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Ethical Decision MakingRecent ICAC Cases
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Nov 2025Senior executive of contractor of COVID-19 Community Testing Centres charged by ICAC for concealing conflict of interest in $120m contractA then senior executive of a contractor of COVID-19 Community Testing Centres (CTCs) was charged by the ICAC yesterday (November 5) for allegedly concealing his conflict of interest when contracting out the daily operation of CTCs to a company controlled by him and others, resulting in service payments totalling $120 million.Wong Lei-po, 56, former laboratory director of the Hong Kong Molecular Pathology Diagnostic Centre Limited (HKM), faces one count of fraud, contrary to section 16A (1) of the Theft Ordinance. He was released on ICAC bail, pending his appearance at the Eastern Magistrates’ Courts tomorrow (November 7) for mention.Amid the pandemic, HKM was one of the designated service providers engaged by the government to operate CTCs, comprising the daily operation and laboratory testing. HKM contracted out CTCs’ daily operation, including registration and crowd control, to Health Conscience Limited (HCL).At the material time, the defendant was the laboratory director of HKM overseeing its operation, including the selection of subcontractors. HKM required its staff members to avoid any conflict of interest situation and to declare any actual or potential conflict of interest in writing. The defendant had never declared to HKM his interest in HCL.It is alleged that between January and December 2022, the defendant had concealed from or failed to disclose to HKM his interest in HCL, and with intent to defraud, induced HKM to award the service agreement for daily operation of CTCs to HCL.The ICAC investigation arose from a corruption complaint. Enquiries revealed that HCL was set up and controlled by the defendant and others. HKM made service payments totalling $120 million to HCL for the service provided by HCL at the material time.HKM rendered full assistance to the ICAC during its investigation into the case.The ICAC advises business organisations to formulate clear guidelines and systems of declaring conflict of interest. Staff members of business organisations are reminded to avoid conflict of interest situations and to make timely declaration to their employers. Concealing any conflict of interest in relation to one’s official duties to benefit himself or his associates may constitute a breach of the Prevention of Bribery Ordinance or other criminal law. 05
Nov 2025CFA unanimously allows DoJ’s appeal and restores convictions of four defendants in listed company bonds placement conspiracy to defraud caseThe Court of Final Appeal (CFA) today (November 5) unanimously allowed the appeal by the Department of Justice (DoJ) and restored the convictions of four persons, including senior executives of a then listed company, who were charged by the ICAC with conspiracy to defraud over bonds placement of the listed company.Mak Kwong-yiu, 51, former executive director of Convoy Financial Services Holdings Limited (Convoy Financial Services); Chan Lai-yee, 53, former chief financial officer of Convoy Financial Services; Wong Shuk-on, 46, former manager of Convoy Financial Services; and Lee Yick-ming, 55, former general manager of Gransing Securities Co., Limited (Gransing), were found guilty of two counts of conspiracy to defraud, contrary to the Common Law, after trial at the District Court in September 2021. Mak and Lee were respectively jailed for seven months and five months, while Chan and Wong were respectively sentenced to five months’ and four months’ imprisonment, both suspended for 18 months.The four defendants’ appeal against their convictions was subsequently allowed by the Court of Appeal (CA) of the High Court. The DoJ then filed an appeal with the CFA against the ruling. The appeal was heard by Permanent Judges Mr Justice Roberto Ribeiro, Mr Justice Joseph Fok and Mr Justice Johnson Lam Man-hon, as well as Non-Permanent Judges Mr Justice Frank Stock and Sir William Young on September 3 and 4, 2025.In the judgment handed down by the CFA today, the five judges unanimously allowed the DoJ’s appeal against the CA’s ruling and restored the four defendants’ convictions. Mak and Lee will serve their jail terms.The CFA judges noted in the judgment that the court viewed the bonds placement agreements as a whole and construed the Rules Governing the Listing of Securities (the Listing Rules) on the The Stock Exchange of Hong Kong Limited (SEHK) purposively when assessing whether the transactions involved in the present case constituted connected transactions. The defendants interposed Gransing which served no commercial purpose in the chain of contracts to conceal the indirect interests in the bond placements agreements, breaching the fiduciary duty and constituting the conviction for conspiracy to defraud.The ICAC’s investigation commenced upon receiving complaints in 2017 which alleged breaches of the Prevention of Bribery Ordinance and the Securities and Futures Ordinance. An operation was jointly