Legal Disclosures & Terms

Legal Disclosures & Terms

Please Carefully read the Terms and Conditions of Use (the "Terms"). Your access to or use of Pacific Investment's website signifies that you understand and agree to be bound by the Terms.

If you do not agree to be bound by or comply with these Terms, do not access or use our website.

Pacific Investments reserves the right, in our sole discretion, to change, modify, add or remove Terms or portions thereof at any time. Any changes, modifications, or additions to, or deletions from the Terms shall be effective upon posting on this website. If you use this website after we post changes to the Terms, you accept the Terms as changed.

This website is owned and operated by Pacific Investments (China) Ltd. ("Pacific Investments"), a Financial Investment company, located in Hong Kong. registered with the Monetary Authority of Hong Kong.(Company Registration No: 1575310).

Intended Audience and Purpose

The information provided on our website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Pacific Investments, its wholly-owned affiliates, or any of its products to any registration requirement within such jurisdiction or country. Pacific Investments assumes no responsibility for access to this website by any person located within a country or jurisdiction where such access would be contrary to any law or regulation in that country.

Our website and its contents is for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy any security that may be referenced on or through our website. Further, our website and its contents does not constitute an offering or recommendation by Pacific Investments or its wholly-owned affiliates of any transaction, product or service, including securities transactions and investment management or advisory services. Pacific Investments does not provide investment advice, tax advice, or legal advice through this website, and you agree that this website will not be used by you for such purposes.

The information provided on our website is intended for institutional investors and Professional Clients and Eligible Counterparties as defined by the FCA under the Markets in Financial Instruments Directive. It is not intended for retail investors.

Use Limitations

All copyrights, trademarks, logos, service marks, trade names, or other intellectual property displayed on, or used in conjunction with, this website are proprietary to Pacific Investments, unless otherwise noted. The content of this website is protected by applicable intellectual property (copyright) law. Pacific Investments reserves all rights with respect to intellectual property ownership of all material on this website, and will enforce such rights to the full extent permissible by law.

The material accessible on or through this website is accessible for personal browsing and printing purposes only. Users of this website may not otherwise:

(1) copy, reproduce, sell, republish, post, transmit (by electronic means or otherwise), modify, link into, use for any public or commercial purpose or distribute in any way material from this website without the express, written permission of Pacific Investments;

(2) use, copy, modify, or display any Pacific Investments name, Pacific Investments employee name, logo, text or graphic image without Pacific Investment's express, written permission;

(3) display any of the pages, text, images or other content of this website in any manner without Pacific Investments's express written permission;

(4) modify or use the pages, text, images, papers, or other content from this website for any purpose other than browsing or printing for personal, non-commercial use; or

(5) take any action to create an impression of affiliation, sponsorship or endorsement between any user and/or website and Pacific Investments.


We will not request and you should not send personal identification information such as a social security or passport number, bank or other investment account numbers, or any other specific personal financial information through our website.

However, Pacific Investments may collect information about you when you access the website if you voluntarily choose to send Pacific Investments electronic mail, request information, or ask to be contacted. Pacific Investments may use this information to provide you with updated information about the products and services we offer. Certain employees of Pacific Investments and our wholly-owned affiliates may be given the information you provide to respond to your requests. Employees of Pacific Investments and its affiliates are instructed to handle any information you provide confidentially.

Our website uses "cookies" and "web beacons" (such as Google Analytics) to collect, store and aggregate data about usage and browsing patterns. We use cookies and web beacons for session management and to analyze site usage; we do not use cookies and web beacons to store any personally identifiable information about you. A "cookie" is a small text file containing a random and unique alphanumeric identifier that we transfer to your computer's hard drive through your web browser (unless you set your browser to reject cookies) that enables our systems to recognize your browser. A "web beacon" (also known as a "page tag," "data tag" or "image tag") is a mechanism by which a small section of code that is embedded in our website pages allows us to check that a user has viewed the page. These technologies can help us analyze and better understand how our website is being used and improve the user experience.

Hong Kong Personal Data Protection Act 2012

The Personal Data Protection Act 2012 (PDPA) governs the collection, use, and disclosure of personal data by Hong Kong organizations. It consists of two sets of requirements, covering personal data protection and the Do Not Call (DNC) registry

Pacific Investments aims to comply with the requirements set forth in the Act, and respects your personal data held or controlled by us. Should you have any feedback or inquiries pertaining to your personal data, please contact the Data Protection Officer via email at or in writing to the Hong Kong office address.


Pacific Investments does not warrant this website for any particular purpose. It is provided "as is" and on an "as available" basis. Pacific Investments disclaims, to the fullest extent of the law, any warranty of any kind, whether express or implied, as to any matter relating to this website, including without limitation the implied warranties of merchantability, fitness for a particular purpose, and non-infringement. Use of this website is at your own risk.

All content on this website is presented as of the date published or indicated. It may not reflect current opinions or events. Although the information and data provided to you on this website is obtained or compiled from sources believed to be reliable, Pacific Investments cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information, data or opinions made available to you for any particular purpose. This website may include forward-looking statements, which are based on current opinions, expectations and projections. Pacific Investments expressly disclaims any duty to update or revise any information, opinion or forward-looking statement appearing on this website. Decisions based on information contained on this website are solely your responsibility.

In no event will Pacific Investments be liable for any decision made, action or inaction taken by you in reliance on any information or data on our website and under no circumstances is any information available on our website to be construed as investment advice or recommendations.

Pacific Investments does not warrant that our website, or the functions contained in our website, will be uninterrupted or error-free, that defects will be corrected, or that our website, or the servers that make it available, are free from viruses or other harmful components. You assume the entire cost of any necessary servicing, repairing, or correcting of your property or operations as a result of using our website. You accept at your own risk that the Internet or other online communications medium may not perform as intended as a result of human, mechanical or other error, despite the efforts of Pacific Investments, you or any third party.

