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
04
Jun 2025Printing company trio charged by ICAC for concealing conflicting interest in $6.6m delivery services fraudTwo former employees of a printing company and the wife of one of them were charged by the ICAC yesterday (June 3) for allegedly deceiving the company into engaging a relative to provide delivery services and making payments totalling about $6.6 million by concealing conflicting interest for personal gain of about $1.2 million.So Keung, 52, former assistant production manager of Bannershop Hong Kong Limited (Bannershop); his wife Poon Po-lin, 54; and Zhang Haiqi, 33, former delivery section supervisor of Bannershop, jointly face one count of fraud, contrary to section 16A(1) of the Theft Ordinance.The case unfolded in an ICAC investigation arose from a corruption complaint. The defendants were released on ICAC bail, pending their appearance at the Kwun Tong Magistrates’ Courts tomorrow (June 5) for mention. The prosecution will apply for transferring the case to the District Court for plea.Bannershop is engaged in digital printing, graphic design, exhibition decoration and installation. At the material time, So was an assistant production manager responsible for managing the production of printed products while Zhang, being the delivery section supervisor, was responsible for managing the delivery of printed products to customers.In February 2018, upon the recommendation of Zhang, the brother-in-law of the So’s couple was engaged by Bannershop to deliver products to its customers. Zhang would submit the relevant invoices to the company for settling delivery fees.The staff handbook and code of conduct of the company stipulated that staff members were obliged to notify the company where their spouse or sibling held any business negotiation with the company, and that they should avoid conflict of interests.The charge alleges that between May 2018 and January 2022, the three defendants had concealed from Bannershop So’s familial relationship with his brother-in-law and Poon, and defrauded the company to remain engaged with the brother-in-law to provide delivery services and settle delivery fees totalling $6.6 million.ICAC enquiries revealed that Poon’s bank account was arranged to receive payments from Bannershop. While about $5.4 million was transferred to the bank account of the brother-in-law of the So’s couple, So and Zhang received over $800,000 and over $300,000 respectively. So had never declared to Bannershop his familial relationship with his brother-in-law and Poon.Bannershop rendered full assistance to the ICAC during its investigation into the case. 30
May 2025Salesman of groceries supplier charged by ICAC admits fraud over goods worth $12mA then senior sales executive of a groceries supplier, charged by the ICAC, today (May 30) admitted at the District Court that he has made false representations about the orders placed by various clients to induce the supplier to release goods worth totalling over $12 million in nine months and resold them for personal gain.Mak Ka-wing, 46, former senior sales executive of Dah Chong Hong Limited (DCH), pleaded guilty to 32 counts of fraud, contrary to section 16A of the Theft Ordinance.Deputy Judge Ms Stephanie Tsui May-har adjourned the case to July 17 for sentence. The defendant was remanded in custody of the Correctional Services Department.The court heard that at the material time, the defendant was a senior sales executive of DCH’s food trading unit which engaged in the supply of groceries. He was responsible for handling groceries orders placed by clients. Upon receiving a request from a client, DCH would issue an invoice for arranging release or delivery of goods to the client.The ICAC investigation arose from a corruption complaint. Enquiries revealed that in the nine months between August 2020 and April 2021, the defendant had input fictitious orders into the DCH’s computer system and falsely represented that 32 clients had ordered goods from the company. As a result, DCH issued a total of 410 invoices to the clients and arranged goods worth totalling over $12 million to be released.Enquiries also found that the defendant forged signatures of clients on the receipts. He subsequently resold the goods for personal gain, but he only repaid about $280,000 to DCH.DCH rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Douglas Lau, assisted by ICAC officer William Leung. 27
