Autorité des Marchés Financiers, this UCITS presents disproportionate communication on the consideration of non-financial criteria in its investment policy.

Information for investors in Australia
This document has been prepared and issued by EFG Asset Management (UK) Limited, a private limited company with registered number 7389746 and with its registered office address at Park House, 116 Park Street, London W1K 6AP (telephone number +44 (0)20 7491 9111). EFG Asset Management (UK) Limited is regulated and authorized by the Financial Conduct Authority No.536771.
EFG Asset Management (UK) Limited is exempt from the requirement to hold an Australian financial services licence in respect of the financial services it provides to wholesale clients in Australia and is authorised and regulated by the Financial Conduct Authority of the United Kingdom (FCA Registration No. 536771) under the laws of the United Kingdom which differ from Australian laws.
This document is confidential and intended solely for the use of the person to whom it is given or sent and may not be reproduced, in whole or in part, to any other person.

ASIC Class Order CO 03/1099
EFG Asset Management (UK) Limited notifies you that it is relying on the Australian Securities & Investments Commission (ASIC) Class Order CO 03/1099 (Class Order) exemption (as extended in operation by ASIC Corporations (Repeal and Transitional Instrument 2016/396) for UK Financial Conduct Authority (FCA) regulated firms which exempts it from the requirement to hold an Australian financial services licence (AFSL) under the Corporations Act 2001 (Cth) (Corporations Act) in respect of the financial services we provide to you.

UK Regulatory Requirements
The financial services that we provide to you are regulated by the FCA under the laws and regulatory requirements of the United Kingdom which are different to Australia. Consequently any offer or other documentation that you receive from us in the course of us providing financial services to you will be prepared in accordance with those laws and regulatory requirements. The UK regulatory requirements refer to legislation, rules enacted pursuant to the legislation and any other relevant policies or documents issued by the FCA.

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In order that we may provide financial services to you, and for us to comply with the Class Order, you must be a 'wholesale client' within the meaning given by section 761G of the Corporations Act. Accordingly, by accepting any documentation from us prior to the commencement of or in the course of us providing financial services to you, you:warrant to us that you are a ‘wholesale client’; agree to provide such information or evidence that we may request from time to time to confirm your status as a wholesale client; agree that we may cease providing financial services to you if you are no longer a wholesale client or do not provide us with information or evidence satisfactory to us to confirm your status as a wholesale client; and agree to notify us in writing within 5 business days if you cease to be a 'wholesale client' for the purposes of the financial services that we provide to you.

Offering Documents
Neither this document nor any document under which Interests in the New Capital UCITS Fund plc (the “Fund”) are offered is a prospectus, product disclosure statement or other formal disclosure document under the Corporations Act. Interests in the Fund may not be offered, issued, sold or distributed in Australia other than by way of or pursuant to an offer or invitation that does not need disclosure to investors either under Part 7.9 or Part 6D.2 of the Corporations Act, whether by reason of the investor being a wholesale client (as defined in section 761G of the Corporations Act and applicable regulations) or otherwise. Nothing in this document nor any document under which interests in the Fund are offered constitutes an offer of interests in a financial product or financial product advice to a 'retail client' (as defined in section 761G of the Corporations Act and applicable regulations).
The issuer of the interests in the Fund relies on exemptions available under Australian law from the need to hold an AFSL for the provision of financial services to Australian wholesale clients.Note that as all investors must be wholesale clients, no cooling off rights are available in relation to an investment in the Fund.

Americas
The Company is an open-ended umbrella type investment company with variable capital authorised by the Central Bank of Ireland pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 as amended. EFGAM and the Company are affiliated with EFG Capital International Corp., an SEC registered and FINRA/SIPC member broker-dealer.

Notice to Residents of the United States: Shares of the Fund may not be offered or sold, directly or indirectly, within the United States or to U.S. Persons (as defined in the Fund’s Prospectus).

Notice to Residents of Argentina: These shares may not be offered or sold to the public in Argentina. Accordingly, the offering of the shares has not been submitted to the Comisión Nacional de Valores (CNV) for approval. Documents relating to this offering (as well as information contained herein) may not be supplied to the general public for purposes of a public offering in Argentina or be used in connection with any offer or subscription for sale to the public in Argentina.

Notice to Residents of Bermuda: The securities being offered hereby are being offered on a private placement basis to investors who satisfy the criteria outlined in the prospectus. The prospectus is not subject to and has not received approval from either the Bermuda Monetary Authority or the Registrar of Companies in Bermuda and no statement to the contrary, explicit or implicit, is authorised to be made in this regard. The securities being offered may be offered or sold in Bermuda only in compliance with the provisions of the Investment Business Act 2003 of Bermuda. Additionally, non-Bermudian persons may not carry on or engage in any trade or business in Bermuda unless such persons are authorized to do so under applicable Bermuda legislation. Engage in the activity of offering or marketing the securities being offered in Bermuda to persons in Bermuda may be deemed to be carrying on business in Bermuda.

