Harvest Global Investments Limited

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of
o
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event
gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HARVEST FUND MANAGEMENT CO.,
LTD
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that
event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than
ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CHINA SECURITIES REGULATORY COMMISSION
2.
Principal Sanction:
Other
Other Sanctions: 
ADMINISTRATIVE MEASURES
3.
Date Initiated (MM/DD/YYYY): 
02/13/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHINA SECURITIES REGULATORY COMMISSION (THE "CSRC") HAS IDENTIFIED THE FOLLOWING MAIN ISSUES IN RELATION TO THE COMPANY DURING AN EARLIER
INDUSTRY EXAMINATION, MAINLY COVERING CERTAIN NON COMPLIANCE ISSUES IN RELATION TO THE MANAGEMENT ISSUES OF PORTFOLIO MANAGER'S APPOINTMENT AND
AUTHORIZATION, INEFFECTIVE IMPLEMENTATION OF THE STAFF COMMUNICATION TOOLS POLICY AND CERTAIN DEFICIENCIES IN RELATION TO STAFF'S PERSONAL ACCOUNT
DEALING POLICIES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
05/13/2015
 Exact
 Explanation
If not exact, provide explanation:
ADMINISTRATIVE MEASURES ON THE COMPANY ORDERING IT TO IMPLEMENT RECTIFICATION ACTIONS FOR A PERIOD OF THREE MONTHS FROM FEBRUARY 13, 2015. DURING
THE RECTIFICATION PERIOD, THE REGISTRATION OF THE COMPANY'S RETAIL FUND PRODUCTS WILL NOT BE PROCESSED.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations
Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and
whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion
levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
NOT APPLICABLE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space
provided).
THE COMPANY HAS TAKEN THE FOLLOWING RECTIFICATION MEASURES AND HAS SUBMITTED WRITTEN REPORT OF THE SAME TO THE CSRC: 1.STRICTLY ENFORCE
MANAGEMENT OF ACCESS RIGHTS RELATING TO INVESTMENT PERSONNEL AND STRENGTHEN INTERNAL CONTROLS CONCERNING APPROVAL OF ACCESS RIGHTS 2.STRENGTHEN
MANAGEMENT POLICY OF STAFF COMMUNICATION TOOLS. INVESTMENT AND RESEARCH PERSONNEL ARE REQUIRED TO SURRENDER THEIR MOBILE PHONES AND KEEP THE
SAME IN DESIGNATED LOCKED AREA. REGISTRATION IS REQUIRED FOR TEMPORARY COLLECTION OF MOBILE PHONE. REGULAR SURVEILLANCE IN THIS CONNECTION HAS ALSO
BEEN STRENGTHENED. 3.ENHANCE THE STAFF PERSONAL ACCOUNT DEALING POLICIES WITH TOUGHER PUNITIVE MEASURES. FURTHER STRENGTHEN MANAGEMENT OF STAFF
PERSONAL ACCOUNT DEALING 4.ENHANCE STAFF PERSONAL ACCOUNT DEALING DECLARATION'S REQUIREMENTS IN RELATION TO COMPLETE COVERAGE OF THE STAFF
MEMBERS' RELATIVES. STRENGTHEN POST-EVENT REVIEW IN RELATION TO THE OPENING OF STAFF PERSONAL ACCOUNTS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of
Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event
gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HARVEST FUND MANAGEMENT CO.,
LTD
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that
event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than
ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.

 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CHINA SECURITIES REGULATORY COMMISSION
2.
Principal Sanction:
Other
Other Sanctions: 
ADMINISTRATIVE MEASURES
3.
Date Initiated (MM/DD/YYYY): 
12/03/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHINA SECURITIES REGULATORY COMMISSION (THE "CSRC") HAS IDENTIFIED THE FOLLOWING MAIN ISSUES IN RELATION TO THE COMPANY, MAINLY COVERING CERTAIN
NON COMPLIANCE ISSUES IN RELATION TO THE MANAGEMENT ISSUES OF COMPLIANCE AND INTERNAL CONTROL, INVESTMENT MANAGEMENT AND CORPORATE FINANCE
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
02/03/2026
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NOT APPLICABLE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations
Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and
whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion
levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
NOT APPLICABLE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space
provided).
THE COMPANY HAS COMPLETED THE RECTIFICATION BY STRENGTHENING INSTITUTIONAL DEVELOPMENT, IMPROVING INTERNAL PROCESSES AND MECHANISMS, OPTIMISING
SYSTEM FUNCTIONS AND ENHANCING STAFF TRAINING, AND HAS SUBMITTED A RECTIFICATION COMPLETION REPORT TO THE BEIJING CSRC.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part 1A or Item 2.F. of Part
1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated
civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HARVEST FUND MANAGEMENT CO.,
LTD. ("HFM")
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.(1)(a), and only if that
event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than
ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
KRANE DISTRIBUTION, LLC ("KD")
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
SPECIFIC PERFORMANCE OF CONTRACT

3.
Filing Date of Court Action (MM/DD/YYYY):
05/19/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
EXCHANGE TRADED FUNDS
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): 
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 14-CV-3589.
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
KD ALLEGES THAT HGI AND ITS PARENT, HFM SET UP (THROUGH THEIR AFFILIATE) A UNITED STATES ENTITY WITH KD IN ORDER TO MISAPPROPRIATE KD'S INTELLECTUAL
PROPERTY REGARDING DISTRIBUTION OF MUTUAL FUNDS AND EXCHANGE TRADED FUNDS IN THE UNITED STATES AND CANADA.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
05/30/2014
 Exact
 Explanation
If not exact, provide explanation:
30 MAY 2014 (ON HGI) AND 23 JANUARY 2015 (ON HFM)
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
10/05/2015
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
A SETTLEMENT AGREEMENT HAS BEEN EXECUTED AMONG THE PARTIES. ALL ACTIONS FILED BY KD AGAINST HGI AND/OR HUSA AND HFM WERE DISMISSED.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations
Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and
whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement, or monetary compensation, provide total amount, portion
levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
THE PARTIES' BUSINESS RELATIONSHIP HAS BEEN SEVERED AND HUSA IS NOW THE SOLE OWNER OF HARVEST KRANE LLC.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space
provided). 
THE CLAIMS MADE BY KRANE DISTRIBUTION WERE WITHOUT MERIT. THE PARTIES TO THE ACTION SETTLED THE MATTER AND KD DISMISSED ALL ACTIONS AGAINST HGI AND/OR
HUSA AND HFM. THE PARTIES EXCHANGED MUTUAL RELEASES. KD ALSO RELINQUISHED ITS OWNERSHIP INTEREST IN HARVEST KRANE, LLC FOR THE SUM OF $400,000. THE
OPERATING AGREEMENT WAS TERMINATED AND ALL KD'S REPRESENTATIVES RESIGNED FROM THE BOARD OF DIRECTORS. KD AGREED TO PROVIDE THE FOLLOWING APOLOGY
TO HUSA AND HGI?. "[KRANE DISTRIBUTION LLC] APOLOGIZES FOR ANY RHETORIC IN ANY OF ITS SUBMISSIONS FILED IN THE DELAWARE ACTION, NEW YORK ACTION, OR
HONG KONG ARBITRATION, THAT MAY HAVE CAST ASPERSIONS ON THE CHARACTER, HONOR, OR ETHICS OF [HARVEST FUND MANAGEMENT LIMITED, HARVEST GLOBAL
INVESTMENTS LIMITED, AND HARVEST USA, INC.]