Conclusion of Inspection No. 83/KL-TT Regarding ACB Securities Company Limited

On December 22, 2025, the State Securities Inspectorate issued Conclusion of Inspection No. 83/KL-TT regarding the inspection at ACB Securities Company Limited. The full text of the Conclusion of Inspection is as follows:

1. General Overview ACB Securities Company Limited was licensed by the State Securities Commission (SSC) to establish and operate under Business License No. 06/GPHD dated June 29, 2000, and subsequent amendment licenses. The company's owner's investment capital (Charter Capital) as of June 30, 2025 (according to the audited half-year 2025 Financial Statements) is 11,000,000,000,000 VND, wholly owned by Asia Commercial Joint Stock Commercial Bank (ACB). At the time of inspection, the company's licensed business operations included: Securities brokerage; Proprietary trading; Securities investment advisory; Securities underwriting. The company is also licensed to trade derivatives securities (including: Derivatives securities brokerage, Derivatives proprietary trading, Derivatives investment advisory). The company provides the following services: Securities margin trading; Securities sale advance payment; Online securities trading; Clearing and settlement services for derivatives securities transactions. Business operation results: According to the audited 2023 and 2024 Financial Statements and the reviewed half-year 2025 Financial Statements by KPMG Audit Company Limited, the company's net profit after tax for 2023, 2024, and the first half of 2025 were 391,782.98 million VND, 675,907.05 million VND, and 330,973.36 million VND, respectively.

2. Inspection and Verification Results 2.1. Maintenance of Licensing Conditions The company meets the requirements for maintaining operational licensing conditions regarding infrastructure, minimum charter capital, and personnel as stipulated in Clause 4 and Clause 5 of Article 74 of the Securities Law; Articles 175, 2(d) of Clause 2 of Article 190, and Clause 2 of Article 191 of Government Decree No. 155/2020/NĐ-CP dated December 31, 2020, detailing certain articles of the Securities Law (Decree No. 155/2020/NĐ-CP).

2.2. Proprietary Trading Activities 2.2.1. Proprietary Trading Procedures The company has issued its Securities Investment Operation Regulations.

2.2.2. Proprietary Trading Operations The company's proprietary trading includes: Basic securities proprietary trading (including listed and unlisted/unregistered shares); Government bonds, corporate bonds; Fund certificates; Underlying assets for warrant risk hedging; Deposit certificates, deposit contracts, and derivatives securities. According to the audited 2023 and 2024 Financial Statements, reviewed half-year 2023, 2024, 2025 Financial Statements, and the first 9 months of 2025 Financial Statements, the company's investment ratios in listed/registered shares, unlisted shares, and corporate bonds relative to owner's equity at the dates of January 1, 2023, June 30, 2023, December 31, 2023, June 30, 2024, December 31, 2024, June 30, 2025, and September 30, 2025 comply with the regulations in Clause 3 and Clause 4 of Article 28 of Circular No. 121/2020/TT-BTC dated December 31, 2020, by the Minister of the Ministry of Finance on securities company operations (Circular No. 121/2020/TT-BTC).

2.3. Securities Brokerage Activities 2.3.1. Brokerage Procedures The company has issued procedures related to brokerage activities.

2.3.2. Implementation Status As of October 6, 2025, the company had 152,252 securities trading accounts opened. Sample checks of 25 securities trading accounts revealed:

• Regarding account opening contracts: The securities trading account opening contracts between investors and the company contain complete signatures of both parties, ID cards/passports (for individual customers), and business registration/establishment and operation licenses (for organizational customers).
• Regarding order receipt, execution, and order evidence retention: Customers can place orders via: counter service, or online trading channels specified by the company. Sample checks of trading activities on certain accounts on certain dates showed that for counter-placed orders, the company provided order slips confirmed by both the customer and the company, containing complete information: security code, order quantity, order price, and order receipt time. For online orders, the company provided order evidence showing security code, order quantity, order price, order receipt time, and device identification/IP address information. Sample checks of order placement times for certain accounts showed that at the time of order placement, customers had sufficient funds in their securities trading accounts.

