Integrity Focus
Menu
Recent ICAC Cases Anti-Corruption Laws in Hong Kong Corruption Myths Cross-Boundary Business Operations Conflict of Interest
What is conflict of interest? Examples of conflict of interest Problems arising from conflict of interest How to handle conflict of interest? How well are we managing conflict of interest?
Ethical Decision MakingRecent ICAC Cases
30
Sep 2025Couple charged by ICAC in private residential project subcontractor worker wage fraud case jailed for 18 monthsA couple from a subcontractor of a construction project in Mid-Levels, charged by the ICAC, were today (September 30) sentenced to 18 months’ imprisonment, with the wife’s jail term suspended for 24 months, at the District Court for defrauding the project contractor of almost $9.6 million by falsifying and overstating the wages of workers.Hon Sang, 53, company secretary of Honsang Company Limited (Honsang); and his wife Ada Law Yin-nei, 49, sole director-cum-shareholder of Honsang, were earlier convicted after trial of two counts of fraud, contrary to section 16A of the Theft Ordinance.In sentencing, Deputy Judge Miss Veronica Heung Shuk-han remarked that the present case was an isolated one with no significant impact on the construction industry. The court took a starting point of 18 months’ imprisonment while the risk of reoffending for the defendants was low and that their actual gain was $1.1 million. Hon was the main culprit in the case and his wife, Law, only played a minor role. Having considered Law’s mitigating factors, including being required to take care of her ill-health son, her jail term was suspended for 24 months.The ICAC investigation arose from a corruption complaint regarding the release of wages to workers by Honsang. At the material time, Honsang was a subcontractor of aluminium and glass related works of a private residential construction project on Borrett Road in Mid-Levels. Honsang was required to submit wage payments related documents, including copies of cheques issued to workers and the relevant receipts, to a contractor of the project – CR Construction Company Limited (CR Construction) – for reimbursing expenses on an accountable basis.The court heard that between September 2018 and April 2019, CR Construction received from Honsang photocopies of over 1,200 cheques and relevant receipts, which purported to show that wages totalling about $30 million were paid to workers. CR Construction consequently settled the entire payment with Honsang.The ICAC investigation revealed that the payees and the payable amounts in 43 of the cheques, involving a sum of around $9.3 million, were falsified and deposited into bank accounts of the Hon couple and other individuals.Since Honsang had failed to pay wages to workers on time, CR Construction subsequently made direct payments to workers. Between May and August 2019, the Hon couple had overstated the wages of over 10 workers, causing CR Construction to overpay those workers by almost $300,000. They had also instructed workers to return the wages overpaid by CR Construction to Honsang.CR Construction rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Susanna Ku, assisted by ICAC officer Andy Yip. 22
Sep 2025Tenant charged by ICAC for bribing estate agent to avoid paying default tenancy compensationA tenant was charged by the ICAC for allegedly offering a bribe of $1,000 to an estate agent, requesting the latter to conceal from an estate agency that he had defaulted a tenancy agreement to avoid giving up his deposit as compensation.Du Du, 48, was charged last Friday (September 19) with one count of offering an advantage to an agent, contrary to section 9(2)(a) of Prevention of Bribery Ordinance (POBO). He was released on ICAC bail, pending his appearance at the Shatin Magistrates’ Courts tomorrow (September 23) for plea.On the morning of November 6, 2022, the defendant viewed a rental residential flat in Tai Wai upon the arrangement by an estate agent of Midland Realty International Limited (Midland Realty). The defendant rented the flat at $16,000 per month by signing a provisional tenancy agreement with the flat owner on the spot.On the same afternoon, the defendant contacted the estate agent expressing his wish to cancel the provisional tenancy agreement. According to the terms of the agreement, the party cancelling the agreement had to pay a compensation equivalent to the deposit, i.e., $16,000.The charge alleges that the defendant had offered a bribe of $1,000 to the estate agent on that day, requesting the latter to assist in concealing from Midland Realty that the provisional tenancy agreement was signed between the defendant and the flat owner, and the default of the defendant on