This Disclosure Statement serves as a formal explanation of how Halogen Capital Sdn Bhd (“Halogen Capital”) utilises proprietary technology, automated systems, and algorithmic logic to manage your investment assets.

Halogen Capital utilises a proprietary Digital Investment Management ("DIM") framework designed to bridge the gap between institutional-grade expertise and digital accessibility. This framework combines the strategic oversight of our Investment Committee with the precision of automated algorithmic execution. Our primary objective is to provide a seamless investment experience that adheres to disciplined financial principles, ensuring that every portfolio is managed with consistency, transparency, and a focus on long-term outcomes.

Before any investment is made, our proprietary Suitability Assessment Algorithm evaluates your profile to recommend a portfolio that is suitable for you. This process ensures that your investment strategy is aligned with your personal financial circumstances.

The system evaluates your financial knowledge, specific investment objectives, intended time horizon, liquidity requirements, and overall risk tolerance. Based on the aggregate score of these factors, the algorithm assigns a risk profile and recommends one of our core Portfolios.

While the algorithm provides a recommended "best-fit" portfolio based on your data, you retain the option to customise your portfolio by selecting a risk level higher or lower than the recommendation, provided you acknowledge the specific risk disclosures associated with such a change.

You hereby acknowledge that you are solely responsible for providing accurate and complete information. Any inaccurate or misleading data provided by you will lead to an unsuitable portfolio recommendation, for which Halogen Capital shall not be held liable.

We use tolerance bands rebalancing to maintain your portfolio’s target asset allocation. Over time, your portfolio can drift in its actual allocations. For example, equities may rise faster than bonds, becoming a larger portion of your portfolio than previously, and exposing you to more risk than you originally intended.

Our system monitors your portfolio and automatically rebalances it only when allocations move outside predefined thresholds. This innovative, automated approach brings your portfolio back in line, while minimising unnecessary trading.

Why rebalancing matters:

1. Manages risk: keeps your portfolio aligned with your chosen risk profile.
2. Supports disciplined investing: follows a rules-based approach rather than reacting emotionally.
3. Removes emotion from decisions: helps you avoid buying high or selling low.
4. Helps you stay on track: ensures your investment strategy stays consistent over time.

Portfolio rebalancing is one of the most essential habits of long-term, successful investors, and through our Rebalancing Algorithm, we have automated it for you.

While technology enhances efficiency, you must be fully aware of the specific risks inherent to Digital Investment Management:

1. Algorithm and Model Risk: The software may perform differently than intended during extreme market volatility events where historical data patterns no longer apply.
2. Technical Assumptions: The algorithm assumes that historical correlations between asset classes will persist; should these correlations break down, the portfolio may experience volatility levels exceeding your initial expectations.
3. Technology and Cybersecurity Risk: System downtime, software bugs, or connectivity issues may occasionally delay rebalancing activities. While we maintain robust disaster recovery plans, these external factors can impact trade timing.
4. No Human Intervention in Execution: Trades are automated based on programmed logic. The algorithm does not "wait" for news cycles or subjective sentiment unless the Investment Committee manually intervenes to suspend the system.

We believe in being upfront about costs and, Halogen Capital operates under a "No Hidden Fee" policy. You agree to the following costs associated with your account:

1. Management Fee: A simple annual fee for managing your portfolio, calculated and accrued daily based on the daily net asset value ("NAV") before management fees of your investment assets and shall be payable by deducting from the portfolio account at the end of the month.
2. Portfolio Expenses: Essential third-party costs, such as audit and custodian fees, which are generally embedded within the fund's NAV.
3. Transaction Costs: Costs arising from asset switching or rebalancing activities are borne by the portfolio where applicable. We strive to minimise these through efficient trade grouping.

Our core portfolios are thoroughly reviewed every quarter by Halogen Capital Fund Management's Investment Committee. We evaluate how each portfolio has performed over the past three years and whether the actual volatility stays within the limits of the intended risk profiles.

If we find that a portfolio is drifting from its goals, whether due to market changes, new opportunities, or better data; we may fine-tune the strategy to ensure each core portfolio stays 'true to label'. You will be provided with an advance notice via email or app notification regarding any material changes.

We take a data-driven, research-backed approach, and only make changes that we believe are in your best interest.

For full terms and conditions, please refer to our Digital Investment Management Client Agreement and Terms of Use.

We're here to help. If you have a question or want to talk to a real person:

1. Email: support@halogen.my
2. Phone: +603-2779 2990
3. Address: Halogen Capital Sdn Bhd, 3.01A Level 3 Menara BRDB, 285 Jalan Maarof, 59000 Kuala Lumpur.

We aim to respond within 2 business days and resolve most issues within 14 business days.

If you're still not satisfied, you can contact the Financial Markets Ombudsman Service (FMOS):

1. Website: www.fmos.org.my
2. Phone: +603-2272 2811
3. Address: Financial Markets Ombudsman Service, Level 14, Menara Takaful Malaysia, No. 4, Jalan Sultan Sulaiman, 50000 Kuala Lumpur

You can also direct your complaint to the SC even if you have initiated a dispute resolution process with FMOS. To make a complaint, please contact the SC’s Consumer & Investor Office:

1. Website: www.sc.com.my
2. Email: aduan@seccom.com.my
3. Phone: +603-6204 8999
4. Address: Consumer & Investor Office, Securities Commission Malaysia, 3 Persiaran Bukit Kiara, 50490 Kuala Lumpur.