HGC Global Communications Investment Holding Limited (“HGCIH” or “the Company”) and its subsidiaries, (the “Group”) is firmly committed to maintaining high ethical standards in the conduct of its business. All directors, officers and employees (the “Company Personnel”) of the Company, its subsidiaries and affiliated companies over which it exercises control (“the Group”) are required to fully comply with the Company’s Code of Ethics applicable to them to conduct the Group’s business honestly and ethically and in compliance with the applicable laws and regulations.
The Group expects its business partners (e.g. suppliers, vendors, sales agents, contractors, consultants, joint venture partners and other third‑party service providers) who work with the Group to adhere to the same ethical standards. For this purpose, HGCIH Group has drawn up the Code of Conduct for Business Partners, as detailed below, which sets the minimum standards for doing business with the Group.
Each business partner has an obligation to comply with the laws of the jurisdiction(s) in which they operate. This includes, without limitation, laws relating to commercial bribery, information privacy, offering or receiving business courtesies, environmental protection, and occupational health and safety. Business partners are expected to understand and comply with all applicable laws, rules, and regulations governing their operations and, where applicable, any activities undertaken on behalf of the Group.
Business partners must comply with all applicable national and international anti‑bribery and anti‑corruption laws. They must not, directly or indirectly, offer or promise anything of value to improperly influence an official act or obtain an improper business advantage.
To support HGC’s commitment to preventing bribery and corruption, business partners are expected to establish and maintain anti‑bribery and anti‑corruption controls that effectively address the risks associated with their operations and ensure responsible business conduct. These controls include conducting periodic bribery and corruption risk assessments, performing due diligence on third parties, maintaining clear written policies (such as those on gifts, hospitality, donations and sponsorships), keeping accurate financial records, providing relevant staff training, and monitoring the effectiveness of these controls.
Business partners must also promptly escalate any suspected irregularities, bribery risks, or unethical conduct related to obtaining or retaining business or influencing sensitive transactions, by reporting them without delay to HGC’s Compliance Office or through EthicsPoint,
- Compliance Office: compliance@hgc.com.hk
- EthicsPoint: http://hgc.ethicspoint.com
The business partner shall comply with all applicable trade and export control regulations including sanctions and embargoes that apply to their activities.
The business partner shall comply with all applicable laws and regulations designed to combat money laundering activities. The business partner shall maintain financial records and reports according to all applicable international laws and regulations.
A conflict of interest occurs when business partners’ commercial interests, or the interests of one of their other customers, who may be a competitor to the Group, interferes with, or appears to interfere with, in any way with the commercial interests of the Group. Business partners should actively avoid any situation that could impact on their ability to act in the best interests of the Group or that may make it difficult to carry out the agreed work/services objectively and effectively.
The Group requires its business partners to fully disclose to the Group any situations that could reasonably be expected to give rise to a conflict of interest. If a business partner suspects that there may be a conflict of interest, or a situation that others could reasonably perceive as a conflict of interest, such business partner must report it immediately to the Group. The Group expects its business partners to put in place appropriate internal procedures to enable the identification, disclosure and management of any such conflicts of interest.
A business partner must perform its duties and responsibilities for the Group with the highest degree of integrity. A business partner is required to perform its work with honesty, diligence, responsibility and in accordance with applicable laws. In the performance of its work, a business partner must not knowingly be a party to any illegal activity or engage in acts that are discreditable to the Group. Integrity requires a business partner to observe both the form and the spirit of the ethical principles contained in this Code.
The giving and receiving of appropriate gifts may be considered common business practice, but also carry the risk of perceived bribery. The Group understands that appropriate business gifts and courtesies, such as hampers and meals, are designed to build relationships and understanding among business partners. However, gifts and courtesies should never compromise, or appear to compromise, the Group’s or its business partners’ ability to make objective and fair business decisions.
It is the responsibility of both business partners and Company Personnel to use good judgment in this area. As a general rule, Company Personnel may not give or receive gifts or entertainment from business partners unless the gift and entertainment is in compliance with applicable law and Company policy, is insignificant in value, and is not given in consideration or expectation of any action by the recipient.
The Group has an internal Gift and Entertainment Policy governing the giving or receipt of gifts and entertainments, with which all Company Personnel are required to comply. This includes reporting requirements and obtaining prior internal approval. The Group may decline to allow the Company Personnel to receive such offers or may require the return of gifts.
The Group is committed to full compliance with anti-bribery and anti-corruption legislation, including the U.S. Foreign Corrupt Practices Act (“FCPA”) and the United Kingdom Bribery Act 2010 (“Bribery Act”). Business partners of the Group and the Company Personnel are required to fully comply with FCPA, Bribery Act and similar anti-bribery and anti-corruption legislation. These generally prohibit giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. A violation of FCPA, the Bribery Act or similar legislation not only violates the Group’s policy but also constitutes a civil or criminal offense.