the agreement.The estate agent did not accept the bribe and reported the matter to Midland Realty, which rendered assistance to the ICAC during its investigation into the case.According to Section 9 of the POBO, it is a bribery offence for a person who, without lawful authority or reasonable excuse, offers an advantage (including money, gifts, loans, commissions, positions, contracts, services, favours, etc.) to an employee of a private organisation to influence the employee in exercising one’s duties. Bribery is a serious offence carrying a maximum penalty of seven years’ imprisonment and a fine of $500,000. Members of the public should report suspected corruption to the ICAC without delay. The ICAC 24-hour Report Corruption Hotline: 25 266 366. 16
Sep 2025Ex-subcontractor of WSD and three employees charged by ICAC admit $4.6m payment fraud over false service reservoir inspection reportsThe director of a former subcontractor of the Water Supplies Department (WSD) and three of his employees, charged by the ICAC, today (September 16) admitted at the District Court that they had committed conspiracy to defraud by submitting service reservoir inspection reports containing false information to induce the WSD to release service payments totalling about $4.6 million.Lau Ho-kei, 44, sole director-cum-shareholder of Helpful Engineering Company Limited (Helpful Engineering); and three then employees of Helpful Engineering, namely Li Wing-to, 34, clerk; and Kwok Ka-hay and Kwok Ka-kei, both 41 and handymen, today pleaded guilty to a total of two counts of conspiracy to defraud, contrary to the Common Law.Judge Mr Isaac Tam Sze-lok adjourned the case to November 18 for sentence. The defendants were remanded in the custody of the Correctional Services Department.The ICAC today filed an application with the court for confiscating Lau’s crime proceeds involved in the present case. Hearing on the application will be scheduled for a date to be fixed later.The court heard that between July 2020 and June 2022, the WSD awarded two term contracts for the provision various waterworks services for the New Territories East District to Ming Hing Waterworks Engineering Company Limited (Ming Hing). Helpful Engineering was subcontracted to conduct inspections at around 40 service reservoirs in the district to maintain safety and conditions of the service reservoirs.The WSD required its subcontractors to assign a designated number of teams, each consisting of three members to conduct daily inspections. Subcontractors were also required to compile a daily inspection report supported by photographs taken during the inspections.The ICAC investigation arose from a corruption complaint. Enquiries revealed that at the material time, Helpful Engineering did not conduct the relevant inspections in compliance with the requirements of the WSD.The ICAC investigation revealed that on various occasions, Lau had instructed Kwok Ka-hay, Kwok Ka-kei and other employees of Helpful Engineering to take photographs of waterworks facilities and alter the date and time of the photographs, which purported to have been taken on different days. Upon Lau’s instruction, Helpful Engineering’s employees used those photographs to compile the relevant daily inspection reports for submissions to the WSD.Lau and Li had also instructed employees of Helpful Engineering to prepare false attendance records to show that inspection teams had duly conducted daily inspections at the service reservoirs pursuant to the requirements of the WSD and that each inspection was conducted by three members.As a result, the defendants had induced the WSD to release service payments totalling about $4.6 million to Helpful Engineering through the fraudulent scheme.The WSD and Ming Hing rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Noelle Aileen Chit, assisted by ICAC officer Christine Wong. 16
Sep 2025Company director charged with perversion for allegedly inducing subcontractor not to file report with ICACA director of an interior design company was charged by the ICAC yesterday (September 15) with perversion for allegedly conspiring with another person to induce a subcontractor not to file a report with the ICAC.Cheung Chi-on, 29, director of Dimension Interior Design Company Limited (Dimension Interior Design), faces one count of conspiracy to pervert the course of public justice, contrary to the Common Law and section 159A of the Crimes Ordinance. He was released on ICAC bail, pending his appearance at the Eastern Magistrates’ Courts tomorrow (September 17) for plea.The charge alleges that on December 19, 2022, the defendant had conspired with a man to pervert the course of public justice by persuading and