Inspection Conclusion No. 41/KL-TT Regarding Inspection at SSI Fund Management Company Limited

On July 9, 2025, the Inspectorate of the State Securities Commission issued Inspection Conclusion No. 41/KL-TT regarding the inspection at SSI Fund Management Company Limited. The full text of the conclusion is as follows:

1. General Overview
   SSI Fund Management Company Limited was established and operates under Investment Securities Fund Management License No. 19/UBCK-GP dated August 3, 2007, issued by the State Securities Commission (SSC); and the most recent License Adjustment No. 122/GPĐC-UBCK dated December 19, 2022.
   At the time of inspection, the Company's licensed business activities included: Management of securities investment funds; Management of securities investment portfolios; Securities investment advisory.
   The Company's charter capital as of December 31, 2024, and March 31, 2025, was 75,000 million VND. The Company is a subsidiary wholly owned by SSI Securities Joint Stock Company (SSI).
   The Company's headquarters is located on the 5th floor, Building No. 1C Ngo Quyen, Ly Thai To Ward, Hoan Kiem District, Hanoi City (now Hoan Kiem Ward, Hanoi City). The Chairman of the Company is Mr. Nguyen Manh Hung; the Legal Representative of the Company is Ms. Nguyen Ngoc Anh - General Director.

2. Results of Inspection and Verification
   2.1. Maintenance of Licensing Conditions
   The Company meets the conditions for maintaining its license regarding infrastructure, minimum charter capital, and personnel as stipulated in Clause 1, Clause 4, and Clause 5 of Article 75 of the Securities Law, and Clause 3 of Article 175 of Government Decree No. 155/2020/NĐ-CP dated December 31, 2020, detailing the implementation of certain articles of the Securities Law (Decree No. 155/2020/NĐ-CP).

2.2. Company's Organizational Structure

• Organizational Structure: The Company's organizational structure, as per its Charter, is as follows: Chairman of the Company, Inspector, General Director, and operational blocks/departments (including Investment Block, Investment Advisory Block, Operations Block, Business Development Department, and Law and Compliance Control Department).
• Company Charter: The content of the Company's Charter (most recently amended in October 2021) is constructed in accordance with the Company's operational model and contains at least the contents specified in the sample charter for fund management companies issued in Appendix XII attached to Circular No. 99/2020/TT-BTC dated November 16, 2020, by the Minister of the Ministry of Finance guiding the operation of securities investment fund management companies (Circular No. 99/2020/TT-BTC) and the 2020 Enterprise Law.
• Operational Procedures: The Company has issued complete procedures and regulations related to the operation of the fund management company and licensed business activities as stipulated in Clause 2 of Article 10 of Circular No. 99/2020/TT-BTC.

2.3. Internal Control, Internal Audit, and Risk Management Activities
2.3.1. Internal Control Activities
The Company has established an Internal Control Board. During the inspection period, the personnel structure and staff in the Internal Control Department met the regulations in Clause 3 and Clause 4 of Article 6 of Circular No. 99/2020/TT-BTC.
The Company submitted internal control reports for the years 2023 and 2024 to the SSC as stipulated in Clause 6 of Article 6 of Circular No. 99/2020/TT-BTC.

2.3.2. Internal Audit Activities
The Company's Chairman appointed Mr. Tu Cam Hue as the internal auditor. Mr. Tu Cam Hue meets the conditions stipulated in Clause 4 and Clause 5 of Article 5 of Circular No. 99/2020/TT-BTC.
During the inspection period, the Company implemented internal audit activity reports for the years 2023 and 2024 as stipulated in Clause 7 of Article 5 of Circular No. 99/2020/TT-BTC.

2.3.3. Risk Management Activities
The Company has issued risk management strategies, policies, and procedures. Basically, the Company's risk management strategy, policies, and procedures meet the regulations in Clause 4 of Article 10 of Circular No. 99/2020/TT-BTC.
Basically, the Company's risk management activities meet the regulations in Clause 4 of Article 10 of Circular No. 99/2020/TT-BTC.
During the inspection period, the Company implemented semi-annual and annual risk management reports as stipulated in point c, Clause 1, Article 29 of Circular No. 99/2020/TT-BTC.

