From the perspective of the operation process of fund managers, irregularities in major aspects such as fund establishment, fund investment management, and fund information disclosure will bring risk losses and reputational damage. Strengthening fund compliance management is of very important practical significance.

Compliance management can help fund managers control the risk of violations, reduce losses caused by violation penalties and potential losses due to reputational risks. Strengthening compliance management has very long-term strategic significance not only for fund managers but also for the fund industry.

Establish and improve the compliance risk management system for fund managers, achieve effective identification and management of compliance risks, promote the construction of a comprehensive risk management system for fund managers, and ensure that fund managers operate in compliance with laws and regulations.

The compliance department and the inspector general should have independent status in the organizational system of the fund company

Compliance management should be independent of other business operations

This means that compliance personnel should objectively evaluate the facts of violations in accordance with relevant laws and regulations to avoid violations involving collusion between compliance personnel themselves and business personnel.

This means that compliance personnel should adhere to unified standards to assess and report the risk of non-compliance when conducting inspections on business departments.

It means that compliance personnel should be familiar with the business system, understand the operating procedures of various businesses of the fund manager, and accurately understand and grasp the provisions and changing trends of laws and regulations.

It means that compliance personnel should correctly handle the relationship with other departments of the company and regulatory authorities, strive to form the company's compliance synergy, and avoid internal consumption.

(1) Continue to pay attention to the latest developments in laws, regulations and standards, correctly understand the provisions and spirit of laws, regulations and standards, accurately grasp the impact of laws, regulations and standards on fund operations, and provide senior management with compliance advice in a timely manner.

(2) Develop and implement a risk-based compliance management plan, including the implementation and evaluation of specific policies and procedures, compliance risk assessment, compliance testing, compliance training and education, etc.

(3) Review and evaluate the compliance of various policies, procedures and operating guidelines of the fund manager, organize, coordinate and urge various business lines and internal control departments to sort out and revise various policies, procedures and operating guidelines to ensure that all Policies, procedures and operational guidelines comply with laws, rules and guidelines.

(4) Assist relevant training and education departments to conduct compliance training for employees

(5) Organize the development of compliance management procedures, compliance manuals, employee codes of conduct and other compliance guidelines, and evaluate the appropriateness of compliance management procedures and compliance guidelines, and provide guidance for employees to properly implement laws, rules and guidelines.

(6) Proactively identify and assess compliance risks related to the fund manager’s business activities

(7) Collect and screen data that may indicate potential compliance issues

(8) Implement adequate and representative compliance risk assessment and testing

(9) Maintain daily working contact with regulatory agencies

(1) Notify the business organization to stop its illegal activities.

(2) Investigate the company's financial status at any time, review accounting documents, and have the right to request the board of directors to provide information to it.

(3) Review various statements prepared by the board of directors and provided to the shareholders' meeting, and report the review opinions to the shareholders' meeting.

(4) When the supervisory board deems it necessary, usually when major problems arise in the company, it may propose to convene a shareholders' meeting.

(1) When a lawsuit occurs between the company and directors, unless otherwise provided by law, the board of supervisors will handle relevant legal matters on behalf of the company as a party to the lawsuit.

(2) When the directors themselves or others have negotiations with the company, the board of supervisors will negotiate with the directors on behalf of the company.

(3) When supervisors investigate the company's business and financial status and review accounting statements, they have the right to entrust lawyers, accountants or other third-party personnel on behalf of the company to assist in the investigation.

(1) Check the company’s finances.

(2) Supervise the performance of compliance management responsibilities by the company’s directors and senior managers.

(3) Propose the removal of directors and senior managers who have primary responsibility or leadership responsibility for the occurrence of major compliance risks.

(4) Propose to convene an extraordinary shareholders’ meeting.

(5) Attend board of directors meetings.

(6) Other powers stipulated in the company's articles of association.

The Board of Supervisors shall hold at least one meeting every year. Meetings of the Board of Supervisors shall be held when all supervisors are present, and each supervisor shall have one vote. Resolutions of the board of supervisors must be approved by at least half of the supervisors' votes.

(1) Funds and companies commit illegal acts

(2) Funds and companies have major operating risks or hidden dangers

(3) Other circumstances that the Inspector General deems necessary to report according to law

(4) Other situations specified by the China Securities Regulatory Commission

Note: Excludes significant fluctuations in net worth

①Establish and improve the organizational structure of compliance management

②Report and rectify violations in a timely manner when discovering violations of laws and regulations, and implement accountability

③Other requirements determined by the company’s articles of association or the board of directors

All employees of the fund manager must be loyal, honest and fair when engaging in business activities, and demand themselves to the highest standards.

(1) Regularly communicate regulatory requirements, create a company compliance culture, and improve employee compliance awareness.

(2) Review external contracts signed by each business department, control risks, and prevent commercial bribery; review systems revised by business departments; be responsible for reviewing various types of information disclosed by the company to the outside world.

