Zengame Technology Holding Limited (2660.HK): Deep Value Opportunity in a Strategic Pivot

1. Executive Summary

The Strategic Pivot: From Localized Tradition to Modern Casual

Ticker: 2660.HK

Reference Price: HK$ 2.30 (25 November 2025)

Market Capitalization: HK$ 2.379 billion (25 November 2025)

Zengame Technology Holding Limited (“Zengame” or the “Group”) is currently navigating one of the most consequential strategic transitions in its corporate history. Established as a dominant force in the niche market of localized Board and Card games, specifically leveraging the cultural ubiquity of Sichuan Mahjong, the Group is now aggressively pivoting toward the broader, albeit fiercely competitive, Casual game sector. This strategic realignment is not merely an expansionary ambition but an existential necessity. The traditional Board and Card segment, while historically a cash cow, is facing a confluence of structural headwinds: market saturation, user fatigue, and an increasingly restrictive regulatory environment regarding in-game currency and betting mechanics in the People’s Republic of China (PRC).

The financial data for the first half of 2025 (1H2025) provides unequivocal evidence of this friction. The legacy Board and Card portfolio is experiencing a sharp contraction, with revenue declining by 32.3% year-on-year. In stark contrast, the Casual game segment, anchored by the title Fishing Master, has demonstrated explosive traction, registering a growth rate of 162.0% over the same period. However, the current scale of the Casual business (14.5% of total revenue) is insufficient to offset the absolute dollar decline of the legacy pillar (85.5% of total revenue). Consequently, the Group reported a headline revenue contraction of 24.1% and a net profit decline of 41.0% for the interim period ended 30 June 2025.

Financial Impact and Investment Thesis

Despite the deterioration in top-line and bottom-line operational metrics, the investment case for Zengame is robust when viewed through the lens of “Deep Value” and “Income Generation.” The market appears to be pricing the equity for a terminal decline, ignoring the substantial margin of safety provided by the Company’s balance sheet. As of 30 June 2025, Zengame holds a massive net cash position (comprising cash, cash equivalents, time deposits, and liquid wealth management products) that approximates its entire market capitalization. This implies that at the current price of HK$ 2.30, investors are effectively acquiring the operating business for free, or potentially at a negative enterprise value.

Furthermore, the Board has demonstrated a commitment to returning capital to shareholders, declaring an interim dividend of HK$ 0.20 per share for 1H2025. When combined with the final dividend of HK$ 0.15 from FY2024, the stock offers a trailing twelve-month dividend yield of approximately 15.2%. This yield is significantly above market averages and provides a “carry” for investors willing to wait for the stabilization of the Casual game pivot. However, recent cash flow analysis suggests this dividend is currently uncovered by organic free cash flow, representing a return of capital rather than on capital.

In a nutshell, at current prices, the market seem to have over-penalized the operational decline while under-appreciating the floor value established by the cash reserves. However, this is not a growth play; it is an asset-play heavily dependent on capital discipline. The primary risks involve the potential for “value trap” dynamics if cash is hoarded or squandered, and the persistent regulatory overhang from the National Press and Publication Administration (NPPA).

2. Company Overview

Background and History

Founded in 2010, Zengame Technology began its journey as a specialized developer focused on the digitalization of traditional Chinese board and card games. Unlike generic developers, Zengame adopted a localized strategy, identifying specific regional rule sets, most notably the “Bloody Battle” (Xuezhan Daodi) variation of Mahjong popular in Sichuan province, and translating them into authentic mobile experiences. This localization strategy allowed the Company to build a loyal, distinct user base that larger, generalist competitors like Tencent initially overlooked.

The Company listed on the Main Board of the Stock Exchange of Hong Kong (HKEX) in April 2019 (Stock Code: 2660.HK). The IPO capital was utilized to scale its user acquisition and proprietary technology infrastructure. Over the past decade, Zengame has evolved from a single-genre developer into a mobile game operator with a portfolio of 50 self-developed games and 6 third-party games as of mid-2025.

