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Ethical Decision MakingRecent ICAC Cases
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Jul 2025Over 20 months’ jail for apparel company employee charged by ICAC for using false receipts to swindle $480,000A former executive assistant of an apparel manufacturer, charged by the ICAC with an offence under the anti-bribery law, was today (July 31) sentenced to a jail term of 20 months and 3 days at the Shatin Magistrates’ Courts for using false quotations and receipts to swindle works payments totalling $480,000 from the company.Rachel Chong Shui-kwan, 33, former executive assistant of Sterling and Grant Limited (SGL), was earlier convicted after trial of nine charges of agent using document with intent to deceive her principal, contrary to Section 9(3) of the Prevention of Bribery Ordinance.In sentencing, Magistrate Mr Jeffrey Sze Cho-yiu stated that the defendant had abused her employer’s trust to orchestrate a planned scheme which spanned over several months, showing that the offences were not committed out of momentary greed. In addition, the defendant had a criminal record of committing an offence of similar nature and showed no remorse. The court took a starting point of over 23 months imprisonment and reduced the defendant’s jail term to 20 months and 3 days, having considered her full repayment of the sum of money involved in the present case.The court heard that when the defendant worked as executive assistant of SGL, her duties included handling the leasing matters of two residential properties of her employer and the relevant renovation and repair works. Before the commencement of each works order, the defendant was required to seek approval from her employer and provide relevant quotation for the latter’s confirmation. After completion of the works, the defendant had to submit the quotation or receipt issued by the responsible contractor to the company for processing payments.The ICAC investigation arose from a corruption complaint. Enquiries revealed that between July 2020 and January 2021, the defendant submitted false quotations or receipts to SGL on nine occasions to mislead SGL that the documents were issued by a renovation company. As a result, SGL was induced to release about $480,000 in total to the renovation company for settling the works payments.The ICAC investigation revealed that the renovation company had never issued those quotations and receipts, and most of the said payments were deposited into the personal bank account of the defendant.SGL rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Audrey Parwani, assisted by ICAC officer Eva Chan. 30
Jul 2025Three months’ jail for consultancy employee admitting bribery over renovation projects of two Japanese chain storesAn employee of a design consultancy, charged by the ICAC, was today (July 30) sentenced to three months’ imprisonment at the Kowloon City Magistrates’ Courts for accepting bribes of over $230,000 for assisting works contractors to secure renovation projects of two Japanese chain stores involving project fees totalling over $25 million.Pian Pang Ka-shin, 41, then marketing executive of K&C Creation Limited (KCL), earlier pleaded guilty to one count of conspiracy for an agent to accept an advantage, contrary to sections 9(1)(a) of the Prevention of Bribery Ordinance and section 159A of the Crimes Ordinance.In sentencing, Magistrate Mr Philip Chan Chee-fai remarked that the court took a starting point of six months’ imprisonment, and reduced the jail term to three months, having considered the defendant’s guilty plea, her background report and repayment of the amount of bribes involved in the present case to her former employer.The court heard that KCL was a design consultancy. In 2019, it was awarded two renovation projects respectively concerning the store of supermarket chain “Donki Japan” in Macao and a branch of drugstore chain “Tokyo Lifestyle” in Kowloon.At the material time, Pang was a marketing executive of KCL responsible for co-ordinating contractors and arranging tender exercises. For the two renovation projects concerned, she was responsible for submitting quotations and tenders to KCL or Donki for selection.Pang admitted that between June 2019 and January 2022, she had accepted bribes of over $230,000 from three representatives from two works contractors, namely RNK Design and Engineering Company Limited (RNK) and Flaming Engineering Company Limited (FEL), for assisting the trio to secure the renovation projects of Donki and “Tokyo Lifestyle”.Pang was assigned by KCL to assist Donki in arranging a tender exercise. She submitted five tenders for Donki’s selection. Donki eventually awarded the project to FEL and settled project fees totalling over $23.4 million with FEL after the project was completed. Pang admitted that she had given advice to the FEL representative on the relevant tender interview.KCL received two quotations from renovation companies in relation to the renovation project of “Tokyo Lifestyle”. KCL awarded relevant works to RNK based on the recommendation of Pang and paid project fee of $1.7 million to RNK after completion of the works.KCL and Donki rendered full assistance to the ICAC during its investigation into the case.Three co-defendants in the present case, namely Li Po-wah, director cum shareholder of RNK, Pang Wai-yin, former site supervisor of RNK, Yung Chor-chi, operator of FEL, earlier pleaded not guilty to one count of conspiracy for an agent to accept an advantage. Their case was scheduled for a pre-trial review on November 27.The prosecution was today represented by ICAC officer Zacky Chan. 29
