Overview
A. Advisory Business and Ownership
Neo-Criterion Capital Limited. (“NCC”, the “Firm”) is a company incorporated in Hong Kong
on December 20th, 2013, and acts as the investment manager to the NCC China A-Share
Master Fund and the NCC China A-Share Offshore Feeder Fund (collectively, the “Fund”).
The Fund is incorporated in the Cayman Islands as an exempted company with limited
liability. The Firm is wholly owned by Neo-Criterion Cayman Management, which is owned
by KY Capital Holdings Limited, which is majority own by Ji Liu.
B. Services Offered
The principal activity of NCC is to provide discretionary investment management services
including investment advisory services, specializing in China and Greater China equities
investments.
The Firm provides investment management services to the Fund based on specific
investment objectives and strategies. The Fund’s offering documents (as amended and
supplemented from time to time) set forth the investment guidelines and/or the types of
investments in which the assets of the Fund may invest.
In addition to the services provided to the Fund, NCC, together with its affiliate, Neo-
Criterion Capital Limited, provides investment management services to separately managed
accounts
(“SMA”).
C. Ability to Tailor Services and Impose Restrictions
The investment objectives and strategy for the Fund are described in the Fund’s offering
documents. NCC provides investment management services to the Fund based on the
specific investment objectives and strategies of the Fund and not individually to investors
in the Fund (the “Investors”). Since the Firm does not provide tailored advice to the Fund’s
Investors, such investors should consider whether the Fund’s investment strategies are in
line with their risk tolerance. The Fund may from time to time enter into side letter
agreements or other similar agreements (“Side Letters”) providing investors with additional
and/or different rights and benefits. Directors may also reduce the minimum subscription
amounts in consultations with the Firm, subject to requirements by applicable laws.
D. Client Assets
As of December 31st, 2023, NCC together with its affiliate had approximately USD
$35,864,223 of regulatory assets under management on a discretionary basis.
The performance of the Fund will be reported, fees will be calculated, and all subscriptions
and redemptions will be transacted, in US dollars (US$).
Base currency of the SMA portfolios can be in currencies other than US dollars.