This Policy Disclosure page contains the following policy statements of OP Investment Management Limited (OPIM), which may be amended from time to time: 

A.    Privacy Policy Statement 

B.    Cookies Policy 

C.    Climate-related Risk Disclosure Statement 

Privacy Policy Statement

Last updated: August 2023

Governance 

We, OPIM, are committed to protecting your privacy and safeguarding your personal information in accordance with the requirements of the relevant laws of Hong Kong.  This Privacy Policy Statement applies to the personal data that we may collect from you and seeks to explain our information practices relating to such data.

Please read this Privacy Policy Statement carefully.  Provision of your personal data is voluntary; however please take note if you choose not to provide certain of your personal data to us, we may not be able to process your request or provide products or services which you may require.

This Privacy Policy Statement is prepared in accordance with the requirements under the applicable laws and regulations of Hong Kong, in which we are incorporated.   

Consent 

Before collecting and using your personal data, your express consent is required under certain circumstances as stipulated under the applicable laws and regulations.  You can withdraw your consent at any time by notifying us through the communication channel detailed in the “Contact Us” section below.

Types of Personal Data 

Depending on the products or services that we may provide to you, we may collect broadly the following types of personal data from you:

The above are some of the examples of the personal data that we may collect from you, and is by no means exhaustive.  

Purposes for Collecting the Personal Data 

The purposes for which your personal data may be collected may vary depending on the nature of your relationship with us.  They may comprise any or all of the followings:

• as basis for employing or appointing and related decisions as stipulated in the job or engagement application process, and as evidence for verification of your identity and academic results, qualifications and other records
• providing products or services to you
• responding to your enquires or processing your requests 
• entering into a relationship with you in response to your request for products or services
• maintenance and operation in respect of the products or services provided
• conducting due diligence on you, such as anti-money laundering, counter-terrorism, background, credit, identity, sanctions screening (collectively FC Checks)
• providing marketing and promotional materials relating to our products or services
• compliance with requirements of legal, governmental, regulatory, tax, law enforcement, other authorities or courts of competent jurisdiction in or outside of Hong Kong (collectively Competent Authorities)
• inviting you to participate in our events and/or seminars
• conducting research and statistical analysis 
• developing new products or services
• improving and personalising your user experience on this website
• performing website analytics and measuring website performance 
• maintaining our website, including for security purposes  
• enforcing our contractual or legal rights against you
• performing any other purpose related to or in connection with or incidental to any of the above and some other purposes that you may agree from time to time.

Disclosure of Personal Data 

In relation to one or more of the purposes as set out in the “Purposes for Collecting the Personal Data” section above, we may disclose your personal data to any or all of the followings in any jurisdiction:

•  other companies within the Oriental Patron Financial Group (OP Group), of which we are a member
•  agents, business partners, consultants, contractors, intermediaries, professional advisers (such as accountants and lawyers) or service providers (including agencies conducting FC Checks, brokers, custodians, financial advisors, financial institutions, platform providers, computer, telecommunication or IT systems providers), which provide services to any member of the OP Group of companies
•  potential buyer, investor, transferee or seller and its advisers of any interest or business in any OP Group companies or its business in connection with any potential acquisition, disposal, merger or reorganisation
•  Competent Authorities where any members within the OP Group is permitted or required to make the disclosure under the applicable laws or regulations
•  any other persons to whom disclosure is permitted or required pursuant to the relevant laws and regulations

We may share aggregate or non-individual information with third parties for analytic, business, marketing, research and other purposes without your consent.

Transfers of Personal Data  

If we transfer your personal data to jurisdictions outside of Hong Kong, whether for any of the purposes as set out in the “Disclosure of Personal Data” section above or otherwise, we will comply with the requirements that may be prescribed under the Personal Data Privacy Ordinance (Chapter 486 of the Laws of Hong Kong), as amended, re-enacted or substituted (PDPO).

Direct Marketing  

Provided that your consent has been obtained and not subsequently withdrawn, we may use your name, address, telephone number and email address to send advertising, marketing, offering and promoting materials of the products, services or facilities that we and/or any companies within the OP Group may offer. 

We may, having obtained your consent, transfer the personal data collected from you to third parties (subject to applicable laws, regulations, codes and guidelines) for the purpose of enabling such third parties to conduct direct marketing in connection with their goods, facilities and services. 

You may opt out of the use of your personal data for direct marketing activities set out above by notifying us through one of the communication channels detailed in the “Contact Us” section below.  

Retention Period 

We may keep and maintain your personal data for as long as it is necessary to fulfil the purposes set out in this Privacy Policy Statement above, or as required under the applicable laws and regulations.