2.4. Securities Investment Fund Management Activities
During the inspection period, the Company managed 03 open funds (SSI Sustainable Competitive Advantage Investment Fund, Vietnam Long-term Growth Investment Fund, SSI Bond Investment Fund), 02 member funds (SSI Member Investment Fund, Vietnam Digital Technology and Healthcare Investment Fund), and 03 Exchange Traded Funds (ETFs) (SSIAM VNX50 ETF, SSIAM VN30 ETF, SSIAM VNFIN LEAD ETF).

2.4.1. SSI Sustainable Competitive Advantage Investment Fund (SSI-SCA)

• The SSI-SCA Fund was established as an open fund under Fund Registration Certificate No. 15/GCN-UBCK issued by the SSC on September 26, 2014, with an initial charter capital of 111,922 million VND, and unlimited operational duration. The Custodian and Supervising Bank is Standard Chartered Bank Vietnam (NH Standard Chartered VN). The Transfer Agent is the Vietnam Securities Depository and Clearing Corporation (VSDC). The Fund currently has 03 members of the Fund Representative Board and 02 Fund Managers. The Fund has 14 fund certificate distribution agents. The number of investors holding fund certificates as of March 31, 2025, was 31,423 investors.
• The Fund Representative Board held meetings ensuring at least once per quarter as stipulated in Article 34 of the Fund Charter. The Company held the Annual General Meeting of Investors for 2023 and 2024 as stipulated in Article 22 of the Fund Charter.
• Operational Results: According to the Fund's Q1/2025 Activity Report, as of March 31, 2025, the net asset value per fund certificate was 40,359.2 VND; the cumulative investment result was -9,514.83 million VND, of which the realized investment result was 20,068.95 million VND.

2.4.2. Vietnam Long-term Growth Investment Fund (VLGF)

• The VLGF Fund was established as an open fund under Public Fund Registration Certificate No. 51/GCN-UBCK dated December 6, 2021, issued by the SSC, with an initial charter capital of 148,984.24 million VND, and unlimited operational duration. The Custodian and Supervising Bank is NH Standard Chartered VN. The Transfer Agent is VSDC. The Fund has 04 members of the Representative Board and 02 Fund Managers. The Fund has 03 fund certificate distribution agents. The number of investors holding fund certificates as of March 31, 2025, was 4,186 investors.
• The Fund Representative Board held meetings ensuring at least once per quarter as stipulated in Article 34 of the Fund Charter. The Company held the Annual General Meeting of Investors for 2023 and 2024 as stipulated in Article 22 of the Fund Charter.
• Operational Results: According to the Fund's Activity Report, as of March 31, 2025, the net asset value per fund certificate was 11,903.69 VND; the realized investment result (cumulative from the beginning of the year) of the VLGF Fund was 50,948.64 million VND, and the cumulative investment result was -188,095.81 million VND.

2.4.3. SSI Bond Investment Fund (SSIBF)

• The SSIBF Fund was established as an open fund under Fund Registration Certificate No. 26/GCN-UBCK issued by the SSC on August 30, 2017, with an initial charter capital of 68,069 million VND, and unlimited operational duration. The Custodian and Supervising Bank is Joint Stock Commercial Bank for Investment and Development of Vietnam - Ha Thanh Branch (BIDV Ha Thanh). The Transfer Agent is VSDC. The Fund currently has 04 members of the Representative Board and 02 Fund Managers. The Fund has 09 fund certificate distribution agents. The number of investors holding fund certificates as of March 31, 2025, was 12,484 investors.
• The Fund Representative Board held meetings ensuring at least once per quarter as stipulated in Article 34 of the Fund Charter. The Company held the Annual General Meeting of Investors for the SSIBF Fund in 2023 and 2024 as stipulated in Article 22 of the Fund Charter.
• Investment Results: According to the Fund's Q1/2025 Investment Activity Report, as of March 31, 2025, the net asset value per fund certificate was 15,900.88 VND; the realized investment result (cumulative from the beginning of the year) of the Fund was 4,033.07 million VND, and the cumulative investment result was 3,840.79 million VND.