Jul 2025Ex-chairman of listed company wanted by ICAC faces conspiracy to defraud charges over $330m fraudulent transactions upon return to HKA former chairman of a listed company wanted by the ICAC had surrendered himself to the Commission after returning to Hong Kong today (July 29). He will be brought to the court for mention tomorrow (July 30) for allegedly conspiring with then senior executives of the listed company to defraud its shareholders and The Stock Exchange of Hong Kong Limited (SEHK) by inflating the profit and assets of the listed company through fraudulent property transactions involving over $330 million in total.Li Songxiao, 59, former chairman of Neo-China Group (Holdings) Limited (Neo-China) (now renamed as Shanghai Industrial Urban Development Group Limited), faces two counts of conspiracy to defraud, contrary to the Common Law. He will be brought to the Eastern Magistrates’ Courts for mention tomorrow.The conspiracy to defraud offences were revealed in an ICAC investigation stemmed from a corruption complaint in relation to Neo-China. Upon applications made by the ICAC, warrants for the arrest of Li and two then executive directors of Neo-China, namely Che Hanshu and Zhang Yaohui, were issued by a Magistrate in late February 2011 as the trio had already left Hong Kong. The arrest warrants for Che and Zhang were still valid.Between October 2003 and August 2009, Li was the chairman of Neo-China while Che and Zhang were executive directors of the listed company.The charges allege that between November 2003 and July 2007, Li, Chen and Zhang had conspired with the company secretary and financial controller of Neo-China to defraud shareholders of Neo-China and the SEHK.The charges in regard to two property sale and purchase agreements involving Neo-China’s false representation about the acquisition of 100 per cent equity interest in Top Fair Limited (Top Fair) at $210 million, and the disposal of the entire interest in Noble Time Development Inc., a subsidiary of Neo-China, to Northwest Link Investments Limited (Northwest Link) at $123 million.The individuals concerned had allegedly made false representations in the announcements, circulars and an annual report of Neo-China that the owners of Top Fair and Northwest Link were independent of and not connected with the directors, chief executives or substantial shareholders, etc. of Neo-China; created false accounting statements concerning the considerations and profits of the two property sale and purchase agreements, and concealed Li as the beneficiary owner of Top Fair and Northwest Link.By making the fraudulent property transactions, the individual concerned had allegedly induced the shareholders of Neo-China to believe that the two transactions were genuine, and prevented the SEHK from performing its duties in relation to the protection of the minority shareholders of Neo-China.The SEHK rendered full assistance to the ICAC during its investigation into the case.Wanted person Che Hanshu: www.icac.org.hk/en/rc/wanted/index_id_25.htmlWanted person Zhang Yaohui: www.icac.org.hk/en/rc/wanted/index_id_23.html 25
Jul 2025Joint press release: ICAC and SFC joint operation against suspected market manipulation and corrupt practices leads to arrest of two former senior executives of listed companyThe Independent Commission Against Corruption (ICAC) and the Securities and Futures Commission (SFC) on Wednesday (July 23) conducted a joint operation, codenamed “Leverage”, targeting a sophisticated syndicate suspected of manipulating the shares of a listed company and engaging in corrupt activities (Notes 1 & 2).During the joint operation, the ICAC and the SFC searched 14 locations, including the offices of the listed company and SFC-licensed brokers. The ICAC arrested a former chairman and a former executive director of the listed company under the Prevention of Bribery Ordinance (Note 3).The syndicate allegedly conspired to use documents containing false information (including internal records and public announcements of the listed company), to falsely claim that the listed company had entered into a share subscription agreement and formed a joint venture with a Mainland company, involving amounts of over HK$20 million. Additionally, the syndicate allegedly manipulated and/or created false market appearance for the shares of the listed company through multiple nominee accounts.Furthermore, the former executive director of the listed company, who was a responsible officer and director of a broker during the material time, was suspected of accepting advantages from the former chairman of the listed company and misappropriating shares owned by a client of the broker worth approximately HK$9 million.The joint operation was the result of the SFC’s initial detection of suspicious trading activities suggesting potential market misconduct and corruption. The case was subsequently referred to the ICAC for investigation into suspected corruption, while the SFC focused on market misconduct under the Securities and Futures Ordinance.No further comments will be made as the investigation