May 2025Insurance agent charged by ICAC receives 51 months’ jail for $1.6m commissions fraud over bogus policiesAn ICAC investigation earlier revealed that an insurance agent had defrauded an insurer of commissions and bonuses totalling over $1.6 million by making false representations that six clients had taken out various insurance policies. The insurance agent, convicted of fraud after trial, was today (May 27) sentenced to 51 months’ imprisonment at the District Court.Yuki Fan Ting-yan, 49, then financial consultant of AXA China Region Insurance Company Limited (AXA), was earlier found guilty of 12 counts of fraud, contrary to section 16A of the Theft Ordinance.In sentencing, Judge Ms Lily Wong Sze-lai remarked that the offences were serious in nature. The judge reprimanded the defendant for her greediness and breach of the trust placed in her by her employer. The defendant committed a premeditated crime spanning more than a year on several occasions which had brought the insurance industry into disrepute. The judge added that the defendant had not entered a guilty plea and hence would not receive any reduction in her jail term.At the material time, the defendant was a financial consultant of AXA. She would receive a first year commission when an insurance product was sold, and a renewal year commission upon renewal of an insurance policy. She would also receive various bonuses after meeting her sales target.The court heard that between November 2014 and September 2016, AXA received 12 insurance policy applications purportedly taken out by six clients. The defendant signed on the policy applications as the handling agent and falsely represented to AXA that the applications were taken out by those clients. AXA subsequently approved the 12 policies and received the relevant premium payments of the first year or first two years, and released commissions and bonuses in relation to the policies totalling over $1.6 million to the defendant.The ICAC investigation arose from a corruption complaint. Investigation revealed that the six clients did not make the applications and had never paid any premium for the policies. In the end, the insurance policies lapsed after subsequent premiums were not paid.AXA rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel John Marray, assisted by ICAC officer Paul Ho. 27
May 2025Then company manager charged by ICAC guilty of soliciting $3m bribe from business partner for resolving disputeA then manager of a company, charged by the ICAC for soliciting a bribe of $2 million to $3 million from a business partner for assisting the latter to resolve a business dispute between the two companies on terms most favourable to the partner, was today (May 27) found guilty after trial at the Eastern Magistrates’ Courts.Wang Wenning, 65, then manager of China Coal Hong Kong Limited (CCHK, formerly known as Double Resources Limited), was found guilty of one count of agent soliciting an advantage, contrary to section 9(1)(b) of the Prevention of Bribery Ordinance.Magistrate Miss Minnie Wat Lai-man adjourned the case to June 10 for sentence, pending the defendant’s background report. The defendant was remanded in the custody of the Correctional Services Department.The court heard that in 1994, the parent company of CCHK and a business partner jointly invested in a property development project and capital injection was made by CCHK. CCHK subsequently intended to withdraw some of the investment fund from the project but the two parties failed to reach a final agreement. Since 2018, CCHK and the business partner had a dispute over the project. The defendant was assigned to resolve the dispute.The defendant subsequently arranged to meet a director-cum-shareholder of the business partner one-on-one. During the meeting, the defendant told the director-cum-shareholder that he was in urgent need of money for his personal financial problem, and solicited from the latter a bribe between $2 million and $3 million. The defendant claimed that he would assist the latter to resolve the dispute concerned on terms and conditions most favourable to the business partner. However, the business partner rejected the solicitation.CCHK prohibits its employees from soliciting or accepting advantages from others in relation to CCHK’s affairs and business.CCHK and the business partner concerned rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Marc Corlett, assisted by ICAC officer Swing Chan. 26