mounted by the ICAC and the Securities and Futures Commission (SFC) in December 2017.The court heard that at the material time, Convoy Financial Services, later renamed as Convoy Financial Holdings Limited, was listed (publicly listed Convoy) on the Main Board of the SEHK. Gransing and Convoy Investment Services Limited (CIS), which was not a subsidiary of publicly listed Convoy, both provided dealing in securities regulated activity, such as bonds placement.Mak and two other former executive directors of publicly listed Convoy were substantial shareholders of CIS. If a bonds placement agreement involved transactions between publicly listed Convoy and CIS, the transaction was a connected transaction governed by the Listing Rules.On four occasions between July 8, 2014 and January 21, 2015, publicly listed Convoy engaged Gransing as the placing agent of four bond placing exercises of the publicly listed Convoy. The defendants conspired together to arrange Gransing to further engage CIS as the sub-placing agent of the four bond placing exercises. CIS subsequently received around $49.6 million as sub-placing commission from publicly listed Convoy via Gransing and $1.2 million as bonus from Gransing under the sub-placing arrangements.In fact, Gransing did not place any bonds with any investor and CIS was the actual placing agent. The four defendants dishonestly concealed from publicly listed Convoy and its board of directors and shareholders as well as the SEHK that CIS was the actual placing agent of the four bonds. They had also used Gransing to conceal CIS’s involvement in the bonds placement, causing CIS to receive sub-placing commission. In addition, the concealment deprived shareholders of publicly listed Convoy of the right to vote against the sub-placing arrangements, and hindered the SEHK’s enforcement of the Listing Rules.The SFC, the SEHK and the then publicly listed Convoy rendered full assistance to the ICAC during its investigation.An ICAC spokesperson said that the ICAC will continue to maintain close cooperation with the SFC and other relevant regulatory bodies, working together to combat corruption and illegal activities in Hong Kong’s financial market. The ICAC is committed to upholding market integrity, fairness and a clean business environment, thereby reinforcing Hong Kong’s status as an international financial centre.The prosecution was represented by Senior Public Prosecutors Human Lam and Ivan Shiu, assisted by ICAC officer Matthew Pan. 28
Oct 2025Ex-senior manager of developer and five from subcontractors charged by ICAC guilty of bribery over leakage of tendering documentsA senior construction manager of a developer and five directors and staff of four subcontractors, charged by the ICAC, were today (October 28) convicted after trial at the Shatin Magistrates’ Courts of bribery offences. The manager had accepted advantages worth about $180,000, including cash, gifts, etc., provided by the co-defendants for disclosing internal documents and information to assist the latter in the tendering exercises for various work packages of 10 construction projects.The defendants were Constant So Shun-ching, 57, then senior construction manager of Henderson Land Development Company Limited (Henderson Land); Mak Hung-cho, 69, shareholder-cum-director of Lee Shing Masonry Engineering Limited (Lee Shing); Zheng Weicheng, 43, shareholder-cum-director of King Fung Development & Construction Company Limited (King Fung); Chung Yiu-hon, 37, staff member of King Fung; Chow Kit, 50, director of Trigon Building Materials Limited (Trigon); and Chan Lok-kau, 69, consultant of Kinway Engineering Limited (Kinway).The six defendants were found guilty of a total of four counts of conspiracy for agent to accept advantages, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance (POBO) and section 159A of the Crimes Ordinance.Magistrate Mr Jeffrey Sze Cho-yiu adjourned the case to November 27 for mitigation and sentence. The defendants were remanded in the custody of the Correctional Services Department.The court heard that at the material time, So was a senior construction manager of Henderson Land. He was responsible for overseeing the works conducted by subcontractors, and providing assistance in tendering exercises of work packages. Lee Shing, King Fung, Trigon and Kinway were registered subcontractors of Henderson Land. They were respectively responsible for plastering, concrete formwork and structure, false ceiling and miscellaneous works.The offences took place between June 2014 and July 2021. So had accepted from the five co-defendants various advantages worth totalling about $180,000 for assisting the four subcontractors – Lee Shing, King Fung, Trigon and Kinway – in the tendering exercises of Henderson Land or its subsidiaries.The advantages which So had accepted were $100,000 in cash, four smartphones worth totalling over $46,000, a birthday banquet worth over $9,000, hotel accommodation in Macao worth about $5,700 and furniture worth $18,000.The ICAC investigation revealed that So had disclosed to the five co-defendants the internal tender documents of Henderson Land in relation to various work packages of 10 residential as well as industrial and commercial construction projects. Such documents contained information including Henderson Land’s estimated cost for the relevant works as well as that concerning tenderers which had submitted the lowest bids.Henderson Land rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Victor Chiu, assisted by ICAC officer Vincent Ching.The ICAC has been actively promoting anti-corruption messages in the construction industry, reminding practitioners to adhere strictly to the POBO and not to abuse one’s official capacity for accepting bribes, thus undermining the integrity of the tendering system and clean business environment. 23
