“Vision is the art of seeing things invisible.”

– Jonathan Swift - Irish satirist and author.

AFC Funds Performance Summary

Asian Frontier Markets Bounce Back in November Led by AFC Asia Frontier Fund & AFC Iraq Fund

AFC Funds recovered strongly after October’s sell-off and as we discussed in last month’s newsletter, the stock market correction in October presented a good opportunity for long-term investors to invest in Asian frontier markets since we have communicated since the start of the year that Asian frontier markets are primed for a re-rating.

November’s performance reflects this ongoing re-rating in Asian frontier markets, with the AFC Asia Frontier Fund recording its third-best monthly performance since inception at +6.8%, taking its year-to-date return to an outstanding +22.7%. The AFC Iraq Fund, meanwhile, continues its strong run in 2023 with a gain of +5.1% which takes its 2023 return so far to a stellar 97.4%!

The strong performance by Asian frontier markets in 2023 only signifies the importance of being invested in these markets, as we have seen with the performance of the Iraqi equity market throughout the year, as well as with the stock market rallies in both Pakistan and Sri Lanka in the second half of 2023.

The robust performance so far in 2023, especially by the AFC Asia Frontier Fund and AFC Iraq Fund, shows the diversification benefits of being invested in Asian frontier markets, especially when so many large emerging markets in Asia have underperformed this year. An investor would have done well in 2023 relative to most other Asian emerging markets if they had some exposure to Asian frontier markets.

We expect the momentum and re-rating in Asian frontier markets to continue into 2024 as key macro conditions are moving in favour of our country universe. You can read more on our outlook shortly as we will soon release the AFC Asia Frontier Fund’s “2023 Review and Outlook for 2024” – stay tuned.

The AFC Asia Frontier Fund has seen a Strong Outperformance in 2023 as Asian Frontier Markets Re-rate 
(Year to Date Total Returns in USD)

Co-Fund Manager of the AFC Asia Frontier Fund, Ruchir Desai also appeared on Bloomberg TV on 12^th December 2023 and gave his view on the Asian Frontier Markets and in detail on the Vietnamese stock market as well as a snapshot of the outlook for 2024 and which markets he thinks can have relative outperformance in 2024. Click the link below to watch the Bloomberg TV interview with Ruchir Desai.

AFC Vietnam Fund – Ten-year anniversary
 

December 2023 is an important month for AFC as we are celebrating the 10^th anniversary of our AFC Vietnam Fund. Being our largest and best-performing fund (in terms of total return since inception). With an annualized return since inception on 23^rd December 2013 of +12.0% p.a. and a total return of +207.2%, the fund has fulfilled its target return and pleased many of our investors and shown that investing in frontier markets can be a very attractive option in terms of performance enhancement and risk diversification.

The entire AFC Team wishes all our investors and newsletter readers happy holidays and a peaceful and profitable New Year!

December Subscription Cut-off Date

The next cut-off date for subscriptions for our funds will be 21^st December 2023. If you would like to know more about the subscription process, please get in touch with us at This email address is being protected from spambots. You need JavaScript enabled to view it. 

Please find below the managers’ comments on each of our four funds for November 2023.

AFC in the Press

Upcoming AFC Travel

Thomas Hugger, Ruchir Desai, and Peter de Vries are based in Hong Kong, while Andreas Vogelsanger is based in Bangkok, Vicente Nguyen in Ho Chi Minh City, Scott Osheroff in Tashkent, and Ahmed Tabaqchali in London and Iraq. If you have an interest in meeting with our team at their homeports or during their travels, please contact Peter de Vries at This email address is being protected from spambots. You need JavaScript enabled to view it..