remains ongoing.Notes:1. Trading in shares of the listed company had been suspended since March 2025, following a court order mandating its liquidation.2. The joint operation was conducted under the arrangement of the Memorandum of Understanding signed between the ICAC and the SFC. For further details, please visit the websites of the ICAC and the SFC.3. The individuals involved are suspected of breaching the provisions under the Prevention of Bribery Ordinance, including offering advantages to agents and agents accepting advantages (i.e., offering and acceptance of bribes), as well as agents using false documents with the intent to deceive their principals. Additionally, they are also suspected of committing offences under the Organized and Serious Crimes Ordinance, specifically handling property known or believed to represent proceeds of indictable offences, and under the Securities and Futures Ordinance involving market manipulation and other forms of market misconduct. 22
Jul 2025Six months’ jail for team leader of Three-Runway System Project’s subcontractor for briberyA team leader of a subcontractor of the Three-Runway System Project (3RS Project) of the Hong Kong International Airport, charged by the ICAC, was today (July 22) sentenced to six months’ imprisonment at the West Kowloon Magistrates’ Courts for soliciting a bribe of $100 to $200 per day from a crane operator for continuing his employment.Hui Wai-kwok, 39, former team leader of New Ocean Machine Co., Limited (New Ocean), was earlier found guilty of one count of agent soliciting an advantage, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance.In sentencing, Magistrate Mr Gary Chu Man-hon remarked that the offence in the present case was serious in nature. The defendant exploited his subordinate out of greed, warranting a deterrent sentence.At the material time, New Ocean was a crane rental service provider of the 3RS Project. The company prohibited its employees from soliciting or accepting any advantages from others in relation to its business and affairs. As a team leader of New Ocean responsible for leading a team of crane operators to work at the construction site of the 3RS Project, the defendant had the authority to dismiss workers under his supervision.The ICAC investigation revealed that in early December 2022, the defendant solicited a bribe of $100 to $200 per day from a worker under his supervision for assisting latter to continue his employment with New Ocean. The worker joined New Ocean in November 2022 at a daily wage of $1,400. Soon after the defendant made the solicitation, the worker resigned and did not pay any bribe.New Ocean rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Stephen Lau, assisted by ICAC officer Lawrence Wong.
Jul 2025Over 20 months’ jail for apparel company employee charged by ICAC for using false receipts to swindle $480,000A former executive assistant of an apparel manufacturer, charged by the ICAC with an offence under the anti-bribery law, was today (July 31) sentenced to a jail term of 20 months and 3 days at the Shatin Magistrates’ Courts for using false quotations and receipts to swindle works payments totalling $480,000 from the company.Rachel Chong Shui-kwan, 33, former executive assistant of Sterling and Grant Limited (SGL), was earlier convicted after trial of nine charges of agent using document with intent to deceive her principal, contrary to Section 9(3) of the Prevention of Bribery Ordinance.In sentencing, Magistrate Mr Jeffrey Sze Cho-yiu stated that the defendant had abused her employer’s trust to orchestrate a planned scheme which spanned over several months, showing that the offences were not committed out of momentary greed. In addition, the defendant had a criminal record of committing an offence of similar nature and showed no remorse. The court took a starting point of over 23 months imprisonment and reduced the defendant’s jail term to 20 months and 3 days, having considered her full repayment of the sum of money involved in the present case.The court heard that when the defendant worked as executive assistant of SGL, her duties included handling the leasing matters of two residential properties of her employer and the relevant renovation and repair works. Before the commencement of each works order, the defendant was required to seek approval from her employer and provide relevant quotation for the latter’s confirmation. After completion of the works, the defendant had to submit the quotation or receipt issued by the responsible contractor to the company for processing payments.The ICAC investigation arose from a corruption complaint. Enquiries revealed that between July 2020 and January 2021, the defendant submitted false quotations or receipts to SGL on nine occasions to mislead SGL that the documents were issued by a renovation company. As a result, SGL was induced to release about $480,000 in total to the renovation company for settling the works payments.The ICAC investigation revealed that the renovation company had never issued those quotations and receipts, and most of the said payments were deposited into the personal bank account of the defendant.SGL rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Audrey Parwani, assisted by ICAC officer Eva Chan. 30
