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Association of Private Bankers in Greater China Region
                 The Principles of Practice for Private Wealth Management



Introduction

The Association has mission to develop and promote the Principles of Practice to foster
responsible wealth management and to protect the private wealth owners and their
beneficiaries.

In this connection, the Association has good will to advocate the following paradigms:
    ● Prudent management of the private wealth management practice
    ● Full transparency of fees and commissions
    ● Full disclosure on material information that are of interests of wealth owners and their
         beneficiaries
    ● Dedicated effort to avoid conflicts of interest
    ● Caution of investment not offering transparency or liquidity
    ● Customized solution addressing unique and in-different needs of wealth owners and
         their beneficiaries

The Principles of Practice are a set of best practices intended to create ethical discipline,
process and transparency in private wealth management in greater China region. The
Association encourages the members and professionals who manage significant wealth to
adopt and implement the practice following our valued principles.

Supporting members and professionals can sign the Charter of Private Wealth Management
Practitioners to signify their conviction and buy-in to the paradigms and the principles.

The Principles of Practice are focused on the key areas of wealth management :
   ● Governance
   ● Service Approach
   ● Investment Management
   ● Oversight and Monitoring

                           © Association of Private Bankers in Greater China Region
The Principles of Practice for Private Wealth Management

Governance

    Principle 1
    Practitioners should maintain financial stability. There should be a track record of
    consistent growth in assets and relationships over a period of 3-5 years. The practicing
    institutions should present the sustainable corporate ownership, the prudent governance
    structure and the proven firm profitability.

    Principle 2
    Practitioners should demonstrate commitment in fulfilling the multi-generational needs
    of wealthy family. The practicing institutions should develop their mission that reflects
    this commitment. Prime focus should be given in cultivating long-term and trustful
    relationships, attaining diversified goals of wealth owners and assisting in wealth and
    business transition.

    Principle 3
    Practitioners should employ competency and stable senior management and staff. The
    senior management and the responsible officers should demonstrate the conviction to high
    ethical standards and display the integrity in all the ways of managing the private wealth
    management practice. The execution staffs should carry recognized industry credentials
    and adequate experience in the private wealth management field.

Service Approach

    Principle 4
    Practitioners should adopt a client-centered relationship management approach and
    practice in the way that reflect this live philosophy.

    Principle 5
    Practitioners should adopt an integrated service delivery process. This holistic approach
    to the wealth management process should consider the entirety of the clients’ situation and
    their best interest. The execution should reflect this live philosophy.

    Principle 6
    Practitioners should adopt a disciplined investment process. The practicing institutions
    should establish the well-documented investment strategy, develop and maintain the
    investment policy statements. The investment committee should be set up for supervising
    and monitoring the investment.




                          © Association of Private Bankers in Greater China Region
Principle 7
   Practitioners should maintain a diversified menu or platform of investment products. The
   practicing institutions should get the access to a broad range of investment product, asset
   management services, financing solution and diversified asset classes.

Investment Management

   Principle 8
   Each investment portfolio shall be diversified as completely as practical. There should
   be diversification of asset classes, investment managers, investment style, currencies,
   banking and brokerage exposure, and geopolitical risks.

   Principle 9
   Every portfolio shall have an investment Policy statement, and every manager shall have
   a clearly articulated mandate; and the investment Policy statement and mandate shall be
   monitored.

   Principle 10
   Any investment portfolio shall be designed taking into account the assets, objectives,
   needs, and character of the wealth owner and/or beneficiary; and should be monitored with
   those in mind; and a Foundation shall have a process to determine whether the investment
   program reflects the values of its mission and its philanthropic grant program.

   Principle 11
   There shall be clear, disciplined, and objective process for selecting, monitoring, removing,
   and replacing investment managers, custodians, banks, trade execution, accounting, and
   other professionals.

   Principle 12
   Any investment manager or specific fund to be used shall have a strategy and style
   which can be easily understood and explained to others by the Wealth owners and their
   beneficiaries or by one of the trustees, directors, or staff members of the Trust, Foundation,
   or Family Office. If no one other than the Investment Manager or the fund representative is
   able to explain the strategy and style, the manager or fund shall not be used.

   Principle 13
   Special scrutiny and limitations should be applied to any Investment Manager who does
   not offer complete transparency, or whose portfolio is not liquid. Such investments are not
   prohibited, but should be limited in proportion to total portfolio investments.

   Principle 14
   Custody of assets, accounting for assets, and investment management services shall each
   be performed independently and separately.



                         © Association of Private Bankers in Greater China Region
Oversight and Monitoring

    Principle 15
    The wealth owners and beneficiaries, the Trustees of a Trust, or the Directors of a
    Foundation shall articulate purposes, goals, expectations and risk tolerance with respect
    to the Wealth; and shall be ultimately responsible for maintaining the currency of that
    articulation.