AFC Travel

 AFC Asia Frontier Fund - Manager Comment

The AFC Asia Frontier Fund (AAFF) USD A-shares returned +6.8% in November 2023 with a NAV of USD 1,498.87. The fund underperformed the MSCI Frontier Markets Asia Net Total Return USD Index (+11.2%), the MSCI Frontier Markets Net Total Return USD Index (+7.1%) and the MSCI World Net Total Return USD Index (+9.4%). The performance since inception on 30^th March 2012 now stands at +49.9% versus the benchmark, which is down by 26.2% during the same period. The broad diversification of the fund’s portfolio has resulted in lower risk with an annualised volatility of 10.7% and a correlation of the fund versus the MSCI World Net Total Return USD Index of 0.51, all based on monthly observations since inception.

Fund performance came back very strongly in November with the third-best monthly performance since the fund’s inception, with a broad all-round rally across our markets. With many central banks in our universe already in a monetary easing cycle and with the markets expecting the U.S. Fed to begin cutting interest rates at some point in 2024, it was not surprising to us to see such a strong rally in both global and Asian frontier markets. 

Our key message since the end of 2022 has been that the key headwinds of higher inflation and interest rates will turn into tailwinds in 2023 as inflation begins to come down, which in turn would give global central banks the room to initiate an interest rate easing cycle. 

This key macro development has been the main factor for the strong rally in Asian frontier markets this year and we expect the momentum to continue into 2024 as central banks in our universe are not done with their monetary easing while earnings should see a big recovery next year. This combination of lower interest rates, strong earnings growth and still discounted valuations means we remain very bullish on Asian frontier markets in 2024. The strong run of 2023 will have momentum in 2024 and this is the time to be invested in Asian frontier markets.

Oustanding Absolute and Relative Performance by the AFC Asia Frontier Fund in 2023
(Year to Date Total Returns in USD)

The rally in Asian frontier markets was led by Pakistan, the fourth best-performing market globally in November, with a USD gain of +15.4%. Since the end of June 2023, the KSE-Index is, in fact, the best-performing market globally with a USD return of +47.2%. We have increased our weight to Pakistan in 2023 and expect the bull market to move into 2024 since a historically low P/E ratio of 4.3x should re-rate due to a potentially new and longer IMF deal, political stability via parliamentary elections in February 2024, and possibly significant interest rate cuts in the upcoming future supporting the ongoing stock market strength.

The KSE-100 Index in Pakistan is the Best Performing Market Globally since June 2023
(Returns in USD)

Sticking to monetary easing, the National Bank of Kazakhstan (NBK) reduced its benchmark interest rate by another 25 basis points, bringing its total interest rate reduction to 100 basis points since the NBK began its interest rate easing cycle in August 2023.

Monetary Policy Continues to be Eased in Kazakhstan as Inflation Declines

The Central Bank of Sri Lanka also continued with its monetary policy easing and cut its benchmark interest rates by another 100 basis points, bringing its total interest rate reductions to 650 basis points since June 2023, when it began reducing interest rates. We believe the continued easing of interest rates in our Asian frontier universe will drive positive investor sentiment and a recovery in earnings growth going forward.

The Central Bank of Sri Lanka Cut Interest Rates by 650 Basis Points since June 2023

In a significant development for Sri Lanka, the U.S. International Development Finance Corporation (U.S. DFC) committed to invest USD 553 mn in the West Container Terminal (WCT) at the Port of Colombo. This investment in the WCT by the U.S. DFC will be in the form of a long-term loan, which will help finance the project and support the equity financing being provided by the Adani Group of India, John Keells Holdings of Sri Lanka (which the fund holds), and the Government of Sri Lanka.

We have pointed out in the past that Sri Lanka’s geographic location is very strategic with respect to global shipping lanes and this investment in the Port of Colombo signifies the importance Sri Lanka is gaining, especially concerning the status as a transhipment hub for the rest of South Asia. 

The Port of Colombo is already South Asia’s busiest port by volume handled and its strategic location and ability to offer deep water harbours have led to high-capacity utilisation levels at the port. The Port of Colombo’s capacity will increase from 8 million TEU containers (twenty-foot equivalent) currently to more than 11 million TEU containers as the WCT comes online in the next few years.

