Legal Disclosures

ALLIANCE CHUAN GROUP (BVI) LIMITED — LEGAL DISCLOSURES

This Legal Disclosures section (this "Disclosure") is published by Alliance CHUAN Group (BVI) Limited and its affiliates (collectively, "CHUAN," the "Company," "we," "us," or "our") in connection with the operation of the websites located at www.capitalchuan.com and www.chuanx.xyz (collectively, the "Sites") and the investment management activities carried on by CHUAN and its affiliates.

This Disclosure sets out the regulatory frameworks, codes, and policies that CHUAN and its affiliates observe in respect of their investment management business, including applicable Hong Kong, British Virgin Islands, and international standards, to the extent such frameworks apply to CHUAN in light of its actual business operations. For the avoidance of doubt, CHUAN does not currently conduct investment business in the United States, the United Kingdom, the European Economic Area, Japan, Luxembourg, or any other jurisdiction, and the regulatory disclosures applicable to such jurisdictions (including the U.S. NYAG Public Pension Fund Reform Code, the UK Stewardship Code, the EU Shareholder Rights Directive II, the UK Modern Slavery Act 2015, the Financial Instruments and Exchange Act of Japan, the EU Sustainable Finance Disclosure Regulation, and the Luxembourg Commission de Surveillance du Secteur Financier rules) are not applicable to CHUAN and are therefore not reproduced in this Disclosure.

Should CHUAN in the future commence investment business in any additional jurisdiction, or become subject to any additional regulatory framework, this Disclosure will be updated accordingly to reflect the relevant regulatory requirements.

1. Regulatory Status and Authorisation

CHUAN Group (BVI) Limited is a company incorporated in the British Virgin Islands, registered under the BVI Business Companies Act (as revised), and authorised to carry on business from its principal place of business in Hong Kong. To the extent CHUAN or any of its affiliates carry on any regulated activity (including without limitation fund management, advisory, dealing, or arranging activities) in Hong Kong, such activity is, or will be, conducted under the relevant licence or registration issued by the Hong Kong Securities and Futures Commission (the "SFC") or such other regulatory authority as may be applicable, in accordance with the Securities and Futures Ordinance (Cap. 571) of Hong Kong (the "SFO").

CHUAN's investment funds are typically organised as BVI-registered business companies, BVI-registered limited partnerships, Cayman Islands exempted companies or limited partnerships, or such other corporate or partnership vehicles as may be appropriate to the strategy and the jurisdictions of the underlying investors. The fund vehicles themselves are not subject to SFC authorisation unless expressly stated in the relevant offering documents, and interests in such vehicles are offered on a private placement basis only to qualifying investors in accordance with applicable law.

2. Restrictions on Marketing and Sale

Interests in any investment vehicle managed or sponsored by CHUAN or any of its affiliates (each, a "Fund") are offered and sold solely on a private placement basis to qualified, professional, sophisticated, and accredited investors within the meaning of the applicable securities laws of the jurisdictions in which such investors reside. Interests in a Fund are not, and will not be, offered or sold to the general public, and are not, and will not be, registered under the United States Securities Act of 1933, as amended, the United States Investment Company Act of 1940, as amended, or any other applicable securities laws of the United States, the United Kingdom, the European Economic Area, Japan, or any other jurisdiction in which such registration, qualification, or licensing would be required.

In particular:

• United States. CHUAN does not market, offer, or sell interests in any Fund, or engage in any investment business, in the United States, and does not hold itself out as being engaged in any securities business in the United States.

• European Economic Area and United Kingdom. CHUAN does not market, offer, or sell interests in any Fund, or engage in any investment business, in the European Economic Area, the United Kingdom, Switzerland, or any other European jurisdiction, and does not hold itself out as being engaged in any securities business in such jurisdictions.

• Japan. CHUAN does not market, offer, or sell interests in any Fund, or engage in any investment business, in Japan, and does not hold itself out as being engaged in any securities business in Japan.

• Other Restricted Jurisdictions. CHUAN does not market, offer, or sell interests in any Fund, or engage in any investment business, in any other jurisdiction in which such activities would require registration, qualification, or licensing.

