1. Purpose
Hang Lung Group Limited, Hang Lung Properties Limited and their respective subsidiaries (collectively, the “Group”) are committed to upholding the highest ethical standards in all business dealings and operating their business fairly and with integrity, honesty, and impartiality. The Group has zero tolerance for bribery, corruption, money laundering and terrorist financing. The Group is also committed to complying with all applicable laws relating to anti-bribery, anti-corruption, anti-money laundering and counter-terrorist financing in the jurisdictions where it operates, including the Prevention of Bribery Ordinance (Cap. 201 of the Laws of Hong Kong), the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615 of the Laws of Hong Kong), the Anti-Unfair Competition Law, Criminal Law, Anti-Money Laundering Law and Anti-Terrorism Law of the People’s Republic of China (the "PRC").
This policy (the “Policy”) sets out the conduct the Group forbids and the standards and practices the Group expects from its stakeholders in support of the Group’s commitment to conducting business with integrity and in compliance with applicable laws and regulations. This Policy supplements and shall be read in conjunction with other relevant corporate policies, including but not limited to the Group’s Staff Handbook, Code of Conduct and Whistleblowing Policy, and forms an integral part of the Group’s corporate governance framework.
2. Definitions
Bribery is the act of directly or indirectly offering, giving, receiving, or soliciting any advantage to or from a public servant (i.e. officers, members and employees of public bodies) or any employee of a company or other person connected with a business, as an inducement or reward for or otherwise on account of such person’s conduct in the performance of his or her duties.
The advantage needs not be financial and may include (i) money, gifts, rewards, commissions, (ii) any office, employment or contract, (iii) any payment or discharge of loan, obligation or other liability, (iv) any other service or favor, (v) the exercise or forbearance from the exercise of any right or any power or duty, and (vi) any offer, undertaking or promise.
Money laundering refers to dealing with any property, knowing or having reasonable grounds to believe that the property, in whole or in part and directly or indirectly, represents the proceeds of crime, or engaging in any act intended to conceal, disguise, convert, transfer or otherwise deal with such property so as to make it appear legitimate or not to represent the proceeds of crime. Property includes money, goods, choses in action, land and any rights or interests in property.
Terrorist financing means the provision or collection, directly or indirectly and by any means, of any property with the intention that, or knowing that, it will be used, in whole or in part, to commit one or more terrorist acts, or the making available of any property, financial or related services, or other support (such as provision of information, human resources, technology or venue) to or for the benefit of a terrorist or terrorist associate.
3. Scope
This Policy applies to all executives, employees, staff members, agents, representatives of and those acting for and on behalf of the Group (collectively, the “Relevant Party(ies)”), and all parties doing business with the Group including but not limited to business partners, contractors, tenants, vendors and suppliers (collectively, the “External Party(ies)”).
Relevant Parties shall understand this Policy and their roles and responsibilities in complying with the requirements and implementing the relevant measures hereunder. Relevant Parties shall take reasonable steps to require External Parties who have or intend to have business dealings with the Group to comply or agree to comply with all applicable laws, rules, regulations and regulatory requirements related to anti-bribery, anti-corruption, anti-money laundering, and counter-terrorist financing in jurisdictions where the Group has operations and this Policy and to ensure their compliance. Due care and diligence should be exercised in selecting External Parties and in monitoring their activities.
4. Roles and Responsibilities
The CEO and senior management team are responsible for the day-to-day management of the Group’s business operations, by setting the right tone from the top and demonstrating strong, visible, and active commitment to anti-bribery, anti-corruption, anti-money laundering, and counter-terrorist financing business practices, including prevention, and where applicable, mitigation practices.
The senior management team periodically reviews fraud, corruption, money laundering and terrorist financing risks under the Group’s established Enterprise Risk Management framework, ensures that controls are in place to mitigate risks, and reports material breaches of this Policy to the Board / Audit Committee.