The Port of Colombo Operates near Capacity of 8 million TEUs - The New West Container Terminal to add more than 3 million TEUs to its Capacity (Twenty Foot Equivalent Containers)

The VN-Index in Vietnam witnessed a rebound of +6.4% and this supported the continued outperformance of our top picks in Vietnam, i.e. FPT Corp. (FPT) and Gemadept (GMD), both of which, in our view, are among the better ways to play the long-term Vietnam growth story.

The Fund’s Top Picks in Vietnam – FPT Corp (FPT) and Gemadept (GMD) Continue to Significantly Outperform the VN-Index

The best-performing indexes in the AAFF universe in November were Pakistan (+16.5%) and Iraq (+7.1%). The poorest-performing markets were Laos (-1.3%) and Bangladesh (-0.9%). The top-performing portfolio stocks this month were a Mongolian junior miner (+100.0%), a Myanmar financial company (+72.7%), a Pakistani mobile phone assembler and distributor (+53.4%), a Pakistani paint company (+29.5%), and a Mongolian coking coal producer (+29.0%).

In November, the fund purchased a Vietnamese consumer electronics and grocery retailer and added to its existing positions in Pakistan. The fund also exited its two positions in Jordan, a potash producer and a phosphate producer, and also exited an industrial company in Sri Lanka and reduced existing positions in Mongolia and Sri Lanka.

At the end of November 2023, the portfolio was invested in 68 companies, 2 funds and held 7.8% in cash. The two biggest stock positions were a fintech company in Kazakhstan (5.0%) and a bank in Kazakhstan (4.0%). The countries with the largest asset allocation were Iraq (20.2%), Mongolia (13.1%), and Kazakhstan (11.5%). The sectors with the largest allocation of assets were consumer goods (17.4%) and financials (13.2%). The fund's estimated weighted harmonic average trailing 12 months P/E ratio (only companies with profit) was 6.50x, the estimated weighted harmonic average P/B ratio was 1.29x, and the estimated weighted average portfolio dividend yield was 3.55%. The fund’s portfolio carbon footprint is 0.53 tons per USD 1 mn invested.

AFC Iraq Fund - Manager Comment

The AFC Iraq Fund Class D shares returned +5.1% in November 2023 with a NAV of USD 1,342.45 versus its benchmark, the Rabee Securities US Dollar Equity Index (RSISUSD index), which gained 7.1% during the month. For the year, the AFC Iraq Fund is up 97.4%, outperforming the index’s increase of 85.7%. Since inception, the fund has gained 34.2% while the RSISUSD index is down 2.5%, an outperformance of 36.7%.

The market resumed its rally in November 2023, ending the short and shallow pull-back that marked October 2023. Average daily turnover increased 17.6% month-on-month, but the market’s momentum moderated as the month came to an end. The top-quality banks continued their market leadership, however, promisingly market breadth broadened somewhat with the inclusion of top-quality names in consumer staples and telecom sectors. As discussed a few months ago in “Banks to Fuel the Market’s Next Phase”, the AFC Iraq Fund’s investment thesis for the banking sector got a substantial boost from a potent combination of recent fundamental and technical developments that promises to accelerate the adoption of banking and bring about a transformation of the sector and its role in the economy. Such a transformation should lead to sustainable earnings growth, particularly for the top-quality banks, which would provide the fuel for the stock market's next phase.

Rabee Securities US Dollar Equity Index

Over the last couple of months, the government started implementing the expansionary three-year budget for 2023-25 which was passed into law in June 2023. Central Bank of Iraq (CBI)’s data of the Ministry of Finance (MoF)’s sales of U.S. dollars (derived from oil revenues) to the CBI in exchange for Iraq dinars (IQD) – in order for the government to execute the budget – showed an increase of 115.7% in the average monthly volumes for August-October 2023 over those for January-July 2023, indicating that the government was gearing up to execute the budget. However, MoF’s budget execution reports show that average monthly current expenditures were down 4.4% in August-September 2023 versus those for January-July 2023, but within these expenditures, those for public sector salary spending were up 15.0% and for welfare spending (which includes public sector pensions) were up 4.4%. On the other hand, in the same timeframes, non-oil investment spending was down 13.9%, while the government’s special programs, which cover both current and investment expenditures, were up a combined 202.6% (*). 

