Anti-Bribery And Corruption Statement

Effective Date: December 2023

Zero tolerance for Bribery and Corruption

We strive to support our employees in avoiding the potential impact of intentional and unintentional bribery involvement, whether as the recipient or offeror, in upholding the integrity of our company’s reputation.

All Edifice employees and third parties acting for and on behalf of Edifice at every level of the organisation are expected to always do business under the values and behaviours of 

Edifice has a zero-tolerance policy for bribery and corruption in all forms. This means no bribery is accepted, whether it involves giving or receiving bribes inside or outside Hong Kong and in any country’s public or private sector. Edifice will not engage in business relationships that may expose it to corrupt, fraudulent, or illegal activities.

A close-up of a logo Description automatically generated in all of our interactions and business engagements, we are dedicated to conducting business with integrity, wisdom, and accountability in our

Edifice has implemented thorough procedures, robust systems, and controls to identify and prevent financial crime, including bribery and corruption. Its employees are trained to recognize and assess financial crime risks, and these risks are regularly taken into account when determining whether to establish business relationships. Special attention is given when engaging with:

foreign public officials;
intermediaries such as introducers, distributors, and
investor or suppliers.

In such cases, Edifice may require anti-bribery and corruption clauses in relevant contracts and may also wish to investigate the adequacy of its counterparties’ anti-bribery procedures and controls.

Edifice operates to the highest standards of honesty and integrity and expects its business partners to observe the same standards in all business dealings with Edifice.

Edifice does not, and will not, accept and pay bribes or offer improper inducements or anything that could be perceived as such. We expect the same level of integrity from our counterparty, customers, business partners, and third parties that perform services or deliver business on our behalf. This mutual understanding and compliance are crucial for maintaining our ethical business standards.

Edifice Anti-Bribery and Corruption Policy obligations include the following:

All forms of bribery and corruption, including facilitation payments, are strictly prohibited.
Gifts and entertainment should always be reasonable and proportionate, serve a legitimate purpose, and not create a conflict of interest or the perception of one. Cash or cash equivalents as part of gifts and entertainment are not allowed.
Employees and third parties may not donate to political parties or offer gifts or entertainment to candidates campaigning for political positions on behalf of Edifice.
Paid and unpaid internships and secondments should only be offered merit-based.
Senior management plays a crucial role in establishing a positive tone at the top, which helps promote a work culture where bribery and corruption are not tolerated.

1. Public officials

Business engagements involving public officials or state-owned entities are subject to increased scrutiny and stricter regulations, including the need for pre-approvals and lower thresholds for gifts and entertainment.

2. Travel and accommodation

Travel and accommodation must not be offered or accepted as part of hospitality.

3. Charitable contributions

Charitable contributions should be directed only to legitimate charitable organizations to ensure that they are not utilized to disguise a bribe.

4. Recording and registration

All third-party payments should be accurately recorded and monitored in Edifice’s books.
All gifts and entertainment must be accurately registered in Edifice’s hospitality register(s).

5. Promoting a culture of open communication and encouraging reporting

Employees and third parties representing Edifice are expected to promptly report any potential or actual breaches to management or use the designated whistleblower reporting channels.

Edifice Global Markets Limited: Effective Date: 14th December 2023

- End of Statement -