2.3.3. Management of Customers' Securities Trading Deposits a) For customers opening accounts directly at commercial banks selected by the securities company to manage securities trading funds The company signed Framework Service Contract No. 01/HSO.CM.120423 dated April 12, 2023, with ACB regarding the management of investor deposit accounts for securities trading transactions when customers open accounts directly at the bank. According to the company's report, as of October 6, 2025, the company had 67,824 customers using this service.

b) For managing customers' securities trading funds via specialized accounts opened by the securities company at commercial banks According to the company's report, the company opened 33 specialized accounts at 14 commercial banks to manage investors' securities trading deposits (specialized accounts). Regarding the management of customers' derivatives securities trading funds, the company has 01 master account opened at ACB – Truong Dinh Branch and 08 accounts at other commercial banks to receive funds for derivatives securities trading/margin deposits from investors.

2.3.4. Derivatives Securities Brokerage Activities The company has issued derivatives securities brokerage business procedures. As of October 6, 2025, the total number of customers' derivatives securities (DS) trading accounts at the company was 11,628 accounts, all domestic accounts, with no foreign accounts. Sample checks of 5 DS trading accounts opened at the company showed that the DS trading account opening contracts between the company and customers basically contained the required content and information per Article 26 of Decree No. 158/2020/NĐ-CP dated December 31, 2020, by the Minister of the Ministry of Finance on derivatives securities and the derivatives securities market.

2.3.5. Entrusted Management of Individual Investors' Securities Trading Accounts According to the company's report, no such activities occurred during the inspection period.

2.4. Securities Investment Advisory Activities The company has issued Securities Investment Advisory Procedures. According to the company's report, no securities investment advisory activities occurred during the inspection period.

2.5. Securities Underwriting Activities The company has issued Securities Underwriting Procedures. According to the company's report, no securities underwriting activities occurred during the inspection period.

2.6. Other Advisory Activities During the inspection period, the company signed and provided advisory services for 26 issuance dossiers of 6 issuing organizations (IPOs), including: Vietnam International Joint Stock Commercial Bank (VIB); Vietnam Export-Import Joint Stock Commercial Bank (EIB); Dong Phu Rubber Joint Stock Company (DPR); Vietnam Bank for Investment and Development Joint Stock Commercial Bank (BVB); Hoa Binh Construction Joint Stock Corporation (HBC); Bac A Joint Stock Commercial Bank (BAB). Sample checks of dossiers related to issuance services revealed:

• The pre-issuance information disclosure document (PID) dated September 28, 2023, for VIB's 2023 private bond issuance dossier (for which the company advised the offering dossier) lacked complete content in Clause 1.0 of Section IV, Plan for Use of Proceeds from the Issuance (did not specify the disbursement timeline for funds from the bond issuance), per Section IV.1 Appendix I - Pre-offering bond information disclosure of Circular No. 122/2020/TT-BTC dated December 31, 2020, by the Minister of the Ministry of Finance guiding information disclosure and reporting regimes per Government Decree No. 153/2020/NĐ-CP dated December 31, 2020, on private corporate bond offerings and international offerings (Circular No. 122/2020/TT-BTC).
• The pre-issuance PID dated July 23, 2024, and August 21, 2024, for VIB's 2024 private bond issuance dossier (for which the company advised the offering dossier) lacked complete content in Clause 1.0 of Section IV, Plan for Use of Proceeds from the Issuance (did not specify the disbursement timeline for funds from the bond issuance), per Section IV.1 Appendix I - Pre-offering bond information disclosure of Circular No. 122/2020/TT-BTC. Thus, the company failed to fully fulfill its responsibility to review compliance with complete regulations for VIB's bond offering dossiers, violating Clause 6, Article 14 of Government Decree No. 153/2020/NĐ-CP dated December 31, 2020, on private corporate bond offerings and international offerings (Decree No. 153/2020/NĐ-CP), as amended by Clause 11, Article 1 of Government Decree No. 65/2022/NĐ-CP dated September 16, 2022, amending certain articles of Decree No. 153/2020/NĐ-CP (Decree No. 65/2022/NĐ-CP).

2.7. Customer Service Provision Activities 2.7.1. Securities Sale Advance Payment Activities The company was approved by the SSC to provide securities sale advance payment services per Decision No. 133/QĐ-UBCK dated March 18, 2022. The company has issued procedures for depositing, transferring, and advancing basic securities funds. According to the audited 2023 standalone Financial Statements, reviewed half-year 2024 standalone Financial Statements, audited 2024 standalone Financial Statements, and reviewed half-year 2025 standalone Financial Statements, the company's securities sale advance payment balances at January 1, 2023, December 31, 2023, June 30, 2024, December 31, 2024, and June 30, 2025, were 67,991.34 million VND, 112,892.41 million VND, 264,319.49 million VND, 132,859.32 million VND, and 87,264.76 million VND, respectively. According to the company's report, the total securities sale advance payment balance as of October 6, 2025, was 106,961.81 million VND.