More monthly budget execution reports are needed to discern a clear trend that smooths over the timeliness issues and shortcomings of the data, nevertheless, the figures suggest that the government has prioritized the allocations for public sector salaries, public sector pensions, welfare spending, and its special programs as it started implementing the new budget. The plodding bureaucratic procedures of government machinery mean that the overall budget implementation and other expenditure increases should ramp up slowly but steadily over the next few months.

The budget calls for increasing federal current expenditures by 21.5% in 2023 over 2022, representing a liquidity injection of 13.7% to 2022’s estimated federal non-oil GDP. While planned non-oil investment spending for 2023 is equally meaningful and potentially far-reaching, which could add a further 13.2% liquidity injection to the non-oil economy, enhancing the liquidity injections of its current expenditures. However, given the historically low execution rates in investment spending and the state bureaucracy’s capacity constraints, it is unlikely that most of this planned investment spending will actually materialize. Note: federal excludes the Kurdistan Region of Iraq (KRI), details are in the table below and notes below (**).

Federal Expenditures: Planned for 2023 versus 2022’s Actual Spending

Ultimately, it will be the government’s current expenditures, in the form of the public sector payroll, welfare and social security, and spending on goods and services, which, in combination with the positive global macro-economic developments, will drive economic growth that would eventually feed into meaningful growth in corporate profits, which in turn would sustain the market’s current rally.

At the end of November 2023, the AFC Iraq Fund was invested in 14 names and had a cash level of 14.9%. The fund invests in both local and foreign-listed companies that have the majority of their business activities in Iraq. The markets with the largest asset allocation were Iraq (83.7%), Norway (1.2%), and the UK (0.2%).

The sectors with the largest allocation of assets were financials (69.1%) and consumer staples (8.8%). The fund's estimated weighted harmonic average trailing 12 months P/E ratio (only companies with profit) was 7.72x, the estimated weighted harmonic average P/B ratio was 1.39x, and the estimated weighted average portfolio dividend yield was 3.36%. The fund’s portfolio carbon footprint is 0.08 tons per USD 1 mn invested.

AFC Vietnam Fund - Manager Comment

The AFC Vietnam Fund returned +4.6% in November with a NAV of USD 3,072.00, bringing the year-to-date return to +6.5% and return since inception to +207.2%. The Ho Chi Minh City VN Index gained 7.7% in November 2023, gained 5.8% year to date, and is up by 87.1% since inception of the fund, in USD terms, showing the fund strongly outperformed the index by 120.1%. The fund’s annualised return since inception stands at +12.0% p.a. The broad diversification of the fund’s portfolio resulted in an annualised volatility of 15.06%, a Sharpe ratio of 0.70, and a low correlation of the fund versus the MSCI World Index USD of 0.50, all based on monthly observations since inception.

Market Developments

It is essential to recognize that the October market downturn, which saw a drop of over 10%, lacked clear fundamental triggers related to macroeconomics or corporate earnings. Similarly, the November market recovery occurred without any specific positive news. This phenomenon underscores the inherent volatility of a frontier market like Vietnam, where the stock market can exhibit substantial fluctuations in short periods without specific catalysts. In the Vietnamese stock market, over 90% of daily trading volume is attributed to local individual investors, many of whom utilize high leverage ratios. As a fund, we don’t engage in excessive buying or selling like these individual investors, but we capitalize on market volatility to acquire quality stocks at favourable prices. For those with a long-term investment horizon, market downturns present favourable buying opportunities. For example, our CIO, Vicente Nguyen, has been investing personally in the AFC Vietnam Fund each quarter since 2016, weathering both high and low market phases, resulting in a satisfactory average price over time. Overall, a regular investment approach could be a prudent option, particularly for those who share our confidence in the long-term prospects of the Vietnamese economy and stock market over the next 10-20 years.

