3. Corruption pitfalls
Video 9 – Covert operation
Case analysis
Simon
- ● Simon discloses to his fiancée the price-sensitive information about the bank obtained via an internal channel and asks her to sell all the shares in the bank. Both of them are in breach of insider dealing offence under the Securities and Futures Ordinance.
- ● His acts are also in contravention of the HKMA Supervisory Policy Manual – Code of Conduct. (Please refer to para 2.9 of the Code: Use of information and para 2.10: Personal investments)
- ● He violates the Prevention of Bribery Ordinance as he offers an advantage to his subordinate Yee in the hope that Yee would help him cover up his wrongdoing.
Yee
- ● Yee rejects Simon’s offer and reports the matter to the management in accordance with the HKMA Supervisory Policy Manual – Code of Conduct. Yee will not only protect herself from being involved in the scam, but will also stop the wrongdoing and bring the offenders to justice. (Please refer to para 2.12 of the Code: Reporting responsibility)