4
Sector Rating Price target HK$1.33 52wk H-L (HK$) 1.81-1.02 Market cap (HK$) 3,285.0m Shrs outstanding 2,469.9m Main ownership 12/16A 12/17A 12/18E 12/19E EPS(HKD) 0.06 0.01 0.06 0.07 P/B(x) 1.0 0.9 0.7 0.7 P/E(x) 21.6 120.0 21.0 19.8 EV/EBITDA 8.2 13.6 9.1 8.1 Div. yield(%) 0.6 n.a n.a n.a ROE(%) 4.3% 0.8% 3.8% 3.3% ROA(%) 1.6% 0.3% 1.4% 1.4% Sources: Company data, Bloomberg, Anli research Sources: Bloomberg as of 16 May, 2018 Fig.1: Valuation comps P/B(x) 2017A 2018E 2019E 2017A 2342 HK COMBA TELECOM SY 418 1.33 120.0 21.0 19.8 0.9 0.3 0.8 -11.9 16.7 -11.3 763 HK ZTE-H suspended suspended 19.0 21.0 16.0 2.8 3.6 15.7 0.0 66.0 -12.8 947 HK MOBI DEVELOPMENT 122 1.17 n.a 11.9 10.0 0.7 -2.1 -4.0 30.0 -8.6 -21.5 1155 HK CENTRON TELECOM 31 0.29 1.4 n.a n.a 0.1 4.5 7.4 0.0 -46.3 -38.3 552 HK CHINA COMM SER-H 1,294 5.07 10.5 9.5 8.4 1.0 4.1 9.9 -1.0 8.7 -3.2 Average 37.7 15.8 13.5 1.1 2.1 6.0 n.a n.a n.a 002792 CH TONGYU COMMUNI-A 1,019 28.74 58.7 34.9 25.7 3.5 9.3 14.3 -3.6 -6.9 -19.2 300597 CH JILIN JLU COMMUN 689 18.29 101.6 n.a n.a 9.1 11.0 17.3 -6.1 -3.8 -12.3 002194 CH WUHAN FING -A 486 5.48 n.a n.a n.a 2.1 -20.0 -25.8 -5.4 -37.6 -46.9 300050 CH DINGLI COMMUNI-A 651 7.39 42.7 18.0 13.8 1.5 3.1 3.7 -1.9 -28.5 -6.1 300310 CH GUANGDONG EAST-A 1,258 8.96 33.8 23.8 17.8 2.3 5.4 6.7 -0.1 -34.3 -22.7 Average 59.2 25.6 19.1 3.7 1.8 3.2 n.a n.a n.a CSCO US CISCO SYSTEMS 219,101 45.48 21.5 17.5 15.8 4.3 -1.1 -2.5 -1.0 32.6 18.7 JNPR US JUNIPER NETWORKS 9,368 26.83 19.1 14.7 12.7 2.2 2.5 5.0 1.2 -12.3 -5.9 IBM US IBM 131,949 143.74 10.3 10.4 10.2 7.3 4.7 31.1 -0.3 -6.5 -6.3 Average 17.0 14.2 12.9 4.6 2.0 11.2 n.a n.a n.a Source: Bloomberg as of 16 May 2018, Anli research Px % chg. YTD ROA (%) ROE (%) P/E(x) A share TMT International TMT Px % chg. WTD Px % chg. 1 yr H share TMT Ticker Company name Mkt Cap (US$m) Last Price HK$1.6 TUNG LING FOK (32.79%) Kimmy Tong/+852 23235118/[email protected] Price performance Research Analyst Key indicator forecast Price (HK$/shr) as of 16 May, 2018 May 16, 2018 Comba Telecom (2342.HK); Future looks promising; BUY Key data TMT BUY Unstable share price movement. Comba Telecom’s share price dropped significantly on May 15, 2018 given large trading volume in sold shares. Management dismiss concerns raised by significant price movement on the market and claimed that company business operation and cashflow from operation remain stable. We attribute the share price movement to be related to the potential reversal of ZTE’s (763.HK suspended) ban by President Trump. It may have triggered some investors to shift