2.7.2. Margin Trading Activities 2.7.2.1. Procedure Formulation The company has issued Margin Trading Procedures.

2.7.2.2. Implementation Status According to the company's report, as of October 6, 2025, the company had 19,805 margin trading accounts opened, including 19,687 domestic individual accounts and 118 domestic organizational accounts, with no foreign investor accounts. Sample checks of 33 margin trading accounts revealed: a) Regarding margin trading account opening The company executed margin trading account opening contracts with customers per regulations. b) Regarding the List of Eligible Margin Trading Securities Each month, the company prepares and notifies customers of the list of eligible margin trading securities. The company has published updated eligible margin trading securities lists on its electronic website. Sample checks of the company's eligible margin trading securities portfolio from January 2023 to September 2025 showed that the published list complies with the lists published by the 02 Stock Exchanges. c) Regarding margin trading loan limits

• Sample checks of the company's total margin trading loan balance at January 1, 2023, December 31, 2023, June 30, 2024, December 31, 2024, and June 30, 2025, showed that the total margin trading loan balance did not exceed 200% of the company's owner's equity.
• Sample checks of the company's margin trading loan balances for certain customers at January 1, 2023, June 30, 2024, December 31, 2024, June 30, 2025, and June 10, 2025, showed that the total margin trading loan balance for any single customer at each point in time did not exceed 3% of the company's owner's equity.
• Sample checks of loan balances for certain securities codes at certain dates (June 30, 2024, December 31, 2024, March 31, 2025, June 30, 2025, and October 6, 2025) with the largest margin trading loan disbursements showed: The total loan balance for any single security did not exceed 10% of owner's equity, and the total margin trading securities for any single security did not exceed 5% of the listed volume. d) Regarding margin trading ratios Sample checks showed that no loans had a margin ratio lower than the 30% maintenance margin ratio.

2.8. Issuance of Secured Warrants Activities The company has issued Procedures for Offering Secured Warrants to Investors. According to the company's report, during the inspection period, the company issued 61 warrant codes across 9 batches. The company's warrants were issued based on underlying securities FPT, HPG, MBB, MSN, MWG, STB, TCB, TPB, VHM, VIB, VNM, VPB, VRE. As of October 6, 2025, the company had 28 warrant codes still listed from 3 offering batches (offering dates: November 4, 2024, May 20, 2025, and July 18, 2025). Regarding collateral assets for payment of listed warrant codes, the company signed collateral payment margin contracts with Bank for Investment and Development of Vietnam Joint Stock Commercial Bank - Nam Ky Khoi Nghia Branch per Clause 3, Article 5 of Circular No. 107/2016/TT-BTC dated June 29, 2016, by the Minister of the Ministry of Finance guiding the offering and trading of secured warrants. On September 12, 2025, the SSC issued Administrative Penalty Decision No. 267/QĐ-XPHC against the company for inaccurate information disclosure (the company disclosed inaccurate information in the Secured Warrant Issuance Notice dated July 17, 2025, compared to the Prospectus submitted to the SSC, regarding the number of accounts receiving funds for the purchase of 3 warrant codes: MWG/ACBS/Call/EU/Cash/7M/84, STB/ACBS/Call/EU/Cash/7M/85, TCB/ACBS/Call/EU/Cash/7M/86). The company submitted Letter No. 178.3/CV-ACBS.25 dated September 22, 2025, reporting compliance with Administrative Penalty Decision No. 267/QĐ-XPHC dated September 12, 2025, whereby the company paid the administrative fine and implemented corrective measures by correcting the information per regulations.

2.9. Private Bond Issuance Activities The Company's Member Council issued Resolution No. 58/NQ-HĐTV-ACBS dated August 12, 2025, approving the 2025 private bond issuance plan with a total value of 200 billion VND. On August 19, 2025, ACBS submitted information disclosure on the bond offering results to the Hanoi Stock Exchange, showing a total issued value of 200 billion VND, with 01 organizational investor purchasing the bonds: Mobile World Joint Stock Corporation. On August 28, 2025, the company used the 200 billion VND raised from the bond issuance to restructure its debt at Vietnam Export-Import Joint Stock Commercial Bank – District 1 Branch. The Vietnam Securities Depository Corporation issued Securities Registration Certificate No. 309/2025/GCNTPRL-VSDC dated September 11, 2025, for the company's bonds. The Hanoi Stock Exchange issued Letter No. 4222/TB-SGDHN dated September 22, 2025, announcing the first trading date of the company's bond ASS12501, with the first trading date being September 25, 2025 (trading code: ASS12501).

