Anti-Corruption & Anti-Bribery Policy
Fuyuan Legacy Limited 福源世業有限公司
Last updated: April 2026
1. Purpose
Fuyuan Legacy Limited 福源世業有限公司 a company incorporated and operating under the laws of Hong Kong, business registration number 79932127 (“the Company”), is committed to conducting all business activities with the highest standards of integrity, honesty, and transparency. This Policy sets out the Company’s zero-tolerance approach to corruption and bribery in all forms and provides clear guidance to directors, employees, agents, and business partners on how to recognise, prevent, and report corrupt conduct.
2. Legal Framework
This Policy is established in compliance with the following laws and regulations:
- Prevention of Bribery Ordinance (Cap. 201) (“POBO”) — the primary anti-bribery legislation in Hong Kong, enforced by the Independent Commission Against Corruption (ICAC)
- Independent Commission Against Corruption Ordinance (Cap. 204)
- Crimes Ordinance (Cap. 200) of Hong Kong
- Applicable anti-corruption laws in all jurisdictions where the Company conducts business
Under the POBO, any person who offers, solicits, or accepts a bribe — in both the public and private sectors — commits a criminal offence punishable by a fine of up to HKD 500,000 and 7 years’ imprisonment.
3. Scope
This Policy applies to:
- All directors and officers of the Company
- All full-time, part-time, and contract employees
- Agents, intermediaries, consultants, and representatives acting on behalf of the Company
- Business partners, suppliers, and third parties engaged in dealings with the Company
- All business operations in Hong Kong and any overseas jurisdictions
4. Definition of Bribery and Corruption
For the purposes of this Policy, bribery means the offering, giving, receiving, or soliciting of any advantage to improperly influence the actions or decisions of any person in a business or official capacity.
Under the POBO, “advantage” includes:
- Any gift, loan, fee, reward, or commission consisting of money or valuable property
- Any office, employment, or contract
- Any payment, release, or discharge of a loan or other liability
- Any service, favour, or forbearance
- Any exercise or forbearance from exercising any right or power
Corruption includes any act of dishonesty or abuse of position for personal gain, or to benefit or disadvantage another party.
5. Prohibited Conduct
The following actions are strictly prohibited under this Policy:
- Offering, promising, or giving a bribe to any person — whether a government official, public servant, or private individual
- Requesting, agreeing to receive, or accepting a bribe
- Using a third party (agent, intermediary, or partner) to offer or receive a bribe on the Company’s behalf
- Making facilitation payments — informal payments made to expedite routine government actions
- Making political donations on behalf of the Company without prior Board approval
- Using Company funds or resources to obtain any improper business advantage
- Falsifying records, invoices, or accounts to conceal corrupt conduct
6. Gifts, Entertainment & Hospitality
The Company recognises that reasonable and proportionate gifts and hospitality are a legitimate part of international business relationships. However, all gifts and hospitality must:
- Be of modest value and consistent with customary local business practice
- Not be offered or accepted with the intent to influence a business decision
- Never be in cash or cash equivalents (e.g. gift cards, vouchers of significant value)
- Be transparently recorded in the Company’s gifts and hospitality register
- Not be offered to public officials or government representatives without prior written approval from the Director
Any gift or hospitality exceeding HKD 500 in value must be reported to the Director for prior approval.
7. Conflicts of Interest
All directors, employees, and agents must promptly disclose any situation that may constitute or give rise to a conflict of interest — including personal, financial, or family relationships that could influence business decisions.
Disclosed conflicts must be managed appropriately, which may include recusal from relevant decisions or transactions.
8. Due Diligence on Third Parties
Before engaging any agent, intermediary, supplier, or business partner, the Company will conduct appropriate due diligence to assess their integrity and anti-corruption compliance.
Due diligence measures include:
- Background checks and verification of business credentials
- Review of reputation and any known regulatory or legal issues
- Requiring third parties to acknowledge and comply with this Policy
- Including anti-corruption clauses in all relevant contracts and agreements
9. Record Keeping
The Company maintains accurate and transparent financial records in accordance with applicable accounting standards. All payments, expenses, gifts, and hospitality must be properly recorded with clear supporting documentation.
No off-the-books accounts or transactions will be permitted under any circumstances.
10. Training and Awareness
All directors and employees will receive training on this Policy upon joining the Company and on a regular basis thereafter. Training will cover:
- The requirements of the POBO and applicable anti-corruption laws
- Recognition of bribery and corrupt conduct
- Reporting obligations and whistleblowing procedures
- Consequences of non-compliance
11. Reporting Violations — Whistleblowing
The Company encourages all directors, employees, and third parties to report any suspected or actual violations of this Policy without fear of retaliation.
Reports may be made:
- Directly to the Director of Fuyuan Legacy Limited
- Via email to: admin@fuyuanlegacy.com
Anonymously through any available reporting channel
All reports will be treated with strict confidentiality. The Company expressly prohibits any form of retaliation against individuals who make good-faith reports of suspected corruption.
Serious cases will be referred, after consulting legal advisers, to the ICAC or other relevant authorities.
12. Consequences of Non-Compliance
Any breach of this Policy by a director or employee will be treated as a serious disciplinary matter and may result in:
- Immediate suspension or termination of employment or engagement
- Referral to the ICAC or relevant law enforcement authorities
- Civil or criminal prosecution under applicable law
Violations by third parties may result in immediate termination of the business relationship.
13. Monitoring and Review
The Director of the Company is responsible for overseeing the implementation and effectiveness of this Policy. This Policy will be reviewed at least annually and updated as necessary to reflect changes in applicable laws, business activities, or best practices.
14. Contact
For questions or guidance regarding this Policy, please contact:
Fuyuan Legacy Limited 福源世業有限公司
Compliance contact: admin@fuyuanlegacy.com
Website: www.fuyuanlegacy.com
For external reporting:
ICAC Hong Kong: www.icac.org.hk
ICAC Hotline: 2526 6366