Apart from supervising the execution of their respective business operations, line managers should also exercise effective supervision to ensure that the existing business processes and practices comply with this Policy. They should provide guidance and advice to the Relevant Parties and External Parties where necessary, and exercise reasonable monitoring over their conduct. Relevant Parties should comply with, and take reasonable steps to require External Parties to comply with the requirements of this Policy, and promptly bring to the attention of the management of any actual breaches or suspected breaches of this Policy noted at the earliest possible stage.
5. Anti-Bribery and Anti-Corruption
Relevant Parties and External Parties should not engage in or conduct any of the following activities and, if they become aware of, or have reasonable grounds to believe that any person is engaging in or conducting any of the following activities, they should follow the procedures set out in Section 9 of this Policy.
5.1 Conflicts of Interest: One shall avoid any situation which may lead to an actual, potential or perceived conflict of interest.
As set out in the Code of Conduct – Section 4, a conflict of interest situation arises when the private interest of a director or staff member of the Group competes or conflicts with the interest of any Group company. Private interest includes both the financial and personal interests of staff members of the Group and those of their connections. Connections include family members, relatives, and close personal friends.
As required in the Code of Conduct – Section 4, staff members of the Group should make a declaration in writing to senior management when a conflict of situation arises.
5.2 Soliciting, Accepting or Offering Advantages: One shall not without the permission of his employer or reasonable excuse solicit or accept any advantage, or offer an advantage for themselves or for and on behalf of others, when conducting his employer’s affairs or business.
“Advantage” includes, but is not limited to money, gifts, loans, fees, rewards, employment, contracts, services, and favor of any form.
As required in the Code of Conduct – Section 4 and subject to exceptions set out therein, staff members of the Group should make a declaration in writing to senior management when they are offered an advantage (even if the advantage is not accepted) and seek approval on the appropriate way of dealing with the advantage.
5.3 Offering or Accepting Entertainment: One shall not offer any form of entertainment to any person or take any action that might be perceived to be for the purpose of or with an intention to soliciting preferential treatment or advantages or influencing such person in any business decision or dealings.
Although entertainment is an acceptable form of business and social behavior, Relevant Parties of the Group must not accept lavish or frequent entertainment from persons with whom any Group company has business dealings, nor should they accept lavish or frequent entertainment from directors or other staff members of the Group, to avoid placing themselves in a position of obligation to the offeror.
“Entertainment” includes, but is not limited to, food or beverage provided for consumption at the occasion.
5.4 Facilitation Payments and Kickbacks: Facilitation payments refer to payments made to government officials to expedite or ensure the performance of a routine or necessary administrative process (such as obtaining visas, permits or licenses). Kickbacks are bribes to obtain an undue advantage, where a portion of the undue advantage is “kicked back” to the person who gave, or is supposed to give, the undue advantage. The Group strictly prohibits the offering, promising, giving, or accepting of facilitation payments and kickbacks of any form.
6. Anti-Money Laundering and Counter-Terrorist Financing
The Group is committed to conducting its business in a manner that does not facilitate money laundering, terrorist financing or other financial crime. Relevant Parties shall not knowingly engage in, facilitate or participate in any such activity and shall remain vigilant in identifying unusual or suspicious transactions involving an External Party.
For the purposes of this Policy, an unusual or suspicious transaction is a proposed or actual transaction, payment or arrangement that appears inconsistent with the known business or circumstances of the External Party, lacks an apparent legitimate business purpose, or otherwise gives rise to a concern that it may involve money laundering or terrorist financing. Examples may include an unexplained request for cash payment, payment to or from an unrelated third party, use of a bank account in an unusual jurisdiction, unnecessarily complex or frequently changing payment arrangements, material inconsistencies in information provided, or an unwillingness or inability to provide a reasonable explanation or supporting information.
7. Due diligence
Proper due diligence shall be conducted before Relevant Parties engage in business dealings with External Parties on behalf of the Group. This applies to, among others, professional advisors, vendors, suppliers, contractors and tenants.
Where relevant and appropriate, such due diligence may include reasonable enquiries into an External Party’s ownership and organisational structure, business background and activities, financial condition, source of funds, market reputation, material legal, regulatory or disciplinary matters, past convictions and other integrity concerns. Relevant Parties may also obtain and verify supporting information, conduct searches through appropriate public or third-party sources, review payment or bank account arrangements, and require compliance with applicable Group policies or standards. The nature and extent of the due diligence shall be proportionate to the circumstances and the risks reasonably identified.