A business partner may not make any political contributions as a representative of the Group or create the impression that it is acting on the Group’s behalf. In addition, when acting for the Group, a business partner must not offer bribes, similar advantages or anything of value to any public employee, or to any other person or company, with the intent of improperly influencing any governmental entity or individual for the purpose of obtaining or retaining business for the Group, directing business to the Group, or otherwise securing any improper benefit or advantage.
Business partners are also required to identify and appropriately manage sensitive transactions that may carry heightened bribery or corruption risks, whether these involve government officials or individuals in the private sector. These may include interactions involving unusual or high‑risk payments, the offering of gifts or hospitality, dealings related to regulatory or approval processes, donations or sponsorships that are requested, recommended, arranged or otherwise influenced by government officials, business partners or other external parties who may benefit from or influence a business decision, and procurement or supplier selection situations where fairness or transparency may be compromised. All such transactions must be conducted transparently, properly documented, approved where required, and promptly reported if any concerns or suspicions arise.
Business partners must comply with all applicable environmental laws, regulations and standards, and must maintain an effective system to identify, manage, and eliminate potential environmental risks. Business partners are expected to support HGC’s environmental and climate‑protection commitments through the products and services they provide, ensuring these are delivered efficiently and with consideration for their environmental impact.
Business partners should measure and report their environmental impacts, particularly carbon emissions, and should work to reduce their overall environmental footprint. Upon request, business partners must provide HGC with relevant environmental data, documentation, or reporting needed for monitoring and compliance purposes.
Business partners are expected to integrate sustainability principles into their own sourcing and procurement practices. This includes extending the requirements of this Code to the suppliers, subcontractors, and other downstream partners that they engage; conducting risk‑based assessments and evaluations; and carrying out audits where appropriate. When issues are identified, business partners must implement timely and effective corrective actions.
Business partners should ensure traceability for materials and services that present higher sustainability risks, and must avoid sourcing from illegal, unethical, or non‑compliant origins. HGC may request business partners to provide relevant sustainability documentation, performance data, or improvement plans, and may give preference to partners who demonstrate strong sustainability practices and a commitment to continuous improvement.
The business partner shall adhere to relevant data protection and security laws as well as to respective regulations, in particular with regard to personal data of customers, consumers, employees and shareholders. The business partner shall comply with all such requirements when personal data is collected, processed, transmitted or used.
Business partners shall safeguard and make only appropriate use of confidential information. The business partner shall not disclose any information that is not known to the general public.
A business partner, when dealing with the Group or acting on the Group’s behalf, should endeavor to deal fairly with the customers, suppliers, competitors and employees of the Group, governmental authorities and the general public. The Group does not tolerate improperly taking advantage of anyone through manipulation, concealment, abuse of privileged information, intentional misrepresentation of facts or any other unfair practice. Business partners are expected to comply with applicable anti-competition laws. Unfair competition practices such as price fixing or bid rigging are not acceptable. Business partners are advised not to obtain information about our competitors other than from lawful and appropriate sources and may share such information with us only if authorized to do so.
The Group expects business partners to implement a high standard of occupational health and safety by adopting a management approach appropriate to their operations. Business partners must comply with all applicable health and safety laws and maintain a safe and healthy work environment that protects employees and third parties and prevents accidents, injuries and work‑related illnesses.
To safeguard the rights and dignity of employees, the Group encourages business partners to abide by the standards and conditions detailed below:
Business partners have a duty to report any known or suspected violation of this Code, including any violation of laws, rules, regulations or policies that apply to the Group and/or the business that the Group and the business partners carry out together. Reporting in good faith a known or suspected violation of this Code by others will be considered an action to safeguard the reputation and integrity of the Group and the Company Personnel.
If a business partner knows of or suspects a violation of this Code, it is the business partner’s responsibility to immediately report the violation to the Group, and the Group will investigate the matter. All questions and reports of known or suspected violations of this Code will be treated with sensitivity and discretion. Failure to comply with applicable law or with this Code may have serious consequences for both the business partner and the Group. It is the Group’s policy that any business partner who violates this Code will be subject to appropriate action, including possible termination of engagement, based on the facts and circumstances of each particular situation.
Business partners must ensure that workers and stakeholders have safe, accessible, and confidential channels to raise concerns or report potential misconduct. Retaliation against anyone who reports in good faith is strictly prohibited. All concerns should be addressed promptly through thorough investigation and appropriate corrective action.
HGCIH Group reserves the right, upon reasonable notice, to check compliance with the requirements of the Business Partner Code of Conduct. HGCIH Group encourages its business partners to implement their own binding guidelines for ethical behavior.
Any breach of the obligations stipulated in this Business Partner Code of Conduct is considered a material breach of contract by the supplier.