inducing a subcontractor not to file a report with the ICAC.At the material time, Dimension Interior Design was an interior design company of which the defendant was one of the two directors. He was responsible for arranging payments to subcontractors.In December 2022, the other director of Dimension Interior Design learned that a payment of about $140,000 had not been made to subcontractors for the renovation works in relation to six residential properties. The director and the subcontractors demanded an explanation from the defendant, or they would report the matter to the ICAC. The defendant offered no explanation but planned to overstate the renovation costs by falsifying receipts.Upon learning that the director of Dimension Interior Design and a subcontractor decided to report the matter to the ICAC, the defendant, through a man, allegedly persuaded the subcontractor not to do so and told the subcontractor that $15,000 would be offered to him. The subcontractor rejected the offer immediately.Members of the public should report any suspected corruption to the ICAC immediately. ICAC 24-hour Report Corruption Hotline: 25 266 366. An ICAC spokesperson noted that perverting the course of public justice is a serious offence. On conviction, an offender is liable to an imprisonment and a fine, both without an upper limit. 15
Sep 2025Eight months’ jail for beating facial recognition system in $250,000 commercial complex construction wage fraudA foreman of a contractor of a commercial complex construction project, among eight defendants entering guilty pleas following ICAC’s prosecution, was today (September 15) sentenced to eight months’ imprisonment at the West Kowloon Magistrates’ Courts for falsifying the attendance records of workers by altering the facial images registered with the facial recognition system at the construction site to defraud the contractor of wage payments totalling over $250,000.Tang Yu-ching, 44, former assistant general foreman of Sunnic Engineering Limited (Sunnic), earlier pleaded guilty to six counts of fraud, contrary to section 16A (1) of the Theft Ordinance.In sentencing, Magistrate Mr Gary Chu Man-hon said the present case was serious in nature that the defendant had conspired with others to deceive his employer, resulting in a heavy blow to the local employment market and workers’ morale, and undermining Hong Kong’s reputation as a graft-free city. The magistrate took a starting point of 12 months’ imprisonment and reduced the jail term to eight months, having considered the defendant’s guilty plea.Seven other former employees of Sunnic, namely a foreman, Chan Tin-hon; a site administration officer, Lai Yu-kiu; and five construction workers, Chiu Kim-wan, Choi Yun, See Kwok-shing, Johnny Chong Kam-hung and Mak Chi-kin; aged between 35 and 58, earlier pleaded guilty to the six counts of fraud. The case was scheduled for September 30 for sentence.The ICAC investigation stemmed from a corruption complaint. The court heard that in June 2021, Sunnic was engaged as the main contractor of the construction project of a commercial complex in Tsim Sha Tsui. Tang and Chan, respectively the assistant general foreman and foreman of Sunnic, were responsible for supervising the operation of the construction site of the project.Workers of the project were required to register their facial images with the facial recognition system for accessing the site. They were also required to scan their faces for taking attendance when reporting on and off duty. Based on the attendance records, Sunnic would calculate and release wage payments each month. Lai was authorised to operate the system at the material time.The court heard that between December 2022 and January 2023, Tang had referred six construction workers, including Chiu, Choi, See, Chong and Mak, to work at the site as general workers. Facial images of the six workers were registered in the facial recognition system by Chan.The relevant attendance records showed that the six workers had respectively worked at the site for 36 days to 43 days, leading to Sunnic’s subsequent release of wage payments totalling over $250,000 to a subcontractor. But ICAC enquiries revealed that Tang had told the workers that they were not required to work at the site and the wage payments were eventually passed to Tang and Chan.The ICAC investigation revealed that Tang had arranged Chan, with the assistance of Lai, to alter the facial images of the six workers registered with the facial recognition system by replacing them with Chan’s facial image so as to falsify the workers’ attendance records by scanning Chan’s face.Sunnic rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by ICAC officer Ken Yip.
