SHUN YUEN Construction Company Limited (hereinafter called Shun Yuen) prohibits all forms of bribery and corruption and is committed to integrity, honesty, and anti-corruption practices in doing business. All directors and staff (hereinafter called “personnel”) must abide by this integrity policy and the associated company strategies. To this end, Shun Yuen has adopted the following approaches to maintain our integrity management:

- To observe the Prevention of Bribery Ordinance (Cap. 201) and Competition Ordinance (Cap. 619) in Hong Kong and relevant laws in other jurisdictions when carrying out business in the region;

- To prohibit all personnel to solicit or accept any benefits, as defined under the Prevention of Bribery Ordinance (Cap. 201) from any individuals or organizations having business dealings with Shun Yuen unless permission is granted for the acceptance;

- To prohibit all personnel from offering benefits to any staff or member of a government department or any individuals of organizations, whether directly or indirectly through a third party, for influencing them in any dealing, when carrying out with Shun Yuen;

- To avoid all personnel from accepting luxurious or frequent entertainment from others having business dealings with Shun Yuen;

- To avoid all personnel from getting into any conflict-of-interest situation, or the perception of such. Otherwise, the person concerned should make a declaration to the approving authority who should decide on the actions for mitigating the conflict;

- To prohibits all personnel from disclosing any classified information without permission, and misusing any information of Shun Yuen;

- To provide an internal reporting system for our personnel to enquire matters regarding integrity and report possible breaches of integrity requirements,

- To ensure no retaliation will be conducted against any person who reports possible breaches of integrity requirements faithfully, and;

- To carry out internal disciplinary action, including termination of appointment or referral to relevant law enforcement agencies, to the person who in breach of integrity requirements. To render full assistance to law enforcement agencies in the investigation of criminal offences.

This Policy will be understood, implemented, and maintained by all personnel of Shun Yuen. Shun Yuen is committed to partner with ethical business counterparts who share the same value and commit to the same integrity standard.