Value Partners Group Limited (the “Group”, “VP”, together with its subsidiaries) is committed to maintaining the highest level of ethical standards in business and will not tolerate bribery or corruption. VP adopts a zero-tolerance approach towards bribery and prohibits employees from offering, promising, giving or receiving anything of value to improperly influence a decision or to gain an improper or unfair advantage in promoting, enhancing, obtaining or retaining business. VP must observe and comply with relevant provisions of the Prevention of Bribery Ordinance (Cap. 201) (POBO) and follow related guidance issued by the Independent Commission Against Corruption (ICAC) when conducting regulated activities. Employees who violate the policy are subject to disciplinary action, up to and including termination of employment and, if warranted, legal proceedings.
A bribe is anything of value that is offered, promised, given or received to improperly influence a decision or to gain an improper or unfair advantage in promoting, enhancing, obtaining or retaining business. Bribery may not always be in the form of cash payments and may take many other forms, including:
• Gifts, travel, and hospitality;
• Political contributions;
• Charitable donations;
• Employment opportunities, internships or secondments;
• Procurement and service contracts;
• Phony jobs or “consulting” relationships;
• Excessive discounts, rebates, rewards or commission consisting of money or of any valuable security or of other property or interest in property of any description; or
• Non-arm’s length loans, payment, release, forgiveness of debt, obligation or other liability, whether in whole or in part or other transactions;
• any other service, or favour (other than entertainment), including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted;
• the exercise or forbearance from the exercise of any right or any power or duty; and;
• any offer, undertaking or promise, whether conditional or unconditional, of any advantage within the meaning of any of the above [POBO section 2(1)]
but does not include an election donation within the meaning of the Elections (Corrupt and Illegal Conduct) Ordinance (Cap. 554), particulars of which are included in an election return in accordance with that Ordinance.
- Facilitation payments
Facilitation payments are also a form of bribe and are, therefore, not permitted. Facilitation payments are small payments made to secure or speed up routine actions or otherwise induce public officials or other third parties to perform routine functions they are otherwise obligated to perform, such as issuing permits, approving immigration documents or releasing goods held in customs. This does not include legally required or permitted administrative fees for expedited service.
Directors or staff must comply with all local laws and regulations when conducting the Group’s business, and also those in other jurisdictions when conducting business there or where applicable.
- Prevention of Bribery
All directors and staff are prohibited from soliciting, accepting or offering any bribe in conducting VP’s business or affairs, whether in Hong Kong or elsewhere. In conducting all business or affairs of the Group, staff must comply with the POBO of Hong Kong and must not:
• solicit or accept any advantage from others as a reward for or inducement to doing any act or showing favour in relation to the VP’s business or affairs, or offer any advantage to an agent of another as a reward for or inducement to doing any act or showing favour in relation to his principal’s business or affairs;
• offer any advantage to any public servant (including Government / public body employee) as a reward for or inducement to his performing any act in his official capacity or his showing any favour or providing any assistance in business dealing with the Government / a public body; or
• offer any advantage to any staff of a Government department or public body while they are having business dealing with the latter.
- Advantages & Entertainment
Acceptance of Advantages
Staff is prohibited from soliciting or accepting any advantage for themselves or others, from any person or organization having business dealings with VP or any subordinate 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.
Gifts or souvenirs described in paragraph 5(a) that are presented to directors and staff in official functions are deemed as offers to the Group. Staff should immediately report the acceptance to the Compliance Team and seek direction as to how to handle the gifts or souvenirs.
Staff should decline an offer of advantage if acceptance could affect his/her objectivity in conducting the VP’s business or induce him/her to act against the interest of the VP, or acceptance will likely lead to perception or allegation of impropriety.
Staff may offer or receive gifts only if they are small in value and customary in nature. For any gifts worth HK$500 or above, staff must obtain prior written approval from Compliance Team. This includes political donations. The gifts/hospitality offered or received by or to any individual is subject to a maximum limit of HK$2,000 per item.
The grant of permission would depend amongst other things on:
i) Whether there is any conflict of interest or the extent of official dealings, if any, between the giver/receiver and the staff;
ii) Whether the acceptance will place the staff in a position of obligation towards the giver and compromise the staff’s position in his/her dealings with the giver or would place the receiver in a similar position in relation to the staff; and
iii) The frequency of similar permission being sought by the staff.
A register of benefits above the limit is maintained by the Compliance Team.
Offer of Advantages
Directors and staff are prohibited from offering advantages to any director, staff member or agent 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 VP’s business. Even when an offer of advantage carries no intention of improper influence, it should be ascertained that the intended recipient is permitted by his employer/principal to accept it under the relevant circumstance before the advantage is offered.
Director or staff member should avoid accepting lavish or frequent entertainment from persons with whom VP has business dealing (e.g. suppliers or contractors) or from his/her subordinates to avoid placing himself/herself in a position of obligation.
 “Entertainment” as defined in POBO.