Sep 2025Couple charged by ICAC in private residential project subcontractor worker wage fraud case jailed for 18 monthsA couple from a subcontractor of a construction project in Mid-Levels, charged by the ICAC, were today (September 30) sentenced to 18 months’ imprisonment, with the wife’s jail term suspended for 24 months, at the District Court for defrauding the project contractor of almost $9.6 million by falsifying and overstating the wages of workers.Hon Sang, 53, company secretary of Honsang Company Limited (Honsang); and his wife Ada Law Yin-nei, 49, sole director-cum-shareholder of Honsang, were earlier convicted after trial of two counts of fraud, contrary to section 16A of the Theft Ordinance.In sentencing, Deputy Judge Miss Veronica Heung Shuk-han remarked that the present case was an isolated one with no significant impact on the construction industry. The court took a starting point of 18 months’ imprisonment while the risk of reoffending for the defendants was low and that their actual gain was $1.1 million. Hon was the main culprit in the case and his wife, Law, only played a minor role. Having considered Law’s mitigating factors, including being required to take care of her ill-health son, her jail term was suspended for 24 months.The ICAC investigation arose from a corruption complaint regarding the release of wages to workers by Honsang. At the material time, Honsang was a subcontractor of aluminium and glass related works of a private residential construction project on Borrett Road in Mid-Levels. Honsang was required to submit wage payments related documents, including copies of cheques issued to workers and the relevant receipts, to a contractor of the project – CR Construction Company Limited (CR Construction) – for reimbursing expenses on an accountable basis.The court heard that between September 2018 and April 2019, CR Construction received from Honsang photocopies of over 1,200 cheques and relevant receipts, which purported to show that wages totalling about $30 million were paid to workers. CR Construction consequently settled the entire payment with Honsang.The ICAC investigation revealed that the payees and the payable amounts in 43 of the cheques, involving a sum of around $9.3 million, were falsified and deposited into bank accounts of the Hon couple and other individuals.Since Honsang had failed to pay wages to workers on time, CR Construction subsequently made direct payments to workers. Between May and August 2019, the Hon couple had overstated the wages of over 10 workers, causing CR Construction to overpay those workers by almost $300,000. They had also instructed workers to return the wages overpaid by CR Construction to Honsang.CR Construction rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Susanna Ku, assisted by ICAC officer Andy Yip. 22
Sep 2025Tenant charged by ICAC for bribing estate agent to avoid paying default tenancy compensationA tenant was charged by the ICAC for allegedly offering a bribe of $1,000 to an estate agent, requesting the latter to conceal from an estate agency that he had defaulted a tenancy agreement to avoid giving up his deposit as compensation.Du Du, 48, was charged last Friday (September 19) with one count of offering an advantage to an agent, contrary to section 9(2)(a) of Prevention of Bribery Ordinance (POBO). He was released on ICAC bail, pending his appearance at the Shatin Magistrates’ Courts tomorrow (September 23) for plea.On the morning of November 6, 2022, the defendant viewed a rental residential flat in Tai Wai upon the arrangement by an estate agent of Midland Realty International Limited (Midland Realty). The defendant rented the flat at $16,000 per month by signing a provisional tenancy agreement with the flat owner on the spot.On the same afternoon, the defendant contacted the estate agent expressing his wish to cancel the provisional tenancy agreement. According to the terms of the agreement, the party cancelling the agreement had to pay a compensation equivalent to the deposit, i.e., $16,000.The charge alleges that the defendant had offered a bribe of $1,000 to the estate agent on that day, requesting the latter to assist in concealing from Midland Realty that the provisional tenancy agreement was signed between the defendant and the flat owner, and the default of the defendant on the agreement.The estate agent did not accept the bribe and reported the matter to Midland Realty, which rendered assistance to the ICAC during its investigation into the case.According to Section 9 of the POBO, it is a bribery offence for a person who, without lawful authority or reasonable excuse, offers an advantage (including money, gifts, loans, commissions, positions, contracts, services, favours, etc.) to an employee of a private organisation to influence the employee in exercising one’s duties. Bribery is a serious offence carrying a maximum penalty of seven years’ imprisonment and a fine of $500,000. Members of the public should report suspected corruption to the ICAC without delay. The ICAC 24-hour Report Corruption Hotline: 25 266 366. 16