May 2025Then foreman of airport expansion works subcontractor charged by ICAC admits soliciting and accepting bribes from bar-bendersA then foreman of a subcontractor of the Terminal 2 expansion works of the Hong Kong International Airport, charged by the ICAC, today (May 26) admitted at the West Kowloon Magistrates’ Courts that he had solicited and accepted bribes totalling about $16,000 from three bar-benders for assisting them to continue their employment and assigning overtime work to earn extra payments.Ko Chun-yin, 31, then foreman of Ho Chau & Sons (HK) Engineering Limited (HCL), pleaded guilty to two counts of agent soliciting an advantage and six counts of agent accepting an advantage, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance. The prosecution offered no evidence to three similar charges against him.Magistrate Mr Gary Chu Man-hon adjourned the case to June 9 for sentence, pending the defendant’s background report. The defendant was remanded in the custody of the Correctional Services Department.The court heard that HCL was a subcontractor of the Terminal 2 expansion works of the Hong Kong International Airport at the material time. The defendant was a foreman of HCL responsible for leading a team of bar-benders and assigning work to them. Should workers be required to work overtime, they would be paid 1.5 to two times of the standard hourly rate. HCL prohibited its employees from soliciting or accepting any advantages from others in relation to its business and affairs.Between April 2022 and February 2023, the defendant had respectively solicited from three bar-benders bribes of $100 per working day or an unspecified amount of “tea money” for assisting them to continue their employment with HCL. During the period, the defendant had eventually accepted bribes totalling $6,800 from the trio.The defendant had also solicited from one of the bar-benders bribes of $200 per working day for arranging him to perform overtime work to earn extra payments.The bar-bender reluctantly paid bribes totalling about $6,000 to the defendant for his overtime work on 30 working days.The ICAC investigation stemmed from a corruption complaint. Enquiries revealed that the workers believed that the defendant had the authority to dismiss them. The trio reluctantly paid bribes to the defendant as they worried about losing their jobs. One of the workers was dismissed on the spot after he refused to pay a bribe of $3,000 solicited by the defendant.HCL rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by ICAC officer Moon Leung.An ICAC spokesperson notes that the Commission has zero tolerance for corruption and will continue to collaborate with government departments, public bodies, industry bodies and other relevant stakeholders to prevent similar crimes. Should construction workers be asked to pay bribes in exchange for their employment or continuing their employment, they should reject and report to the ICAC immediately. The ICAC’s report corruption hotline: 25 266 366.
Jun 2025Printing company trio charged by ICAC for concealing conflicting interest in $6.6m delivery services fraudTwo former employees of a printing company and the wife of one of them were charged by the ICAC yesterday (June 3) for allegedly deceiving the company into engaging a relative to provide delivery services and making payments totalling about $6.6 million by concealing conflicting interest for personal gain of about $1.2 million.So Keung, 52, former assistant production manager of Bannershop Hong Kong Limited (Bannershop); his wife Poon Po-lin, 54; and Zhang Haiqi, 33, former delivery section supervisor of Bannershop, jointly face one count of fraud, contrary to section 16A(1) of the Theft Ordinance.The case unfolded in an ICAC investigation arose from a corruption complaint. The defendants were released on ICAC bail, pending their appearance at the Kwun Tong Magistrates’ Courts tomorrow (June 5) for mention. The prosecution will apply for transferring the case to the District Court for plea.Bannershop is engaged in digital printing, graphic design, exhibition decoration and installation. At the material time, So was an assistant production manager responsible for managing the production of printed products while Zhang, being the delivery section supervisor, was responsible for managing the delivery of printed products to customers.In February 2018, upon the recommendation of Zhang, the brother-in-law of the So’s couple was engaged by Bannershop to deliver products to its customers. Zhang would submit the relevant invoices to the company for settling delivery fees.The staff handbook and code of conduct of the company stipulated that staff members were obliged to notify the company where their spouse or sibling held any business negotiation with the company, and that they should avoid conflict of interests.The charge alleges that between May 2018 and January 2022, the three defendants had concealed from Bannershop So’s familial relationship with his brother-in-law and Poon, and defrauded the company to remain engaged with the brother-in-law to provide delivery services and settle delivery fees totalling $6.6 million.ICAC enquiries revealed that Poon’s bank account was arranged to receive payments from Bannershop. While about $5.4 million was transferred to the bank account of the brother-in-law of the So’s couple, So and Zhang received over $800,000 and over $300,000 respectively. So had never declared to Bannershop his familial relationship with his brother-in-law and Poon.Bannershop rendered full assistance to the ICAC during its investigation into the case. 30
