incentive systems) with regard to its partners and professional staff are designed to demonstrate the firm’s overriding commitment to quality; · The firm devotes sufficient resources for the development

regardless of textual matters, pictures, sounds, signs or any symbol, and whether making through medias or any device. “ sale promotion ” means providing incentive gifts, rights or other benefits to a client

providing incentive gifts, rights or other benefits to a client in order to stimulate or reward the client to immediately [i] use offered services or [ii] invest in capital market products presented by the