Legal analysis: Private fund managers can't buy stocks. Private fund managers and institutions engaged in private fund custody business manage and use private fund property, institutions engaged in private fund sales business and other private fund service institutions engaged in private fund service activities should fulfill their duties and fulfill their obligations of honesty, credibility, prudence and diligence. Private equity fund practitioners shall abide by laws and administrative regulations, and abide by professional ethics and codes of conduct.

Legal basis: Article 40 of the Securities Law of People's Republic of China (PRC), employees of securities exchange places, securities companies, securities registration and settlement institutions, staff of securities supervision and administration institutions and other personnel prohibited from participating in stock trading by laws and administrative regulations shall not hold, buy or sell stocks or other securities with equity nature directly or in the name of others, or accept stocks or other securities with equity nature donated by others during their term of office or within the statutory time limit. When becoming a person listed in the preceding paragraph, the stocks or other securities with equity nature that he has held must be transferred according to law. Employees of securities companies that implement the equity incentive plan or employee stock ownership plan may hold or sell their own shares or other securities with equity nature in accordance with the provisions of the the State Council Securities Regulatory Authority.