Notice to Residents of Brazil: These shares may not be offered or sold to the public in Brazil. Accordingly, the offering of the shares has not been nor will be submitted to the Brazilian Securities Commission - CVM for approval nor has it been submitted to the foregoing agency for approval. Documents relating to such offering, as well as the information contained herein and therein may not be supplied to the public, as a public offering in Brazil or be used in connection with any offer for subscription or sale to the public in Brazil.

Notice to Residents of Chile: Fecha de inicio de la oferta: [11.10.2013]
(i) La presente oferta se acoge a la Norma de Carácter General N° 336 de la Superintendencia de Valores y Seguros de Chile.
(ii) La presente oferta versa sobre valores no inscritos en el Registro de Valores o en el Registro de Valores Extranjeros que lleva la Superintendencia de Valores y Seguros, por lo que los valores sobre los cuales ésta versa, no están sujetos a su fi scalización;
(iii) Que por tratarse de valores no inscritos, no existe la obligación por parte del emisor de entregar en Chile información pública respecto de estos valores; y
(iv) Estos valores no podrán ser objeto de oferta pública mientras no sean inscritos en el Registro de Valores correspondiente.
(i) The commencement date of the offer and the fact that the relevant offer is made pursuant to this SVS Rule 336;
(ii) That the offer deals with securities that are not registered in the Securities Registry (Registro de Valores) or in the Foreign Securities Registry (Registro de Valores Extranjeros) kept by the SVS, which are, therefore, not subject to the supervision of the SVS. It is not sufficient to include disclaimers stating that the securities are registered in a specific jurisdiction other than Chile and supervised by the correspondent regulator; the SVS requires including in the communications and material used to offer the securities to potential investors the disclaimer provided by the NCG 336 and in Spanish;
(iii) That, given that the securities are not registered, there is no obligation for the issuer to disclose in Chile public information about said securities; and
(iv) That the securities may not be publicly off ered as long as they are not registered in the corresponding Securities Registry.

Notice to Residents of Colombia: This presentation does not have the purpose or the effect of initiating, directly or indirectly, the purchase of a product or the rendering of a service by the company to Colombian residents. The company’s products and/or services may not be promoted or marketed in Colombia or to Colombian residents unless such promotion and marketing is made in compliance with decree 2555 of 2010 and other applicable rules and regulations related to the promotion of foreign financial and/ or securities related products or services in Colombia. Colombian residents acknowledge that the receipt of this message constitutes a solicitation from the company’s products and/or services. Colombian residents acknowledge and represent that they are not receiving from the company any direct or indirect promotion or marketing of financial products and/or services.

Notice to Residents of Costa Rica: This is an individual and private offer which is made in Costa Rica in reliance on an exemption from registration before the General Superintendence of Securities (“SUGEVAL"), pursuant to articles 7 and 8 of the Regulations on the Public Offering of Securities (“Reglamento sobre Oferta Pública de Valores”). This information is confidential and is not to be reproduced or distributed to third parties as this is not a public offering of securities in Costa Rica. The product being offered is not intended for the Costa Rican public or market and neither is registered or will be registered before the SUGEVAL, nor can be traded in the secondary market.

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Notice to Residents of El Salvador: The recipient of this documentation hereby acknowledges that the same has been provided by EFG Capital International Corp. upon the recipient’s express request and instructions, and on a private placement basis.

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Notice to Residents of Mexico: The shares have not been, and will not be, registered under the Mexican Securities Market Law (Ley del Mercado de Valores) and may not be offered or sold in the United Mexican States. The Prospectus relating to the Securities Offering may not be distributed publicly in Mexico and the shares may not be traded in Mexico.

Notice to Residents of Panama: Neither these securities, nor their offer, sale or transfer, have been registered with the Superintendence of the Securities Market (before named National Securities Commission). The exemption from registration is based on numeral 3 of Article 129 of Decree Law 1 of July 8, 1999 (Institutional Investors), as amended. In consequence, the tax treatment established in Articles 334 to 336 of Decree Law 1 of July 8, 1999, as amended, does not apply to them. These securities are not under the supervision of the Superintendence of the Securities Market (before named National Securities Commission).

Notice to Residents of Uruguay: Shares of the Fund are not available publicly in Uruguay and are offered only on a basis which constitutes a private placement in Uruguay. As such, the Shares are not required to be, and will not be, registered with the Central Bank of Uruguay. The Shares correspond to an investment fund that is not an investment fund regulated by Uruguayan law 16,774 dated September 27, 1996, as amended.

Hong Kong
The contents of this document have not been reviewed nor endorsed by any regulatory authority in Hong Kong. Hong Kong residents are advised to exercise caution in relation to this offer. An investment in the Fund may not be suitable for everyone. If you are in any doubt about the contents of this document, you should consult your stockbroker, bank manager, solicitor, accountant or other financial adviser for independent professional advice.
The Fund is not authorised by the Securities and Futures Commission (“SFC”) in Hong Kong pursuant to Section 104 of the Securities and Futures Ordinance (Cap 571, Laws of Hong Kong) (“SFO”). This document has not been approved by the SFC in Hong Kong, nor has a copy of it been registered with the Registrar of Companies in Hong Kong and, must not, therefore, be issued, or possessed for the purpose of issue, to persons in Hong Kong other than (1) professional investors within the meaning of the SFO (including professional investors as defined by the Securities and Futures (Professional Investors) Rules); or (2) in circumstances which do not constitute an offer to the public for the purposes of the Companies Ordinance (Cap 32, Laws of Hong Kong) or the SFO. This document is distributed on a confidential basis and may not be reproduced in any form or transmitted to any person other than the person to whom it is addressed. No interest in the Fund will be issued to any person other than the person to whom this document has been addressed and no person other than such addressee may treat the same as constituting an invitation for him to invest.