Sep 2025Ex-subcontractor of WSD and three employees charged by ICAC admit $4.6m payment fraud over false service reservoir inspection reportsThe director of a former subcontractor of the Water Supplies Department (WSD) and three of his employees, charged by the ICAC, today (September 16) admitted at the District Court that they had committed conspiracy to defraud by submitting service reservoir inspection reports containing false information to induce the WSD to release service payments totalling about $4.6 million.Lau Ho-kei, 44, sole director-cum-shareholder of Helpful Engineering Company Limited (Helpful Engineering); and three then employees of Helpful Engineering, namely Li Wing-to, 34, clerk; and Kwok Ka-hay and Kwok Ka-kei, both 41 and handymen, today pleaded guilty to a total of two counts of conspiracy to defraud, contrary to the Common Law.Judge Mr Isaac Tam Sze-lok adjourned the case to November 18 for sentence. The defendants were remanded in the custody of the Correctional Services Department.The ICAC today filed an application with the court for confiscating Lau’s crime proceeds involved in the present case. Hearing on the application will be scheduled for a date to be fixed later.The court heard that between July 2020 and June 2022, the WSD awarded two term contracts for the provision various waterworks services for the New Territories East District to Ming Hing Waterworks Engineering Company Limited (Ming Hing). Helpful Engineering was subcontracted to conduct inspections at around 40 service reservoirs in the district to maintain safety and conditions of the service reservoirs.The WSD required its subcontractors to assign a designated number of teams, each consisting of three members to conduct daily inspections. Subcontractors were also required to compile a daily inspection report supported by photographs taken during the inspections.The ICAC investigation arose from a corruption complaint. Enquiries revealed that at the material time, Helpful Engineering did not conduct the relevant inspections in compliance with the requirements of the WSD.The ICAC investigation revealed that on various occasions, Lau had instructed Kwok Ka-hay, Kwok Ka-kei and other employees of Helpful Engineering to take photographs of waterworks facilities and alter the date and time of the photographs, which purported to have been taken on different days. Upon Lau’s instruction, Helpful Engineering’s employees used those photographs to compile the relevant daily inspection reports for submissions to the WSD.Lau and Li had also instructed employees of Helpful Engineering to prepare false attendance records to show that inspection teams had duly conducted daily inspections at the service reservoirs pursuant to the requirements of the WSD and that each inspection was conducted by three members.As a result, the defendants had induced the WSD to release service payments totalling about $4.6 million to Helpful Engineering through the fraudulent scheme.The WSD and Ming Hing rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Noelle Aileen Chit, assisted by ICAC officer Christine Wong. 16
Sep 2025Company director charged with perversion for allegedly inducing subcontractor not to file report with ICACA director of an interior design company was charged by the ICAC yesterday (September 15) with perversion for allegedly conspiring with another person to induce a subcontractor not to file a report with the ICAC.Cheung Chi-on, 29, director of Dimension Interior Design Company Limited (Dimension Interior Design), faces one count of conspiracy to pervert the course of public justice, contrary to the Common Law and section 159A of the Crimes Ordinance. He was released on ICAC bail, pending his appearance at the Eastern Magistrates’ Courts tomorrow (September 17) for plea.The charge alleges that on December 19, 2022, the defendant had conspired with a man to pervert the course of public justice by persuading and inducing a subcontractor not to file a report with the ICAC.At the material time, Dimension Interior Design was an interior design