2.4.4. SSI Member Investment Fund (SSIIMF)

• The Fund was established and operates under Notification No. 130/TB-UBCK dated July 27, 2010, by the SSC, with unlimited operational duration. The Fund's charter capital as of December 31, 2024, was 530,500 million VND. The Fund has 02 contributing members: SSI (404,000 million VND, 76.15% ratio) and NDH (126,500 million VND, 23.85% ratio) according to the Notification Adjustment Certificate Confirming Fund Establishment No. 12/GCN-UBCK dated April 15, 2022. The Custodian Bank is NH Standard Chartered VN. The Fund currently has 03 members of the Representative Board and 02 Fund Managers.
• The Fund Representative Board holds meetings ensuring at least once per quarter as stipulated in Article 28 of the Fund Charter. The Company held the Annual General Meeting of Investors in 2023 and 2024 as stipulated in Article 18 of the Fund Charter.
• Investment Results: According to the Fund's Q1/2025 Investment Activity Report, as of March 31, 2025, the Fund's total assets were 588,090.3 million VND; the realized net result was -257.7 million VND; the Fund's net asset value was 587,365.3 million VND; the net asset value per 01 fund unit was 11,071.91 VND.

2.4.5. Vietnam Digital Technology and Healthcare Investment Fund (VDHF)

• The Fund was established on September 29, 2021, under Member Fund Registration Certificate No. 38/GCN-UBCK with the name Vietnam Digital Technology Investment Fund, with an operational duration of 05 years from the date of establishment. On May 15, 2023, the SSC issued Certificate No. 53/GCN-UBCK adjusting the Member Fund Establishment Certificate, whereby the Fund changed its name to Vietnam Digital Technology and Healthcare Investment Fund. The Fund's charter capital is 50,000 million VND, consisting of 02 contributing members: SK South East Asia Investment (80%) and SSI (20%). The Custodian Bank is Woori Bank Vietnam Joint Stock Company Limited. The Fund currently has 03 members of the Representative Board and 02 Fund Managers.
• The Fund Representative Board holds meetings ensuring at least once per quarter as stipulated in Article 28 of the Fund Charter. The Company held the Annual General Meeting of Investors in 2023 and 2024 as stipulated in Article 18 of the Fund Charter.
• Operational Results: According to the Fund's Investment Activity Report, as of March 31, 2025, the Fund's total assets were 55,722 million VND; the realized net result distributed during the period was 130.3 million VND; the Fund's net asset value was 55,315.8 million VND; the net asset value per 01 fund unit was 11,063.16 VND/fund certificate.

2.4.6. SSIAM VNX50 ETF Fund

• The SSIAM HNX30 ETF Fund (predecessor of the SSIAM VNX50 ETF Fund) was established as an ETF Fund under Public Fund Establishment Certificate No. 17/GCN-UBCK issued by the SSC on December 10, 2014, with an initial charter capital of 101,000 million VND, and unlimited operational duration. On August 21, 2017, the SSC issued Amendment Certificate No. 02/GCN-UBCK changing the Fund's name to SSIAM VNX50 ETF Fund. The Fund switched to tracking the VNX50 index. The Custodian and Supervising Bank is BIDV Ha Thanh. The Transfer Agent is VSDC. The Fund currently has 03 members of the Representative Board and 02 Fund Managers. The Fund has 07 fund certificate distribution agents. The number of investors holding fund certificates as of March 31, 2025, was 1,869 investors.
• The Fund Representative Board held meetings ensuring at least once per quarter as stipulated in Article 32 of the Fund Charter. The Company held the Annual General Meeting of Investors for the Fund in 2023 and 2024 as stipulated in Article 21 of the Fund Charter.
• Operational Results: According to the Fund's Q1/2025 Investment Activity Report, as of March 31, 2025, the net asset value per fund unit was 20,276.68 VND; the realized investment result (cumulative) of the SSIAM VNX50 ETF Fund was -209.7 million VND, and the cumulative investment result was 1,132.49 million VND.