Core Business: The “Free-to-Play” (F2P) Model

Zengame operates exclusively on the “Free-to-Play” (F2P) business model, which lowers the barrier to entry for users, maximizing the size of the player funnel. Monetization is achieved through two distinct but complementary channels:

1. Sales of Virtual Items (Microtransactions): This is the primary revenue engine, accounting for 95.3% of total revenue in 1H2025. In the F2P economy, players play for free but purchase virtual currency (e.g., “beans” or “coins”) to continue playing after exhausting their daily free allocation, or to purchase cosmetic items (avatars, table skins, special effects) that convey status. The model relies on high-volume, low-value transactions from a wide user base, alongside high-value transactions from a small cohort of “whales” (high spenders).
2. In-Game Information Service (Advertising): Accounting for 4.7% of revenue, this stream monetizes the non-paying user base. By integrating banner ads, interstitials, and rewarded video ads (where users watch an ad to gain in-game currency), Zengame extracts value from “free-riders,” effectively subsidizing server and development costs.

Key Products

• Fingertip Sichuan Mahjong (指尖四川麻將):
  • Status: The undisputed flagship of the portfolio. It consistently ranks among the top 5 best-selling board/card games on the iOS platform in China.
  • Product Strategy: To combat the inherent visual stasis of board games, Zengame has introduced RPG (Role-Playing Game) elements and 3D visual effects. Recent updates include the “Journey to the West (西遊行)” mode and “Dragon Three Kingdoms (天龍三國),” which integrate mythological characters and narratives into the scoring mechanics. This strategy aims to deepen immersion and provide new avenues for monetization beyond simple table wagers.
  • Performance: Despite its popularity, this title is the epicenter of the revenue decline, suffering from user fatigue and lower spending per user in 1H2025.
• Fishing Master (捕魚神手):
  • Status: The vanguard of the Company’s pivot to Casual gaming. “Fishing” games are a popular sub-genre in Asia, combining arcade shooting mechanics with RNG (Random Number Generation) rewards.
  • Mechanics: Players use virtual currency to fire cannons at fish; capturing fish yields currency rewards. The game features high-fidelity graphics, distinct “Boss” fish (e.g., the “White Snake”), and dynamic screen effects designed to stimulate dopamine responses similar to slot mechanics, though strictly within non-gambling regulatory limits.
  • Performance: This title drove the 162% growth in the Casual segment, validating the Company’s ability to succeed outside the Mahjong niche.

Revenue Mix

The revenue composition highlights the ongoing transition. While the dependence on Board and Card games has decreased, it remains the dominant contributor, exposing the Group to significant concentration risk during this transition period.

Source: FY2025 Interim Report

3. Industry Landscape & Regulatory Environment

Trends: Market Saturation and the Fight for Attention

The Chinese mobile gaming market has matured past its rapid growth phase (the “demographic dividend”) into a phase of intense competition for retention and user time. The Board and Card segment is particularly saturated. The barriers to entry for basic card games are low, leading to a proliferation of “skins” (clones) that dilute the market.

• The “Matthew Effect”: The industry is witnessing a consolidation where top titles capture disproportionate revenue. To survive, mid-tier developers like Zengame must innovate on gameplay (e.g., 3D Mahjong) or pivot to genres with higher engagement loops, such as the “Mid-Core” Casual games exemplified by Fishing Master.
• Casual Market Growth: Unlike the stagnant board game market, the casual segment continues to grow, driven by fragmented playtime (commutes, breaks). However, customer acquisition costs (CAC) in this segment are rising due to competition for ad inventory on platforms like Douyin (TikTok) and WeChat.

Regulatory Risks: The Defining Constraint

Regulation is the single largest external variable impacting Zengame’s valuation multiple. The regulatory framework in China is overseen principally by the National Press and Publication Administration (NPPA).

• ISBN Licensing: Since 2018, the Chinese government has strictly controlled the number of new game licenses (ISBNs) issued annually. A game cannot monetize without an ISBN. Zengame’s library of 50 licensed self-developed games acts as a “regulatory moat,” protecting it from new entrants who cannot obtain licenses. However, it also limits the Company’s ability to quickly launch new titles to replace fading ones.
• Anti-Addiction Regulations: The stringent rules implemented in 2021 limit minors (under 18) to one hour of gameplay on Fridays, weekends, and holidays. Zengame has implemented mandatory real-name authentication and facial recognition systems to comply. While the direct revenue impact is manageable (as card games typically skew towards older demographics), the broader regulatory climate discourages “addictive” game loops, forcing developers to moderate their monetization tactics.
• In-Game Spending Limits: Periodic draft rules from the NPPA (such as those proposed in late 2023) regarding spending limits and bans on “daily login” rewards create persistent uncertainty. Board and Card games are often scrutinized for resemblance to gambling. Zengame must rigorously ensure its virtual currency cannot be converted back to fiat money (Reverse Real Money Trading), maintaining a closed-loop economy to avoid classification as gambling.