May 2025Salesman of groceries supplier charged by ICAC admits fraud over goods worth $12mA then senior sales executive of a groceries supplier, charged by the ICAC, today (May 30) admitted at the District Court that he has made false representations about the orders placed by various clients to induce the supplier to release goods worth totalling over $12 million in nine months and resold them for personal gain.Mak Ka-wing, 46, former senior sales executive of Dah Chong Hong Limited (DCH), pleaded guilty to 32 counts of fraud, contrary to section 16A of the Theft Ordinance.Deputy Judge Ms Stephanie Tsui May-har adjourned the case to July 17 for sentence. The defendant was remanded in custody of the Correctional Services Department.The court heard that at the material time, the defendant was a senior sales executive of DCH’s food trading unit which engaged in the supply of groceries. He was responsible for handling groceries orders placed by clients. Upon receiving a request from a client, DCH would issue an invoice for arranging release or delivery of goods to the client.The ICAC investigation arose from a corruption complaint. Enquiries revealed that in the nine months between August 2020 and April 2021, the defendant had input fictitious orders into the DCH’s computer system and falsely represented that 32 clients had ordered goods from the company. As a result, DCH issued a total of 410 invoices to the clients and arranged goods worth totalling over $12 million to be released.Enquiries also found that the defendant forged signatures of clients on the receipts. He subsequently resold the goods for personal gain, but he only repaid about $280,000 to DCH.DCH rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by Senior Public Prosecutor Douglas Lau, assisted by ICAC officer William Leung. 27
May 2025Insurance agent charged by ICAC receives 51 months’ jail for $1.6m commissions fraud over bogus policiesAn ICAC investigation earlier revealed that an insurance agent had defrauded an insurer of commissions and bonuses totalling over $1.6 million by making false representations that six clients had taken out various insurance policies. The insurance agent, convicted of fraud after trial, was today (May 27) sentenced to 51 months’ imprisonment at the District Court.Yuki Fan Ting-yan, 49, then financial consultant of AXA China Region Insurance Company Limited (AXA), was earlier found guilty of 12 counts of fraud, contrary to section 16A of the Theft Ordinance.In sentencing, Judge Ms Lily Wong Sze-lai remarked that the offences were serious in nature. The judge reprimanded the defendant for her greediness and breach of the trust placed in her by her employer. The defendant committed a premeditated crime spanning more than a year on several occasions which had brought the insurance industry into disrepute. The judge added that the defendant had not entered a guilty plea and hence would not receive any reduction in her jail term.At the material time, the defendant was a financial consultant of AXA. She would receive a first year commission when an insurance product was sold, and a renewal year commission upon renewal of an insurance policy. She would also receive various bonuses after meeting her sales target.The court heard that between November 2014 and September 2016, AXA received 12 insurance policy applications purportedly taken out by six clients. The defendant signed on the policy applications as the handling agent and falsely represented to AXA that the applications were taken out by those clients. AXA subsequently approved the 12 policies and received the relevant premium payments of the first year or first two years, and released commissions and bonuses in relation to the policies totalling over $1.6 million to the defendant.The ICAC investigation arose from a corruption complaint. Investigation revealed that the six clients did not make the applications and had never paid any premium for the policies. In the end, the insurance policies lapsed after subsequent premiums were not paid.AXA rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel John Marray, assisted by ICAC officer Paul Ho. 27
