Business Ethics and Integrity


The Group places great importance on upholding a strong sense of integrity and ethical behaviour in all aspects of our business operations. Our longstanding reputation for honesty, trustworthiness and fair play is an asset that contributes to our long-term growth and prosperity. Our company policies address various areas such as fair labour, conflicts of interest, bribery, competition and antitrust, privacy compliance and equal opportunity. Every colleague of the Group is required to fully adhere to the company policies and acknowledge their understanding of its contents in writing upon joining the company.

We are dedicated to maintaining the highest standards of business ethics in order to prevent unethical labour practices, corruption, bribery and conflicts of interest throughout our entire value chain. To ensure this, we have implemented various P&P, such as the Bribery and Illicit Advantage P&P, the Conflict of Interest P&P, the Advantage Entertainment P&P, the Anti-Money Laundering and Counter-Terrorists Financing P&P and the Whistle-blowing P&P. These policies outline the reporting requirements for handling any issues in a proper and timely manner. They are included in our Code of Conduct and Staff Handbook and are provided to all new hires as a guide for making ethical decisions and to emphasise our zero tolerance for corruption.

During the Reporting Period, we dedicated 993 hours to compliance and anti-bribery training for our colleagues, reinforcing our firm stance against bribery and no material non-compliance incidents regarding corrupt practices were identified. The Group was also not aware of any violations of regulations on child and forced labour, bribery, extortion, fraud and money laundering, including, but not limited to, the Employment of Children Regulations and the Prevention of Bribery Ordinance.



Colleagues Completed the Anti-corruption Training


0 Non-compliance

Number of Significant Fines or Non-Monetary Sanctions for Non-compliance with Environmental, Health and Safety Laws and Regulations


Ensuring the safety and efficiency of our business operations is our utmost priority, which is why we prioritise cybersecurity. Our Information Security P&P is designed to assist colleagues in protecting information from unauthorised access and guaranteeing its confidentiality. According to our Information Security P&P, all colleagues, including third parties, have a responsibility to safeguard our information and assets. Managers are also responsible for implementing appropriate control measures, both physically and electronically, to ensure information security aligns with the required levels.

During the Reporting Period, we provided 2,034 hours of online Information Technology (“IT”) security training sessions to our colleagues to enhance their awareness of cybersecurity. No incidents about material cybersecurity failure were identified.


Data Privacy & Intellectual Property

Under the Group’s Personal Data Privacy Policy and Procedures, any inquiries or requests related to personal data and privacy, our business units should reach out to the designated Personal Data Officer. The Personal Data Officer will then coordinate with the Legal Department for necessary review and advice. Additionally, when collecting personal data, business units must provide a Personal Information Collection Statement (“PICS”) to ensure customer privacy. In addition, we fully comply the Personal Data (Privacy) Ordinance and any other regulation on data privacy, with which the Group was unaware of anynon-compliance.

During the Reporting Period, the Legal Department reviewed and advised on one PICS submitted by business units regarding their collection and use of personal data and no incidents of material non- compliance were identified. We will continue handling our customers’ data with great care and working relentlessly to protect their privacy.

In addition, we are committed to safeguarding our intellectual property. Our colleagues are required to follow the Information Security policy, which outlines the proper and safe way of utilising information technologies, when using and handling any mobile devices that contain any intellectual property of the Group. We have also established the IT Policy and Procedure for the operations of Nina Hospitality, and it mandated how licensed software should be used, processed and managed. Our colleagues are required to report any non-compliance cases or infringement of intellectual property to the relevant departments.

Ensuring High-Quality Products and Services

We are highly committed to delivering products and services of high quality, as maintaining great customer satisfaction has always been our top mission. A set of rigorous quality assurance procedures have been established for many of our products and operations. We have implemented the “Minimum Quality Service Standards” to ensure the operations and handling of our hospitality and catering services would follow predefined criteria that covered, e.g., front desk, guest rooms, recreational facilities, catering and restaurant operations, and meet a consistently high level of quality. We have also adopted a series of service pledges that ensure the delivery of excellent property management services in regards to utilities, repairment, responses to emergencies and other aspects.


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