Competition

Zengame operates in a stratified competitive landscape:

• Boyaa Interactive (0434.HK): The most direct listed competitor. Historically a poker/chess specialist, Boyaa has recently diverged strategically by allocating significant capital into cryptocurrency (Bitcoin/Ethereum) and Web3 gaming. This makes Boyaa a crypto-proxy, whereas Zengame remains a pure-play gaming cash cow. This divergence makes Zengame a preferred choice for investors seeking traditional gaming exposure without crypto volatility.
• Tencent & NetEase: The titans of the industry dominate the general gaming market. Zengame avoids direct confrontation by focusing on localized rules (Sichuan rules vs. Standard rules) where the giants have less granularity.
• Micro-Studios: Thousands of small studios compete in the casual space. Zengame relies on its balance sheet and marketing budget to outspend these smaller rivals on user acquisition.

4. Corporate Structure (Variable Interest Entity)

To navigate the strict foreign investment laws of the PRC, Zengame utilizes a Variable Interest Entity (VIE) structure. Understanding this structure is critical for institutional investors, as it dictates the nature of their ownership.

Regulatory Context: The Negative List

The Special Administrative Measures for Access of Foreign Investment (Negative List) prohibits foreign ownership in “Internet Culture Businesses” (excluding music). Consequently, Zengame Technology Holding Limited (the Cayman Islands listed entity) cannot legally own the equity of the domestic companies that operate its games and hold the indispensable Internet Content Provider (ICP) licenses.

The VIE Structure

To bypass this, the Group separates economic ownership from legal equity ownership through a series of Structured Contracts.

1. The Listed Entity: Zengame Technology Holding Limited (Cayman).
2. The WFOE (Wholly Foreign-Owned Enterprise): Shenzhen Tiantianlaiwan Technology Co., Ltd. (“Tiantianlaiwan”). This entity is 100% owned by the listed group and sits within the PRC legal jurisdiction.
3. The VIEs (PRC Operating Entities): Shenzhen Zen-Game Technology Co. Ltd. (“Zen-Game Shenzhen”) and its subsidiaries, including Shenzhen Zhijian Interactive Entertainment Co., Ltd. (“Fingertip Interactive”). These entities hold the licenses and operate the games.
4. Registered Shareholders: The VIEs are legally owned by PRC nationals, primarily the founders Mr. Ye Sheng and Mr. Yang Min.

The Structured Contracts

The economic benefits and control are transferred from the VIEs to the WFOE via four key agreements:

• Exclusive Consultancy and Technical Service Agreement: The VIEs pay substantially all of their net profit to the WFOE as “service fees” for technical support and consultancy. This is the mechanism of profit transfer.
• Exclusive Call Option Agreement: The WFOE has an irrevocable option to purchase the equity or assets of the VIEs for the lowest price permitted by law, exercisable if/when PRC laws change to permit foreign ownership.
• Equity Pledge Agreement: The Registered Shareholders pledge their equity interest in the VIEs to the WFOE to guarantee the performance of contractual obligations.
• Shareholders’ Rights Entrustment Agreement / Power of Attorney: The Registered Shareholders irrevocably assign their voting rights and management control of the VIEs to the WFOE.

Ownership Concentration

The structure relies heavily on the cooperation of the Registered Shareholders. Ownership is highly concentrated:

• Mr. Ye Sheng (Chairman & CEO): Controls approximately 22.41% of the shares via Sky-zen Capital Limited.
• Mr. Yang Min (Vice Chairman & CTO): Controls approximately 19.11% of the shares via J&L Y Limited.

Together, the founders control over 41% of the company. This concentration provides stability but also poses “Key Man Risk.” The effectiveness of the VIE structure depends on their adherence to the contracts; while legal remedies exist, enforcing VIE contracts in PRC courts can be complex.