Panda diplomacy – a potential normalization between U.S. and China relationship

One of the recent positive developments is China's decision to resume lending Pandas to the United States after a hiatus as a noteworthy signal of potential normalisation between the two nations. The interruption in Panda lending, occurring just before President Xi's visit to the U.S., underscored the growing divergence between the two economic giants. However, the renewed gesture announced post Xi's visit suggests a thawing in relations. This diplomatic move is an initial indicator of a potential improvement in ties between the U.S. and China. Given China's crucial role as an economic engine in the region, any positive shift in its relationship with the U.S. could bode well for Asia, particularly in light of China's recent economic challenges exacerbated by its isolation from the U.S. Panda diplomacy, while seemingly symbolic, carries broader implications for regional economic dynamics.

The VN-Index is Approaching its 200-Day Moving Average on the Upside Again

Export Recovery Continues

We are particularly optimistic about the recovery of Vietnam's export sector which appears to have bottomed in the first half of 2023. The aggressive increase in inflation in 2022 prompted U.S. and European consumers to reduce spending, causing a significant drop in Vietnamese exports. However, as inflation subsides and signals suggest the Fed may cease rate hikes or even reduce rates in 2024, consumer confidence is expected to rebound, positively impacting Vietnamese exports.  November marked the third consecutive month of positive export growth in 2023, reinforcing our belief that exports will continue to recover, returning to consistent positive growth in 2024 and beyond. Accordingly, we maintain a comfortable position by strategically investing in export stocks, which currently constitute around 20% of our portfolio, making it the largest sector allocation.

Vietnam’s Exports had the Third Positive Growth Month in a Row

Vietnam to Join the Global Semiconductor Value Chain

Vietnam's strategic positioning in Southeast Asia, its extensive global integration through numerous free-trade agreements (FTAs), government support through tax incentives, low-cost labor, and abundant rare earth reserves positions it favorably to further contribute to the global semiconductor value chain. In 2022, Vietnam's semiconductor exports reached USD 6.5 billion, growing by 83% YoY and representing 3.8% of global exports for this product. The country ranks among the top three Asian nations exporting semiconductors to the U.S., indicating its emergence as an outsourced semiconductor assembly and test (OSAT) player. Global semiconductor companies have increasingly invested in Vietnam, mainly in OSAT facilities in the northern region and R&D centers in the south.

Computer and Cellphone Export Value of Vietnam (USD bn)

Drawing parallels with Vietnam's transformation in the past decade—from an agricultural exporter to the world's second-largest cellphone exporter—we anticipate a similar trajectory in the semiconductor industry. With China and Taiwan experiencing conflicts and uncertainties, the need for diversification in semiconductor manufacturing is paramount. Vietnam, with its proactive investment environment and significant potential, may become a key player in the global semiconductor market over the next 10-15 years.

Cellphone Export by Country (%, Market Share in 2022)

At the end of November 2023, the fund’s largest positions were: TNG Investment and Trading JSC (7.9%) – an apparel manufacturer, Lam Dong Minerals and Building Materials JSC (7.8%) – a building material supplier, Thien Long Group (7.8%) – a manufacturer of office supplies, Minh Phu Seafood Corp (7.6%) – a seafood company, and Ha Do Group JSC (6.9%) – a real estate services company.

The portfolio was invested in 56 names and held 3.5% in cash. The sectors with the largest allocation of assets were consumer (56.3%) and financials (11.3%). The fund's estimated weighted harmonic average trailing 12 months P/E ratio (only companies with profit) was 12.22x, the estimated weighted harmonic average P/B ratio was 1.23x, and the estimated weighted average portfolio dividend yield was 4.03%. The fund’s portfolio carbon footprint is 2.45 tons per USD 1 mn invested.

AFC Uzbekistan Fund - Manager Comment

The AFC Uzbekistan Fund Class F shares returned −1.1% in November 2023 with a NAV of USD 1,765.33, bringing the return since inception (29^th March 2019) to +76.5%, while the return for the year stands at +1.6%. On an annualised basis, the fund has returned +12.9% p.a. with a Sharpe ratio of 0.80.