May 2025Then company manager charged by ICAC guilty of soliciting $3m bribe from business partner for resolving disputeA then manager of a company, charged by the ICAC for soliciting a bribe of $2 million to $3 million from a business partner for assisting the latter to resolve a business dispute between the two companies on terms most favourable to the partner, was today (May 27) found guilty after trial at the Eastern Magistrates’ Courts.Wang Wenning, 65, then manager of China Coal Hong Kong Limited (CCHK, formerly known as Double Resources Limited), was found guilty of one count of agent soliciting an advantage, contrary to section 9(1)(b) of the Prevention of Bribery Ordinance.Magistrate Miss Minnie Wat Lai-man adjourned the case to June 10 for sentence, pending the defendant’s background report. The defendant was remanded in the custody of the Correctional Services Department.The court heard that in 1994, the parent company of CCHK and a business partner jointly invested in a property development project and capital injection was made by CCHK. CCHK subsequently intended to withdraw some of the investment fund from the project but the two parties failed to reach a final agreement. Since 2018, CCHK and the business partner had a dispute over the project. The defendant was assigned to resolve the dispute.The defendant subsequently arranged to meet a director-cum-shareholder of the business partner one-on-one. During the meeting, the defendant told the director-cum-shareholder that he was in urgent need of money for his personal financial problem, and solicited from the latter a bribe between $2 million and $3 million. The defendant claimed that he would assist the latter to resolve the dispute concerned on terms and conditions most favourable to the business partner. However, the business partner rejected the solicitation.CCHK prohibits its employees from soliciting or accepting advantages from others in relation to CCHK’s affairs and business.CCHK and the business partner concerned rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by prosecuting counsel Marc Corlett, assisted by ICAC officer Swing Chan. 26
May 2025Then foreman of airport expansion works subcontractor charged by ICAC admits soliciting and accepting bribes from bar-bendersA then foreman of a subcontractor of the Terminal 2 expansion works of the Hong Kong International Airport, charged by the ICAC, today (May 26) admitted at the West Kowloon Magistrates’ Courts that he had solicited and accepted bribes totalling about $16,000 from three bar-benders for assisting them to continue their employment and assigning overtime work to earn extra payments.Ko Chun-yin, 31, then foreman of Ho Chau & Sons (HK) Engineering Limited (HCL), pleaded guilty to two counts of agent soliciting an advantage and six counts of agent accepting an advantage, contrary to section 9(1)(a) of the Prevention of Bribery Ordinance. The prosecution offered no evidence to three similar charges against him.Magistrate Mr Gary Chu Man-hon adjourned the case to June 9 for sentence, pending the defendant’s background report. The defendant was remanded in the custody of the Correctional Services Department.The court heard that HCL was a subcontractor of the Terminal 2 expansion works of the Hong Kong International Airport at the material time. The defendant was a foreman of HCL responsible for leading a team of bar-benders and assigning work to them. Should workers be required to work overtime, they would be paid 1.5 to two times of the standard hourly rate. HCL prohibited its employees from soliciting or accepting any advantages from others in relation to its business and affairs.Between April 2022 and February 2023, the defendant had respectively solicited from three bar-benders bribes of $100 per working day or an unspecified amount of “tea money” for assisting them to continue their employment with HCL. During the period, the defendant had eventually accepted bribes totalling $6,800 from the trio.The defendant had also solicited from one of the bar-benders bribes of $200 per working day for arranging him to perform overtime work to earn extra payments.The bar-bender reluctantly paid bribes totalling about $6,000 to the defendant for his overtime work on 30 working days.The ICAC investigation stemmed from a corruption complaint. Enquiries revealed that the workers believed that the defendant had the authority to dismiss them. The trio reluctantly paid bribes to the defendant as they worried about losing their jobs. One of the workers was dismissed on the spot after he refused to pay a bribe of $3,000 solicited by the defendant.HCL rendered full assistance to the ICAC during its investigation into the case.The prosecution was today represented by ICAC officer Moon Leung.An ICAC spokesperson notes that the Commission has zero tolerance for corruption and will continue to collaborate with government departments, public bodies, industry bodies and other relevant stakeholders to prevent similar crimes. Should construction workers be asked to pay bribes in exchange for their employment or continuing their employment, they should reject and report to the ICAC immediately. The ICAC’s report corruption hotline: 25 266 366.