5. Management Discussion & Analysis (MD&A)

Strategic Pivot: Managing the Decline

Management’s commentary in the 2025 Interim Report is notably transparent regarding the challenges in the core business. They explicitly attribute the 24.1% revenue decline to “a decrease in the number of paying users and the ARPPU for board and card games”. This admission signals that the decline is structural, not merely cyclical. The strategy is effectively to manage the “cash cow” Board and Card segment for profitability while aggressively reinvesting the proceeds into the high-growth Casual segment.

The 162% growth in Casual game revenue validates the functional success of this pivot. Management emphasizes “continuously refining content updates” and “revitalizing the product” (e.g., Fishing Master) as key drivers. The challenge remains the rate of substitution; the new business is growing fast, but from a small base, and is not yet large enough to fully offset the contraction of the legacy giant.

AI Integration: Operational Leverage

The 2025 report details a significant strategic push into Artificial Intelligence (AI) and AIGC (AI-Generated Content). Management is moving beyond buzzwords to practical application:

• Product Development: The Group uses AI-powered art creation tools for “real-time painting” and “image-based 3D” generation. In the context of casual games, which consume vast amounts of 2D and 3D assets, this is a potent cost-saving lever. It reduces dependency on large art teams and external outsourcing.
• Game Operations: The deployment of “AI opponents” in board games is crucial for maintaining liquidity. As the user base shrinks (MAU down 17%), wait times for matches would naturally increase, leading to further churn. AI bots ensure instant match-making, preserving the user experience for the remaining human players.
• Data Analysis: AI is used to validate numerical designs and game balance, ensuring that monetization mechanics are optimized without breaking game fairness.

Metrics Analysis: The Bear Case

The operational metrics present a sobering picture of the business’s health:

• MAU (Monthly Active Users): Decreased from 25.2 million (1H2024) to 20.8 million (1H2025), a sharp drop of 17.6%. This indicates a narrowing top-of-funnel; fewer players are engaging with the platform.
• DAU (Daily Active Users): Dropped from 4.5 million to 3.8 million.
• MPU (Monthly Paying Users): Declined from 525,000 to 450,000.
• ARPPU (Average Revenue Per Paying User): Fell from RMB 271 to RMB 253.

Analysis: The simultaneous decline in both the quantity of paying users (MPU) and the quality of their spend (ARPPU) is a negative signal. Typically, as casual users churn, ARPPU rises because only the dedicated “whales” remain. The drop in ARPPU suggests that even the core high-spenders are tightening their wallets, likely due to macroeconomic factors or dissatisfaction with the game economy.

6. Financial Performance

Income Statement Analysis

• Negative Operating Leverage: While revenue fell 24.1%, Net Profit contracted by 41.0%. This non-linear decline is a textbook example of negative operating leverage. As the top line shrinks, fixed costs and rising variable costs eat into margins aggressively.
• Cost of Sales Dynamics: Cost of sales decreased by 21.8%, generally tracking revenue. However, a specific line item divergence exists:
  • Channel Costs: Decreased, tracking revenue (lower fees paid to Apple/Android stores).
  • Information Service Costs: Increased significantly from RMB 89.4 million to RMB 111.9 million. This likely reflects higher server and cloud computing costs required to support the more complex, data-heavy Casual games (3D physics, AI computations) compared to the lightweight 2D card games. The pivot to higher-quality games is structurally increasing the cost base.
• Selling and Distribution Expenses: This is the most critical red flag. Expenses surged 76.7% to RMB 73.0 million in 1H2025. Management is spending aggressively to acquire users for the Casual segment to stem the bleeding. However, the fact that revenue still fell significantly despite this massive spend increase indicates a sharp deterioration in marketing efficiency (Customer Acquisition Cost vs. Lifetime Value).

Balance Sheet: The Fortress

In contrast to the income statement, the balance sheet remains pristine and is the cornerstone of the “Deep Value” thesis.

• Cash & Cash Equivalents: RMB 517.5 million.
• Time Deposits (>3 months): RMB 1,137.9 million.
• Time Deposits (>1 year): RMB 351.2 million.
• Financial Assets (FVPL): RMB 648.7 million. (Primarily liquid wealth management products from banks like JP Morgan and UBS).

Net Cash Calculation (approximate):

Total Liquid Assets = 517.5 + 1,137.9 + 351.2 + 648.7 = RMB 2,655.3 million

Total Liabilities = RMB 344.8 million (Current + Non-current)

Net Cash Position works out to approximately RMB 2.31 billion

Comparison to Market Cap:

The Market Capitalization is HK$ 2.379 billion (approx. RMB 2.2 billion at prevailing exchange rates).