    Principle 16
    With respect to a Family Office, a Trust, or a Foundation; the governance structure
    together with various governance roles and responsibilities shall be clearly set forth and
    shall include provision for the communication of those roles and responsibilities and
    assurance that they are understood and accepted.

    Principle 17
    Any Trust or Foundation and any Trustee or Director shall adhere to best fiduciary
    practices; and there shall be established process for monitoring the discharge of fiduciary
    duties by the Trust, Foundation, a Trustee, or a Director.

    Principle 18
    Succession shall be set out where possible and shall be considered. For the Wealth
    owners and their beneficiaries, provisions shall be in existence for disposition of assets and
    management of affairs from and after death or in the event of incapacity. For the Family
    Office, Trust, or Foundation; provision shall be made for succession of governance and
    management.

    Principle 19
    Practitioners should establish a process for reviewing the governance mechanism, the
    work policies and procedures. There shall be a method for managing and monitoring
    internal and external resources.

    Principle 20
    Practitioners should maintain comprehensive financial reporting to enable clients to
    understand their consolidated and latest financial position.

    Principle 21
    Practitioners should comply with all regulatory and financial requirements. The practicing
    institutions should be able to demonstrate the evidence of compliance with regulatory
    agencies and reliance on routine internal control procedures, such as financial, security
    and technology audits.




                          © Association of Private Bankers in Greater China Region
Principle 22
Practitioners should develop their robust technology platform. The practicing should
hold reliable hardware and software systems that support the complex needs of multi-
generational wealth owners and their beneficiaries.

Principle 23
Practitioners should enable full transparency of fees, commission and expenses.
Full disclosure and clear explanation must be offered to the wealth owners and their
beneficiaries prior to the execution and the disclosure should be arranged on an on-going
basis.

Principle 24
Practitioners should maintain an equitable policy where the compensation and fees paid
to staff, directors, and governors of Family Offices, Foundations, or Boards shall not be
calculated on the basis of “investment return” of shorter duration than five years. Any
salary, bonus, or fee must be fully disclosed as to its amount and its calculation. Any direct
or indirect payment to or for staff or governors other than a payment designated salary,
bonus, or fee (or similar designation) is discouraged.

Principle 25
Practitioners should maintain a staff dealing policy where the self-dealing by staff, trustees,
or directors of any Family Office, Trust, or Foundation is strictly prohibited. Investment
portfolios of these parties shall be subject to strict disclosure rules which ensure
compliance with the prohibition against self-dealing. Any grant or payment to any agency
or company in which such a party has any interest whatsoever should clearly reflect that
interest in the deliberation relating to that grant or payment.




                      © Association of Private Bankers in Greater China Region

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Principles of Practice - Private Wealth Management

