All Industries (Managerial Staff) 10/11/2026
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'All Industries Frontline Practitioners 11/9/2026
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Good relations with complications
Given the increasing demand of the hotel guests for local tour services, the hotel’s senior management decided to set up a consignment corner for a travel agency to deal with these requests. Janice, the hotel’s Marketing Manager, was assigned to the task.
It seemed only natural, therefore, for Janice to call Tommy, her brother-in-law, to enquire whether the travel agency he worked for would be interested.
In the midst of a recession, the performance of Tommy’s company had already been discouraging.
Hence, the pressure on Tommy, the Business Development Manager, to find a solution was intensified. The prospect of winning the consignment corner came as a huge relief to Tommy. He explained that this would save his career and urged Janice to grant the consignment contract to his travel agency. Believing that Tommy’s agency was as good as any other agencies and no one would discover their relationship, Janice made her decision easily.
A month later, as a token of gratitude, Tommy presented Janice a tour package to Hawaii as her birthday present.
Considering the close relationship with her brother-in-law, Janice should have observed her company’s internal guidelines on declaration of conflict of interest and refrained from being involved in the granting of contract. Conflict of interest situations such as this, if not dealt with properly, may easily lead to corruption.
Under the Prevention of Bribery Ordinance (POBO), a tour package is an advantage. Janice might breach the POBO if she, without the permission of the hotel, accepted the tour package as a reward for granting the contract to Tommy’s agency. In that case, Tommy might also breach the POBO for offering of bribe.
False attendance record
Ophelia, who worked part-time at a hotel, was responsible for hosting guests during conferences and banquets. Recently, she planned a week-long Japan trip with her boyfriend, which meant she would forfeit a substantial part of her income. Therefore, Ophelia asked her cousin, Ollie, who also worked at the hotel, to forge her signature on the monthly attendance record sheet to make it appear as if she had worked and to deceive the hotel of wages.
However, Ollie believed that forging false records might constitute fraud and firmly refused Ophelia's request. Ophelia then approached Oscar, another part-time employee, with the same request. To persuade Oscar, Ophelia promised to help him buy limited-edition anime figures from Japan. Unable to resist the temptation, Oscar agreed to help Ophelia by forging her signature on the attendance record sheet. Ollie was aware of Ophelia's collusion with Oscar but, reluctant to report her cousin, chose to turn a blind eye to the illegal behaviour.
Ophelia deliberately submitted false attendance record to her company intending to deceive the employer of wages. She might violate Section 9(3) of the Prevention of Bribery Ordinance or other fraudulent offences as she intentionally used documents containing false information to deceive her employer. Oscar might also commit an offence of conspiracy to defraud. When faced with Ophelia’s offer to help him purchase limited-edition anime figures, Oscar should decline the offer immediately to avoid putting himself in an obligatory position that could lead to illegal acts.
Ollie was aware that Ophelia had submitted false documents to deceive the hotel but chose to turn a blind eye. Deliberately concealing or shielding unlawful behaviour may give rise to suspicions of involvement in illegal activities. Therefore, to safeguard the interests of oneself and the company, employees should adopt a zero-tolerance stance toward corruption and report it to the ICAC.
The best employee?
The hotel was in the midst of a busy banquet season and often hired temporary workers at an hourly wage to assist with operations. According to the hotel's policy, employees who left their posts after midnight were eligible for an additional transportation allowance.
Nancy had been working at the hotel for some time and was highly regarded by the hotel manager, Nick, due to her efficiency and diligence. In order to receive the additional transportation allowance, Nancy asked Nick if she could report her off hour at midnight even though she actually only worked until 11 p.m. Initially, Nick hesitated, but considering the difficulties in hiring within the hotel industry, he eventually decided to turn a blind eye to Nancy’s actions and signed off her attendance records to help her obtain the extra allowance.
Nancy deliberately submitted false attendance records to her company with the intent to deceive her employer of wages. She might violate Section 9(3) of the Prevention of Bribery Ordinance or committed other fraudulent offences, as she intentionally used documents containing false information to mislead her employer. Even though Nick did not receive any advantages, he might also be guilty of conspiracy to defraud.
As a managerial staff, Nick has a responsibility to carry out his supervisory duties. Apart from performing his own duties, he should serve as a role model and set a good example for his subordinates. It is his duty to oversee the conduct and performance of his subordinates, ensuring their compliance with laws and regulations.
Employees should always remain vigilant and adopt a zero-tolerance stance toward corruption and unethical practices, and report to the ICAC and the company. If employees turn a blind eye or condone illegal behaviour, it not only tarnishes the corporate culture but also harms the company's interests.
Partners in crime
Michael, the chief engineer of the hotel, was responsible for purchasing spare parts for the repair of the hotel’s air-conditioning system. According to the purchasing policy of the hotel, Michael was required to declare any conflict of interest and obtain quotations from various suppliers for each purchase and recommend a selected supplier to the hotel.
Michael’s high school classmate, Mike, was a spare parts supplier of the hotel but Michael never declared the conflict of interest to the hotel. They agreed that for each procurement exercise, Michael would first disclose the quotations from other companies to Mike, who would then submit his quotation before the submission deadline. Mike’s company often won the supply contract with the lowest bid. In case where no quotations were received for minor purchase items, they falsified multiple quotations, and Mike’s company secured the contracts with the lowest bid.
On the other hand, Mike submitted false invoices to the hotel, falsely claiming that he had delivered all the parts according to the quoted quantities. In reality, the amount of goods delivered was insufficient and Michael assisted in concealing the under-delivery.
Michael is regarded as an agent of the hotel. Without the hotel’s permission, he accepted rebates from Mike for disclosing quotation information of other bidders to the latter so that Mike could secure the contract at the lowest bid. Michael might breach Section 9 of the Prevention of Bribery Ordinance (POBO) while Mike might also commit the offence by offering bribes. Michael conspired with Mike to use false documents to deceive his employer so that Mike could obtain the supply contract, he might breach Section 9(3) of the POBO or other fraudulent offences and Mike might also commit a conspiracy to defraud offence. Similarly, Mike submitted false invoices to the hotel to conceal the under-delivery and Michael assisted to cover up the matter. Both of them might commit the offence of conspiracy to defraud.
Michael and Mike were high school classmates which constituted a conflict of interest. Michael did not declare the conflict of interest to the hotel intentionally and might violate the company’s internal policies. Employees must adhere to the company’s guidelines and procedures when conducting procurement exercises, including the guidelines on handling conflicts of interest. They should avoid conflict of interest as far as possible and make timely declarations strictly following the internal guidelines. Mishandling conflict of interest may distort and cast doubt on the reliability of one’s professional judgement. On the other hand, companies should implement internal monitoring mechanisms and effective checks and balances to ensure that employees properly follow the procurement policies and goods receiving procedures.
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