You hereby agree to indemnify, defend and hold harmless Pacific Investments and its wholly-owned affiliates, and their directors, officers, employees and agents, from and against any and all claims, liabilities, damages, losses or expenses (including reasonable attorneys' fees and expenses) arising out of or in any way connected with your access to or use of our website.

Proxy Voting


Whether Pacific Investments will have proxy voting responsibility on behalf of a separate account client is subject to negotiation as part of the overall investment management agreement executed with each client. Should a client desire that Pacific Investments vote proxies on their behalf, Pacific Investments will accept such authority and agree with the client whether votes should be cast in accordance with Pacific Investment's proxy voting policy or in accordance with a client specific proxy voting policy. Should the client wish to retain voting responsibility themselves, Pacific Investments would have no further involvement in the voting process but would remain available to provide reasonable assistance to the client as needed.

Pacific Investments has adopted a proxy voting policy reasonably designed to ensure that it votes proxies in the best interest of clients. Pacific Investments utilizes the services of Institutional Shareholder Services ("ISS"), an unaffiliated proxy firm, to help manage the proxy voting process and to research and vote proxies on behalf of Pacific Investments's clients who have instructed Pacific Investments to vote proxies on their behalf. Unless a client provides a client specific voting criteria to be followed when voting proxies on behalf of holdings in their portfolio, each vote is made according to predetermined guidelines agreed to between the proxy service firm and Pacific Investments. Pacific Investments believes that utilizing this proxy service firm helps Pacific Investments vote in the best interest of clients and insulates Pacific Investments's voting decisions from any potential conflicts of interest.

When voting proxies on behalf of our clients, Pacific Investments assumes a fiduciary responsibility to vote in our clients' best interests. In addition, with respect to benefit plans under the Employee Retirement Income Securities Act (ERISA), Pacific Investments acknowledges its responsibility as a fiduciary to vote proxies prudently and solely in the best interest of plan participants and beneficiaries. So that it may fulfill these fiduciary responsibilities to clients, Pacific Investments has adopted and implemented these written policies and procedures reasonably designed to ensure that it votes proxies in the best interest of clients.


Proxy Voting Guidelines

Pacific Investments acknowledges it has a duty of care to its clients that requires it to monitor corporate events and vote client proxies when instructed by the client to do so. To assist in this effort, Pacific Investments has retained ISS to research and vote its proxies. ISS provides proxy-voting analysis and votes proxies in accordance with predetermined guidelines. Relying on ISS to vote proxies is intended to help ensure that Pacific Investments votes in the best interest of its clients and insulates Pacific Investments's voting decisions from any potential conflicts of interest. Pacific Investments will also accept specific written proxy voting instructions from a client and communicate those instructions to ISS to implement when voting proxies involving that client's portfolio.

In specific instances where ISS will not vote a proxy, will not provide a voting recommendation, or other instances where there is an unusual cost or requirement related to a proxy vote, Pacific Investments's Proxy Coordinator will conduct an analysis to determine whether the costs related to the vote outweigh the potential benefit to our client. If we determine, in our discretion, that it is in the best of interest of our client not to participate in the vote Pacific Investments will not participate in the vote on behalf of our client. If we determine that a vote would be in the best interest of our client, the Proxy Coordinator will seek a voting recommendation from an authorized member of our investment team and ensure the vote is cast as they instruct.

Unless contrary instructions are received from a client, Pacific Investments has instructed ISS to not vote proxies in so-called "share blocking" markets. Share-blocking markets are markets where proxy voters have their securities blocked from trading during the period of the annual meeting. The period of blocking typically lasts from a few days to two weeks. During the period, any portfolio holdings in these markets cannot be sold without a formal recall. The recall process can take time, and in some cases, cannot be accomplished at all. This makes a client's portfolio vulnerable to a scenario where a stock is dropping in attractiveness but cannot be sold because it has been blocked. Shareholders who do not vote are not subject to the blocking procedure.

Pacific Investments also reserves the right to override ISS vote recommendations under certain circumstances. Pacific Investments will only do so if they believe that voting contrary to the ISS recommendation is in the best interest of clients. All overrides will be approved by an Officer of Pacific Investments and will be documented with the reasons for voting against the ISS recommendation.

Conflicts of Interest

Occasions may arise during the voting process in which the best interest of clients conflicts with Pacific Investments's interests. In these situations ISS will continue to follow the same predetermined guidelines as formally agreed upon between Pacific Investments and ISS before such conflict of interest existed. Conflicts of interest generally include (i) business relationships where Pacific Investments has a substantial business relationship with, or is actively soliciting business from, a company soliciting proxies, or (ii) personal or family relationships whereby an employee of Pacific Investments has a family member or other personal relationship that is affiliated with a company soliciting proxies, such as a spouse who serves as a director of a public company. A conflict could also exist if a substantial business relationship exists with a proponent or opponent of a particular initiative.

If Pacific Investments learns that a conflict of interest exists, its Proxy Coordinator will prepare a report for review with a compliance officer, and senior management if needed, that identifies (i) the details of the conflict of interest, (ii) whether or not the conflict is material, and (iii) procedures to ensure that Pacific Investments makes proxy voting decisions based on the best interests of clients. If Pacific Investments determines that a material conflict exists, it will defer to ISS to vote the proxy in accordance with the predetermined voting policy.

Voting Policies

Pacific Investments has adopted the proxy voting policies developed by ISS, summaries of which can be found at and which are deemed to be incorporated herein. The policies have been developed based on ISS independent, objective analysis of leading corporate governance practices and their support of long-term shareholder value. Pacific Investments may change its proxy voting policy from time to time without providing notice of changes to clients.

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