A balanced and common-sense approach shall be adopted where an External Party, transaction or payment arrangement presents a higher risk of money laundering or terrorist financing. Where relevant and appropriate, further enquiries, verification or internal review shall be undertaken before proceeding.
If Relevant Parties become aware of, or have reasonable grounds to suspect, that any person or transaction may involve money laundering or terrorist financing, they shall follow the procedures set out in Section 9 of this Policy.
Appropriate records of the due diligence conducted, its material results and the rationale for engaging or not engaging an External Party, together with relevant transaction and payment records, shall be maintained in accordance with applicable internal procedures.
8. Training and Communication
Staff training on this Policy forms part of the induction process for all new employees. Employees will also receive regular, relevant integrity training and/or periodic e-mail reminders to ensure that they are aware of the Group’s anti-bribery and anti-corruption requirements.
This Policy and the Group’s zero-tolerance approach towards bribery, corruption, money laundering and terrorist financing will also be clearly communicated to External Parties at the outset of relevant business relationship and as appropriate thereafter.
9. Breaches of this Policy
Any person who becomes aware of, or who has reasonable grounds to believe that there is an actual or suspected breach of this Policy by a Relevant Party or External Party shall promptly report the matter in accordance with the Group’s Whistleblowing Policy, which provides a mechanism for employees and third parties to raise concerns on any suspected impropriety, misconduct, or malpractice through confidential reporting channels.
Upon receipt of a report, the Head of Corporate Audit will conduct a preliminary assessment and determine the appropriate course of action, including whether a formal investigation is warranted. Where appropriate, designated personnel will conduct the investigation, with support from suitably experienced and qualified personnel from relevant departments as necessary. All reported cases and any associated investigation findings will be escalated to and reviewed by the Investigation Panel, comprising heads of relevant corporate functions, to ensure that complaints are handled consistently, objectively, and impartially.
Reports and investigations will be handled confidentially to the extent reasonably practicable and permitted by applicable law, taking into account the need to conduct an effective investigation and take appropriate follow-up action. Employees who raise concerns honestly and in good faith will be protected from retaliation in accordance with the Group’s Whistleblowing Policy.
Any staff member of the Group who breaches this Policy shall be deemed to have committed serious negligence as stipulated in Section 13.2.3.24 and Section 13.2.3.36 of the Staff Handbook (applicable to mainland employees) and (applicable to all staff members of the Group) will be subject to disciplinary action, including but not limited to dismissal. Any External Party who breaches this Policy will be subject to suspension or termination of the relevant business relationship. Serious breaches might be referred to the relevant governmental or law enforcement agencies.
All stakeholders should comply with all applicable laws, rules, regulations and regulatory requirements related to anti-bribery, anti-corruption, anti-money laundering, and counter-terrorist financing in jurisdictions where the Group has operations and this Policy and the breach thereof may result in civil or criminal proceedings and/or penalties, including fines, disgorgement of profits and imprisonment. Any actual or perceived violation as such could also result in severe and irreparable reputational damage to the Group and its directors.
The Group reserves the right to take all appropriate actions in response to any breach of applicable laws or regulations, this Policy or other relevant corporate policies relating to anti-bribery, anti-corruption, anti-money laundering, and counter-terrorist financing. Such action may include termination of employment and/or business dealings and referral to the relevant governmental or law enforcement authorities.
10. Record Retention and Policy Review
The Group will keep detailed, accurate, and complete financial records for payments. Appropriate internal control systems are in place to ensure that all financial transactions are authorized without improper payments, which are subject to regular review and audit. The General Counsel and Company Secretary will conduct periodic reviews and updates on this Policy to ensure it complies with all legal requirements. Any material changes or updates to this Policy shall be proposed by the Sustainability Steering Committee to the Board Executive Committee of the Group for endorsement.
This Policy was endorsed by the Executive Committee of the Group in September 2026.
.png)