Jul 2025Three months’ jail for consultancy employee admitting bribery over renovation projects of two Japanese chain storesAn employee of a design consultancy, charged by the ICAC, was today (July 30) sentenced to three months’ imprisonment at the Kowloon City Magistrates’ Courts for accepting bribes of over $230,000 for assisting works contractors to secure renovation projects of two Japanese chain stores involving project fees totalling over $25 million.Pian Pang Ka-shin, 41, then marketing executive of K&C Creation Limited (KCL), earlier pleaded guilty to one count of conspiracy for an agent to accept an advantage, contrary to sections 9(1)(a) of the Prevention of Bribery Ordinance and section 159A of the Crimes Ordinance.In sentencing, Magistrate Mr Philip Chan Chee-fai remarked that the court took a starting point of six months’ imprisonment, and reduced the jail term to three months, having considered the defendant’s guilty plea, her background report and repayment of the amount of bribes involved in the present case to her former employer.The court heard that KCL was a design consultancy. In 2019, it was awarded two renovation projects respectively concerning the store of supermarket chain “Donki Japan” in Macao and a branch of drugstore chain “Tokyo Lifestyle” in Kowloon.At the material time, Pang was a marketing executive of KCL responsible for co-ordinating contractors and arranging tender exercises. For the two renovation projects concerned, she was responsible for submitting quotations and tenders to KCL or Donki for selection.Pang admitted that between June 2019 and January 2022, she had accepted bribes of over $230,000 from three representatives from two works contractors, namely RNK Design and Engineering Company Limited (RNK) and Flaming Engineering Company Limited (FEL), for assisting the trio to secure the renovation projects of Donki and “Tokyo Lifestyle”.Pang was assigned by KCL to assist Donki in arranging a tender exercise. She submitted five tenders for Donki’s selection. Donki eventually awarded the project to FEL and settled project fees totalling over $23.4 million with FEL after the project was completed. Pang admitted that she had given advice to the FEL representative on the relevant tender interview.KCL received two quotations from renovation companies in relation to the renovation project of “Tokyo Lifestyle”. KCL awarded relevant works to RNK based on the recommendation of Pang and paid project fee of $1.7 million to RNK after completion of the works.KCL and Donki rendered full assistance to the ICAC during its investigation into the case.Three co-defendants in the present case, namely Li Po-wah, director cum shareholder of RNK, Pang Wai-yin, former site supervisor of RNK, Yung Chor-chi, operator of FEL, earlier pleaded not guilty to one count of conspiracy for an agent to accept an advantage. Their case was scheduled for a pre-trial review on November 27.The prosecution was today represented by ICAC officer Zacky Chan. 29
Jul 2025Ex-chairman of listed company wanted by ICAC faces conspiracy to defraud charges over $330m fraudulent transactions upon return to HKA former chairman of a listed company wanted by the ICAC had surrendered himself to the Commission after returning to Hong Kong today (July 29). He will be brought to the court for mention tomorrow (July 30) for allegedly conspiring with then senior executives of the listed company to defraud its shareholders and The Stock Exchange of Hong Kong Limited (SEHK) by inflating the profit and assets of the listed company through fraudulent property transactions involving over $330 million in total.Li Songxiao, 59, former chairman of Neo-China Group (Holdings) Limited (Neo-China) (now renamed as Shanghai Industrial Urban Development Group Limited), faces two counts of conspiracy to defraud, contrary to the Common Law. He will be brought to the Eastern Magistrates’ Courts for mention tomorrow.The conspiracy to defraud offences were revealed in an ICAC investigation stemmed from a corruption complaint in relation to Neo-China. Upon applications made by the ICAC, warrants for the arrest of Li and two then executive directors of Neo-China, namely Che Hanshu and Zhang Yaohui, were issued by a Magistrate in late February 2011 as the trio had already left Hong Kong. The arrest warrants for Che and Zhang were still valid.Between October 2003 and August 2009, Li was the chairman of Neo-China while Che and Zhang were executive directors of the listed company.The charges allege that between November 2003 and July 2007, Li, Chen and Zhang had conspired with the company secretary and financial controller of Neo-China to defraud shareholders of Neo-China and the SEHK.The charges in regard to two property sale and purchase agreements involving Neo-China’s false representation about the acquisition of 100 per cent equity interest in Top Fair Limited (Top Fair) at $210 million, and the disposal of the entire interest in Noble Time Development Inc., a subsidiary of Neo-China, to Northwest Link Investments Limited (Northwest Link) at $123 million.The individuals concerned had allegedly made false representations in the announcements, circulars and an annual report of Neo-China that the owners of Top Fair and Northwest Link were independent of and not connected with the directors, chief executives or substantial shareholders, etc. of Neo-China; created false accounting statements concerning the considerations and profits of the two property sale and purchase agreements, and concealed Li as the beneficiary owner of Top Fair and Northwest Link.By making the fraudulent property transactions, the individual concerned had allegedly induced the shareholders of Neo-China to believe that the two transactions were genuine, and prevented the SEHK from performing its duties in relation to the protection of the minority shareholders of Neo-China.The SEHK rendered full assistance to the ICAC during its investigation into the case.Wanted person Che Hanshu: www.icac.org.hk/en/rc/wanted/index_id_25.htmlWanted person Zhang Yaohui: www.icac.org.hk/en/rc/wanted/index_id_23.html 25