(3) In accordance with the requirements of laws, regulations and company systems, inspect and evaluate the compliance of various activities in fund issuance and daily operations (sales, investment, operations) to prevent operational risks.

(4) Sort out and integrate various laws, regulations, rules and regulations, and conduct compliance training.

(5) Participate in the reengineering of the fund manager’s organizational structure and business processes, and provide compliance support for new products.

(6) Carry out legal consultation and assist external lawyers in jointly handling the company's legal disputes and complaints.

First, the management of the fund manager pays sufficient attention to the construction of compliance culture.

The second is to strengthen information exchange and good interaction between the compliance management department and the business department, supervision and audit department and other departments to achieve resource sharing.

The third is to effectively implement the compliance assessment mechanism. Integrate compliance assessment results with employee performance work and senior management competitive assessment.

Fourth, the fund promotes the concept of compliance for all employees and strengthens compliance cultural and ideological education.

The fund manager's senior management is responsible for developing a written compliance policy.

content include

The company's managers are responsible for implementing compliance policies, ensuring that appropriate corrective measures are taken in a timely manner when violations are discovered, and that those responsible for violations are held accountable accordingly.

Each business unit should follow the company's compliance policy

The Compliance and Risk Control Department is the daily management department for compliance risks.

(1) Whether the company operates independently;

(2) Construction and implementation of fair trade system.

(3) Execution of major related transactions.

(4) Whether the securities investment activity management system of the company’s employees, especially investment and research personnel, their spouses, and interested parties is sound and effective, and whether there are any situations where undisclosed information of the fund is used to obtain benefits.

(5) The basis for the fund company’s investment decision-making, and whether the company’s regulations and investment decision-making process have been breached.

(6) Whether the risk management system covers different risk control links;

Note: Don’t care about the company’s profits, only care about survival

① Laws and regulations related to the fund industry formulated and promulgated by the state

②The company’s internal employee codes and compliance systems for various businesses

③Case warning education

The content covers risk management guidelines for fund managers, risk management experience, internal control evaluation of fund companies and subsidiaries, explanations of relevant cases, etc. It also includes understanding the compliance requirements of company management and management compliance requirements.

Risks of penalties and losses arising from violations of relevant laws, regulations and the company's internal rules and regulations by fund managers' investment business personnel

The fund manager failed to establish and manage a candidate library of investment objects in accordance with regulations and fund contracts;

The fund manager uses fund assets to seek benefits for third parties other than fund unit holders;

Use other undisclosed information other than inside information obtained due to convenience of position to engage in or expressly or imply that others engage in relevant trading activities, and use fund assets to engage in manipulation of securities prices and other improper securities trading activities;

Treat different investment portfolios unfairly and transfer benefits between different investment portfolios directly or through transaction arrangements with third parties;

Fund income distribution violations and dishonesty, company internal controls are weak, and employees fail to perform their duties diligently, leading to fund operation errors and other risk events.

(1) Establish an effective investment process and investment authorization system.

(2) Self-control investment compliance risks by setting risk parameters in the trading system. Investment compliance restrictions that cannot be automatically controlled by the trading system should be controlled through measures such as strengthening manual monitoring and multi-person review.

(3) Focus on monitoring whether there are insider trading, benefit transfer and unfair treatment of different investors in the investment portfolio.

(4) Define abnormal transaction behavior and strengthen the tracking, monitoring and analysis of abnormal transactions.

(5) Track and evaluate the implementation of compliance indicators such as investment ratio and investment scope on a daily basis to ensure that the compliance indicators of the investment portfolio comply with laws, regulations and fund contracts.

(6) Pay attention to the risks inherent in valuation policies and valuation methods.

In the process of information disclosure, fund managers violate relevant laws, regulations and company rules, mislead fund investors or cause a bad reputation to the fund industry, and are at risk of being punished and losing reputation.

(1) Establish an information disclosure risk responsibility system, assign the information that should be disclosed to relevant departments, and make it clear that they are fully responsible for the authenticity, accuracy, completeness and timeliness of the information provided.

(2) Necessary compliance review should be conducted before information disclosure.

Fund managers who violate relevant laws, regulations and internal company rules, violate the principle of fair transactions, and use accounts with different identities to conduct illegal fund transfers are subject to the risk of relevant penalties and losses.

(1) Establish a risk-oriented anti-money laundering prevention and control system and rationally allocate resources.

(2) Develop a strict and effective account opening process, standardize the identification of customers’ identity authentication and authorization qualifications, and preserve the identity certification materials of relevant customers.

(3) Strictly monitor the modification of customer core information, non-transaction transfers and inter-account fund transfers.

(4) Strictly abide by the fund clearing system and control and monitor cash payments.

(5) Establish a customer risk identification and suspicious transaction analysis mechanism that is consistent with industry characteristics.