Oct 2025Employee of interior design company charged by ICAC for $520,000 bribery over subcontracting renovation worksAn employee of an interior design company was charged by the ICAC yesterday (October 22) for allegedly accepting bribes totalling about $520,000 from seven subcontractors for awarding renovation projects to them.Pang Tsz-yeung, 46, then project supervisor of Elite House Design Limited (Elite House), faces seven counts of agent accepting an advantage, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance. He was released on ICAC bail, pending his appearance at the Eastern Magistrates’ Courts tomorrow (October 24) for mention.At the material time, the defendant was a project supervisor of Elite House, an interior design company. He was authorised by the company to select subcontractors for clients’ renovation works. Elite House prohibited its employees from soliciting or accepting advantages from others for matters in relation to its businesses or affairs.The ICAC investigation stemmed from a corruption complaint. It is alleged that between April 2016 and October 2023, the defendant had accepted bribes totalling about $520,000 from seven subcontractors for subcontracting to them Elite House’s renovation projects.The ICAC investigation revealed that the aforesaid subcontractors reluctantly acceded to the defendant’s request for bribes for fear of his authority.Elite House rendered full assistance to the ICAC during its investigation into the case.An ICAC spokesperson notes that according to section 9 of the Prevention of Bribery Ordinance, it is an offence for an agent (e.g. employee), without lawful authority or reasonable excuse, to solicit or accept an advantage for an act in relation to his principal's businesses or affairs. Members of the public should reject and report to the ICAC immediately if they are asked to pay bribes in exchange for business contracts. 20
Oct 2025Senior executive of air cargo company and contractor charged by ICAC for US$1.1m-bribes-for aircraft charter agreementAn assistant general manager of air cargo companies and a service contractor were charged by the ICAC this morning (October 20) for allegedly agreeing to accept and offer bribes of over US$1.1 million (equivalent to over HK$8.5 million) for providing air cargo services for the air cargo companies. The case is set for mention in the West Kowloon Magistrates’ Courts this afternoon.The defendants are Nelson Lee Yiu-wing, 74, assistant general manager of Shenzhen CNT Global Freight Co., Limited (SZCNT) and CNT Global Freight Co., Limited (HKCNT); and Jason Wan Kim-wah, 69, sole director-cum-shareholder of U.L.D. Group Limited (ULD). They jointly face one count of conspiracy for agents to accept advantages, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance and section 159A of the Crimes Ordinance.The duo were released on ICAC bail, pending their appearance at the West Kowloon Magistrates’ Courts this afternoon for mention.The ICAC investigation stemmed from a corruption complaint. SZCNT is an air freight company based in Shenzhen while HKCNT is its office in Hong Kong. At the material time, Lee was responsible for managing daily operations of both companies. ULD was an air cargo services contractor in Hong Kong.The charge alleges that between July and September 2023, Lee and Wan conspired together for Lee to accept from Wan bribes consisting of at least US$1.1 million (equivalent to over HK$8.5 million) for engaging ULD to provide air cargo services for SZCNT.At the material time, SZCNT signed an aircraft charter agreement with ULD. Pursuant to the agreement, ULD was required to provide at least 110 round-trip flights to and from China and the United States for a period of one year. The total value of the agreement sum was over US$57 million (equivalent to over HK$440 million).ICAC investigation revealed that the two defendants had allegedly agreed for Lee to accept a bribe of US$10,000 (equivalent to about HK$78,000) for each round-trip flight. Between July 11 and August 29 2023, Lee accepted bribes totalling US$180,000 (equivalent to about HK$1.4 million). Should ULD be able to honour the agreement by providing 110 round-trip flights, bribes in total would amount to US$1.1 million (equivalent over HK$8.5 million). However, the agreement was subsequently terminated as ULD failed to provide the required services.SZCNT and HKCNT rendered full assistance to the ICAC during its investigation into the case.