2.10. Charter Capital Increase From January 1, 2023, to October 6, 2025, ACBS had a total of 04 charter capital increase rounds (owner ACB contributed additional capital), increasing from 3,000 billion VND to 11,000 billion VND. The SSC issued amendment licenses No. 91/GPĐC-UBCK dated November 13, 2023, No. 05/GPĐC-UBCK dated January 26, 2024, No. 03/GPĐC-UBCK dated January 22, 2025, and No. 07/GPĐC-UBCK dated April 4, 2025, for the company with new charter capitals of 4,000 billion VND, 7,000 billion VND, 10,000 billion VND, and 11,000 billion VND, respectively.

2.11. Internal Audit, Internal Control, and Risk Management Activities 2.11.1. Internal Audit Activities According to the company's report, due to operating as a Limited Liability Company, the company does not staff an internal audit department.

2.11.2. Internal Control Activities The company issued Internal Control Procedure QP-7.72 per Decision No. 71.1/QĐ-ACBS.24 dated October 9, 2024, by the General Director. The company appointed Ms. Do Thi Ngoc Hanh as Head of Internal Control Department per Decision No. 45.1/QĐNS-ACBS.25 by the General Director. Ms. Do Thi Ngoc Hanh meets the requirements for the head of the internal control department per Clause 4, Article 12 of Circular 121/2020/TT-BTC. The company appointed individuals Huynh Kieu Uyen, Tran Thanh Thao, Nguyen Le Cam Tu, Nguyen Minh Thuy, and Dong Thuan Anh as internal control department staff. These individuals meet the personnel requirements for the internal control department per Clause 4, Article 12 of Circular 121/2020/TT-BTC. During the inspection period, the internal control department conducted periodic internal control activities and reported to the General Director and Member Council on internal control work.

2.11.3. Risk Management Activities The company has issued regulations and procedures related to risk management. The company appointed Mr. Duong Anh Tuan as Head of Risk Management Department from August 1, 2025, to July 31, 2026, per Decision No. 79.2/QĐNS-ACBS.25 dated July 31, 2025, by the General Director. Twice a year, the company has submitted risk management activity reports to the SSC. The risk management report is prepared according to the template in Appendix IV attached to Circular No. 121/2020/TT-BTC. During the inspection period, the company's half-year 2025 risk management report was submitted late per Clause 4, Article 29 of Circular No. 121/2020/TT-BTC (noted in Section 2.14 regarding reporting and information disclosure compliance).

2.12. Corporate Governance The company issued documents related to corporate governance, including: Charter, Member Council Operation Regulations, Supervisory Board Control Procedures. At the time of inspection, the company's Member Council had 04 members, appointed by owner ACB, complying with Clause 1 and Clause 3 of Article 80 of the Enterprise Law. During the inspection period, the Member Council organized 86 meetings (2023: 25 meetings; 2024: 31 meetings; 2025: 30 meetings). The number of members on the company's Supervisory Board at the time of inspection was 01 member, complying with Clause 1 of Article 65 of the Enterprise Law. At the time of inspection, the company's Executive Board had 01 General Director, 01 Deputy General Director, and 01 Chief Accountant.

2.13. Anti-Money Laundering Activities The company issued internal regulations on anti-money laundering per Decision No. 14.2/QĐ-ACBS.24 dated March 6, 2024. The company sent Letter No. 42.1/CV-ACBS.24 dated March 6, 2024, to the Anti-Money Laundering Department regarding amendments to internal anti-money laundering regulations per point b, Clause 10, Article 5 of Circular No. 09/2023/TT-NHNN dated July 28, 2023, by the Governor of the State Bank of Vietnam guiding certain articles of the Anti-Money Laundering Law (Circular No. 09/2023/TT-NHNN). The content of internal regulations and anti-money laundering procedures basically complies with the Anti-Money Laundering Law, Government Decree No. 19/2023/NĐ-CP dated April 28, 2023, on certain articles of the Anti-Money Laundering Law, and Circular No. 09/2023/TT-NHNN. The person in charge of anti-money laundering is Mr. Duong Anh Tuan – Head of Risk Management Department, per Decision No. 98.1/QĐNS-ACBS.24 dated November 4, 2024. The company submitted late reports to the State Bank of Vietnam and the SSC regarding the 2024 Money Laundering Risk Assessment Report No. 150.1/CV-ACBS.25 dated August 8, 2025, per Clause 2, Article 13 of Circular No. 121/2020/TT-BTC and Clause 5, Article 3 of Circular No. 09/2023/TT-NHNN.