3. Anti-Money Laundering and Counter-Terrorist Financing

CHUAN and its affiliates are committed to complying with all applicable anti-money-laundering and counter-terrorist-financing ("AML/CFT") laws and regulations in the jurisdictions in which they operate, including without limitation:

• Hong Kong. The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) of Hong Kong and the relevant guidelines issued by the Hong Kong Monetary Authority, the Securities and Futures Commission, and the Insurance Authority (the "HK AMLO");

• British Virgin Islands. The Anti-Money Laundering Regulations (as revised) of the British Virgin Islands and the related guidelines issued by the British Virgin Islands Financial Services Commission;

• Other Jurisdictions. Such other AML/CFT laws and regulations as may apply to CHUAN or its affiliates from time to time in respect of the jurisdictions in which they operate or in which investors in a Fund are located.

In furtherance of its AML/CFT obligations, CHUAN conducts appropriate customer due diligence (including identification, verification, and ongoing monitoring) in respect of all investors, beneficial owners, and other relevant parties, suspends or terminates any relationship where it is unable to satisfy itself as to the identity, source of funds, or legitimacy of any prospective investor, and reports suspicious transactions to the relevant authorities in accordance with applicable law.

4. Tax Disclosures

The information set out in this Section 4 is provided for general information only and does not constitute tax, legal, or accounting advice. Investors should consult their own tax, legal, and accounting advisors regarding the tax consequences of investing in any Fund in light of their particular circumstances.

4.1 Common Reporting Standard (CRS)

The Common Reporting Standard ("CRS") developed by the Organisation for Economic Co-operation and Development ("OECD") has been implemented in Hong Kong under the Inland Revenue (Amendment) (Tax Concessions) Ordinance 2016 and in the British Virgin Islands under the BVI Business Tax (Economic Substance) Act and related regulations. CHUAN and the Funds are required to collect certain tax information from investors and to report certain information concerning investors and their accounts to the relevant tax authorities, which may thereafter exchange such information with the tax authorities of other participating jurisdictions in accordance with CRS.

4.2 U.S. Foreign Account Tax Compliance Act (FATCA)

The United States Foreign Account Tax Compliance Act ("FATCA") and the intergovernmental agreement (or "IGA") entered into between the United States and the British Virgin Islands (or such other IGA as may be applicable to a Fund) require financial institutions to identify and report information on certain U.S. accounts and to withhold on certain payments to non-compliant foreign financial institutions and other persons. CHUAN and the Funds intend to comply with their respective obligations under FATCA and the applicable IGA. Investors may be required to provide certain tax information and documentation, and any failure to do so may result in withholding, redemption, or other consequences as set forth in the relevant subscription documents.

4.3 BVI Tax Status

The British Virgin Islands does not currently levy income tax, corporation tax, capital gains tax, or withholding tax on companies incorporated in the BVI or on holders of BVI company shares, subject to the application of the BVI Economic Substance Act and any other applicable BVI tax legislation. CHUAN Group (BVI) Limited is incorporated in the BVI and is not currently subject to BVI income tax on its investment income, subject to the application of the BVI Economic Substance Act and any other applicable BVI tax legislation. CHUAN Group (BVI) Limited will, where required, comply with its economic substance obligations in the BVI.

4.4 Hong Kong Tax

Profits tax, salaries tax, and property tax are imposed under the Inland Revenue Ordinance (Cap. 112) of Hong Kong. CHUAN Group (BVI) Limited is not, as of the date of this Disclosure, subject to Hong Kong profits tax on its investment income derived from sources outside Hong Kong, subject to the application of the Inland Revenue Ordinance and any other applicable Hong Kong tax legislation. Investors who are tax residents of Hong Kong should consult their own tax advisors regarding the Hong Kong tax consequences of investing in any Fund.

