Anti-Bribery and Corruption Policy Statement

Purpose


The Hong Kong Radar Aviation Services Limited (hereinafter called “HKRadar”) is committed to the highest standards of business conduct and has zero tolerance for bribery and corruption. At HKRADAR, all employees of the HKRadar (the “Employees”) are required to follow all applicable laws, rules, and regulations related to ant-bribery and corruption, Section 4 and Section 9 of the Prevention of Bribery Ordinance (Cap. 201), guidance(s) issued by the Independent Commission Against Corruption (“ICAC”) and other similar laws and regulations in other countries/jurisdictions when conducting business there or where appropriate.

HKRadar has a strong stance against all forms of bribery and corruption and its restrictions in soliciting or accepting any advantage from others as well as offering any advantage to an agent of another or public servant by its Employees.

Employees are expected to adhere to the HKRadar’s policies and rules in relation to anti- bribery and corruption, which include but not limited to the followings:

Conflict of Interest Policy – Employees are required to avoid any conflict of interest situations or the perception of such conflicts. Whenever Employees have any financial or non- financial interest, direct or indirect, in a customer, supplier, or other principal dealing with the HKRadar, and that interest is of such an extent that it might reasonably affect their judgment or decisions exercised on behalf of the HKRadar, they have to declare their interest and refrain from making the decision themselves. Employees should decline to provide any assistance, advice or information to a customer, supplier, or other principal dealing with the HKRadar for any acts that deviate from the legitimate and/or normal course of action.

Conduct Obtaining Business – Employees are prohibited from offering any bribe or advantage (as defined in the Prevention of Bribery Ordinance, including but not limited to any gift, loan, fee, reward, commission, employment contract, etc.) to any person, public servant, agent of a company or an organisation in relation to the business of his/its principal, in order to influence his/its execution of duties in relation to his/its principal’s affairs, whether directly or indirectly.

Personal Benefits – In general, Employees are prohibited from soliciting, accepting, or retaining personal benefits from any other Employee, customer of the HKRadar, or any individual or organisation doing or seeking to do business with the HKRadar.

Employees who fail to comply with any legal obligation or statutes, internal or regulatory requirements related to anti-bribery and corruption will be subject to disciplinary action (which may include termination) initiated by the HKRadar and where applicable, to criminal prosecution if concerned authority (e.g. law enforcement agencies) considers appropriate.

All directors, agents, contractors, suppliers associated persons and etc. are also expected to act in compliance with all applicable policies, laws, rules and regulations related to anti-bribery and corruption in the performance of their services for or on behalf of HKRADAR. HKRADAR reserves the right to terminate any business relationship that violates HKRADAR’s zero-tolerance policy against bribery and corruption.

This Statement shall be reviewed annually and as required to ensure its relevance and effectiveness.
(reviewed and approved on 2 Nov 2023)