its investing position from Comba Telecom to “ZTE concept stocks”, such as Mobi (764.HK). Thus, Mobi’s share price rebounded 23% while Comba Telecom’s share price plunged 18% post Trump’s intervention in ZTE. Diversified chips supply. Management mentions that any potential US-China trade war conflicts had not been affected, nor will it affect the Co.’s business structure as most of its chips not only come from US but also in Taiwan through third-party agents. However, they worry ZTE’s ban may delay the supply chain schedule of orders in 1H18, especially in the network system segment. Due to seasonality and ZTE sales ban, customers’ orders in 1Q18 have shifted, and management mentioned more orders will come in 2Q18. Ranked Top 2 supplier for China Unicom. China Unicom (762.HK) announced CAPEX increased by 19% to RMB50bn in FY2018E post mixed ownership reform in cooperation with BAT - Tencent (700.HK), Baidu (BIDU.US) and Alibaba (BABA.US). More importantly, Comba Telecom won 20-30% of tender bid from China Unicom post mix-ownership reform, making them the company with the 2nd most tender bids. Management said the orders will improve segment margins in upcoming years. As one of Comba Telecom’s three major customers, we project a larger revenue contribution, up from 15% last year as CU’s new stakeholders emphasize greater network capacity and productivity for FY2018E. We reiterate our BUY rating with a TP of HK$1.60/shr, implying a 20.3% upside. We think Comba Telecom’s result looks promising despite delay from ZTE sales ban & supply chain in FY1H18, given: 1) Potential customer’s orders increase post ZTE sales ban; 2) Uncertainty in ZTE sales ban this may allow Comba Telecom to expand its market share in China’s Telecom service industry; 3) Undemanding valuation as company NAV per share is HK$1.53 as of 31 Dec 2017, representing a ~15% of discount; 4) Ongoing share buyback for <100m shares, boosting Co.’s full year EPS growth; 5) Management guidance of overseas revenue to increase 20-30% YoY in FY2018E due to new metro project in Bangkok; 6) Business unaffected by US-China trade war, will remain as R&D developer in China’s 5G industry. Meanwhile, we uplift Comba Telecom EPS growth to reflect these positive factors. Key risks; Longer than expected transitional phase to 5G solutions, delayed tender bidding schedules for wireless network equipment; large volatility in foreign currency prices. 0 0.2 0.4 0.6 0.8 1 1.2 1.4 1.6 1.8 2 0 5000 10000 15000 20000 25000 30000 35000 HK$/shr Pts Hangseng Index (LHS) Comba (2342 HK) (RHS) 1