Your Rights – Access and Correction 

In accordance with the PDPO, you have the rights to: 

• ascertain whether we hold your personal data, and access to such personal data; and 
• request us to correct any personal data of yours which is inaccurate or incomplete. 

You may exercise your rights under this section by lodging a written request at the facsimile number detailed in the “Contact Us” section below.  In exceptional circumstances, we reserve the right to refuse your personal data access request and may provide you with an explanation where the applicable laws or regulations require. 

We reserve the right to charge a reasonable fee in consideration of our administrative and actual costs incurred in complying with your data access requests.  

Security Measures 

Your privacy is important to us. We have implemented various physical, electronic, technical and organisational measures to protect the integrity and security of your personal data, such as physical security control, administrative and technical controls over personal data access, monitoring of security breaches, education and training to staff members and security incidents handling procedures.  However, we are not in the position to guarantee the confidentiality and security of any personal data that may be transmitted to and from you via the Internet.   

Cookies 

This website also automatically installs and uses “cookies” on your browser to ensure and improve your user experience.  For more details, please reference to the below Cookies Policies.  

Third Party Websites 

This website may contain links to other websites that are not controlled or maintained by us.  We are not responsible for any content of these websites.  This Privacy Policy Statement does not apply to any of these third-party websites.  You are advised to read the privacy policy statement displayed on each of these websites to understand the privacy policy in respect of the handling of your personal data.  

Updates to this Privacy Policy Statement

We reserve the right to revise and update this Privacy Policy Statement from time to time.  Any changes to this Privacy Policy Statement will be reflected on this page.  You are recommended to visit this page regularly to view the latest version of this Privacy Policy Statement. 

Contact Us 

If you wish to access your personal data, request for correction, object to the use of your personal data for direct marketing purpose or have any questions on this Privacy Policy Statement, please contact: 

The Compliance Officer  

OP Investment Management Limited 

9/F, The Wellington, 198 Wellington Street, Central, Hong Kong 

Facsimile: (852) 2916 9223 

Cookies Policy

Last updated: August 2023

Introduction 

To ensure the operation of this website and your user experience, OPIM place small data files named “cookies” on your computer or mobile devices when you visit this website.

This Cookie Policy sets out how cookies and similar technologies (collectively cookies) are used on this website, and explains what cookies are, the types of cookies OPIM uses, how cookies work when you visit this website.  By using or accessing this website, you consent to the following terms in this Cookie Policy.

What are cookies? 

A cookie is a small text file that is transferred to and stored on your device or browser when you access a website.  Cookies enable the website to recognize you when you revisit, keep track of the pages you have browsed, remember your preferences including any specific data you have entered into the forms, record your online activities such as the date and time of your visit, and prevent fraudulent activities.

Notification to the use of cookies 

Our website automatically installs and uses cookies on your browser when you access this website.  The purpose of using cookies is to help us improve website performance and user experience.

The cookies used in connection with our website do not collect or store personally identifiable and/or behavioural information.  You may refuse to accept cookies by changing the setting within your browser.  Please note that blocking cookies may result in not being able to take full advantage of this website.

Types of cookies and usage 

Two types of cookies are used on this website:

Session cookies are temporary cookies that only lasts for a session.  They remain in your browser until the time you leave this website or close your browser window.  In other words, they are stored in a temporary memory location and are deleted immediately when the session ends.  They enable this website to recognize you when you move between web pages and facilitate your user experience by, for example, saving the need to re-enter repetitive information on each page that you visit.

Persistent cookies are stored on your device’s hard disk to help remember the information, preferences and settings which you have previously saved.  They have an expiry date assigned by the webserver, and will remain between various browsing sessions until expiry or deletion.  They enable this website to remember when you return, and ensure a more convenient and tailor-made browsing experience.

Updates to this Cookies Policy 

OPIM reserves the right to revise and update this Cookies Policy from time to time. You are recommended to visit this page regularly to view the latest version of this Cookies Policy.   Your continued browsing of this website shall be regarded as your consent to the terms in this Cookies Policy.

Privacy Policy

See the above Privacy Policy Statement for more information about the types of information OPIM gathers.

Contact Us 

If you have any questions on this Cookies Policy, please contact:

The Compliance Officer

OP Investment Management Limited

9/F, The Wellington, 198 Wellington Street, Central, Hong Kong

Facsimile: (852) 2916 9223

Climate-related Risk Disclosure Statement

Last update: November 2022

Subject to the Amendments to the Fund Manager Code of Conduct (FMCC) on the Management and Disclosure of Climate-related Risks in August 2021 by the Securities and Futures Commission of Hong Kong (SFC), OPIM is required, under certain baseline requirements as set out under the FMCC, to disclose its governance, investment management and risk management framework in relation to assessing climate-related risks under its managed funds (Funds).  The purpose of this statement is to provide clients and investors under the Funds, certain information relating to OPIM’s policy in identifying, assessing, managing and monitoring relevant and material climate-related risks applicable to investments within the relevant Funds.

