
Treasury stock has long been considered an important tool in the governance of listed companies, playing a role in adjusting capital structure, protecting shareholder interests, and strengthening market confidence. When this activity is not managed properly, companies may face numerous financial risks or create unrealistic expectations. However, with advanced governance models around the world, especially the disciplined approach of Berkshire Hathaway, treasury stock can become a crucial part of a long-term capital allocation strategy.
HVA Group currently The share buyback program has not yet been implemented., The company is currently researching and shaping a suitable approach for the future. This article shares the perspective, management spirit, and principles that HVA is considering in preparation for the potential application of treasury stock as a tool when conditions are ripe.
Legal basis and improvement of the governance framework
Circular 115/2025/TT-BTC and the new transparency requirements of the market.
Circular 115/2025/TT-BTC, effective from January 28, 2026, amends and supplements several articles of Circular 118/2020/TT-BTC guiding certain aspects of securities offerings, public tenders, share buybacks, registration of public companies, and delisting of public companies. Despite the changes, it maintains strict requirements regarding information disclosure and shareholder responsibilities, while also facilitating businesses in adjusting their share buyback plans.
In this legal context, HVA views this as an important reference point for building its internal process framework, even though it has not yet implemented any share buyback activities. Understanding and preparing in advance helps the company be ready when the time is right in terms of strategy and financial conditions.
A preparatory and reference-based approach.
The study of legal regulations, analysis of standardized processes, and development of an internal evaluation framework are not intended to confirm that HVA is currently or preparing to repurchase treasury shares, but rather to create a foundation for existing governance. This is a necessary step for the company to expand its capital management tools in the future, if it is deemed that this activity will bring value to shareholders.
Capital management philosophy that HVA references: Learning from the spirit of Berkshire Hathaway.
Treasury stock as a capital allocation option
In international models, particularly Berkshire Hathaway, share buybacks are always viewed as a long-term capital allocation decision rather than a short-term stock price adjustment. This is one of the philosophies that HVA highly values and is considering applying in the future.
This approach emphasizes considering treasury stock alongside other options such as expansion investments, technology development, or M&A, with the common goal of optimizing intrinsic value.
Shareholder interests are the central focus.
HVA's policy is that if treasury stock is considered in the future, all decisions will focus on ensuring the interests of existing shareholders. The plan will only be meaningful if it delivers sustainable added value rather than short-term goals.
Financial conditions and internal evaluation criteria – Initial framework
Develop a set of reference criteria for the future.
Although it has not yet implemented a share buyback program, HVA is researching the financial standards commonly applied by large corporations worldwide. Criteria such as minimum liquidity, liquid asset ratios, and debt control will serve as a reference when the company considers future capital allocation tools.
Focus on intrinsic value – A guiding principle
Any share buyback plan, if considered in the future, should be based on the intrinsic valuation of the business rather than market fluctuations. This is the perspective HVA aims for when researching methods for evaluating businesses and determining the suitability of share buybacks.
Establishing management processes – A preparatory step.
Sharing perspectives on a transparent process.
The treasury stock management process described in this article is for reference only, aiming to establish the correct standard for future operations. Steps such as appraisal, approval, information disclosure, and reporting will be fully complied with by HVA if this activity is implemented, ensuring legal compliance and transparency with the market.
Objective: Be ready when needed, not create immediate expectations.
Establishing this process does not mean that HVA is currently or preparing to repurchase treasury shares. This is a proactive management approach, aimed at ensuring the company is not caught off guard when future needs arise.
Conclusion
HVA Group's approach to treasury stock management is built as part of a long-term capital management vision, not a description of current operations. HVA draws on Berkshire Hathaway's capital discipline, combined with Vietnamese legal regulations, to form a framework of thinking and internal processes ready for the future.
The goal of this research and sharing is to help shareholders and investors understand the governance direction; and to affirm that HVA only considers treasury stock when market, legal, and financial conditions are all suitable, ensuring the creation of real intrinsic value for shareholders.