2.4.7. SSIAM VN30 ETF Fund

• The SSIAM VN30 ETF Fund was established as an ETF Fund under Public Fund Registration Certificate No. 45/GCN-UBCK dated July 22, 2020, with an initial charter capital of 56,000 million VND, and unlimited operational duration. The Custodian and Supervising Bank is Joint Stock Commercial Bank for Foreign Trade of Vietnam. The Transfer Agent is VSDC. The Fund currently has 04 members of the Representative Board and 02 Fund Managers. The Fund has 06 fund certificate distribution agents. The number of investors holding fund certificates as of March 31, 2025, was 1,796 investors.
• The Fund Representative Board held meetings ensuring at least once per quarter as stipulated in Article 33 of the Fund Charter. The Company held the Annual General Meeting of Investors for the Fund in 2023 and 2024 as stipulated in Article 23 of the Fund Charter.
• Operational Results: According to the Fund's Investment Activity Report as of March 31, 2025, the net asset value per fund unit was 16,888.09 VND; the realized investment result (cumulative from the beginning of the year) of the Fund was 859.01 million VND, and the cumulative investment result was 1,813.57 million VND.

2.4.8. SSIAM VNFIN LEAD ETF Fund

• The SSIAM VNFIN LEAD ETF Fund was established as an ETF Fund under Public Fund Establishment Certificate No. 42/GCN-UBCK issued by the SSC on February 24, 2020, and most recently adjusted on December 19, 2022, under License Adjustment No. 122/GPĐC-UBCK of the SSC, with an initial charter capital of 262,000 million VND, and unlimited operational duration. The Custodian and Supervising Bank is Joint Stock Commercial Bank for Foreign Trade of Vietnam. The Transfer Agent is VSDC. The Fund currently has 04 members of the Fund Representative Board and 02 Fund Managers. The Fund has 07 fund certificate distribution agents. The number of investors holding fund certificates as of March 31, 2025, was 2,047 investors.
• The Fund Representative Board held meetings ensuring at least once per quarter as stipulated in Article 33 of the Fund Charter. The Company held the Annual General Meeting of Investors for the Fund in 2023 and 2024 as stipulated in Article 23 of the Fund Charter.
• Operational Results: According to the Fund's Q1/2025 Investment Activity Report, as of March 31, 2025, the net asset value per fund unit was 22,981.85 VND; the realized investment result (cumulative from the beginning of the year) of the Fund was 23,585.61 million VND, and the cumulative investment result of the Fund was 22,277.72 million VND.

2.5. Investment Portfolio Management Activities
The Company issued Decision No. 22/2023/QĐ-SSIAM-ĐT dated August 9, 2023 (this Decision replaces Decision No. 34/2020/QĐ-SSIAM-ĐT dated October 7, 2020) regarding the issuance of the Investment Portfolio Management Procedure, and Decision No. 36/2020/QĐ-SSIAM-ĐT dated October 7, 2020, regarding the issuance of the Asset Allocation Procedure.
During the inspection period, the total number of investment portfolio management contracts the Company managed at various times were as follows: As of January 1, 2023: 53 contracts, including 24 contracts with institutional clients and 29 contracts with individual clients; As of December 31, 2023: 49 contracts, including 27 contracts with institutional clients and 22 contracts with individual clients; As of December 31, 2024: 57 contracts, including 27 contracts with institutional clients and 30 contracts with individual clients; As of March 31, 2025: 61 contracts, including 27 contracts with institutional clients and 34 contracts with individual clients. The Company signed Securities Custody Contracts with BIDV - Ha Thanh Branch, Joint Stock Commercial Bank for Industry and Trade of Vietnam - Hanoi City Branch (Vietinbank - Hanoi Branch); accordingly, BIDV - Ha Thanh Branch and Vietinbank - Hanoi Branch opened and managed custody accounts in the name of SSIAM for each delegating investor. Specifically, for some insurance company clients, assets are custodied at HSBC Bank Vietnam Limited (HSBC). Additionally, some institutional and individual clients delegated portfolio management on their securities trading accounts at SSI Securities Company. During the inspection period, the Company had 09 institutional clients, accounting for a large proportion of the total delegated investment portfolio. Sampling inspection results showed that, basically, delegating clients authorized the Company to hold the investment portfolio in its name, except for some delegating clients that are insurance organizations. For some delegating clients that are insurance organizations, the clients are registered as owners on all accounts used for investment activities; all assets of the investment portfolio are registered under the client's name; the client authorizes the Company to make investment decisions and execute related transactions in accordance with investment requirements, investment restrictions under the contract, and legal regulations. The Company implements investment portfolio activity reports for delegating clients as stipulated. Annually, the Company has issued documents updating information and identifying clients as stipulated. For individual clients, the Company signs Investment Delegation Contracts with clients and mainly opens custody accounts for each client at BIDV Ha Thanh. Basically, delegating clients authorize the Company to hold the ownership title according to the investment portfolio, except for some delegating clients managing assets on securities trading accounts opened at SSI. The Company implements investment portfolio activity reports for delegating clients as stipulated. Annually, the Company has issued documents updating information and identifying clients as stipulated.