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Page 1: Comba Telecom (2342.HK); Future looks promising; BUYanli.com.hk/.../2018/05/Comba-Telecom-2342.HK-analysis-report.pdf · A share TMT International TMT WTD 1 yr ... won 20-30% of tender

Sector

Rating

Price targetHK$1.33

52wk H-L (HK$) 1.81-1.02

Market cap (HK$) 3,285.0m

Shrs outstanding 2,469.9m

Main ownership

12/16A 12/17A 12/18E 12/19E

EPS(HKD) 0.06 0.01 0.06 0.07

P/B(x) 1.0 0.9 0.7 0.7

P/E(x) 21.6 120.0 21.0 19.8

EV/EBITDA 8.2 13.6 9.1 8.1

Div. yield(%) 0.6 n.a n.a n.a

ROE(%) 4.3% 0.8% 3.8% 3.3%

ROA(%) 1.6% 0.3% 1.4% 1.4%Sources: Company data, Bloomberg, Anli research

Sources: Bloomberg as of 16 May, 2018

Fig.1: Valuation comps

P/B(x)

2017A 2018E 2019E 2017A

2342 HK COMBA TELECOM SY 418 1.33 120.0 21.0 19.8 0.9 0.3 0.8 -11.9 16.7 -11.3

763 HK ZTE-H suspended suspended 19.0 21.0 16.0 2.8 3.6 15.7 0.0 66.0 -12.8

947 HK MOBI DEVELOPMENT 122 1.17 n.a 11.9 10.0 0.7 -2.1 -4.0 30.0 -8.6 -21.5

1155 HK CENTRON TELECOM 31 0.29 1.4 n.a n.a 0.1 4.5 7.4 0.0 -46.3 -38.3

552 HK CHINA COMM SER-H 1,294 5.07 10.5 9.5 8.4 1.0 4.1 9.9 -1.0 8.7 -3.2

Average 37.7 15.8 13.5 1.1 2.1 6.0 n.a n.a n.a

002792 CH TONGYU COMMUNI-A 1,019 28.74 58.7 34.9 25.7 3.5 9.3 14.3 -3.6 -6.9 -19.2

300597 CH JILIN JLU COMMUN 689 18.29 101.6 n.a n.a 9.1 11.0 17.3 -6.1 -3.8 -12.3

002194 CH WUHAN FING -A 486 5.48 n.a n.a n.a 2.1 -20.0 -25.8 -5.4 -37.6 -46.9

300050 CH DINGLI COMMUNI-A 651 7.39 42.7 18.0 13.8 1.5 3.1 3.7 -1.9 -28.5 -6.1

300310 CH GUANGDONG EAST-A 1,258 8.96 33.8 23.8 17.8 2.3 5.4 6.7 -0.1 -34.3 -22.7

Average 59.2 25.6 19.1 3.7 1.8 3.2 n.a n.a n.a

CSCO US CISCO SYSTEMS 219,101 45.48 21.5 17.5 15.8 4.3 -1.1 -2.5 -1.0 32.6 18.7

JNPR US JUNIPER NETWORKS 9,368 26.83 19.1 14.7 12.7 2.2 2.5 5.0 1.2 -12.3 -5.9

IBM US IBM 131,949 143.74 10.3 10.4 10.2 7.3 4.7 31.1 -0.3 -6.5 -6.3

Average 17.0 14.2 12.9 4.6 2.0 11.2 n.a n.a n.a

Source: Bloomberg as of 16 May 2018, Anli research

Px % chg.

YTDROA (%) ROE (%)

P/E(x)

A share TMT

International TMT

Px % chg.

WTD

Px % chg.

1 yr

H share TMT

Ticker Company name Mkt Cap (US$m) Last Price

HK$1.6

TUNG LING FOK (32.79%)

Kimmy Tong/+852 23235118/[email protected]

Price performance

Research Analyst

Key indicator forecast

Price (HK$/shr) as of 16 May, 2018

May 16, 2018

Comba Telecom (2342.HK); Future looks promising; BUY

Key data

TMT

BUY

Unstable share price movement. Comba Telecom’s share price dropped significantly on May 15,2018 given large trading volume in sold shares. Management dismiss concerns raised bysignificant price movement on the market and claimed that company business operation andcashflow from operation remain stable. We attribute the share price movement to be related to thepotential reversal of ZTE’s (763.HK suspended) ban by President Trump. It may have triggeredsome investors to shift its investing position from Comba Telecom to “ZTE concept stocks”, suchas Mobi (764.HK). Thus, Mobi’s share price rebounded 23% while Comba Telecom’s share priceplunged 18% post Trump’s intervention in ZTE.

Diversified chips supply. Management mentions that any potential US-China trade war conflictshad not been affected, nor will it affect the Co.’s business structure as most of its chips not onlycome from US but also in Taiwan through third-party agents. However, they worry ZTE’s ban maydelay the supply chain schedule of orders in 1H18, especially in the network system segment.Due to seasonality and ZTE sales ban, customers’ orders in 1Q18 have shifted, and managementmentioned more orders will come in 2Q18.

Ranked Top 2 supplier for China Unicom. China Unicom (762.HK) announced CAPEXincreased by 19% to RMB50bn in FY2018E post mixed ownership reform in cooperation with BAT- Tencent (700.HK), Baidu (BIDU.US) and Alibaba (BABA.US). More importantly, Comba Telecomwon 20-30% of tender bid from China Unicom post mix-ownership reform, making them thecompany with the 2nd most tender bids. Management said the orders will improve segmentmargins in upcoming years. As one of Comba Telecom’s three major customers, we project alarger revenue contribution, up from 15% last year as CU’s new stakeholders emphasize greaternetwork capacity and productivity for FY2018E.