Jul 2025Joint press release: ICAC and SFC joint operation against suspected market manipulation and corrupt practices leads to arrest of two former senior executives of listed companyThe Independent Commission Against Corruption (ICAC) and the Securities and Futures Commission (SFC) on Wednesday (July 23) conducted a joint operation, codenamed “Leverage”, targeting a sophisticated syndicate suspected of manipulating the shares of a listed company and engaging in corrupt activities (Notes 1 & 2).During the joint operation, the ICAC and the SFC searched 14 locations, including the offices of the listed company and SFC-licensed brokers. The ICAC arrested a former chairman and a former executive director of the listed company under the Prevention of Bribery Ordinance (Note 3).The syndicate allegedly conspired to use documents containing false information (including internal records and public announcements of the listed company), to falsely claim that the listed company had entered into a share subscription agreement and formed a joint venture with a Mainland company, involving amounts of over HK$20 million. Additionally, the syndicate allegedly manipulated and/or created false market appearance for the shares of the listed company through multiple nominee accounts.Furthermore, the former executive director of the listed company, who was a responsible officer and director of a broker during the material time, was suspected of accepting advantages from the former chairman of the listed company and misappropriating shares owned by a client of the broker worth approximately HK$9 million.The joint operation was the result of the SFC’s initial detection of suspicious trading activities suggesting potential market misconduct and corruption. The case was subsequently referred to the ICAC for investigation into suspected corruption, while the SFC focused on market misconduct under the Securities and Futures Ordinance.No further comments will be made as the investigation remains ongoing.Notes:1. Trading in shares of the listed company had been suspended since March 2025, following a court order mandating its liquidation.2. The joint operation was conducted under the arrangement of the Memorandum of Understanding signed between the ICAC and the SFC. For further details, please visit the websites of the ICAC and the SFC.3. The individuals involved are suspected of breaching the provisions under the Prevention of Bribery Ordinance, including offering advantages to agents and agents accepting advantages (i.e., offering and acceptance of bribes), as well as agents using false documents with the intent to deceive their principals. Additionally, they are also suspected of committing offences under the Organized and Serious Crimes Ordinance, specifically handling property known or believed to represent proceeds of indictable offences, and under the Securities and Futures Ordinance involving market manipulation and other forms of market misconduct. 22
Jul 2025Six months’ jail for team leader of Three-Runway System Project’s subcontractor for briberyA team leader of a subcontractor of the Three-Runway System Project (3RS Project) of the Hong Kong International Airport, charged by the ICAC, was today (July 22) sentenced to six months’ imprisonment at the West Kowloon Magistrates’ Courts for soliciting a bribe of $100 to $200 per day from a crane operator for continuing his employment.Hui Wai-kwok, 39, former team leader of New Ocean Machine Co., Limited (New Ocean), was earlier found guilty of one count of agent soliciting an advantage, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance.In sentencing, Magistrate Mr Gary Chu Man-hon remarked that the offence in the present case was serious in nature. The defendant exploited his subordinate out of greed, warranting a deterrent sentence.At the material time, New Ocean was a crane rental service provider of the 3RS Project. The company prohibited its employees from soliciting or accepting any advantages from others in relation to its business and affairs. As a team leader of New Ocean responsible for leading a team of crane operators to work at the construction site of the 3RS Project, the defendant had the authority to dismiss workers under his supervision.The ICAC investigation revealed that in early December 2022, the defendant solicited a bribe of $100 to $200 per day from a worker under his supervision for assisting latter to continue his employment with New Ocean. The worker joined New Ocean in November 2022 at a daily wage of $1,400. Soon after the defendant made the solicitation, the worker resigned and did not pay any bribe.New Ocean rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Stephen Lau, assisted by ICAC officer Lawrence Wong.