2.6. Securities Investment Advisory Activities
The Company issued business procedures for securities investment advisory under Decision No. 20/2023/QĐ-SSIAM-PC dated August 9, 2023, which replaces Decision No. 24/2013/QĐ-SSIAM-PC dated October 31, 2013.
During the inspection period, the Company implemented 21 securities investment advisory contracts, of which 16 advisory contracts were terminated with clients. At the time of inspection, 02 staff members of the Company performed investment advisory business: Mr. Nguyen Manh Hung and Ms. Tran Thuy Trang, who are employees holding securities business certificates as stipulated in Clause 3 of Article 22 of Circular No. 99/2020/TT-BTC.
During the inspection period, the Company committed a violation by assigning staff as investment advisory employees who were simultaneously members of the Company's Investment Council, participating in signing off on investment items of investment funds and delegated investment portfolios, violating the regulation in point b, Clause 20, Article 10 of Circular No. 99/2020/TT-BTC. On October 13, 2023, the SSC issued Administrative Penalty Decision No. 894/QĐ-XPHC against the Company, which included the violation of assigning staff, securities practitioners, to hold concurrent positions in cases where concurrency is not allowed, as stipulated in point c, Clause 1, Article 32 of Government Decree No. 156/2020/NĐ-CP dated December 31, 2020, regulating administrative penalties in the field of securities and the securities market (Decree No. 156/2020/NĐ-CP). According to the Company's report and documents provided, the Company assigned Mr. Nguyen Manh Hung as an advisory specialist and was responsible for receiving the handover of advisory clients; the Company notified clients of the change of advisory specialist. The revenue from securities investment advisory activities of the Company in 2023, 2024, and Q1/2025, according to the audited financial statements for 2023, 2024, and Q1/2025, were 30,194.85 million VND, 33,845.15 million VND, and 11,714.6 million VND, respectively.

