Compliance &
Disclosures

Firm Registration

Vantage Capital Group (Private) Limited is registered with the Securities and Exchange Commission of Sri Lanka as a Licensed Investment Manager under the Securities and Exchange Commission Act No. 36 of 1987, as amended. Registration No: VCG/SEC/2024/0042.

Our Singapore subsidiary, Vantage Capital Management (Singapore) Pte Ltd, holds a Capital Markets Services Licence issued by the Monetary Authority of Singapore (MAS Licence: CMS100789-2).

• Registered principal office: One Vantage Plaza, Floor 42, Colombo 01, Sri Lanka
• Incorporated in Sri Lanka, Company No: PV 12384
• VAT Registration No: 114023456-7000
• Directors: Marcus Ellerton, Sophia Ellerton-Vaas, Damien Frost

Risk Disclosures

Investments are subject to market risk, including the possible loss of principal. Past performance of any investment is not indicative of future results. Investment returns and the value of an investment will fluctuate, so that an investor's investment, when sold, may be worth more or less than its cost.

The following specific risks apply to services provided by Vantage Capital Group:

• Market Risk: Fluctuations in securities prices, interest rates, and foreign exchange rates may adversely affect portfolio values.
• Liquidity Risk: Alternative investments, private equity, and direct lending instruments may have limited liquidity and long lock-up periods.
• Credit Risk: Issuers of debt instruments may default on their obligations, resulting in partial or total loss of investment.
• Currency Risk: Investments denominated in foreign currencies are subject to exchange rate fluctuations that may affect returns.
• Concentration Risk: Concentrated portfolios may experience greater volatility than diversified portfolios.
• Regulatory Risk: Changes in laws or regulations in any jurisdiction may adversely affect investments or the firm's ability to conduct business.

Fee Structure

Vantage Capital Group operates on a fee-only basis. We do not accept commissions, trails, or any third-party remuneration. All fees are fully disclosed to clients prior to engagement and are documented in the Investment Management Agreement.

• Wealth Management: Annual advisory fee of 0.65%–0.85% of assets under management, billed quarterly in arrears. Fee scale available upon request.
• Portfolio Strategy Mandate: Annual fee of 0.50%–0.70% of mandate value.
• Estate Planning: Fixed project fees, agreed prior to engagement. Range: USD 15,000–USD 85,000 depending on complexity.
• Family Office: Annual retainer of USD 120,000–USD 250,000, plus AUM-based fee for assets under advisement.

Clients are responsible for custodial fees, brokerage commissions, fund management fees (for any underlying funds held), and applicable taxes. These are disclosed separately in client reporting.

Conflicts of Interest

As a fee-only registered investment advisor, Vantage Capital Group's primary conflicts of interest are minimised by our compensation structure. However, we disclose the following potential conflicts:

• Partners and staff may hold personal investments in securities recommended to clients. We maintain a restricted list and require pre-clearance for personal trades.
• The firm may recommend third-party services (legal, accounting) where the relationship has no financial benefit to Vantage Capital Group.
• Certain proprietary research tools and analytics platforms are used firm-wide, representing an efficiency that benefits the firm as well as clients.

A complete Conflicts of Interest Policy is available upon request and is provided to all clients at the commencement of an engagement.

Privacy Policy

Vantage Capital Group treats client information with the highest degree of confidentiality. We collect only the personal and financial information necessary to deliver services and meet regulatory obligations.

• Client information is never sold or rented to third parties.
• Information is shared with service providers solely to facilitate client services, under strict confidentiality agreements.
• Clients have the right to access, correct, and request deletion of personal data, subject to regulatory retention requirements.
• We comply with the Personal Data Protection Act (Sri Lanka) and applicable GDPR principles for European-resident clients.

Data Handling & Security

Client data is stored in ISO 27001-certified secure environments with end-to-end encryption. All electronic communications with clients use TLS 1.3 or higher. Client portal access is protected by multi-factor authentication.

• Data is stored in Sri Lanka and Singapore-based servers with no transfer to non-equivalent jurisdictions.
• Employee access to client data is governed by a strict need-to-know policy.
• Annual penetration testing is conducted by an independent cybersecurity firm.
• In the event of a data breach, clients will be notified within 72 hours.

Complaints Procedure

Vantage Capital Group takes client complaints seriously and is committed to resolving them promptly and fairly. All complaints should be submitted in writing to our Compliance Officer.

• Complaints are acknowledged within 2 business days of receipt.
• A full written response is provided within 14 business days.
• Unresolved complaints may be escalated to the Securities and Exchange Commission of Sri Lanka.

Compliance Officer:
Email: [email protected]
Post: Attn: Compliance Officer, One Vantage Plaza, Floor 42, Colombo 01, Sri Lanka

Regulatory Contact Information

Securities & Exchange Commission of Sri Lanka
No. 29, Sri Jayawardenepura Mawatha, Rajagiriya, Sri Lanka
Tel: +94 11 243 7042
www.sec.gov.lk

Monetary Authority of Singapore
10 Shenton Way, MAS Building, Singapore 079117
www.mas.gov.sg