Li & Fung Limited
Anti-Bribery Policy
Li & Fung Limited Anti-Bribery Policy
September 2012 Page 1 of 7
Li & Fung Limited
Anti-Bribery Policy
1. INTRODUCTION
The foundation of Li & Fungs culture lies in our history and our values. We believe that we
should always conduct ourselves and our business openly, honestly and in compliance with
all applicable laws.
Our reputation is built by the actions of our people and this is why what you do everyday is
so important. We believe that our success should be based on a common vision of shared
values and a consistent standard of conduct.
At Li & Fung, we take a zero-tolerance approach to bribery and are committed to complying
with all applicable anti-bribery laws. This Policy sets out the rules and principles as they
relate to bribery and forms part of our Code of Conduct and Business Ethics. It has the full
support of our Board of Directors.
You should read and understand this Policy and apply it every day. If the laws in your
country are stricter, then you must comply with them in addition to this Policy.
If you have a question on anything related to this Policy, you should speak to your Grade 2
line manager. He or she will raise matters to the Branch Manager, the Hub Manager or the
Group Chief Compliance Officer as appropriate. Alternatively, you can send your query to
[email protected]. We also welcome any suggestions you may have for improving the prevention of bribery in our business.
2. THIS POLICY APPLIES TO EVERYONE IN THE LI & FUNG LIMITED GROUP
This Policy is mandatory for the directors, officers and employees of all Li & Fung Limited
Group companies (Li & Fung Limited and all of its subsidiaries) no matter where they are
located or what their position (collectively, Associates).
This Policy also applies to all non-Li & Fung persons or companies who perform services for
us or on our behalf anywhere in the world. We have called them Business Associates in this
Policy.
The rules and principles under this Policy apply regardless of:
the country in which you or the recipient are located
whether the bribe is promised or given by you personally or by a third person (e.g. by an agent or intermediary)
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September 2012 Page 2 of 7
whether the bribe is received by the recipient or through another person (e.g. a family member or a friend of the recipient)
local custom / locally acceptable practice
the value of the bribe
whether the decision relevant to the business of the company has already been made (e.g. where the bribe is a reward for a decision already made).
The reason why this Policy has application worldwide is that some anti-bribery laws (such as
the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977) apply beyond their
national borders and to corporate entities from other countries. As a result, complying with
local anti-bribery laws alone will not necessarily ensure full legal compliance.
3. WHAT IS BRIBERY?
Bribery is when a person offers, promises or gives another person a benefit directly or
indirectly (e.g. through a third party) intending that benefit to influence that person to
perform their job improperly, or as a reward for doing so. Asking for, agreeing to receive or
accepting such a benefit is also bribery. It doesn't matter if the bribe is offered or accepted
by a third party. It is still a bribe.
The benefit does not need to be in the form of cash - it can be any type of advantage. Some
examples are: gifts, meals or sports tickets, travel expenses, discounts, rebates, kick-backs,
donations, preferential treatment and favours.
Bribery laws concerning public officials are even stricter - providing a benefit to a public
official can be bribery even if no misconduct or improper motive is involved. Consequently,
great care needs to be taken when dealing with public officials. Please refer to the Guidance
Notes for further guidance on who are public officials.
Examples of bribery include:
a payment from a factory to clear goods for shipment to the customer
a payment to a building inspector official to encourage him to overlook the lack of a fire permit
a payment made through a customs broker to a customs official for the release of goods
an expensive gift to an employee by a telecom company after LF awards a contract to that company
requesting or accepting a payment from a factory in return for placing an order with the factory
free stays at a luxury hotel for arranging a conference at the hotel's facilities
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September 2012 Page 3 of 7
We take a zero-tolerance approach to bribery.
In many countries, it may be customary business practice to make small payments or give
small gifts to junior public officials in order to speed up or secure a routine action or process
to which the payer is entitled. These are sometimes known as "facilitation" or grease"
payments. You should be aware that facilitation or grease payments are bribes.
4. WHAT ARE THE RULES?
(a) You must NOT offer, promise or give a benefit of any kind to a person if that benefit
is intended to or is likely to influence him or her to perform their job improperly or
to reward such improper performance.
(b) You must NOT ask for, agree to receive or accept such a benefit.
(c) You must NOT give or accept gifts or hospitality unless it is consistent with our
Guidelines on Gifts, Entertainment and Hospitality.
(d) You must NOT give gifts or hospitality where you know or suspect that they would
violate the recipient's own internal rules, guidelines or policies.
(e) You must NOT offer or make facilitation payments. Any request for a facilitation
payment must be reported as soon as possible to your Grade 2 line manager.
(f) You must keep accurate financial and business records see paragraph 6 below.
5. HOW DO I RAISE CONCERNS?
You have a responsibility to help prevent bribery and to raise concerns about any behaviour
that may amount to bribery. If you come across something that may amount to bribery (by
another Associates or by a non-Li & Fung person), you must report it at the earliest possible
time. Raising concerns early may help us address problems before they result in serious
consequences.
As an initial step, you should report your concern to your direct line senior management in
writing or by telephone. If for whatever reason, you:
feel that you cannot speak with your direct line senior management about your concern or complaint; or
consider that your concern or complaint has not been handled by your direct line senior management properly; or
prefer to make the report anonymously,
you can direct your concern and provide all the relevant information and supporting
documents you have to the Group Chief Compliance Officer by e-mail at
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September 2012 Page 4 of 7
([email protected]), by post (to 1/F, LiFung Tower, 888 Cheung Sha Wan Road,
Kowloon, Hong Kong) or by fax (+852 3165 6295).
Please take a look at our Reporting of Concerns Guidelines as posted on our OneFamily
intranet site. These Guidelines include multiple channels to raise concerns, including
anonymous reporting.
The Li & Fung Limited Group does not tolerate retaliation of any kind against Associates who
raise genuine concerns or who participate in the investigation of a report of suspected
misconduct. If you engage in retaliation you will be subject to disciplinary action, which may
include the termination of your employment.
6. WHAT ARE THE CONSEQUENCES IF YOU COMMIT AN ACT OF BRIBERY?
Li & Fungs continued success is dependent on its reputation and this reputation is
dependent on the actions of its people. If you commit an act of bribery, you will bring the
entire Li & Fung into disrepute. In other words, your action impacts all of us.
There are very serious consequences for bribery.
For you:
disciplinary action (which will result in your dismissal or termination of your employment)
criminal sanctions by governmental authorities (which includes imprisonment and unlimited fines in many jurisdictions)
For the Company:
criminal sanctions by governmental authorities including unlimited fines
serious reputational damage
high value breach of contract claims by third parties
blacklisting from public and private tendering opportunities
termination of contracts by our counterparties
further criminal sanctions for money-laundering offences
Full compliance with this Policy at all times is therefore extremely important.
7. RECORD-KEEPING
We must keep accurate financial and business records that reflect our business dealings. If
we dont, such failure (whether it was intentional or not) may result in our business breaking
the law and being subject to severe penalties. Accordingly, an employee's failure to report
Li & Fung Limited Anti-Bribery Policy
September 2012
