All Industries (Frontline Practitioners) 1/12/2026

Date
Time
4:00 - 5:00 p.m.
Language
All Sector / Industry
On
Course Outline
Corruption prone areas in the business sector
Legal and administrative controls
Handling of conflict of interests
Role of staff in corruption prevention
Zero tolerance toward corruption
ICAC resources and services
Target
Frontline practitioners working in the business sector
Enquiry
2826 3197 (Ms LEE)
Course Full
On
CPD Course
Off
Course Title Industry
Course Title Object

Corruption Myths in the Business Community

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Myth en
Import Data

[EN] Corruption Myths in the Business Community https://hkbedc.icac.hk/Upload/guides/101/pdf/7433ac18545c446095f232144ddd8a37.pdf Image link: https://hkbedc.icac.hk/cache/img/268701c3cb5c840048c06e46e75e8fa6.jpg [ZH-HANT] 商界的貪污迷思 https://hkbedc.icac.hk/Upload/guides/101/pdf/a81b092c04d24880af961d9971f115f9.pdf Image link: https://hkbedc.icac.hk/cache/img/a489f1aa4b9f73aa8504823f51607984.jpg [ZH-HANS] 商界的贪污迷思 https://hkbedc.icac.hk/Upload/guides/101/pdf/a81b092c04d24880af961d9971f115f9.pdf Image link: https://hkbedc.icac.hk/cache/img/a489f1aa4b9f73aa8504823f51607984.jpg

All Trades/ Industries
Off
migration_resource_id
leaflets_001
Show Only in Sector/Industry
False

Corruption Prevention Good Practices on Conveyancing and Related Transactions for Law Firms

Cover
Image
Corruption Prevention Good Practices on Conveyancing and Related Transactions for Law Firms
Import Data

[EN] Corruption Prevention Good Practices on Conveyancing and Related Transactions for Law Firms https://cpas.icac.hk/UPloadImages/InfoFile/cate_43/2023/3949097e-e7f7-4b85-97c6-422f4677c459.pdf Please use the image at the left [ZH-HANT] 律師行的物業轉易及相關交易 - 防貪錦囊 https://cpas.icac.hk/UPloadImages/InfoFile/cate_43/2023/066c6395-b84f-45aa-950e-87977bbd7d9e.pdf Please use the image at the left [ZH-HANS] 律师行的物业转易及相关交易 - 防贪锦囊 https://cpas.icac.hk/UPloadImages/InfoFile/cate_43/2023/066c6395-b84f-45aa-950e-87977bbd7d9e.pdf Please use the image at the left

All Trades/ Industries
Off
migration_resource_id
leaflets_012
Show Only in Sector/Industry
False

All Industries (Frontline Practitioners) 17/11/2026

Date
Time
10:00 - 11:00 a.m.
Language
All Sector / Industry
On
Course Outline
Corruption prone areas in the business sector
Legal and administrative controls
Handling of conflict of interests
Role of staff in corruption prevention
Zero tolerance toward corruption
ICAC resources and services
Target
Frontline practitioners working in the business sector
Enquiry
2826 3197 (Ms LEE)
Course Full
On
CPD Course
Off
Course Title Industry
Course Title Object

All Industries (Managerial Staff) 10/11/2026

Date
Time
4:00 - 5:30 p.m.
Language
All Sector / Industry
On
Course Outline
Corruption prone areas in the business sector
Legal and administrative controls
Handling of conflict of interests
Tips on managing staff integrity
Integrity management in action
ICAC resources and services
Target
Managerial staff working in the private sector
Enquiry
2826 3197 (Ms Lee)
Course Full
On
CPD Course
Off
Course Title Industry
Course Title Object

All Industries (Managerial Staff) 21/10/2026

Date
Time
10:00 - 11:30 a.m.
Language
All Sector / Industry
On
Course Outline
Corruption prone areas in the business sector
Legal and administrative controls
Handling of conflict of interests
Tips on managing staff integrity
Integrity management in action
ICAC resources and services
Target
Managerial staff working in the private sector
Enquiry
2826 4725 (Ms Lee)
Course Full
On
CPD Course
Off
Course Title Industry
Course Title Object

Common trade practice is not a defence

Andrew was the chief accountant of a large trading company. He discovered a number of fraudulent and corrupt activities involving senior sales representatives and their mainland clients and such activities were condoned by the senior management.
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Common trade practice is not a defence
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cases_089_cover_en
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Andrew was the chief accountant of a large trading company.  Due to keen competition, the business of the company deteriorated substantially.  To improve the situation, the company attempted to invest in the Mainland.

When reviewing the books and bank statements, Andrew found that there was evidence of fraudulent activities involving some sales representatives. Andrew discovered that there were no supporting documents for some cash payments claimed by the sales representatives.  When asked for explanations, the sales representatives replied that those expenses had been incurred for the purpose of building up new businesses in the Mainland.  They further explained that the offering of commission to agents of business clients was a common practice.  When consulting the Marketing Director who was a long serving staff of the company, Andrew was told that the expenses were approved by  the Marketing Director personally. 

With no choice, Andrew went to see the Vice-president.  The Vice-president pacified Andrew and told him that in real business life, the company had to tolerate some minor variations in order to get the job done.

Next day, a cheque was placed on Andrew’s desk and the phone rang.  It was the Marketing Director.  Andrew was asked to sign the cheque and was told that it would be deposited in a designated Hong Kong bank account belonging to a buyer of a firm in the Mainland.  The arrangement enabled the buyer to pay for his various expenses while on business in Hong Kong.  He further suggested that the sum could be paid by an overseas subsidiary of the company.

Although Andrew knew that the client was very important to the company, he suspected that the payment might be unlawful.

What should Andrew do?

Case Analysis

The sales representatives committed an offence under Section 9(3) of the Prevention of Bribery Ordinance (POBO) offence if they had submitted false documents i.e. claims of commissions or entertainment expenses to deceive their principal i.e. the company.   

Furthermore, the offering of illegal commissions to agents of business clients with a view to obtaining or securing business might constitute a bribery offence under the POBO.   Agents of clients should obtain permission from their principals, i.e. their employers, for accepting advantages or commissions in relation to their work.  As approval should be given by the principal of the acceptor not the offeror, the Managing Director’s approval on the expense payments would not be considered the principal’s approval in this case.  

Although the clients were located in the Mainland, if any part of the act of bribery (including offering, soliciting or accepting a bribe) takes place in Hong Kong, the case may still be pursued by the ICAC under the POBO.  In any case, customary trade practice could not be a defence in any proceeding for a bribery offence under the POBO.  

Andrew should bring the issues to the attention of the company management and avoid involve in any acts that might call his integrity and professionalism into question. He should take into account his own views on ethics and legality and offer advice to the management if there were better alternatives.  

If corruption involving senior management was suspected, and all his attempts to find legal and ethical alternatives were rejected, then Andrew should consider resigning from the company and refuse to carry out any illegal transactions. He should consider reporting corruption to the ICAC and other crimes to the police.

All Trades/ Industries
Off
migration_resource_id
cases_089
Survey Questions
1. In which country or region are you currently located?
Hong Kong
Chinese Mainland
Other (please specify)
2. What type of organisation do you represent?
Listed company
Large private company
SME / start-up
NGO / non-profit
Public organisation
Chamber / trade association
Other (please specify)
3. What is the size of your organisation?
1 - 49 employees
50-99 employees
100 - 199 employees
200 or more employees
4. What is your staff level or position?
Executive / senior management
Middle management
Professional
Supervisory level
Frontline/Technical Staff
Other (please specify)

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