2.7. Anti-Money Laundering Work
The Company has issued an Internal Regulation implementing measures for anti-money laundering, anti-terrorist financing, and anti-proliferation of weapons of mass destruction.
The Company has assigned staff responsible for anti-money laundering work and has registered with the Anti-Money Laundering Department under the State Bank of Vietnam information about the officer responsible for reporting anti-money laundering work as stipulated.
The Company has prepared and submitted internal audit reports on anti-money laundering work for 2023 and 2024 as stipulated in Clause 10 of Article 5 of Circular No. 09/2023/TT-NHNN dated July 28, 2023, by the Governor of the State Bank of Vietnam guiding the implementation of certain articles of the Law on Anti-Money Laundering (Circular No. 09/2023/TT-NHNN); Risk Assessment Reports on anti-money laundering and terrorist financing for 2023 and 2024 to the Anti-Money Laundering Department, State Bank of Vietnam, as stipulated in Clause 1 of Article 15 of the Law on Anti-Money Laundering and Clause 5 of Article 3 of Circular No. 09/2023/TT-NHNN. The Company has propagated and disseminated internally the Report on the results of the national risk assessment on the proliferation of weapons of mass destruction issued under Decision No. 828/QĐ-TTg dated May 31, 2021, by the Prime Minister of the Government. According to the Company's report, the Company is currently applying customer identification and information update measures as stipulated, including collecting information, updating information, and verifying and cross-checking customer information with blacklists, lists of individuals related to terrorism and terrorist financing, and warning lists provided by the Ministry of National Defense and the State Bank of Vietnam under Article 22 of Decree No. 81/2019/NĐ-CP dated November 11, 2019, on anti-proliferation of weapons of mass destruction; the Company has conducted checks and reviews of customers, customer transactions, and parties related to customer transactions with lists of organizations and individuals related to terrorism and terrorist financing as stipulated in Clause 1 of Article 8 of Decree No. 122/2013/NĐ-CP dated October 11, 2013, of the Government, amended and supplemented according to Clause 9 of Article 1 of Decree No. 93/2024/NĐ-CP dated July 18, 2024, of the Government.

2.8. Reporting and Information Disclosure Regime

• Regarding the subject of information disclosure:
  The person responsible for implementing information disclosure of the Company is Ms. To Thuy Linh, Deputy General Director.
  The Company has established the electronic website https://ssiam.com.vn to implement periodic and irregular information disclosure obligations as stipulated.
• Regarding the reporting and information disclosure regime: During the inspection period, the Company basically complied with the reporting and information disclosure regime as stipulated.

2.9. Financial Investment Activities
The Company issued Decision No. 21/2023/QĐ-SSIAM-ĐT dated August 9, 2023, regarding the procedure for investing from SSIAM's equity capital.
According to the audited Financial Statements for 2023 and 2024, and the Q1/2025 Financial Statement of the Company, the total value of the Company's financial investment items at the times of January 1, 2023, December 31, 2023, December 31, 2024, and March 31, 2025, were 196,089.41 million VND; 319,944.27 million VND; 380,996.90 million VND; and 357,283.85 million VND, respectively. During the inspection period, the Company's financial investment items were all short-term financial investments (mainly into listed stocks, listed bonds, and certificates of deposit), with no long-term financial investments.

2.10. Financial Safety Ratio Report
The Company prepared and implemented periodic reports to the SSC on the financial safety ratio as stipulated in Circular No. 91/2020/TT-BTC dated November 13, 2020, by the Minister of the Ministry of Finance regulating financial safety indicators and handling measures for securities business organizations that do not meet financial safety indicators (Circular No. 91/2020/TT-BTC).
According to the Company's report, the available capital ratio according to the audited and reviewed Financial Safety Ratio Reports at the times of June 30, 2023, December 31, 2023, June 30, 2024, and December 31, 2024, were 410.36%; 466.38%; 473.03%; and 451.83%, respectively. Basically, the Company's available capital ratio meets the financial safety indicator for securities business organizations as stipulated in Circular No. 91/2020/TT-BTC.

3. Conclusion
   During the inspection period, the Company basically complied with the law on securities and the securities market in its licensed business activities. The Company committed a violation by assigning staff, securities practitioners, to hold concurrent positions in cases where concurrency is not allowed, as stipulated in point b, Clause 20, Article 10 of Circular No. 99/2020/TT-BTC.

4. Handling Measures within Competence
   On October 13, 2023, the SSC issued Administrative Penalty Decision No. 894/QĐ-XPHC against the Company, imposing a fine of 40,000,000 (Forty Million) VND for the violation of regulations on assigning staff, securities practitioners, to hold concurrent positions in cases where concurrency is not allowed, as stipulated in point c, Clause 1, Article 32 of Decree No. 156/2020/NĐ-CP.

5. Recommendations for Handling Measures
   The Inspectorate of the SSC requests the Company to continue strictly complying with the regulations on securities and the securities market and related legal regulations.