company of which the defendant was one of the two directors. He was responsible for arranging payments to subcontractors.In December 2022, the other director of Dimension Interior Design learned that a payment of about $140,000 had not been made to subcontractors for the renovation works in relation to six residential properties. The director and the subcontractors demanded an explanation from the defendant, or they would report the matter to the ICAC. The defendant offered no explanation but planned to overstate the renovation costs by falsifying receipts.Upon learning that the director of Dimension Interior Design and a subcontractor decided to report the matter to the ICAC, the defendant, through a man, allegedly persuaded the subcontractor not to do so and told the subcontractor that $15,000 would be offered to him. The subcontractor rejected the offer immediately.Members of the public should report any suspected corruption to the ICAC immediately. ICAC 24-hour Report Corruption Hotline: 25 266 366. An ICAC spokesperson noted that perverting the course of public justice is a serious offence. On conviction, an offender is liable to an imprisonment and a fine, both without an upper limit. 15
Sep 2025Eight months’ jail for beating facial recognition system in $250,000 commercial complex construction wage fraudA foreman of a contractor of a commercial complex construction project, among eight defendants entering guilty pleas following ICAC’s prosecution, was today (September 15) sentenced to eight months’ imprisonment at the West Kowloon Magistrates’ Courts for falsifying the attendance records of workers by altering the facial images registered with the facial recognition system at the construction site to defraud the contractor of wage payments totalling over $250,000.Tang Yu-ching, 44, former assistant general foreman of Sunnic Engineering Limited (Sunnic), earlier pleaded guilty to six counts of fraud, contrary to section 16A (1) of the Theft Ordinance.In sentencing, Magistrate Mr Gary Chu Man-hon said the present case was serious in nature that the defendant had conspired with others to deceive his employer, resulting in a heavy blow to the local employment market and workers’ morale, and undermining Hong Kong’s reputation as a graft-free city. The magistrate took a starting point of 12 months’ imprisonment and reduced the jail term to eight months, having considered the defendant’s guilty plea.Seven other former employees of Sunnic, namely a foreman, Chan Tin-hon; a site administration officer, Lai Yu-kiu; and five construction workers, Chiu Kim-wan, Choi Yun, See Kwok-shing, Johnny Chong Kam-hung and Mak Chi-kin; aged between 35 and 58, earlier pleaded guilty to the six counts of fraud. The case was scheduled for September 30 for sentence.The ICAC investigation stemmed from a corruption complaint. The court heard that in June 2021, Sunnic was engaged as the main contractor of the construction project of a commercial complex in Tsim Sha Tsui. Tang and Chan, respectively the assistant general foreman and foreman of Sunnic, were responsible for supervising the operation of the construction site of the project.Workers of the project were required to register their facial images with the facial recognition system for accessing the site. They were also required to scan their faces for taking attendance when reporting on and off duty. Based on the attendance records, Sunnic would calculate and release wage payments each month. Lai was authorised to operate the system at the material time.The court heard that between December 2022 and January 2023, Tang had referred six construction workers, including Chiu, Choi, See, Chong and Mak, to work at the site as general workers. Facial images of the six workers were registered in the facial recognition system by Chan.The relevant attendance records showed that the six workers had respectively worked at the site for 36 days to 43 days, leading to Sunnic’s subsequent release of wage payments totalling over $250,000 to a subcontractor. But ICAC enquiries revealed that Tang had told the workers that they were not required to work at the site and the wage payments were eventually passed to Tang and Chan.The ICAC investigation revealed that Tang had arranged Chan, with the assistance of Lai, to alter the facial images of the six workers registered with the facial recognition system by replacing them with Chan’s facial image so as to falsify the workers’ attendance records by scanning Chan’s face.Sunnic rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by ICAC officer Ken Yip.