The principal activities of SMTHK are provision of securities, investment advisory and fund management services. SMTHK is licensed under the Hong Kong Securities and Futures Ordinance to conduct activities under the licenses of Type 1, 4 and 9.

SMTHK shall only provide services to professional investors. The term "professional investor" is as defined in the Securities and Futures Ordinance and its subsidiary legislation.


Conflict of Interests

SMTHK has implemented and maintained a written Code of Conduct Policy to control and manage relevant conflicts of interest with clients and other counterparties.

SMTHK has procedures and measures in place that are designed to ensure that the services provided and activities conducted are carried out with integrity and an appropriate degree of independence to protect the interests of clients. These procedures and measures include the prevention or control of information exchange, appropriate organizational structures, supervisory roles, etc.


Personal Account Dealing

SMTHK has controls in place on personal account dealing with the objectives to prevent:

  • conflicts of interest between the SMTHK, its employees and its customers
  • employees from misusing their job function or position to acquire personal economic benefits
  • damage to the reputation of SMTHK resulting from unethical personal account dealing by its employees
  • employees from violating applicable law when carrying out personal account dealings

SMTHK has implemented its controls on personal account dealing in the following areas:

  • maintaining and reporting of trading accounts
  • trading activities by employees
  • avoidance of conflict of interest
  • trading activities considered as market abuse, in particular insider dealing
  • specific process requirements on pre-approval for employees


Offering and Accepting Gift and Entertainment

As a general rule, SMTHK staff should refrain from accepting any benefit offered by customers, counterparties and third parties whether or not it is accompanied by a request to do or forbear to do something in relation to their affairs with SMTHK.

However, it is recognized that the exchange of business courtesies, such as modest gifts, hospitality, and entertainment (including meals, invitations to attend promotional events or corporate functions) particularly during festive periods is customary and legitimate to create goodwill, and/or strengthen business and commercial relationships. Such courtesies are allowed if they are not lavish, appropriate, and reasonable in the light of accepted business practices of the relevant businesses in which SMTHK operates and is not intended to improperly influence the decisions of the person involved. In this connection, for the avoidance of doubt, SMTHK staff need to follow relevant application and approval process to obtain relevant pre-approvals before giving or receiving any form of gift or entertainment.


Complaint Handling

SMTHK has implemented complaint handling procedures that require all complaints must be reported in writing. The complaint must be responded with written acknowledgement of the receipt of the complaint within 3 business days and any complaint received must be resolved within 30 days.

The complaint handling procedures are in place to ensure the proper handling of complaints from clients, all complaints are handled fairly, consistently and promptly, including investigation by an independent person. Proper records are maintained including a copy of the written complaint, SMTHK’s response and any action taken.


Marketing Disclaimer

SMTHK’s sales and marketing activities are conducted in accordance with the regulatory license requirements and conditions imposed on SMTHK. License requirements do not impose any restrictions on the domicile of funds to be distributed.

SMTHK shall only provide services to professional investors. The term "professional investor" is as defined in the Securities and Futures Ordinance and its subsidiary legislation.

For Type 1 regulated activity, SMTHK shall only carry on the business of dealing in collective investment schemes. The terms "collective investment scheme" and "dealing" are as defined under the Securities and Futures Ordinance.