Conclusion: The Company is trading at or slightly below its Net Cash value. The market is assigning a negative Enterprise Value (EV) to the operating business. Investors are paying zero for the profitable gaming operations.

Cash Flow & Dividend Coverage Analysis

• Operating Cash Flow (OCF): Operating cash flow generated in 1H2025 was RMB 56.6 million, a steep decline from RMB 278.7 million in 1H2024. This decline outpaced the drop in net profit, suggesting adverse working capital movements and higher cash costs for user acquisition.   
• Dividend Coverage Ratio:
  • FY2024:
    • Dividend Paid (Final): ~HK$ 154.9 million (approx. RMB 143m).
    • Free Cash Flow (FCF): RMB 469.2 million (OCF RMB 490.0m – CapEx RMB 20.8m).
    • Coverage: The dividend was comfortably covered (3.3x)
  • 1H2025:
    • Dividend Declared (Interim): ~HK$ 206.8 million (approx. RMB 191m).
    • Free Cash Flow (FCF): RMB 53.9 million (OCF RMB 56.6m – CapEx RMB 2.7m).   
    • Coverage: 0.28x. The dividend is not covered by current free cash flow. The company is distributing approximately 3.5x its organic cash generation. This confirms that the current yield is being funded by the balance sheet (excess cash reserves), not current operations.

7. Valuation Assessment

Net Cash per Share

• Total Liquid Assets (RMB): ~2.655 billion.
• Shares Outstanding: ~1.034 billion.
• Net Cash per Share (RMB): ~2.57 RMB.
• Converted to HKD (approx. 1.08 rate): ~HK$ 2.77 per share.

Insight: With the stock price at HK$ 2.30, the shares are trading at a ~17% discount to the cash on hand. This is a rare anomaly, typically signaling that the market expects severe corporate governance issues (cash hoarding/theft) or massive future value destruction. Given the dividend payments, the governance risk appears overstated.

Dividend Analysis

• Stated Policy: The Company does not have a fixed dividend payout ratio. As stated in the Directors’ Report: “The Company has adopted a dividend policy on payment of dividends. The Company does not have any pre-determined dividend payout ratio. Depending on the financial conditions, operational needs, capital requirements and factors as set out in the dividend policy, dividends may be proposed and/or declared by the Board during a financial year.”    
• Yield:
  • Dividend Policy: No fixed ratio, but highly responsive to cash position.
  • Final 2024: HK$ 0.15 per share.
  • Interim 2025: HK$ 0.20 per share.
  • Trailing 12-Month (TTM) Payout: HK$ 0.35 per share.
  • Implied Yield: $0.35 / 2.30 = 15.2%.

Sustainability Check: The Interim 2025 dividend payout (HK$ 0.20) will cost approximately HK$ 206.8 million. The Net Profit for the period was RMB 182.8 million (approx. HK$ 197 million).

Conclusion: The payout ratio is effectively over 100% of current earnings. The dividend is being subsidized by the massive accumulated cash pile, not just current flow. While sustainable for several years due to the RMB 2.3 billion reserve, this is technically a return of capital, not just a return on capital.

Intrinsic Value (Dividend Discount Model – DDM)

Given the shrinking nature of the business and the focus on yield, a DDM is the most appropriate valuation tool.

• Assumption: Dividends decline by 5% annually into perpetuity (reflecting the shrinking legacy business).
• Discount Rate (Cost of Equity): 9% (3% risk free rate and 6% equity risk premium).
• Formula: P0 = D1 / (ke – g)
• Inputs: D1 = 0.35, ke = 0.09, g = -0.05 (negative growth).
• Calculation: P0 = 0.35 / (0.09 + 0.05) = 0.35 / 0.14 = HK$ 2.50.

Bull Case (Stabilization): If the Casual pivot succeeds and dividends stabilize at flat growth (g = 0):

• P0 = 0.35 / 0.09 = HK$ 3.89.

Assessment: The stock is fairly valued even under a pessimistic scenario of perpetual decline. Under a stabilization scenario, it offers ~69% upside. The “Net Cash” floor of HK$ 2.77 provides a hard backstop to valuation, making the risk-reward asymmetric.