Nov 2025Senior executive of contractor of COVID-19 Community Testing Centres charged by ICAC for concealing conflict of interest in $120m contractA then senior executive of a contractor of COVID-19 Community Testing Centres (CTCs) was charged by the ICAC yesterday (November 5) for allegedly concealing his conflict of interest when contracting out the daily operation of CTCs to a company controlled by him and others, resulting in service payments totalling $120 million.Wong Lei-po, 56, former laboratory director of the Hong Kong Molecular Pathology Diagnostic Centre Limited (HKM), faces one count of fraud, contrary to section 16A (1) of the Theft Ordinance. He was released on ICAC bail, pending his appearance at the Eastern Magistrates’ Courts tomorrow (November 7) for mention.Amid the pandemic, HKM was one of the designated service providers engaged by the government to operate CTCs, comprising the daily operation and laboratory testing. HKM contracted out CTCs’ daily operation, including registration and crowd control, to Health Conscience Limited (HCL).At the material time, the defendant was the laboratory director of HKM overseeing its operation, including the selection of subcontractors. HKM required its staff members to avoid any conflict of interest situation and to declare any actual or potential conflict of interest in writing. The defendant had never declared to HKM his interest in HCL.It is alleged that between January and December 2022, the defendant had concealed from or failed to disclose to HKM his interest in HCL, and with intent to defraud, induced HKM to award the service agreement for daily operation of CTCs to HCL.The ICAC investigation arose from a corruption complaint. Enquiries revealed that HCL was set up and controlled by the defendant and others. HKM made service payments totalling $120 million to HCL for the service provided by HCL at the material time.HKM rendered full assistance to the ICAC during its investigation into the case.The ICAC advises business organisations to formulate clear guidelines and systems of declaring conflict of interest. Staff members of business organisations are reminded to avoid conflict of interest situations and to make timely declaration to their employers. Concealing any conflict of interest in relation to one’s official duties to benefit himself or his associates may constitute a breach of the Prevention of Bribery Ordinance or other criminal law. 05
Nov 2025CFA unanimously allows DoJ’s appeal and restores convictions of four defendants in listed company bonds placement conspiracy to defraud caseThe Court of Final Appeal (CFA) today (November 5) unanimously allowed the appeal by the Department of Justice (DoJ) and restored the convictions of four persons, including senior executives of a then listed company, who were charged by the ICAC with conspiracy to defraud over bonds placement of the listed company.Mak Kwong-yiu, 51, former executive director of Convoy Financial Services Holdings Limited (Convoy Financial Services); Chan Lai-yee, 53, former chief financial officer of Convoy Financial Services; Wong Shuk-on, 46, former manager of Convoy Financial Services; and Lee Yick-ming, 55, former general manager of Gransing Securities Co., Limited (Gransing), were found guilty of two counts of conspiracy to defraud, contrary to the Common Law, after trial at the District Court in September 2021. Mak and Lee were respectively jailed for seven months and five months, while Chan and Wong were respectively sentenced to five months’ and four months’ imprisonment, both suspended for 18 months.The four defendants’ appeal against their convictions was subsequently allowed by the Court of Appeal (CA) of the High Court. The DoJ then filed an appeal with the CFA against the ruling. The appeal was heard by Permanent Judges Mr Justice Roberto Ribeiro, Mr Justice Joseph Fok and Mr Justice Johnson Lam Man-hon, as well as Non-Permanent Judges Mr Justice Frank Stock and Sir William Young on September 3 and 4, 2025.In the judgment handed down by the CFA today, the five judges unanimously allowed the DoJ’s appeal against the CA’s ruling and restored the four defendants’ convictions. Mak and Lee will serve their jail terms.The CFA judges noted in the judgment that the court viewed the bonds placement agreements as a whole and construed the Rules Governing the Listing of Securities (the Listing Rules) on the The Stock Exchange of Hong Kong Limited (SEHK) purposively when assessing whether the transactions involved in the present case constituted connected transactions. The defendants interposed Gransing which served no commercial purpose in the chain of contracts to conceal the indirect interests in the bond placements agreements, breaching the fiduciary duty and constituting the conviction for conspiracy to defraud.The ICAC’s investigation commenced upon receiving complaints in 2017 which alleged breaches of the Prevention of Bribery Ordinance and the Securities and Futures Ordinance. An operation was jointly mounted by the ICAC and the Securities and Futures Commission (SFC) in December 2017.The court