We reiterate our BUY rating with a TP of HK$1.60/shr, implying a 20.3% upside. We thinkComba Telecom’s result looks promising despite delay from ZTE sales ban & supply chain inFY1H18, given: 1) Potential customer’s orders increase post ZTE sales ban; 2) Uncertainty in ZTEsales ban – this may allow Comba Telecom to expand its market share in China’s Telecomservice industry; 3) Undemanding valuation as company NAV per share is HK$1.53 as of 31 Dec2017, representing a ~15% of discount; 4) Ongoing share buyback for <100m shares, boostingCo.’s full year EPS growth; 5) Management guidance of overseas revenue to increase 20-30%YoY in FY2018E due to new metro project in Bangkok; 6) Business unaffected by US-China tradewar, will remain as R&D developer in China’s 5G industry. Meanwhile, we uplift Comba TelecomEPS growth to reflect these positive factors. Key risks; Longer than expected transitional phase to5G solutions, delayed tender bidding schedules for wireless network equipment; large volatility inforeign currency prices.

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

0

5000

10000

15000

20000

25000

30000

35000

HK$/shrPts Hangseng Index (LHS)

Comba (2342 HK) (RHS)

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Page 2: Comba Telecom (2342.HK); Future looks promising; BUYanli.com.hk/.../2018/05/Comba-Telecom-2342.HK-analysis-report.pdf · A share TMT International TMT WTD 1 yr ... won 20-30% of tender

Source: Company data, Anli research estimates Source: Company data, Anli research estimates

Source: Company data, Anli research Source: Company data, Anli research

Source: Company data, Anli research Source: Company data, Anli research

May 16, 2018

Fig.2: We estimate an 8.1%/12% YoY growth in FY18E/19E

Fig.3: Margins plunged due to CAPEX reduction in 4G

operators in FY2017

Fig.4: Management hopeful on revenue contribution from CU to

increase in FY18 Fig.5: Company brings in new operator business

Fig.6: China's 4G network near completion, dragged down

Comba's revenue growth in FY2017 and look to 5G

Fig.7: R&D expenses tick up in preparation for China's 5G

development

2,616 3,092

2,502 2,397 2,638 2,389 2,174

1,848

1,142 1,004 885 1,005

337 286 393 221

93

-

1,000

2,000

3,000

4,000

FY14 FY15 FY16 FY17

HK$mRevenue breakdown by business

Antennas & subsystems Services Network system Others Operator business

2.9% 3.4% 3.8%6.0%

7.6% 7.0% 9.1%9.2%

11.7%12.4% 11.9%

10.3%

0%

20%

40%

60%

80%

100%

FY14 FY15 FY16 FY17

Cost structure breakdown

R&D costs Selling and distribution expenses

Administrative expenses Finance costs

Taxation charge Other expenses

48%

31% 29% 30%

14%

26% 26%

15%17%

23% 20%23%20%

17% 18%

24%

1%3%

7% 7%

0% 0% 0% 2%0%

20%

40%

60%

FY14 FY15 FY16 FY17

Revenue breakdown by clients

CM CU CT International customers Enterprise ETL

85.1% 74.3% 64.6%

5% 6%10%

6% 4% 5%

0%

20%

40%

60%

80%

100%

FY15 FY16 FY17

Revenue breakdown by region

PRC Asia Pacific Americas EU Middle East Others

6,733.2 6,770.9

5,954.3 5,563.7

6,013.9

6,735.5

-15%

-10%

-5%

0%

5%

10%

15%

20%

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

FY14 FY15 FY16 FY17 FY18E FY19E

HK$mCompany revenue

26.1%28.3% 29.0%

25.8% 26.2%27.5%

3.0%4.9% 4.2%

0.9%3.2% 3.4%

2.2% 3.1% 2.6%0.5%

2.6%2.5%

0%

5%

10%

15%

20%

25%

30%

35%

FY14 FY15 FY16 FY17 FY18E FY19E

Margins analysis

Gross margin(%) Operating margin(%) Net margin(%)

2

Page 3: Comba Telecom (2342.HK); Future looks promising; BUYanli.com.hk/.../2018/05/Comba-Telecom-2342.HK-analysis-report.pdf · A share TMT International TMT WTD 1 yr ... won 20-30% of tender

FY16 FY17 FY18E FY19E FY16 FY17 FY18E FY19E

5,954.3 5563.7 6,013.9 6,735.5 PP&E 538.0 1106.9 1,217.6 1,339.3

(4,225.9) (4,126.7) (4,437.2) (4,881.0) Goodwill & intangibles assets 237.9 1101.5 1,186.4 1,279.7