November saw the announcement of two planned IPOs on the Tashkent Stock Exchange as well as the government accelerating the lifting of subsidies on water, heat, and waste services in order to more closely align them with the real cost of services as Uzbekistan continues to liberalise the broader economy.

AFC Uzbekistan Fund Valuations as of 30^th November 2023:

IPOs in the Pipeline

During November, there were announcements and roadshow launch presentations for two state-owned companies, UzbekInvest and Uzbek Telecom. 

UzbekInvest is the largest state-owned insurer and the second largest overall in Uzbekistan, with a 15% market share. The government plans to issue preferred shares up to 5% of authorized capital of the company, with a dividend yield set at the central bank rate (currently 14%) plus 10%. This is certainly interesting as the yield will be attractive to local entities whose average term deposit rates are currently 17.9%, lower than the ~24% retail can receive on a term deposit. The annual insurance premiums in Uzbekistan are less than 1% of GDP and have ample room for growth in the years ahead as the industry is in its nascent stages of development. Thus, we will consider a possible investment when we get greater clarity on the issuance terms and timing.

The second company, which in our view is much more interesting, is Uzbek Telecom (UZTL). UZTL has an enterprise value of USD 635 million and is a de-facto monopoly in various parts of Uzbekistan’s telecommunications infrastructure. The company has 83% market share in broadband (1.5 million subscribers) and 23% in mobile (6.8 million subscribers). The government plans to sell up to 2% of the company, which we believe will be oversubscribed by local investors. It is a very small transaction, but certainly a start for Uzbekistan’s privatisation efforts through the capital markets. 

Frankly, in our view, it is better that these placements are smaller than too grandiose in size as it makes more sense to have oversubscribed placements, and let investors obtain an “easy win”, which would incentivise demand in future placements and encourage more locals to start paying attention to the domestic capital markets and accelerate brokerage account openings. 

Until it is easier for foreign capital to enter the local market, smaller placements are more suitable. However, with what we are hearing from the new independent capital market regulator (the former regulator was an arm of the Ministry of Finance and therefore not independent from the government) is that in addition to the presidential decree in September 2023 to further accelerate reforms of Uzbekistan’s capital markets, the piping roadblock will eventually be resolved as the government is increasingly serious about creating an alternative and cheaper financing marketplace competing with traditional and prohibitively expensive bank lending. Of course, more efficient capital markets with an influx of foreign investors will also help to drive down the high cost of capital. We hope to have more to share on this front in 2024 as there are several discussions we are privy to which, once finalized, will make it much more attractive for foreign funds to begin investing in Uzbekistan’s capital markets.

Liberalisation of Utilities is Underway

Uzbekistan still has a history of heavy subsidies for utilities, including hot and cold water, gas, wastewater treatment, and electricity. This is a legacy of the formerly planned economy which of course has its roots in the days of the Soviet Union. With Uzbekistan fast transitioning to a free-market economy, the government has been assessing a steady increase in tariffs while eliminating others all at once, such as the subsidy on bread flour. 

While earlier this year, the government began liberalization in prices for electricity consumption, on 9^th December 2023, households will see the cost of water and waste services rise from UZS 400 per cubic meter to UZS 1,400 and from UZS 350 to UZS 1,000 respectively. For legal entities, prices will increase from UZS 1,000 to UZS 3,000 and from UZS 820 to UZS 2,200. Dollar figure-wise, these amounts are still very inexpensive, but percentage-wise, they are significant, with the cost of water rising roughly 200%. 

In the medium term, this is a needed move on behalf of the government as price of utilities must rise closer to the actual cost of production since the government already incurs heavy annual losses due to subsidies, with the cost of electricity subsidies already at more than USD 1 billion per annum. Because the cost of utilities is exceptionally cheap, the concept of conserving resources is a novelty (even I am guilty of having my air conditioner on 24/7 during the summer when it’s 40 degrees Celsius in Tashkent). 