Singapore
The Fund and the offer of the Shares / Units which are the subjects of this document do not relate to a collective investment scheme which is authorised by the Monetary Authority of Singapore (“MAS”) under section 286 of the Securities and Futures Act (Cap. 289) (the "SFA") or recognised by the MAS under section 287 of the SFA, and Shares / Units of the Fund are not allowed to be offered to the retail public.

This document (as well as any other document issued in connection with the offer or sale of Shares / Units is not a prospectus as defined in the SFA, nor will it be lodged or registered as a prospectus with the MAS and, accordingly, statutory liability under the SFA in relation to the content of prospectuses does not apply, and potential investors should carefully consider whether an investment in the Shares / Units is suitable for them. The MAS assumes no responsibility for the contents of this document (nor any other document issued in connection with the offer or sale of the Shares / Units.

No offer of the Shares / Units for subscription or purchase, or invitation to subscribe for or purchase the Shares / Units, may be made, nor any document or other material (including but not limited to this document relating to the Shares / Units may be circulated or distributed, either directly or indirectly, to any person in Singapore other than: (i) to an institutional investor (as defined in section 4A of the SFA) pursuant to section 304 of the SFA; (ii) to a relevant person (as defined in section 305(5) of the SFA) pursuant to section 305(1) of the SFA; (iii) on terms that the minimum consideration is the equivalent of Singapore dollars 200,000 in accordance with section 305(2) of the SFA; or (iv) otherwise pursuant to, and in accordance with the conditions of, any other exemption under the SFA.

Pursuant to section 305 of the SFA, read in conjunction with regulation 32 of and the Sixth Schedule to the Securities and Futures (Offers of Investments) (Collective Investment Schemes) Regulations 2005, the Fund has been entered into the list of restricted schemes maintained by the MAS for the purposes of offering Shares / Units in the Fund to relevant persons (as defined in section 305(5) of the SFA), or, for the purposes of offering Shares / Units in the Fund in accordance with the conditions of section 305(2) of the SFA.

Where an offer is made to institutional investors pursuant to section 304 of the SFA, the following restrictions (under section 304A) apply to Shares / Units acquired pursuant to such an offer. Where such Shares / Units are first sold to any person other than an institutional investor, the requirements of Subdivisions (2) and (3) of Division 2 to Part XIII of the SFA will apply to the offer resulting in such sale, save where the Shares / Units acquired are of the same class as, or can be converted into Shares / Units of the same class as, the other Shares / Units:
i. which are listed for quotation on an approved exchange (as defined in the SFA); and
ii. in respect of which any offer information statement, introductory document, unitholders’ circular for a reverse take-over, document issued for the purposes of a trust scheme, or any other similar document approved by an approved exchange (as defined in the SFA), was issued in connection with an offer of those Shares / Units, or the listing for quotation of those Shares / Units.

Where an offer is made to relevant persons pursuant to section 305 of the SFA, the following restrictions (under section 305A) apply to Shares / Units acquired pursuant to such an offer. Where such Shares / Units are first sold to any person other than (i) an institutional investor; (ii) a relevant person; or (iii) on terms in accordance with section 305(2) of the SFA, the requirements of Subdivisions (2) and (3) of Division 2 to Part XIII of the SFA will apply to the offer resulting in such sale, save where the Shares / Units acquired are of the same class as other Shares / Units:
i. which are listed for quotation on an approved exchange (as defined in the SFA); and
ii. in respect of which any offer information statement, introductory document, unitholders’ circular for a reverse take-over, document issued for the purposes of a trust scheme, or any other similar document approved by an approved exchange (as defined in the SFA), was issued in connection with an offer of those Shares or Units, or the listing for quotation of those Shares / Units.

Further, where the Shares / Units are acquired pursuant to an offer made in reliance on section 305 of the SFA and the acquirer is:
a. a corporation which is not an accredited investor (as defined in the SFA), whose sole business is to hold investments and the entire share capital of which is owned by individuals each of whom is an accredited investor); or
b. a trust of which the trustee is not an accredited investor and whose sole purpose is to hold investments for the benefit of beneficiaries each of whom is an accredited investor,
then no securities of such a corporation and no rights and interests of the beneficiaries in such a trust (as the case may be) shall be transferred for a period of 6 months from the time the corporation or trust (as the case may be) acquired the Shares / Units, unless such transfers are in accordance with the conditions specifically provided in sections 305A(2) and 305A(3) of the SFA (as the case may be).