Corruption Prevention Policy
 
The Company believes that honesty, integrity and fair play are its important assets in business. All employees must ensure that the Company’s reputation is not tarnished by dishonesty, disloyalty or corruption.
 
1) Prevention of Bribery Ordinance
Any employee soliciting or accepting an advantage in connection with his/her duties without the permission of the Company commits an offence under the Prevention of Bribery Ordinance. The term "advantage" includes money, gift, loan, fee, reward, office, employment, contract, service and favor.
 
2) Soliciting Advantages
It is the policy of the Company to prohibit employees to solicit any advantage from clients, suppliers or any person in connection with the Company’s business.
 
3) Accepting Advantages
Employees should decline advantages offered in connection with their duties if the acceptance of advantages could affect their objectivity or induce them to act against the Company’s interests or lead to complaints of bias.
 
Employees could consider accepting voluntarily given advantages only if:
   a) the acceptance will not influence the performance of the recipient;
   b) the recipient will not feel obliged to do something in return for the offer or;
   c) the recipient is able to openly discuss the acceptance without reservation; and
   d) the nature (e.g. advertising or promotional gift, customary gift or lucky money given during festive occasions) and the value of the advantage (not exceeding HK$250) are such that refusal could be seen as unsociable or impolite
 
In case of doubt, the recipient should refer the matter to their immediate supervisors for advice and instructions.
4) Offering Advantages
Under no circumstances may an employee offer bribes or similar considerations to any person or company for the purpose of influencing such person or company in obtaining or retaining business for, or directing business to the Company.
 
Any commissions paid or payment paid, or favorable terms conceded, or other advantages given by any employee in the conduct of the Company’s business should be in accordance with the Company’s prevailing policies on such matters and should obtain the prior written approval of the Company.
 
5) Entertainment
Although entertainment is an acceptable form of business and social behavior, employees should turn down invitations to meals or entertainment that are excessive in nature or frequency, so as to avoid embarrassment or any potential loss of objectivity when conducting the Company’s business. If it is impolite to decline an invitation, employee might accept, on the understanding that he/she be allowed to reciprocate.
 
6) Use of Proprietary Information
Employees are not allowed at any time to disclose any proprietary information to anybody outside the Company without permission. Such information may relate to all aspects of the Company’s operations including investment strategies, sales and marketing plans, new products, financial projects, clientele databases, etc.
 
It is the responsibility of each employee who has access to or in control of the proprietary information to provide adequate safeguards to prevent its abuse or misuse. Examples of misuse include disclosure of information in return for monetary rewards; use of information for personal interest; and disclosure of information to sabotage the Company’s interest.
 
7) Conflict of Interest
Conflict of Interest situation arise when the personal interests of an employee compete or conflict with the Company’s interests. Every employee of the Company should take it as his/her personal responsibility to avoid engaging in situations that may lead to or involve conflict of interest with the Company. He/she should at all times ensure that his/her dealings with customers, suppliers, contractors and colleagues do not place him/her in a position of obligation that may lead to a conflict of interest.
 
In cases where employee or his/her immediate family members might have engaged or considered engaging in business, investments or activities that may have existing or potential conflict with the Company’s interests, it is the responsibility of the employee to make full disclosure in writing to the his/her immediate supervisor and make a copy to the Human Resources and Administration Department.
 
8) Misuse of the Company’s Assets and Resources
Appropriation of the Company’s properties, including raw materials and finished goods by employees for personal use or for resale is a crime of theft and any offenders may be dismissed and prosecuted.
 
9) Loans to and from Suppliers
No employee or his/her immediate family members should make or guarantee a loan to, or accept a loan from or through the assistance of any individual or organization having business dealings with the Company. There is, however, no restriction on normal loans from banks or financial institutions made at the prevailing interest rates and terms.
 
10) Outside Employment
Employees who wish to take concurrent employment, either regularly or on a consulting basis, must seek the prior written approval from both department head and Human Resources and Administration Department before accepting the employment.
 
11) Gambling
 
Employees are advised not to engage in frequent and excessive gambling of any kind, including games of mahjong, with persons having business dealings with the Company. In social games with clients, contractors or suppliers, employees must exercise judgment and withdraw from any high stake games.
12) Use of Contractors for Personal Work
Employees may use company contractors for personal work provided that they:
   a) have no responsibility for, or not in a position to influence, the appointment or supervision of the contractor;
   b) pay for the services at commercial rates; and
   c) report the use in writing to the General Manager/Managing Director / Chief Executive Officer before commencement of work.
 
13) Company Records and Accounts
Employees are reminded that falsifying documents or furnishing false accounting records are also offences under the Prevention of Bribery Ordnance and are strictly prohibited.
 
14) Breach of Company Rules
The Company will not tolerate any illegal or unethical acts. Anyone breaching the Company's rules will be disciplined, including termination of employment. In cases of suspected corruption or other forms of criminality, a report will be made to the ICAC or appropriate authorities.
 
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