Section 3: Anti-bribery Legislation in Hong Kong

Prevention of Bribery Ordinance (POBO)

Section 3: Anti-bribery Legislation in Hong Kong

Spirit of the POBO

Maintains a corruption-free environment in Hong Kong

Safeguards the interests of different stakeholders

Protects principals against agents’ abuses of authority for personal gain

Section 3: Anti-bribery Legislation in Hong Kong

Coverage of the POBO

Governs both private and public sectors

Prohibits employees from accepting illegal advantages by abusing their official power

Section 3: Anti-bribery Legislation in Hong Kong

Bribery Offence

Four major elements of corruption:

An Agent

Accept / Solicit Advantages

An Act in relation to principal’s business

Without Approval of principal

The person who offers the advantages is also guilty

Section 3: Anti-bribery Legislation in Hong Kong

Agent and Principal

Section 3: Anti-bribery Legislation in Hong Kong

Advantage

Advantage means anything which is of value, including any gift (both of money and in kind), loan, fee, reward, commission, office, employment, contract, service and favour but excludes "entertainment".

Section 3: Anti-bribery Legislation in Hong Kong

Entertainment

"Entertainment" means the provision of food or drink for consumption on the occasion when it is provided, and of any other entertainment connected with or provided at the same time.

One should avoid lavish or frequent entertainment.

Section 3: Anti-bribery Legislation in Hong Kong

No Defence for Corruption

Customary practice

No power to act

No intention or did not act

Section 3: Anti-bribery Legislation in Hong Kong

Use of False Documents to Deceive Principal

Section 9(3) of the POBO

Any agent uses any receipt, account or other document which is false/erroneous/defective

With intent to deceive his principal

Shall be guilty of an offence

Maximum penalty: Seven years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

POBO Provisions Governing Private Sector Corruption

Section 3: Anti-bribery Legislation in Hong Kong

Private Sector Corruption

Section 9 of the POBO

Agent

Employee of a private organisation
e.g. professional staff of a consultant firm

Advantage

Accepts/Solicits advantage

Act

An Act in relation to employer’s business

Without Approval

Approval from the employer e.g. consultant firm

Maximum penalty: Seven years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

Bribery in relation to Public Contracts

Section 5 of the POBO

Any person offers an advantage to a public servant

For giving assistance in securing contracts from the *public body

Both the offeror and recipient of the advantage shall be guilty of an offence

* Public body includes the Government and any board, commission, committee or other body specified in Schedule 1 of the POBO.

Maximum penalty: Ten years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

Bribery in relation to Tenders

Section 6 of the POBO

Any person offers an advantage to any other person

For not making a tender in relation to a public body’s project

Both the offeror and recipient of the advantage will commit an offence

Maximum penalty: Ten years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

Dealings with Public Servants

Section 8 of the POBO

Any person

While having dealings of any kind with a public body

Offers any advantage to any public servant employed by that public body

Shall be guilty of an offence

Maximum penalty: Seven years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

Cross-boundary Corruption

If any part of the act of bribery – including offering, soliciting or accepting a bribe – takes place in Hong Kong, it may still be pursued under the POBO.

Section 3: Anti-bribery Legislation in Hong Kong

POBO Provisions Governing Public Sector Corruption

Section 3: Anti-bribery Legislation in Hong Kong

Public Sector Corruption

Section 4 of the POBO

Agent

Public servants e.g. government and public bodies employee

Advantage

Accepts/ Solicits advantage in Hong Kong or elsewhere

Act

An act in public servant’s official capacity

Without Approval

  • Without lawful authority or reasonable excuse
  • Without public body’s written permission

Maximum penalty: Seven years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

Bribery in relation to Public Contracts

Section 5 of the POBO

Any public servant

Without permission of the public body

Solicits or accepts an advantage for giving assistance in securing contracts from the public body

Both the offeror and recipient of the advantage shall be guilty of an offence

Maximum penalty: Ten years’ imprisonment and a fine of $500,000

Section 3: Anti-bribery Legislation in Hong Kong

Acceptance of Advantages by Government Officers

Section 3 of the POBO

Any *prescribed officer or staff working in the government

Without the general or special permission of the Chief Executive

Solicits or accepts any advantage

Shall be guilty of an offence

* Prescribed officer includes any person holding an office of emolument, whether permanent or temporarily, under the government.

Maximum penalty: One year’s imprisonment and a fine of $100,000

Section 3: Anti-bribery Legislation in Hong Kong

Acceptance of Advantages by Government Officers

The general permission for government officers to accept advantages is stipulated in the
Acceptance of Advantages (Chief Executive’s Permission) Notice (AAN).

Click to view AAN

Section 3: Anti-bribery Legislation in Hong Kong

Misconduct in Public Office (MIPO)

MIPO is a common law offence which targets all forms of serious abuse of office by public officials.

Section 3: Anti-bribery Legislation in Hong Kong

Misconduct in Public Office (MIPO)

The misconduct must be deliberate rather than accidental.

Wilful misconduct without reasonable excuse or justification is culpable.

Key elements of MIPO:

A public official;

In the course of or in relation to his public office;

Wilfully misconducts himself; by act or omission (for example, by wilfully neglecting or failing to perform his duty);

Without reasonable excuse or justification; and

Where such misconduct is serious, not trivial, having regard to the responsibilities of the office and the office-holder, the importance of the public objects which they serve and the nature and extent of the departure from those responsibilities

Section 3: Anti-bribery Legislation in Hong Kong

Misconduct in Public Office

A public officer, even if his misconduct does not involve any bribery, may commit MIPO if he:

  • misuses his official position for pecuniary gains (whether for himself or others); or
  • uses his discretionary power improperly; or
  • dishonestly shows partiality to a contractor; or
  • wilfully neglects to perform his duties

Maximum penalty: Seven years’ imprisonment and a fine

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