5. Conflicts of Interest

CHUAN and its affiliates have adopted and maintain a written Conflicts of Interest Policy (the "Conflicts Policy") that identifies the categories of conflicts of interest that may arise in the course of CHUAN's business and sets out the procedures and controls that CHUAN has implemented to identify, manage, prevent, and disclose such conflicts. Categories of conflicts addressed by the Conflicts Policy include, without limitation:

• Fund-Level Conflicts. Conflicts between CHUAN, its affiliates, and any Fund (including allocation of investment opportunities, allocation of expenses, and side-by-side management of multiple accounts);

• Inter-Account Conflicts. Conflicts between a Fund and other accounts managed by CHUAN or its affiliates (including conflicts over the allocation of investment opportunities and the allocation of aggregated orders);

• Investor-Level Conflicts. Conflicts between investors in a Fund and other persons (including service providers, counterparties, and other investors);

• Personal Conflicts. Conflicts between employees, officers, and directors of CHUAN or its affiliates and CHUAN, the Funds, or the investors (including personal trading, gifts and entertainment, and outside business activities).

A copy of the Conflicts Policy (or a summary thereof) is available to investors and prospective investors upon request to operations@alliancechuan.com.

6. Complaints Handling

CHUAN is committed to handling complaints from investors, prospective investors, and other persons in a fair, prompt, and transparent manner. CHUAN has adopted and maintains a written Complaints Handling Policy (the "Complaints Policy") that sets out the procedures and channels for submitting complaints, the timeframes within which CHUAN will acknowledge and respond to complaints, and the escalation paths available where a complainant is not satisfied with CHUAN's response.

Complaints may be submitted to CHUAN in writing at Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong, Attn: Compliance Officer, or by email to operations@alliancechuan.com. CHUAN will acknowledge receipt of a complaint within five (5) Hong Kong business days and will use reasonable endeavours to provide a substantive response within thirty (30) calendar days.

If a complainant is not satisfied with CHUAN's response, the complainant may elect to escalate the matter to the Hong Kong Securities and Futures Commission (where CHUAN or the relevant affiliate is licensed or registered with the SFC), the Hong Kong Financial Dispute Resolution Centre, the Hong Kong Monetary Authority, or such other regulatory or dispute resolution body as may be appropriate in the circumstances.

7. Whistleblowing

CHUAN has adopted and maintains a written Whistleblowing Policy (the "Whistleblowing Policy") that provides channels for the confidential, retaliation-free reporting of suspected violations of law, regulation, or CHUAN policy by employees, officers, directors, contractors, and other persons. Reports may be submitted in writing on a confidential or anonymous basis, and CHUAN will investigate all reports in accordance with the procedures set out in the Whistleblowing Policy.

Reports may be submitted to CHUAN's Compliance Officer at Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong, Attn: Compliance Officer, or by email to operations@alliancechuan.com. Reports may also be made to the Hong Kong Securities and Futures Commission, the Hong Kong Monetary Authority, the Hong Kong Independent Commission Against Corruption, the Hong Kong Police Force, or such other regulatory or law enforcement body as may be appropriate in the circumstances.

8. Best Execution and Order Handling

CHUAN has adopted and maintains a written Best Execution Policy (the "Best Execution Policy") that sets out the procedures and controls CHUAN implements to obtain the best possible result for the Funds and other clients when executing transactions in financial instruments, taking into account the execution factors of price, costs, speed, likelihood of execution and settlement, size, nature, and any other relevant considerations.

A summary of CHUAN's Best Execution Policy is available to investors and prospective investors upon request to operations@alliancechuan.com.

9. Risk Disclosures

Investment in any Fund involves a high degree of risk and is suitable only for investors who have the financial sophistication and ability to bear the loss of their entire investment. Investors should review carefully the risk factors and conflicts of interest set forth in the relevant offering documents, subscription agreements, and constitutional documents of each Fund before making any investment decision. The principal risks include, without limitation, the following:

• Capital Loss Risk. Loss of capital, including total loss of investment;

• Liquidity Risk. Lack of liquidity, including restrictions on transfer and redemption, and the possibility that CHUAN may suspend or limit redemptions in stressed market conditions;

• Concentration Risk. Concentration of investments in particular sectors, geographies, strategies, or counterparties;

• Leverage and Derivative Risk. Exposure to leverage, derivatives, and short positions, which may amplify losses;

• Counterparty and Credit Risk. Exposure to counterparties, including brokers, custodians, prime brokers, lenders, and derivatives counterparties, and the risk of default by such counterparties;

• Operational Risk. Exposure to operational, technology, cybersecurity, legal, tax, regulatory, and reputational risks;

• Market Risk. Fluctuations in currency exchange rates, interest rates, and market prices generally;

• Regulatory and Tax Risk. Changes in legal, regulatory, fiscal, and tax regimes applicable to CHUAN, the Funds, or the investors.

