its custody of clients’ assets for at least five years. Such information and documents shall be stored, during the first two years, in a manner that enables prompt access for review by the SEC Office
and documents shall be stored, during the first two years, in a manner that enables prompt access for review by the SEC Office upon request. Chapter 3 Custody of Clients’ Assets Clause 17 A securities
temporary closure of hotels under management agreements depends on the decision of the hotel owners. • Postponed the new hotel opening and prepared team for prompt opening in accordance with the COVID-19
SEC Office shall take into consideration the following factors: (1) involvement role and behaviors of the person under consideration; (2) sanction already imposed on such person; (3) impact on or damage
for sustainability of businesses and society as a whole which are a part of normal business operation; 10.2 additional practice guideline concerning prevention of involvement in corruption activities
, competition policy, etc., to ensure fairness, environmental friendliness, non-involvement in corruption and stakeholders’ rights protection. Describe the actions taken to comply with the environmental
; (5) keep evidence of the performance as specified in subclauses (1), (2), (3) and (4) in the manner of prompt demonstration to the SEC Office as requested. Chapter 7 Acceptance of Trading Orders of
III whereas the limited partners are essentially financial investors in SSG III who have no involvement with the operations of SSG III and do not have any relationship with the Company which would led