heard that at the material time, Convoy Financial Services, later renamed as Convoy Financial Holdings Limited, was listed (publicly listed Convoy) on the Main Board of the SEHK. Gransing and Convoy Investment Services Limited (CIS), which was not a subsidiary of publicly listed Convoy, both provided dealing in securities regulated activity, such as bonds placement.Mak and two other former executive directors of publicly listed Convoy were substantial shareholders of CIS. If a bonds placement agreement involved transactions between publicly listed Convoy and CIS, the transaction was a connected transaction governed by the Listing Rules.On four occasions between July 8, 2014 and January 21, 2015, publicly listed Convoy engaged Gransing as the placing agent of four bond placing exercises of the publicly listed Convoy. The defendants conspired together to arrange Gransing to further engage CIS as the sub-placing agent of the four bond placing exercises. CIS subsequently received around $49.6 million as sub-placing commission from publicly listed Convoy via Gransing and $1.2 million as bonus from Gransing under the sub-placing arrangements.In fact, Gransing did not place any bonds with any investor and CIS was the actual placing agent. The four defendants dishonestly concealed from publicly listed Convoy and its board of directors and shareholders as well as the SEHK that CIS was the actual placing agent of the four bonds. They had also used Gransing to conceal CIS’s involvement in the bonds placement, causing CIS to receive sub-placing commission. In addition, the concealment deprived shareholders of publicly listed Convoy of the right to vote against the sub-placing arrangements, and hindered the SEHK’s enforcement of the Listing Rules.The SFC, the SEHK and the then publicly listed Convoy rendered full assistance to the ICAC during its investigation.An ICAC spokesperson said that the ICAC will continue to maintain close cooperation with the SFC and other relevant regulatory bodies, working together to combat corruption and illegal activities in Hong Kong’s financial market. The ICAC is committed to upholding market integrity, fairness and a clean business environment, thereby reinforcing Hong Kong’s status as an international financial centre.The prosecution was represented by Senior Public Prosecutors Human Lam and Ivan Shiu, assisted by ICAC officer Matthew Pan. 28
Oct 2025Ex-senior manager of developer and five from subcontractors charged by ICAC guilty of bribery over leakage of tendering documentsA senior construction manager of a developer and five directors and staff of four subcontractors, charged by the ICAC, were today (October 28) convicted after trial at the Shatin Magistrates’ Courts of bribery offences. The manager had accepted advantages worth about $180,000, including cash, gifts, etc., provided by the co-defendants for disclosing internal documents and information to assist the latter in the tendering exercises for various work packages of 10 construction projects.The defendants were Constant So Shun-ching, 57, then senior construction manager of Henderson Land Development Company Limited (Henderson Land); Mak Hung-cho, 69, shareholder-cum-director of Lee Shing Masonry Engineering Limited (Lee Shing); Zheng Weicheng, 43, shareholder-cum-director of King Fung Development & Construction Company Limited (King Fung); Chung Yiu-hon, 37, staff member of King Fung; Chow Kit, 50, director of Trigon Building Materials Limited (Trigon); and Chan Lok-kau, 69, consultant of Kinway Engineering Limited (Kinway).The six defendants were found guilty of a total of four counts of conspiracy for agent to accept advantages, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance (POBO) and section 159A of the Crimes Ordinance.Magistrate Mr Jeffrey Sze Cho-yiu adjourned the case to November 27 for mitigation and sentence. The defendants were remanded in the custody of the Correctional Services Department.The court heard that at the material time, So was a senior construction manager of Henderson Land. He was responsible for overseeing the works conducted by subcontractors, and providing assistance in tendering exercises of work packages. Lee Shing, King Fung, Trigon and Kinway were registered subcontractors of Henderson Land. They were respectively responsible for plastering, concrete formwork and structure, false ceiling and miscellaneous works.The offences took place between June 2014 and July 2021. So had accepted from the five co-defendants various advantages worth totalling about $180,000 for assisting the four subcontractors – Lee Shing, King Fung, Trigon and Kinway – in the tendering exercises of Henderson Land or its subsidiaries.The advantages which So had accepted were $100,000 in cash, four smartphones worth totalling over $46,000, a birthday banquet worth over $9,000, hotel accommodation in Macao worth about $5,700 and furniture worth $18,000.The ICAC investigation revealed that So had disclosed to the five co-defendants the internal tender documents of Henderson Land in relation to various work packages of 10 residential as well as industrial and commercial construction projects. Such documents contained information including Henderson Land’s estimated cost for the relevant works as well as that concerning tenderers which had submitted the lowest bids.Henderson Land rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Victor Chiu, assisted by ICAC officer Vincent Ching.The ICAC has been actively promoting anti-corruption messages in the construction industry, reminding practitioners to adhere strictly to the POBO and not to abuse one’s official capacity for accepting bribes, thus undermining the integrity of the tendering system and clean business environment. 23