The risks identified above are not exhaustive, and other risks may arise in the course of the operation of a Fund. Past performance is not a reliable indicator of future results, and forward-looking statements are subject to inherent uncertainties. Investors should not construe the contents of the Sites, this Disclosure, or any other communication from CHUAN as legal, tax, accounting, investment, or other professional advice.

10. No Investment, Tax, or Legal Advice

The information contained on the Sites and in this Disclosure is for general informational purposes only and does not constitute, and shall not be construed as, (i) an offer to sell, or a solicitation of an offer to purchase, any security, interest in a fund, or other financial instrument, (ii) investment advice, recommendation, or opinion, (iii) tax, legal, accounting, or other professional advice, or (iv) a representation that any investment is suitable or appropriate for any particular investor. Each prospective investor must make its own independent investigation and evaluation of any investment opportunity, based on its own financial circumstances and investment objectives, and must consult its own legal, tax, accounting, and other professional advisors before making any investment decision.

11. Forward-Looking Statements

Statements contained on the Sites or in any other communication from CHUAN may constitute "forward-looking statements" within the meaning of applicable securities laws. Forward-looking statements relate to future events, future performance, or the future financial condition of CHUAN or its affiliates, and reflect CHUAN's current expectations, estimates, projections, beliefs, assumptions, and subjective judgments. Forward-looking statements are not guarantees of future performance, condition, or results, and are subject to numerous risks, uncertainties, and other factors, many of which are outside CHUAN's control. Actual results and conditions may differ materially from those expressed or implied in any forward-looking statement. CHUAN undertakes no obligation to update, revise, or correct any forward-looking statement, whether as a result of new information, future events, changed circumstances, or otherwise. Each prospective investor should not rely on any forward-looking statement and should refer to CHUAN's official offering documents for a description of the risks, uncertainties, and other factors that may affect CHUAN's future performance.

12. Privacy and Data Protection

CHUAN's collection, use, disclosure, retention, and other processing of personal information is governed by CHUAN's Privacy Policy and is incorporated by reference into this Disclosure. The Privacy Policy describes the categories of personal information CHUAN collects, the purposes for which CHUAN uses and discloses personal information, the rights of individuals under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, and the contact details for CHUAN's Data Protection Coordinator.

13. Documents Available on Request

The following documents are available to investors and prospective investors upon request to operations@alliancechuan.com or at Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong

• Offering Documents. The constitutional documents and offering memoranda of any Fund;

• Financial Reports. The most recent annual report, audited financial statements, and interim reports of any Fund;

• Policies. The Privacy Policy, Conflicts of Interest Policy, Complaints Handling Policy, Whistleblowing Policy, and Best Execution Policy of CHUAN;

• Other Documents. Such other documents and information as may be required to be made available under applicable law or the constitutional documents of any Fund.

14. Changes to this Disclosure

CHUAN reserves the right, in its sole discretion, to modify, alter, or otherwise update this Disclosure at any time. CHUAN will notify investors and other relevant persons of material changes to this Disclosure by posting the revised Disclosure with an updated "Last Updated" date on the Sites. Prospective investors and other persons accessing the Sites are responsible for reviewing this Disclosure periodically to stay informed of any changes.

15. Governing Law

This Disclosure, the Sites, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them, shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region. The parties irrevocably submit to the exclusive jurisdiction of the courts of Hong Kong in respect of any dispute or claim arising out of or in connection with this Disclosure or the Sites, save that CHUAN reserves the right to seek interim or injunctive relief in any court of competent jurisdiction.

16. Contact Information

For any questions regarding this Disclosure, the Sites, or CHUAN's investment management business, please contact us at:

Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong

Email: operations@alliancechuan.com