In order to prevent and resolve risks and ensure that business operations are in line with the company's development plan, the company establishes an organizational mechanism, uses management methods, and implements operating procedures and control measures to form a system based on full consideration of the internal and external environment.

1. Internal environment (elements)

2. Goal setting

3.Identification of matters

4. Risk assessment

5. Risk response

6. Control activities

7.Information and communication

8. Behavior monitoring

Internal control should include the company's various businesses, departments or institutions, and personnel at all levels, and cover all aspects of decision-making, execution, supervision, feedback, etc.

Internal control must emphasize efficiency and effectiveness, and all control systems must be implemented

The responsibilities of each agency, department and position of the fund manager should remain relatively independent

The operations of fund assets, free assets and other assets should be separated

The establishment of internal departments and positions of fund managers should have clear powers and responsibilities and mutual checks and balances.

Achieve the best internal control effect with reasonable cost control

Internal control mechanism, referred to as internal control mechanism, refers to the company's internal organizational structure and their mutual operational constraints. That is, in order to achieve planned goals and prevent and reduce risks, an enterprise organization involves all employees, intervenes and monitors the internal organizational business processes throughout the process, adopts power distribution and mutual checks and balances, and develops a systematic and institutional system. Guaranteed operation process.

First, employee self-discipline

The second is inspection and supervision by supervisors at all levels of the department

The third is the supervision and control of various departments and businesses by the general manager of the company and the inspection and audit department led by him.

The fourth is the inspection, supervision, control and guidance of the audit committee and the inspector general under the leadership of the board of directors

NOTE: There is no regulator check as the regulator is external

(1) In the establishment of internal control institutions, there must be no tendency to focus on immediate commercial profits and not pay attention to the establishment of full-time internal control institutions.

(2) In the establishment of internal control systems, there must be no tendency to focus on the establishment of internal management systems and not pay attention to the establishment of "firewall" systems for internal core departments.

(3) In the implementation of the internal control system, there must be no tendency to focus on the control of non-recurring events and not on the control of recurring events.

(4) In terms of internal control supervision, there should be no tendency to focus on procedural supervision and not pay attention to the supervision of "insiders".

Including business philosophy and internal control culture, corporate governance structure, organizational structure, and employee moral quality

Managers should establish a scientific and rigorous risk assessment system to identify, evaluate and analyze the company's internal and external risks, and prevent and resolve risks in a timely manner.

Fund managers can control the operation of business activities through authorized controls. Authorization control should run through the entire company's business activities.

Fund managers should maintain smooth information communication channels and establish a clear reporting system.

Internal Control Program

basic management system

Department business regulations

(1) Principles of legality and compliance

(2) Principle of comprehensiveness

(3) Principle of prudence

(4) Principle of timeliness

Note: There is no commercial principle

Note: There are no performance reviews

Note: There is no position setting

(1) Research work should remain independent and objective.

(2) Establish strict research work processes and form scientific and effective research methods.

(3) Establish an alternative database system for investment objects. The research department shall establish and maintain an alternative database based on sufficient research in accordance with the requirements of the fund contract.

(4) Establish a business communication system for research and investment and maintain smooth communication channels.

(5) Establish a research report quality evaluation system.

(1) Investment decisions should strictly abide by the relevant provisions of laws and regulations

(2) Improve the investment decision-making authorization system, clearly define investment authority, strictly abide by investment restrictions, and prevent ultra vires decision-making.

(3) Investment decisions should have sufficient investment basis, and important investments should be supported by detailed research reports and risk analysis, as well as decision-making records.

(4) Establish an investment risk assessment and management system to make investment decisions within the set risk authority.

(5) Establish a scientific investment management performance evaluation system, including investment portfolio status, compliance with fund product characteristics and decision-making procedures, fund performance analysis, etc.

(1) A centralized trading system is implemented, and fund managers are not allowed to directly issue investment instructions to traders or conduct transactions directly.

(2) The company should establish a transaction monitoring system, early warning system and transaction feedback system, and improve relevant safety facilities

(3) Investment instructions must be reviewed and approved and executed only after they are confirmed to be legal, compliant and complete.

(4) The company should implement a fair transaction allocation system to ensure that the interests of different investors can be treated fairly

(5) Establish a complete transaction record system, and daily investment portfolio lists should be checked in a timely manner and archived for safekeeping

(6) Establish a scientific trading performance evaluation system

Special transactions such as over-the-counter transactions and offline subscriptions should formulate corresponding processes and rules based on the principles of internal control.

(1) A voucher system should be established to ensure that economic transactions are correctly recorded and economic responsibilities are clarified through a series of voucher management systems such as voucher design, login, delivery, and archiving.

(2) An accounting organization and accounting processing system should be established, accounting books should be correctly set up, and accounting procedures should be effectively controlled.

(3) A review system should be established to prevent accounting errors through accounting review and business review.

(4) Reasonable valuation methods and scientific valuation procedures should be adopted to fairly reflect the value of the securities invested by the fund at the valuation time point.

(5) Fund liquidation and delivery work should be standardized, fund liquidation should be completed promptly and accurately within the scope of authorization, and the safety of fund assets should be ensured.

(6) Strict cost control and performance appraisal systems should be established to strengthen accounting supervision before, during and after the event.

(7) A complete accounting file storage and financial handover system should be developed,