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Operations & Control

This integrated Operations & Control framework is designed to align with the standards and expectations applicable to MAS-regulated investment management entities, including RFMC requirements.

Our approach ensures that investment decisions are executed consistently, risks are actively managed, and governance remains transparent, auditable, and resilient across market cycles.

Investment Process

Million Leaf follows a structured, repeatable, and governance-led investment process designed to support long-term capital preservation and compounding.

Investment Origination
  • Investments are initiated through systematic fundamental analysis and valuation discipline
  • Focus is placed on business quality, intrinsic value, and margin of safety
  • Opportunities are evaluated independently of short-term market sentiment
Due Diligence & Assessment
  • Financial strength, cash flow sustainability, and competitive positioning are assessed
  • Risk factors, downside scenarios, and structural vulnerabilities are identified
  • Investment rationale is documented prior to capital deployment
Execution & Monitoring
  • Trades are executed in accordance with approved mandates and exposure limits
  • Positions are monitored continuously against fundamentals, valuation, and risk thresholds
  • Material changes trigger reassessment or risk mitigation actions
Review & Exit
  • Exit decisions are driven by valuation discipline, risk considerations, or thesis invalidation
  • Emotional or price-driven decision-making is systematically constrained

Risk Management

Risk management at Million Leaf is integrated into every stage of the investment lifecycle and serves as a primary mechanism for capital protection.

Risk Philosophy
  • Risk is defined as permanent capital impairment, not short-term volatility
  • Capital preservation takes precedence over return maximisation
  • Risks are managed proactively rather than reactively
Key Risk Controls
  • Position sizing limits and portfolio concentration controls
  • Exposure management aligned with market conditions and strategy parameters
  • Ongoing monitoring of liquidity, valuation, and downside risk
Behavioral Risk Controls
  • Rule-based frameworks limit discretionary and emotional decisions
  • Investment discipline is enforced through predefined criteria and escalation protocols

Risk management is treated as a continuous process rather than a periodic review.

Regulatory & Compliance

Million Leaf operates with a strong commitment to regulatory integrity, transparency, and fiduciary responsibility.

Regulatory Alignment
  • Investment activities are conducted within scopes consistent with MAS regulatory expectations
  • Business operations adhere to applicable Singapore regulatory frameworks
Governance & Accountability
  • Senior management bears ultimate responsibility for compliance and control
  • Clear accountability structures support effective supervision and escalation
Policies & Internal Controls
  • Documented policies govern investment mandates, risk limits, conflicts of interest, and record-keeping
  • Controls are proportionate, enforceable, and designed for audit readiness
Conflict of Interest Management
  • Potential conflicts are identified, reviewed, and managed through defined procedures
  • Investment decisions are made in the best interests of managed capital
Record Keeping & Transparency
  • Investment decisions, transactions, and rationale are documented and retained
  • Records are maintained to support regulatory review and internal oversight

Ethical Standards & Continuous Improvement

All operations are conducted under high ethical standards and fiduciary duty.

  • Market conduct and integrity are strictly observed
  • Compliance practices are reviewed and enhanced on an ongoing basis
  • Policies evolve with regulatory guidance and operational growth

Million Leaf treats operations, risk control, and compliance not as administrative obligations, but as strategic foundations for long-term investment excellence.