Governance

Governance & Risk

Who decides what, which limits may never be crossed, and what gets reported to whom.

Decision bodies

Family Council

Highest body: approves the Investment Policy Statement, target allocation, capital-flow rules, major family expenditures and admission of new members.

Members: Adult family members who contribute capital
Cadence: Annually (December) and ad hoc
Quorum: ≥ 2/3 of members; decisions by capital-weighted majority

Investment Committee

Approves new strategies and PE/VC deals, reviews desk performance and risk-limit compliance.

Members: CIO, investment desk heads, a Wealth Management representative
Cadence: Quarterly; emergency session on any risk-limit breach
Quorum: CIO + at least one other member

Family Wealth Committee

Oversees liquidity, tax, pension, insurance and succession; sets the constraints the Investment Division must respect.

Members: Family CFO, heads of Treasury, Tax and Pension desks
Cadence: Quarterly
Quorum: CFO + one member

Roles

Chief Investment Officer

Accountable for Investment Division performance
Proposes allocation and strategies to the Council
Maintains the investment decision log

Family Chief Financial Officer

Accountable for liquidity, tax, pension, insurance
Produces the consolidated monthly NAV report
Keeps the central asset register

Desk Head

Runs the desk's books and strategies within approved limits
Reports performance and any limit breach immediately
Reviews each strategy at least annually

Risk & Compliance Officer

Checks risk limits independently of the desks
Tracks legal changes (Regulatory register) and updates statuses
Has authority to halt trading on a breach

Decision matrix

Decision	Approver
Trade within an approved strategy and its limits	Desk Head
New strategy or change to strategy rules	Investment Committee
PE/VC deal (2 tỷ VND)	Investment Committee (below VND 2bn)
Large PE/VC deal (2 tỷ VND)	Family Council (VND 2bn and above)
Change target allocation or capital-flow rules	Family Council
Withdrawal from the Long-term horizon	Family Council
Open a foreign investment channel	Family Council + written legal opinion

Risk limits

Scope	Limit	Action on breach
Fund-wide	No listed position > 10% of NAV	Trim to 8% within 30 days
Digital assets	≤ 15% of NAV	Stop buying; Committee considers trimming
PE + VC + real estate	≤ 30% of NAV	No new deals until below threshold
Short-term trading books	2% of NAV per month, 6% per year	Halt trading until review
Fund-wide	Debt/NAV ≤ 10%; no borrowing in the Long horizon	Repay within 60 days
Family Treasury	Reserve ≥ 6 months of expenses	Trigger the Reserve-refill flow
Banks / exchanges / brokers	≤ 25% of NAV at any one counterparty	Diversify within 30 days

Reporting

Report	Cadence	Audience
Consolidated NAV by horizon, desk and asset class	Monthly	Family Council
Risk-limit checklist and breaches	Monthly	Investment Committee
Each strategy vs. its KPIs	Quarterly	Investment Committee
Tax calendar and estimated liabilities	Quarterly	Family Wealth Committee
Annual report: performance, allocation, next-year plan, legal update	Annually	Whole family

Internal family document — not investment advice and not an offer of securities.