Oct 2025Employee of interior design company charged by ICAC for $520,000 bribery over subcontracting renovation worksAn employee of an interior design company was charged by the ICAC yesterday (October 22) for allegedly accepting bribes totalling about $520,000 from seven subcontractors for awarding renovation projects to them.Pang Tsz-yeung, 46, then project supervisor of Elite House Design Limited (Elite House), faces seven counts of agent accepting an advantage, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance. He was released on ICAC bail, pending his appearance at the Eastern Magistrates’ Courts tomorrow (October 24) for mention.At the material time, the defendant was a project supervisor of Elite House, an interior design company. He was authorised by the company to select subcontractors for clients’ renovation works. Elite House prohibited its employees from soliciting or accepting advantages from others for matters in relation to its businesses or affairs.The ICAC investigation stemmed from a corruption complaint. It is alleged that between April 2016 and October 2023, the defendant had accepted bribes totalling about $520,000 from seven subcontractors for subcontracting to them Elite House’s renovation projects.The ICAC investigation revealed that the aforesaid subcontractors reluctantly acceded to the defendant’s request for bribes for fear of his authority.Elite House rendered full assistance to the ICAC during its investigation into the case.An ICAC spokesperson notes that according to section 9 of the Prevention of Bribery Ordinance, it is an offence for an agent (e.g. employee), without lawful authority or reasonable excuse, to solicit or accept an advantage for an act in relation to his principal's businesses or affairs. Members of the public should reject and report to the ICAC immediately if they are asked to pay bribes in exchange for business contracts. 20
Oct 2025Senior executive of air cargo company and contractor charged by ICAC for US$1.1m-bribes-for aircraft charter agreementAn assistant general manager of air cargo companies and a service contractor were charged by the ICAC this morning (October 20) for allegedly agreeing to accept and offer bribes of over US$1.1 million (equivalent to over HK$8.5 million) for providing air cargo services for the air cargo companies. The case is set for mention in the West Kowloon Magistrates’ Courts this afternoon.The defendants are Nelson Lee Yiu-wing, 74, assistant general manager of Shenzhen CNT Global Freight Co., Limited (SZCNT) and CNT Global Freight Co., Limited (HKCNT); and Jason Wan Kim-wah, 69, sole director-cum-shareholder of U.L.D. Group Limited (ULD). They jointly face one count of conspiracy for agents to accept advantages, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance and section 159A of the Crimes Ordinance.The duo were released on ICAC bail, pending their appearance at the West Kowloon Magistrates’ Courts this afternoon for mention.The ICAC investigation stemmed from a corruption complaint. SZCNT is an air freight company based in Shenzhen while HKCNT is its office in Hong Kong. At the material time, Lee was responsible for managing daily operations of both companies. ULD was an air cargo services contractor in Hong Kong.The charge alleges that between July and September 2023, Lee and Wan conspired together for Lee to accept from Wan bribes consisting of at least US$1.1 million (equivalent to over HK$8.5 million) for engaging ULD to provide air cargo services for SZCNT.At the material time, SZCNT signed an aircraft charter agreement with ULD. Pursuant to the agreement, ULD was required to provide at least 110 round-trip flights to and from China and the United States for a period of one year. The total value of the agreement sum was over US$57 million (equivalent to over HK$440 million).ICAC investigation revealed that the two defendants had allegedly agreed for Lee to accept a bribe of US$10,000 (equivalent to about HK$78,000) for each round-trip flight. Between July 11 and August 29 2023, Lee accepted bribes totalling US$180,000 (equivalent to about HK$1.4 million). Should ULD be able to honour the agreement by providing 110 round-trip flights, bribes in total would amount to US$1.1 million (equivalent over HK$8.5 million). However, the agreement was subsequently terminated as ULD failed to provide the required services.SZCNT and HKCNT rendered full assistance to the ICAC during its investigation into the case.