1.1 It is the Company’s commitment to adopt ethical and anticorruption business practices, enforce the anti-corruption policy and adopt zero tolerance towards corruption of any form.

1.2 The Company regards honesty, integrity and fair play as our core values that must be upheld by all personnel of the Company, including Board of directors, senior executives and staff at all levels (collectively known as “directors and staff”) at all times.

1.3 When conducting business or affairs of the Company, all directors and staff must fully comply with the Prevention of Bribery Ordinance (POBO) of Hong Kong and other anti-bribery laws applicable to the Company.

 

2.1 This Policy and Code applies to all directors and staff. It sets out the basic standard of conduct expected of all directors and staff, and the Company’s policy on acceptance of advantage and handling of conflict of interest when dealing with the Company’s business.

2.2 The Company also expects our business partners, including suppliers and customers to abide by the principles of this Policy and Code

 

3.1 The Company prohibits all forms of bribery and corruption. All directors and staff are prohibited from soliciting, accepting or offering any bribe in conducting the Company’s business or affairs, whether in Hong Kong or elsewhere.

 

4.1 Directors and staff should not in their private capacity, without permission of the Company solicit or accept any advantage for themselves or others, from any person, company or organization having business dealings with the Company, except that they may accept (but not solicit) the following when offered on a voluntary basis:

(a) advertising or promotional gifts or souvenirs of a nominal value; or

(b) gifts given on festive or special occasions, such as Christmas or Chinese New Year hampers or moon cakes, where these are shared with colleagues and not excessive in value compared to the normal market custom; or

(c) discounts or other special offers given by any person or company to them as customers, on terms and conditions equally applicable to other customers in general.

 

4.2 For any gifts worth HK$500 or above, directors and staff must obtain approval from their supervisors and the Human Resources Department.

4.3 However, a director or staff member should decline any offer of advantage if acceptance could affect his/her objectivity in conducting the Company’s business or induce him/her to act against the interest of the Company, or acceptance will likely lead to perception or allegation of impropriety.

4.4 In case of any doubt, directors and staff should report the case to their immediate supervisors and the Human Resources Department for further advice.

 

5.1 Directors and staff are prohibited from offering advantages to any director, staff member of another company or organization, for the purpose of influencing such person in any dealing, or any public official, whether directly or indirectly through a third party, when conducting the Company’s business.

 

6.1 Although entertainment is an acceptable form of business and social behaviour, a director or staff member should avoid accepting lavish or frequent entertainment from persons with whom the Company has business dealing (e.g. suppliers or contractors) or from his/her subordinates to avoid placing himself/herself in a position of obligation.

 

7.1 Directors and staff should ensure that all records, receipts, accounts or other documents they submit to the Company give a true representation of the facts, events or business transactions as shown in the documents. Intentional use of documents containing false information to deceive or mislead the Company, regardless of whether there is any gain or advantage involved, may constitute an offence under the POBO.

 

8.1 Directors or staff must comply with all local laws and regulations when conducting the Company’s business, and also those in other jurisdictions when conducting business there or where applicable.

 

9.1 Directors and staff should avoid any conflict of interest situation (i.e. situation where their private interest conflicts with the interest of the Company) or the perception of such conflicts.

9.2 They should not misuse their position or authority in the Company to pursue their own private interests and those of their family members and relatives.

9.3 When actual or potential conflict of interest arises, they should make declaration to their supervisor and the Human Resources Department.

9.4 Some common examples of conflict of interest are described below but they are by no means exhaustive:

(a) A staff member involved in a procurement exercise is closely related to or has financial interest in the business of a supplier who is being considered for selection by the Company.

(b) One of the candidates under consideration in a recruitment or promotion exercise is a family member or a relative of the staff member involved in the process.

(c) A director of the Company has financial interest in a company whose quotation or tender is under consideration by the Board.

 

10.1 Directors and staff in charge of or having access to any Company assets, including funds, property, information, and intellectual property, should use them solely for the purpose of conducting the Company’s business. Unauthorized use, such as misuse for personal interest, is strictly prohibited.

10.2 Directors and staff should not disclose any classified information of the Company without authorization or misuse any Company information (e.g. unauthorized sale of the information). Those who have access to or are in control of such information, including information in the Company’s computer system, should protect the information from unauthorized disclosure or misuse. Special care should also be taken in the use of any personal data, including directors’, staff’s and customers’ personal data, to ensure compliance with Hong Kong’s Personal Data (Privacy) Ordinance.

 

11.1 If a staff member wishes to take up employment outside the Company, he/she must seek the prior written approval of the Company. The Company should consider whether the outside employment would give rise to a conflict of interest with the staff member’s duties in the Company or the interest of the Company.

 

Directors and staff are advised not to engage in frequent gambling activities (e.g. mahjong) with persons having business dealings with the Company.

Directors and staff should not accept any loan from, or through the assistance of, any individual or organization having business dealings with the Company. There is however no restriction on borrowing from licensed banks or financial institutions.

 

13.1 To prevent, detect and deter corruption, the Company has the anti-corruption programme in place as follows:

(a) offering anti-corruption training and briefings to all new staff members;

(b) requesting all staff to sign an integrity pledge and declare relationship which may have conflict of interests with the Company and their job duties;

(c) inviting speakers in the related fields to conduct anti-corruption training to staff, when needed;

(d) conducting background check or audit on suppliers/customers of the Company and requiring suppliers to sign an integrity pledge;

(e) including suitable anti-corruption and probity requirements in the agreements with the business partners as far as practicable for major contracts and partnering arrangements;

(f) participating in the Business Sector Integrity Charter launched by the ICAC’s Corruption Prevention Department.

 

14.1 Any enquiries or reports of possible breaches of this Policy and Code can be made to Director of HR of the Company and/or Chairman of the Audit Committee. The Company has the whistle-blowing policy in place and provides suitable channels for reporting corruption and violations of the anti-corruption policy.

14.2 The Company provides assurance of confidentiality, prompt handling and non-retaliation to whistle-blowers acting in good faith.

 

15.1 It is the responsibility of directors and staff of the Company to understand and comply with this Policy and Code of Conduct, whether performing their duties of the Company in or outside Hong Kong. Managers and supervisors should also ensure that the staff under their supervision understand well and comply with this Policy and Code.

15.2 The Company adopts the zero-tolerance policy towards any corrupt behaviour detected, which may result in reporting to the ICAC or the relevant law enforcement agency. Directors or staff in breach of this Policy and Code will be subject to disciplinary action, including termination of appointment or employment. In case of suppliers, it may lead to termination of contract and exclusion from future bidding.

 

16.1 This Policy and Code of Conduct will be reviewed regularly and be revised as and when necessary to ensure its effectiveness. It will be included in the Company’s Staff Handbook and be disclosed on the website of the Company.