Springs Capital (Hong Kong) Limited

Event Detail: EACH OF THE FUND AND MR. ZHAO (COLLECTIVELY, THE "DEFENDANTS") WAS CHARGED WITH SIX COUNTS (THE "CHARGES") OF VIOLATIONS (THE "VIOLATIONS") OF SECTION 325(1)(A) AND RELATED SECTIONS OF THE SECURITIES AND FUTURES ORDINANCE, CAP. 571, A MISDEMEANOR, FOR FAILING TO PERFORM A DUTY OF DISCLOSURE IN CONNECTION WITH PURCHASES OF SHARES OF A CERTAIN COMPANY (THE "COMPANY") ON THE STOCK EXCHANGE OF HONG KONG LIMITED (THE "EXCHANGE"). EACH DEFENDANT PLED GUILTY TO EACH CHARGE. Status: Final Disposition: EACH DEFENDANT PLED GUILTY TO ALL CHARGES ON APRIL 14, 2016 AND WAS FINED THE EQUIVALENT IN HONG KONG DOLLARS OF US$516 PER COUNT, FOR AN AGGREGATE FINE OF THE EQUIVALENT IN HONG KONG DOLLARS OF US$3,096 EACH (THE "FINES"). THE FINES WERE PAID APRIL 22, 2016. Summary: DUE TO A TECHNICAL OVERSIGHT, THE MANAGER INADVERTENTLY CAUSED VIOLATIONS OF THE SUBSTANTIAL HOLDINGS DISCLOSURE RULES APPLICABLE TO INVESTMENTS BY THE FUND IN SHARES OF THE COMPANY FOR CERTAIN TRADES WHICH TOOK PLACE BETWEEN SEPTEMBER 2009 AND MAY 2010. THE MANAGER SUBSEQUENTLY DETECTED THE TECHNICAL OVERSIGHT AND THE VIOLATIONS, CORRECTED ITS TECHNICAL OVERSIGHT, SELF-REPORTED THE VIOLATIONS TO THE EXCHANGE AND THE HONG KONG SECURITIES AND FUTURES COMMISSION (THE "SFC"), AND FILED THE REQUIRED DISCLOSURE REPORTS ON A LATE BASIS IN AUGUST 2013. SUBSEQUENTLY, THE SFC INVESTIGATED THE VIOLATIONS AND BROUGHT CHARGES AGAINST THE DEFENDANTS. BECAUSE THE DISCLOSURE RULES ARE PART OF THE CRIMINAL STATUTES IN HONG KONG, THE SFC BROUGHT CHARGES IN THE COURT. AFTER THE DEFENDANTS PAID THE FINES IN FULL, ON APRIL 29, 2016, THE SFC INFORMED THE MANAGER THAT IT HAD CONCLUDED ITS INVESTIGATION OF THE VIOLATIONS AND, ON THE BASIS OF THE EVIDENCE PRESENTED BEFORE IT, WAS NOT PRESENTLY RECOMMENDING ANY ENFORCEMENT ACTION TO BE TAKEN AGAINST THE MANAGER. SPRINGS CAPITAL (HONG KONG) LIMITED WAS NOT SUBJECT TO ANY INVESTIGATION OR PENALTY IN CONNECTION THEREWITH.