Given the revenue decline (-24.1%) and the fact that 1H2025 FCF covered only 28% of the dividend, the dividend discount model has to reflect a “distressed” or “liquidation” scenario for the operating business.

• Assumption: Dividends are cut to match sustainable FCF levels or managed decline.
• D1 Estimate: HK$ 0.15 .
• Cost of Equity (ke): 9% (3% risk free rate and 6% equity risk premium).
• Growth Rate (g): -5% (Perpetual decline of legacy business).
• Formula: P0 = D1 / (ke – g)
• Calculation: P0 = 0.15 / (0.09 – (-0.05)) = 0.15 / 0.14 = HK$ 1.07.

Valuation Synthesis:

The DDM value of the operating business (HK$ 1.07) is significantly below the current share price. However, the stock acts as an Asset Play.

• Operating Business Value: ~HK$ 1.07
• Net Cash per Share: ~HK$ 2.77
• Current Price: HK$ 2.30

Conclusion: The stock is trading below its liquidation value (Net Cash). The market is effectively assigning a negative value to the future operations. As long as management does not destroy the cash pile through bad M&A, the Floor Value remains near HK$ 2.77.

8. Investment Outlook

Catalysts

1. Overseas Expansion: Management has explicitly stated intentions to accelerate expansion into overseas markets. Success in Southeast Asia or MENA regions with titles like Fishing Master would provide a new growth engine free from Chinese regulatory constraints (ISBNs/Anti-addiction).
2. ARPPU Stabilization: If the “Journey to the West” and “Fishing Master” updates succeed in halting the decline of ARPPU in 2H2025, the market’s “terminal decline” narrative will break, leading to a swift re-rating toward the Net Cash value.
3. Share Buybacks: With the stock trading below Net Cash, share buybacks would be immediately accretive to EPS and Net Cash per Share. Initiating a buyback program would be the strongest possible signal of value.

Return Profile

• Income: 15.2% Yield (Cash-backed, though coverage is weak).
• Capital Appreciation: Potential re-rating to Net Cash level (~HK$ 2.77) = +20%.
• Total Potential Return: ~35% over a 12-month horizon.

9. Risk Assessment

Concentration Risk

Despite the pivot, the Group remains heavily reliant on two key IPs: Fingertip Sichuan Mahjong and Fishing Master. If user fatigue accelerates for either title before a replacement is established, revenue could collapse faster than costs can be cut.

Regulatory Risk

This is the “Black Swan.”

• New Restrictions: Any new regulations limiting token mechanics in fishing games or imposing stricter daily spending caps would devastate the Casual segment.
• VIE Enforcement: While unlikely, a strict enforcement of the Foreign Investment Law prohibiting the VIE structure would render the equity worthless.

Value Trap (Governance Risk)

The primary risk to the thesis is that the controlling shareholders (Mr. Ye and Mr. Yang) choose to hoard the RMB 2.3 billion cash rather than distributing it, or worse, deploy it into value-destructive M&A outside their core competency. However, the generous Interim Dividend of 2025 serves as strong counter-evidence, suggesting management is shareholder-friendly.

Operational Risk: Negative Leverage

The spike in selling expenses (+76.7%) amidst falling revenue is dangerous. If CAC continues to rise while LTV falls, the unit economics of the business will break, turning the currently profitable operation into a loss-maker within 12-24 months.

10. Conclusion

Zengame Technology represents a textbook “Deep Value / High Yield” opportunity. The market has priced the equity solely on the trajectory of its declining legacy business, effectively assigning a negative value to its operating assets by trading the stock at a ~17% discount to its Net Cash position.

While the operational picture is undeniably challenging, defined by shrinking user bases and rising acquisition costs, the Company is not in financial distress. It remains profitable, generates positive operating cash flow, and holds a fortress balance sheet with virtually zero debt.

The dividend yield of ~15% appears sustainable in the medium term only due to the massive cash buffer, acting as a lucrative “pay-to-wait” mechanism. Investors are essentially buying a pile of cash at a discount and receiving a 15% coupon while holding a free call option on the success of the Casual game pivot.

Disclaimer

This article is a record of the thinking behind a personal investment decision. It does not represent any recommendation to purchase any stock mentioned in the article. As always, readers are strongly advised to do their own due diligence before making any investment decisions.