2.14. Implementation of Reporting and Information Disclosure Regime The company issued Information Disclosure Regulations per Resolution No. 53/NQ-HĐTV-ACBS.24 dated December 16, 2024, by the Member Council. During the inspection period, Ms. Nguyen Thi Nguyet – Company Secretary, Legal Advisory Director, was authorized for information disclosure per Information Disclosure Authorization Letter No. 07/GUQ-ACBS.24 dated February 16, 2024. Mr. Vo Dinh Nam – Human Resources Director was authorized for information disclosure per Information Disclosure Authorization Letter No. 17/GUQ-ACBS.25 dated May 20, 2025. The company submitted late reports regarding the half-year 2025 Risk Management Report and the 2024 Securities Practitioners List, violating Clause 4, Article 29 of Circular No. 121/2020/TT-BTC and point d, Clause 5, Article 216 of Government Decree No. 155/2020/NĐ-CP.

2.15. Financial Safety Indicators and Available Capital Ratios

• Financial safety management indicators Based on the audited 2023 Financial Statements, audited 2024 Financial Statements, reviewed half-year 2025 Financial Statements, and Q3 2025 Financial Statements of the company, the financial safety management indicators are as follows:
• The company's Total Debt to Owner's Equity ratio at December 31, 2023, December 31, 2024, June 30, 2025, and September 30, 2025, was 1.12 times, 1.82 times, 1.49 times, and 1.82 times, respectively, complying with Clause 1, Article 26 of Circular No. 121/2020/TT-BTC.
• The company's Short-term Debt to Short-term Assets ratio at December 31, 2023, December 31, 2024, June 30, 2025, and September 30, 2025, was 0.54 times, 0.65 times, 0.62 times, and 0.67 times, respectively, complying with Clause 2, Article 26 of Circular No. 121/2020/TT-BTC.
• Financial safety ratio According to the company's half-year 2023, 2024, 2025 reviewed and 2023, 2024 audited financial safety ratio reports, the available capital ratio at June 30, 2023, December 31, 2023, June 30, 2024, December 31, 2024, and June 30, 2025, and the available capital safety ratio of the company were 689%, 649%, 692%, 564.64%, and 639.65%, respectively. The company prepared and submitted periodic reports to the SSC on the aforementioned financial safety ratio reports per Circular No. 91/2020/TT-BTC dated November 13, 2020, by the Minister of the Ministry of Finance on financial safety indicators and handling measures for securities business organizations not meeting financial safety indicators.

3. Conclusions 3.1. Conclusions on Inspection Contents During the inspection period, the company had certain violations and shortcomings as stated in Section 2 of the Conclusion of Inspection.

3.2. Responsibilities The company, General Director, leaders, and staff of relevant departments are responsible for the company's violations, specifically: Failure to ensure that information in bond offering or private bond issuance dossiers contains all required content as stipulated; late submission of reports as required by law.

4. Administrative Sanctions Applied For the company's violations stated in Section 2 of the Conclusion of Inspection (Failure to ensure complete required content in bond offering or private bond issuance dossiers; late report submission), on November 4, 2025, the Inspection Team issued Administrative Violation Record No. 291/BB-VPHC against the company. On November 12, 2025, the State Securities Inspectorate issued Administrative Penalty Decision No. 410/QĐ-XPHC against the company, specifically:

• A fine of 275,000,000 VND per point b, Clause 5, Article 8 of Decree No. 156/2020/NĐ-CP, as amended by point d, Clause 7, Article 1 of Decree No. 128/2021/NĐ-CP, for failing to ensure complete required content in bond offering or private bond issuance dossiers.
• A fine of 65,000,000 VND per point a, Clause 2, Article 43 of Decree No. 156/2020/NĐ-CP, for late report submission as required by law. The total fine amount against the company is 340,000,000 VND.

5. Recommended Sanction Measures The State Securities Inspectorate requests the company to urgently implement measures to rectify and remediate the shortcomings identified post-inspection, specifically:

• Regarding services related to private corporate bond offerings: Strictly comply with Decree No. 153/2020/NĐ-CP, Decree No. 65