1,728.4 1,437.0 1,576.7 1,854.5 Others 691.9 368.9 426.1 466.9

173.7 123.0 135.3 148.9 Non-current asset 1,467.8 2577.3 2,830.1 3,085.9

(227.6) (331.3) (347.9) (417.5) Inventories & trade receivables 5,200.4 5883.1 6,471.3 7,118.4

(1,253.7) (1,086.2) (1,075.3) (1,239.8) Others 688.3 1020.4 919.6 1011.6

Other expenses (119.1) (41.5) (41.0) (49.2) Restricted bank deposits 178.2 234.8 281.7 309.9

Share of results of JV (0.1) (0.9) - - Cash 1,420.2 1176.1 1,058.5 1,164.4

Share of results of an associate (2.3) (1.5) (1.6) (0.2) Current asset 7,487.1 8314.4 8,731.1 9,604.3

Finance cost (47.0) (47.9) (54.1) (64.9) Total assets 8,954.9 10,891.7 11,561.2 12,690.2

PBT 252.2 50.7 192.1 231.8 Trade & other payables 3,999.1 4745.5 4,557.2 5,012.9

Income tax (99.7) (29.2) (35.0) (65.2) Current tax payable 11.2 - - -

Minority interest (0.1) 5.7 (0.2) (0.4) Short-term loans 693.7 1088.5 1,197.3 1,317.1

Net Profit 152.4 27.2 156.9 166.2 Others 70.5 69.9 83.9 83.9

Current liabilities 4,774.5 5903.9 5,838.4 6,413.9 Earning growth

drivers FY16 FY17 FY18E FY19E Long-term loans 673.2 493.9 543.3 597.6

YoY growth Deferred tax liabilities 14.2 162.5 178.7 178.7

Revenue -12.1% -6.6% 8.1% 12.0% Total liabilities 5,461.9 6,560.3 6,560.4 7,190.2

Gross profit -9.7% -16.9% 9.7% 17.6% Total equity 3,493.0 4,331.4 5,000.8 5,500.0

Operating profit -23.3% -79.9% 278.9% 20.7% Minority interest (55.5) (565.2) (565.2) (565.2)

Net profit -28.5% -82.1% 476.8% 5.9% Shareholders capital 3,437.5 3,766.2 4,435.6 4,934.8

Margin analysis

Gross margin(%) 29.0% 25.8% 26.2% 27.5% Cash flow (HK$m) FY16 FY17 FY18E FY19E

Operating margin(%) 4.2% 0.9% 3.2% 3.4% Profit before tax 252.2 50.7 192.1 231.8

Net margin(%) 2.6% 0.5% 2.6% 2.5% Depreciation 76.6 108.3 119.1 131.0

COGS/sales(%) 71.0% 74.2% 73.8% 72.5% Amortization 65.7 111.7 122.9 135.2

SG&A/sales(%) 21.1% 19.5% 17.9% 18.4% Interest income (7.9) (11.7) (12.9) (14.1)

R&D/sales(%) 3.8% 6.0% 5.8% 6.2% Working capital changes 25.6 107.5 161.3 177.5

Others 127.1 55.2 (31.5) (41.4)

Ratios FY16 FY17 FY18E FY19E CFO 539.3 421.7 551.0 620.0

Net gearing(%) net cash 11.0% 15.0% 15.0% Income tax paid (127.6) (99.4) (109.4) (109.4)

Current ratio(x) 1.6 1.4 1.5 1.5 NCFO 411.7 322.3 441.6 510.6

ROE(%) 4.3% 0.8% 3.8% 3.3% CAPEX (52.5) (114.6) (137.6) (151.3)

ROA(%) 1.6% 0.3% 1.4% 1.4% Others (483.3) (578.3) (46.9) (38.8)

Inventories days 133 120 123 135 CFI (535.8) (692.9) (184.5) (190.1)

Receivable days 239 274 302 332 Dividends paid (70.2) (19.7) - -

Payable days 266 291 279 307 Increase in debt 9.5 67.9 224.2 246.6

Source: Company data, Anli research estimates Others (46.7) 31.2 170.1 181.7

CFF (107.4) 11.5 170.1 181.7

Net change of cash (231.5) (359.1) 427.2 502.2

FCF 359.2 207.7 304.0 359.3

Company description

SG&A expenses

Research and development costs

COGS

Gross profit

Other income and gains

May 16, 2018

Balance Sheet (HK$m)

Comba Telecom: financial summary

Profit and Loss (HK$m)

Revenue

Comba Telecom (2342.HK) primarily serves as a wireless solutions provider to its customers in the PRC through its national sales and servicesnetwork. The company also offers antennas and subsystems, wireless access, and wireless enhancement to customer worldwide, and has its ownR&D facilities, manufacturing base, and sales and services teams.

