Asia Investment Management Inc.("A.I.M.")
Asia Investment Management Inc.
Trusted Value Creator

[Code of Ethics]

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Asia Investment Management Inc. (“A.I.M.”) is an asset management company, established according to the Real Estate Investment Company Act and in purposes of expanding opportunities to invest in real estate for the public and activating healthy real estate investments to contribute to the national economy.

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A.I.M. adopts the following code of ethics in order to expand opportunities for the general public to make investments in real estate and to protect its investors. A.I.M. also ensures that its directors and employees abide by the code.

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First, all directors and employees of A.I.M. shall be honest, sincere and fair when conducting business, keeping in mind the social and ethical responsibilities that companies should partake in, and making efforts to win the trust of society as an asset management company (“AMC”) established in accordance to the Real Estate Investment Company Act.

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Second, all directors and employees of A.I.M. shall not be engaged in any unjust transactions that may harm market stability and the soundness of the investment assets. They shall do their best to abide by all the relevant laws and related regulations and practice transparent management operations.

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Third, all directors and employees of A.I.M., as an AMC which must have protecting investors’ profits as its base ideology, shall continue to make efforts to enhance their expertise and skills, establish reasonable and detailed business plans and fulfill their obligations as good managers.

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Fourth, all directors and employees of A.I.M. shall do their best to prevent any conflicts of interest arising between themselves and investors or among other investors, shall not disclose information that they happen to obtain during the process of fulfilling their duties, and shall not attempt to gain profit by using such information.

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Fifth, all directors and employees of A.I.M. shall pledge to abide by the Ethics Code along with the Ethics Regulations and understand that they are subject to punishment if they violate the Ethics Code or the Ethics Bylaws.

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[Ethics Bylaws]

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Section 1: General Rules

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Article 1 (Purpose) These regulations are established in purposes of preventing the directors and employees of A.I.M. from engaging in unfair management activities and encouraging them to conduct management activities in an appropriate and legal manner.

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Article 2 (Compliance with Related Regulations) Directors and employees of A.I.M. shall fully understand and comply with not only these Ethics Bylaws but also with laws, regulations and rules of supervising authorities and related organizations, as well as the A.I.M.’s articles of association and its bylaws.

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Article 3 (Pledge) Directors and employees of A.I.M. shall vow and pledge to comply with the Ethics Code and the Ethics Bylaws.

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Section 2: Behavior Criteria

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Article 4 (Prohibition of Aid and Assistance) Directors and employees of A.I.M. shall not engage in activities that may assist colleagues dealing with, or about to deal with, work that violates the Ethical Regulations.

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Article 5 (Reporting Duty) Directors and employees of A.I.M. shall report to their superiors or the supervisor of legal compliance whenever they identify or suspect that any other directors and/or employees have breached bylaws or other relevant laws and regulations or if they believe that their positions or roles may cause a conflict of interest with customers or other business partners.

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Article 6 (Prohibition of Illegal and Unjust Behavior) Directors and employees of A.I.M. shall not engage in any one of the following activities under any circumstances:

1. Any management activity in violation of the investment standards or criteria determined by related laws and bylaws;

2. Any activity intended to gain personal profit or profit for any third party by revealing any of the operational strategies of the company

    and/or any other material information; 

3. Any and all investment activities based on instructions or recommendations of another company’s employees or those people not

    authorized by the Company or collusion with any party related to the real estate investment;

4. Any activity whereby specific clients or real estate investment company receives preferential treatment or damages through methods of

    real estate transactions or asset allocations, etc.; 

5. Any activity that gives preferential treatment to any third party, such as the company or an affiliate of the company, over the interests of

    the investors;

6. Any activity that guarantee a certain level of yield or promises to take on the entirety or any part of losses in an attempt to attract

    investments from investors; 

7. Any activity that take advantage of positions or roles in the company in an attempt to manipulate the price of a specific asset;  

8. Any activity including transactions listed below and any other unfair transactions:

    A. Unfair trade practices using “undisclosed information” or manipulation of market prices, etc.;

    B. The act of directors or employees who has “confidential information” disclosing to a third party or trading the related asset.

9. Any activity to sell off assets in order to increase sales commissions;

10. Any activity intended to attract multiple deals of asset transactions to a certain broker in order to seek personal profits or the profits of

      any third party; 

11. Any activity that provide other conditions than the terms stipulated in the agreement or the articles of association, or that present and

      promote a determined rate of return;

12. Any activity intended to promote personal, family or third party profits by taking advantage of their position or role in the company; 

13. Any activity intended to handle transactions based on rumors or the spreading of such rumors and making recommendations on those

      rumors;

14. Any activity intended to take advantage of their position or role in the company in order to manipulate the price of a specific real estate

      property or securities thereof.

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Article 7 (Prohibition of Gifts and Entertainment) Directors and employees of A.I.M. shall not give or receive any gifts or entertainment benefits that are contrary to rules that are universally accepted by society.

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Article 8 (Establishing Trust) Directors and employees of A.I.M. shall be honest when handling tasks and projects with people from other investment companies, the company and colleagues, and should maintain their trustworthiness and integrity as directors and employees of A.I.M. at all times.