1) Firm Description
Zeal Asset Management Limited (“ZAML”) is a wholly-owned subsidiary of Zeal Capital Limited and is a
limited liability company incorporated in Hong Kong on August 13, 2009. We are licensed by the Hong
Kong Securities and Futures Commission (the “SFC”) to conduct Dealing in Securities, Advising on
Securities and Asset Management regulated activities. These authorizations are known as “Type 1”
(Dealing in Securities), “Type 4” (Advising on Securities) and “Type 9” (Asset Management). We are also
registered with the U.S. Securities and Exchange Commission under the U.S. Investment Advisers Act of
1940 (the “Advisers Act”).
ZAML is beneficially owned by its principals, Jacky CHOI Nga Chung, Franco NGAN Wai Wah and Daniel
POON Chun Pong, through their ownership of Zeal Capital Limited (“ZCL”), which owns 100% of ZAML.
ZCL is incorporated in the Cayman Islands as an exempted company with limited liability under the
Cayman Companies Law.
ZAML, incorporated and domiciled in Hong Kong, strives to be the premier asset management company
in Asia and the “Greater China” region (meaning mainland China, Taiwan and Hong Kong), with the
objective of helping investors in Asia, Europe and U.S. to achieve attractive and enduring risk-adjusted
returns by tapping the enormous potential in this fast-growing region. The foundation of our company is
our firm commitment to value investing, original fundamental research and bottom-up stock-picking. We
make investments in companies where, in our opinion, the market has failed to properly reflect the
intrinsic value of the company for any of various reasons, such as lack of research coverage and
misunderstanding of the fundamentals. We do not attempt to follow any benchmark indices in
determining the geographical, sector or individual stock weightings.
2) Types of Advisory Services
We provide advisory services to pooled investment vehicles as well as to separately managed accounts
on a discretionary basis. In addition, we provide advisory services on a non-discretionary basis. In all
cases, the client executes an investment management agreement ("IMA") that governs their relationship
with us. We manage assets based on the criteria set forth in the IMA, including, where applicable, the
client’s stated investment objectives and restrictions.
Pooled Investment Vehicles
We currently act as the Investment Manager, meaning that we have full discretionary investment
authority and power to manage assets, for the following five funds:
a) Zeal China Fund Limited (“ZCF”)
An exempted company incorporated with limited liability in the Cayman Islands as an open-ended
investment company.
ZCF is a Greater China long-short equity fund. As a long-short equity fund, ZCF has maximum
flexibility to invest in a wide range of instruments, and may engage in short sales, margin trading,
hedging and other investment strategies. ZCF focuses on investing in companies established in
Greater China or which derive a significant proportion of their revenue from business related to
Greater China.
The shares of ZCF will only be sold to U.S. Persons who are “qualified purchasers”, as defined in
the U.S. Investment Company Act of 1940 (the “1940 Act”). Each subscriber for shares of ZCF that
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is a U.S. Person will be required to certify that it is an “accredited investor” and a “qualified
purchaser”, in each case as defined under applicable U.S. federal securities laws, thereby also
qualifying as a “qualified eligible person” as defined in Rule 4.7 under the United States
Commodity Exchange Act, as amended (the “CEA”). All U.S. Persons will also be required to certify
that they are a “Qualified Client” pursuant to Investment
Adviser Act Rule 205-3 in order for ZCF
to receive incentive compensation.
As of December 29, 2023, the net asset value of ZCF Fund was USD 114.93 million.
b) ZEAL Voyage China Fund (Formerly known as Voyage China Fund) (“ZVCF”)
A unit trust established under the laws of Hong Kong, ZVCF is a long-only China equity fund. The
fund primarily invests in stocks listed in Hong Kong, A-shares and B-shares listed in Shanghai
and/or Shenzhen, China. The fund makes investments into companies that in our opinion as
investment manager, have been undervalued by the market.
This Fund is not open to investment by U.S. Persons.
As of December 29, 2023, the net asset value of the ZVCF Fund was USD 182.99 million.
c) ZEAL China Connect Fund (“ZCCF”)
A sub-fund of ZEAL Investment Series which is an umbrella fund constituted in the form of a unit
trust established under the laws of Hong Kong. The investment objective of the fund is to generate
long-term capital appreciation by primarily investing in equities and debt securities with a China
focus. Between 50% and 100% of the fund’s non-cash assets will be invested in equity securities
which may include (i) A-shares, through investing in Access Products and via the Shanghai-Hong
Kong Stock Connect, (ii) B-Shares, (iii) shares listed on The Stock Exchange of Hong Kong Limited,
Taiwan Stock Exchanges and/or other stock exchanges whose shares are related to China.
Between 0-50% of the fund’s non-cash assets will be invested in debt securities which are related
to China.
This Sub-Fund is not open to investment by U.S. Persons.
As of December 29, 2023, the net asset value of the ZCCF Fund was USD 0.70 million.
Please note that ZCCF has been closed in January 2024.
d) ZEAL Property Fund (“ZPF”)
A sub-fund of ZEAL Investment Series which is an umbrella fund constituted in the form of a unit
trust established under the laws of Hong Kong. The investment objective of the fund is to achieve
long-term capital appreciation and generate steady income primarily by investing in a portfolio of
instruments directly or indirectly related to property and real estate industry in Hong Kong and
Mainland China.
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This Sub-Fund is not open to investment by U.S. Persons.
As of December 29, 2023, the net asset value of the ZPF Fund was USD 0.76 million.
Please note that ZPF has been closed in January 2024.
Also, we currently act as the Sub-Investment Manager for the following fund:
a) Bosera Zeal Hong Kong Equity Plus Fund (“BZHKEPF”)
BZHKEPF is a sub-fund of the Bosera Global Public Funds Series Open-ended Fund Company, which
is a public umbrella open-ended fund company established under Hong Kong law with variable
capital with limited liability and segregated liability between sub-funds. The Sub-Fund aims to
generate long-term capital appreciation primarily through investments in equity securities with a
China focus.
BZHKEPF is not open to investment by U.S. Persons.
As of December 29, 2023, the net asset value of the BZHKEPF Fund was USD 1.06 million.
Separately Managed Accounts
We currently manage separately managed accounts for different parties which are non-US Persons.
As of December 29, 2023, the net asset value of separately managed accounts were USD 916.22 million.
Non-Discretionary Advisory Mandates
We currently do not provide investment advisory services on a non-discretionary basis.
As of December 29, 2023, we manage a total of USD 1,216.66 million in assets in discretionary accounts.
3) Tailored Relationships
The goals and objectives for each client are documented in the IMA between us and the client and in the
case of the Funds, each Fund’s offering material. Clients may impose reasonable restrictions on investing
in certain securities or types of securities for their separately managed accounts.