3

Page 4: Comba Telecom (2342.HK); Future looks promising; BUYanli.com.hk/.../2018/05/Comba-Telecom-2342.HK-analysis-report.pdf · A share TMT International TMT WTD 1 yr ... won 20-30% of tender

May 16, 2018

Important legal disclosures

General DisclosureThis research report is prepared and distributed by Anli Securities Limited (“ASL”) in the conduct of business of regulated activity in Hong Kong.This report or any part thereof may not be distributed, reproduced or disclosed to any other person without the prior written approval of ASL. Inparticular, this research report is not intended for distribution to, or use by, any person or entity in the United States of America, Canada,Australia or any jurisdiction or country where its distribution would be in breach of applicable laws, rules and regulation. The information, data,materials, forecasts, estimates or opinions contained herein are for information only and subject to change without prior notice. ASL makes norepresentation or warranty (whether express, implied or otherwise), with respect to the fairness, correctness, accuracy reasonableness orcompleteness of the information, data, materials, forecasts, estimates, opinions as above but has used its best endeavor to obtain information,data, materials from sources which are believed to be reliable. ASL makes no representation, undertaking, warranty or guarantee as to theupdate, completeness, correctness, reliability or accuracy of information, data, materials, forecasts, estimates or opinions. The opinions hereinare made without taking into consideration of specific financial position, investment objective, investment experience or other need and it istherefore expected that investor shall not make investment decision in reliance on information, data, materials, forecasts, estimates or opinionsherein without seeking professional and independent advice. ASL accepts no liability and responsibility whatsoever for any direct or indirect lossor damage which may be suffered by any person arising out of or in connection with the information, data, materials, forecasts, estimates oropinions provided herein. In any event, this research report does not constitute or form part of and shall not be construed as any offer for sale orsubscription or solicitation or invitation of any offer to purchase or subscribe for any securities and investment products in any jurisdiction.

In distributing this research report, ASL is not providing and does not purport to provide professional investment advice. Except as otherwisedisclosed herein, ASL or its affiliates (“ASL Group”) has no interest in the securities of the companies referred to in this research report as at thedate of the issuance of this research report. ASL Group’s officers, directors and employees may have position in any and may trade for their ownaccount in all or any of the securities or investment mentioned in this research report. In addition, ASL Group may have provided investmentservices and may have underwritten, or may act as market marker in relation to those securities. Commission, fees or other benefit (whethermonetary or non-monetary) may be earned or received by ASL Group in respect of services provided in relation to those securities orinvestments.

RiskThe securities or investments referred to in this research report may not be suitable for all investors. In particular, no consideration has beengiven to any particular investment objectives or experience, financial situation or other needs of any investor. In the said premises, ASL acceptsno liability with regard to the suitability or appropriateness of any of the securities and/or investments referred to herein for any particularinvestor’s circumstances. Investor is reminded to make investment decisions in light of their own investment experience, investment objectives,financial position and particular needs and, where necessary, consult their own professional advisers prior to making investment decision. Thisresearch report is not intended to provide any professional advice and should not be relied upon in that regard. The value of the investment maygo up as well as down. Past performance is not indicative of futures performance. The risk disclosed herein is not intended to be an exhaustivelist of risks associated with the securities or investments. Investor is advised to read and fully understand all the offering or other relevantdocuments relating to securities or investments referred to in this research report as well as all the risk disclosure statements and risk warningstherein before making any investment decision.

Information of ASLASL is licensed by the Securities and Futures Commission of Hong Kong to carry on business of Types 1 and 4 regulated activities under theSecurities and Futures Ordinance (Chapter 571), Laws of Hong Kong and shall, amongst the others, provide services in relation to a series ofresearch products, including, without limitation, fundamental analysis, macro-economic analysis, quantitative analysis and trade ideas, inaccordance with all applicable laws, rules and regulations.

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