  • 1. Association of Private Bankers in Greater China Region The Principles of Practice for Private Wealth Management Introduction The Association has mission to develop and promote the Principles of Practice to foster responsible wealth management and to protect the private wealth owners and their beneficiaries. In this connection, the Association has good will to advocate the following paradigms: ● Prudent management of the private wealth management practice ● Full transparency of fees and commissions ● Full disclosure on material information that are of interests of wealth owners and their beneficiaries ● Dedicated effort to avoid conflicts of interest ● Caution of investment not offering transparency or liquidity ● Customized solution addressing unique and in-different needs of wealth owners and their beneficiaries The Principles of Practice are a set of best practices intended to create ethical discipline, process and transparency in private wealth management in greater China region. The Association encourages the members and professionals who manage significant wealth to adopt and implement the practice following our valued principles. Supporting members and professionals can sign the Charter of Private Wealth Management Practitioners to signify their conviction and buy-in to the paradigms and the principles. The Principles of Practice are focused on the key areas of wealth management : ● Governance ● Service Approach ● Investment Management ● Oversight and Monitoring © Association of Private Bankers in Greater China Region
  • 2. The Principles of Practice for Private Wealth Management Governance Principle 1 Practitioners should maintain financial stability. There should be a track record of consistent growth in assets and relationships over a period of 3-5 years. The practicing institutions should present the sustainable corporate ownership, the prudent governance structure and the proven firm profitability. Principle 2 Practitioners should demonstrate commitment in fulfilling the multi-generational needs of wealthy family. The practicing institutions should develop their mission that reflects this commitment. Prime focus should be given in cultivating long-term and trustful relationships, attaining diversified goals of wealth owners and assisting in wealth and business transition. Principle 3 Practitioners should employ competency and stable senior management and staff. The senior management and the responsible officers should demonstrate the conviction to high ethical standards and display the integrity in all the ways of managing the private wealth management practice. The execution staffs should carry recognized industry credentials and adequate experience in the private wealth management field. Service Approach Principle 4 Practitioners should adopt a client-centered relationship management approach and practice in the way that reflect this live philosophy. Principle 5 Practitioners should adopt an integrated service delivery process. This holistic approach to the wealth management process should consider the entirety of the clients’ situation and their best interest. The execution should reflect this live philosophy. Principle 6 Practitioners should adopt a disciplined investment process. The practicing institutions should establish the well-documented investment strategy, develop and maintain the investment policy statements. The investment committee should be set up for supervising and monitoring the investment. © Association of Private Bankers in Greater China Region
  • 3. Principle 7 Practitioners should maintain a diversified menu or platform of investment products. The practicing institutions should get the access to a broad range of investment product, asset management services, financing solution and diversified asset classes. Investment Management Principle 8 Each investment portfolio shall be diversified as completely as practical. There should be diversification of asset classes, investment managers, investment style, currencies, banking and brokerage exposure, and geopolitical risks. Principle 9 Every portfolio shall have an investment Policy statement, and every manager shall have a clearly articulated mandate; and the investment Policy statement and mandate shall be monitored. Principle 10 Any investment portfolio shall be designed taking into account the assets, objectives, needs, and character of the wealth owner and/or beneficiary; and should be monitored with those in mind; and a Foundation shall have a process to determine whether the investment program reflects the values of its mission and its philanthropic grant program. Principle 11 There shall be clear, disciplined, and objective process for selecting, monitoring, removing, and replacing investment managers, custodians, banks, trade execution, accounting, and other professionals. Principle 12 Any investment manager or specific fund to be used shall have a strategy and style which can be easily understood and explained to others by the Wealth owners and their beneficiaries or by one of the trustees, directors, or staff members of the Trust, Foundation, or Family Office. If no one other than the Investment Manager or the fund representative is able to explain the strategy and style, the manager or fund shall not be used. Principle 13 Special scrutiny and limitations should be applied to any Investment Manager who does not offer complete transparency, or whose portfolio is not liquid. Such investments are not prohibited, but should be limited in proportion to total portfolio investments. Principle 14 Custody of assets, accounting for assets, and investment management services shall each be performed independently and separately. © Association of Private Bankers in Greater China Region
  • 4. Oversight and Monitoring Principle 15 The wealth owners and beneficiaries, the Trustees of a Trust, or the Directors of a Foundation shall articulate purposes, goals, expectations and risk tolerance with respect to the Wealth; and shall be ultimately responsible for maintaining the currency of that articulation. Principle 16 With respect to a Family Office, a Trust, or a Foundation; the governance structure together with various governance roles and responsibilities shall be clearly set forth and shall include provision for the communication of those roles and responsibilities and assurance that they are understood and accepted. Principle 17 Any Trust or Foundation and any Trustee or Director shall adhere to best fiduciary practices; and there shall be established process for monitoring the discharge of fiduciary duties by the Trust, Foundation, a Trustee, or a Director. Principle 18 Succession shall be set out where possible and shall be considered. For the Wealth owners and their beneficiaries, provisions shall be in existence for disposition of assets and management of affairs from and after death or in the event of incapacity. For the Family Office, Trust, or Foundation; provision shall be made for succession of governance and management. Principle 19 Practitioners should establish a process for reviewing the governance mechanism, the work policies and procedures. There shall be a method for managing and monitoring internal and external resources. Principle 20 Practitioners should maintain comprehensive financial reporting to enable clients to understand their consolidated and latest financial position. Principle 21 Practitioners should comply with all regulatory and financial requirements. The practicing institutions should be able to demonstrate the evidence of compliance with regulatory agencies and reliance on routine internal control procedures, such as financial, security and technology audits. © Association of Private Bankers in Greater China Region
  • 5. Principle 22 Practitioners should develop their robust technology platform. The practicing should hold reliable hardware and software systems that support the complex needs of multi- generational wealth owners and their beneficiaries. Principle 23 Practitioners should enable full transparency of fees, commission and expenses. Full disclosure and clear explanation must be offered to the wealth owners and their beneficiaries prior to the execution and the disclosure should be arranged on an on-going basis. Principle 24 Practitioners should maintain an equitable policy where the compensation and fees paid to staff, directors, and governors of Family Offices, Foundations, or Boards shall not be calculated on the basis of “investment return” of shorter duration than five years. Any salary, bonus, or fee must be fully disclosed as to its amount and its calculation. Any direct or indirect payment to or for staff or governors other than a payment designated salary, bonus, or fee (or similar designation) is discouraged. Principle 25 Practitioners should maintain a staff dealing policy where the self-dealing by staff, trustees, or directors of any Family Office, Trust, or Foundation is strictly prohibited. Investment portfolios of these parties shall be subject to strict disclosure rules which ensure compliance with the prohibition against self-dealing. Any grant or payment to any agency or company in which such a party has any interest whatsoever should clearly reflect that interest in the deliberation relating to that grant or payment. © Association of Private Bankers in Greater China Region