As the cost of these services rises, the country should see an increasing trend in conservation which will lighten the burden on the government’s supply of water and gas, among other things. Savings will also help dramatically decrease the water stress the country and region faces currently, as for example, there is an immense wastage of this resource in agriculture, estimated in a recent article at USD 5 billion per year (article below).

AFC Uzbekistan Tour 2024

For those interested in visiting Uzbekistan with us, we are planning our third AFC Uzbekistan Tour, which will be held from Sunday 19^th May 2024 to Tuesday 21^st May 2024. We will begin on the 19^th with a day tour of Tashkent, followed by company meetings and site visits on the 20^th and 21^st. If you are interested in joining, please write us at This email address is being protected from spambots. You need JavaScript enabled to view it..

At the end of November 2023, the fund was invested in 24 names and held 7.3% cash. The portfolio was allocated to Uzbekistan (92.63%) and Kyrgyzstan (0.04%). The sectors with the largest allocation of assets were financials (39.6%) and materials (34.6%). The fund's estimated weighted harmonic average trailing 12 months P/E ratio (only companies with profit) was 4.88x, the estimated weighted harmonic average P/B ratio was 0.97x, and the estimated weighted average portfolio dividend yield was 3.36%.

I hope you have enjoyed reading this newsletter. If you would like any further information, please get in touch with me or my colleagues at This email address is being protected from spambots. You need JavaScript enabled to view it.

With kind regards,

Thomas Hugger
CEO & Fund Manager

This email address is being protected from spambots. You need JavaScript enabled to view it.

Disclaimer:

This Newsletter is not intended as an offer or solicitation with respect to the purchase or sale of any security. No such offer or solicitation will be made prior to the delivery of the Offering Documents. Before making an investment decision, potential investors should review the Offering Documents and inform themselves as to the legal requirements and tax consequences within the countries of their citizenship, residence, domicile and place of business with respect to the acquisition, holding or disposal of shares, and any foreign exchange restrictions that may be relevant thereto. This newsletter is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law and regulation, and is intended solely for the use of the person to whom it is intended. The information and opinions contained in this Newsletter have been compiled from or arrived at in good faith from sources deemed reliable. Opinions expressed are current as of the date appearing in this Newsletter only. Neither Asia Frontier Capital Ltd (AFCL), nor any of its subsidiaries or affiliates will make any representation or warranty to the accuracy or completeness of the information contained herein. Certain information contained herein constitutes “forward-looking statements”, which can be identified by the use of forward-looking terminology such as “may”, “will”, “should”, “expect”, “anticipate”, “project”, “estimate”, “intend”, or “believe” or the negatives thereof or other variations thereon or comparable terminology. Due to various risks and uncertainties, actual events or results or the actual performance of Funds managed by AFCL or its subsidiaries and affiliates may differ materially from those reflected or contemplated in such forward-looking statements. Past performance is not necessarily indicative of future results.

For Switzerland only: This is an advertising document. The state of the origin of the fund is the Cayman Islands. This document may only be provided to qualified investors within the meaning of art. 10 para. 3 and 3ter CISA. In Switzerland, the representative is Acolin Fund Services AG, Leutschenbachstrasse 50, 8050 Zurich, Switzerland, whilst the paying agent is NPB Neue Privat Bank AG, Limmatquai 1 / am Bellevue, 8024 Zurich, Switzerland. The basic documents of the fund report may be obtained free of charge from the representative. Past performance is no indication of current or future performance. The performance data do not take account of the commissions, if any, and fund transfer costs incurred on the issue and redemption of units.

AFC Asia Frontier Fund is registered for sale to qualified/professional investors in Japan, Singapore, Switzerland, the United Kingdom, and the United States. AFC Iraq Fund and AFC Uzbekistan Fund in Singapore, Switzerland, the United Kingdom, and the United States. AFC Vietnam Fund in Japan, Singapore, Switzerland, and the United Kingdom. 

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