Anti-Bribery & Anti-Corruption Policy

This policy is aligned with the Hong Kong Prevention of Bribery Ordinance (Cap. 201) (‘POBO’), the UK Bribery Act 2010 (‘UKBA’, including s.7 corporate offence), the US Foreign Corrupt Practices Act 1977 (‘FCPA’), the OECD Anti-Bribery Convention, and equivalent laws in the jurisdictions in which we operate.

• Offering, giving, requesting, or receiving any advantage (financial or otherwise) as an inducement or reward for improper performance of a function.
• Making or authorising facilitation payments to any public official, in any jurisdiction, without exception.
• Colluding to fix prices or divide markets.
• Using a third party (agent, distributor, consultant) to do what employees may not do directly.
• Falsifying books or records to disguise a prohibited payment.

• Any gift or hospitality received must be recorded in the Register of Interests within 5 business days.
• Cash and cash equivalents (gift cards, cryptocurrency) may never be accepted.
• Aggregate value from any single client, supplier, or public body must not exceed HKD 500 per person per year.
• Gifts to public officials of any value require prior written approval from the Compliance Officer.
• Meals and hospitality must be proportionate, transparent, and directly connected to a legitimate business purpose.

Agents, resellers, and consultants are subject to risk-based due diligence before appointment (screening against Refinitiv World-Check, beneficial-owner verification, adverse-media search) and must sign a contract that includes audit rights, termination for breach, and anti-bribery warranties.

All employees receive anti-bribery training on induction and at least once every two years. Enhanced training is delivered annually to sales, procurement, and management-team members. Records are held for a minimum of 6 years.

Suspected bribery must be reported via the Whistleblowing Policy (COM-024). ALS will not tolerate retaliation against any person who reports in good faith, whether or not the concern is substantiated.

Breach of this policy is a disciplinary offence that may result in dismissal for gross misconduct, termination of contract, and referral to the Hong Kong Independent Commission Against Corruption (ICAC) or equivalent authorities.