OPIM has not committed to achieve any goal in promoting sustainable investment on company level; however related risks and potential economic losses due to climate change, as suggested by SFC, has become a systemic financial risk that is hard to ignore.  OPIM will, in considering compliance with the fast-growing regulatory requirements concerning climate, take into account the related risks in its overall risk assessment when managing a Fund.

Governance 

The board of directors of OPIM (Board) is responsible for the overall oversight of the management of OPIM including the supervision of overall strategy and management of climate-related risks in the Funds.

The Board’s responsibilities include, but are not limited to:

•          Act as central oversight of the management of climate impact to ensure climate risk consideration is factored into the strategic planning and investment process within the management activities across the Funds;
•          Review investment management process and risk management framework covering climate-related risks from time to time;
•          Monitor status of the implementation of policy and the progress of managing climate-related risks, and ensure the actions and responses to climate issues are proportionate; and
•          Determine strategies for managing environmental impact with a focus on climate, and monitor overall fund performance and risk appetite.

OPIM has established a climate risk committee (Committee), consisting of the designated portfolio manager of the Fund, Head of Risk and Head of Compliance of OPIM, focusing on climate-related responsibilities.  The Committee directly reports to the Board on an annual basis.  The Committee has the following responsibilities:

•          Assess from time to time climate-related risks that are relevant and material to investments within the Funds; and set out plans (as proportional to the risk impact and applicable to the Fund) for incorporating climate risk consideration in the investment management and risk management processes;
•          Relying on the designated portfolio manager of the Fund, execute plans developed by the Committee to address climate-related risks when constructing investment portfolios and controlling overall climate risk impacts; 
•          Review regularly the effectiveness of risk management system to ensure any potential significant climate-related risks are addressed in a timely manner; and
•          Monitor for updates to regulatory requirements related to the management of climate-related risks and ensure compliance with such updates.

Investment Management and Risk Management 

OPIM maintains an assessment framework that aims to identify relevant and material climate-related risks within the investments of the Funds. 

Where most of the Funds do not have an investment objective stated expressly to achieve green or sustainable investing, OPIM defines relevance of climate-related risks holistically considering the investment strategy, investment horizon and asset class(es) of a particular Fund. 

OPIM also considers further, if climate-related risks are relevant to the investment strategy, the materiality of the impact of the risks as to the performance of the investments within the Fund using a combination of quantitative and qualitative metrics.  Such materiality assessment aims to identify sectors and geographical regions of the Funds’ investments that are more impacted by climate factors, by drawing references to a variety of indicators such as (a) Sustainability Accounting Standard Board’s Materiality Finder, (b) global environmental-related indices based on academic research and issued by universities ranking states of sustainability across the world, (c) exposure on NACE brown sector and high climate impact sector classified based on EC No. 1893/2006, and (d) weighted average carbon intensity number generated from reported and estimated Scope 1 and Scope 2 GHG emission gas data by available third party service provider. 

Data or reference used for assessment in connection with a Fund highly depends on availability of data and for any quantitative data adopted (where applicable), calculation methodology of a particular service provider that is being relied upon. OPIM provides no guarantee as to the accuracy or completeness of the assessment in concluding climate-related risks impact as to a Fund and any assessment will only be performed on a best effort basis.

To the extent climate-related risks are considered relevant and material to a Fund, OPIM will incorporate climate risk considerations into the stock selection process. Depending on the strategy implemented, the Fund will consider the investee companies’ climate goals and policies and consider from an overall perspective, if there are potential future performance impact on the investee companies.  If climate-related risks are considered not relevant or not material, periodic assessment will be made to reevaluate the relevance and materiality to a Fund.

OPIM may consider deploying a portfolio action plan to mitigate climate-related threats that may impact operation and business of the investment targets in each of the Funds.  The aim is to integrate such risks to the annual strategy review and capital allocation decision.  Regular monitoring and updates on climate-related market trends and regulatory requirements will ensure sufficient incorporation of climate risk factors into the Fund’s investment decision-making processes.  For investments in sectors categorized as having high climate-related risks, such as those in carbon intensive industries, OPIM will engage with the designated portfolio manager to understand the rationale behind the investment decision and determine whether proceeding with such investment aligns with the Fund’s risk appetite.  This is followed by evaluation of relevant mitigation plans in addressing the climate-related risks in such investment.

Disclosure 

Disclosure on Fund specific climate-related information may be provided to specific fund investors depending on data availability for reference.