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These Contractor Terms and Conditions (“Terms”) is entered into by Project Recruit HK Limited (“PRHK”), Rm 136, 8/F, Eton Tower, 8 Hysan Avenue, Causeway Bay, Hong Kong and the individual or Limited Company stated in the associated SOW, hereinafter the “Contractor”.
DEFINITIONS
“Assignment” means the assignment specified in the SOW
“Client” as for whom the final services will be received as detailed in the SOW
“Terms” the contractual agreement between both parties formed by the signing of the SOW associated (via the hyperlink in the SOW) with these terms and conditions
“Contractor” Limited Company or Self-Employed individual
“Services” services agreed to be provided by the Contractor to PRHK
“SOW(s)” (Statement of Works) means the purchase order or such other document issued by PRHK to the Contractor confirming the Contractor’s Assignment with the Client including the details which are set out in the SOW. The SOW is associated with these terms via a hyperlink specified in the SOW
“Day(s)” a working day not including national or bank holidays or weekends (the Hong Kong workday calendar will be used as the international reference point).
IT IS HEREBY AGREED as follows:
1. Orders
1.1 All orders placed by PRHK for the Contractor will be confirmed with a SOW setting out the full details of the services of these terms and conditions of business. SOW’s can be in the form of email, text or electronic signature application from a PRHK employee.
1.2 The Contractor agrees to accept email as a method by which PRHK can communicate business requirements and services. All communication using this method will be sent to the email address supplied by the Contractor at registration.
2. Relationship
Relationship between Contractor and Project Recruit HK Limited
2.1 PRHK will engage the services of the Contractor on a demand basis only. This will result in work being carried out over a variety of working hours or days depending on the specific requirements of the SOW.
2.2 Contractor will not at any time be deemed as, or treated as, employee of PRHK or any client of PRHK. Neither PRHK nor the Contractor will consider their partnership as “exclusive” and as such will not enjoy a preferred status.
2.3 It is understood that the Contractor will be self-employed or a Limited company. Accordingly, PRHK will not at any time be liable for any local employment taxation or National Insurance (or similar local equivalent) liabilities arising on the Contractor as a result of completing any work for PRHK pursuant to these terms and conditions.
Reporting Relationship
2.4 The Contractor may receive an order directly from the Client on where the services are required. All orders will be confirmed in SOW that will be sent by PRHK. Stories and correspondence will be submitted by the Contractor directly to the Client.
2.5 The Contractor shall follow Client’s instructions as to the style and format of Work Product. The Contractor understands and agrees that Client may, in its discretion, revise, edit, change, and use Work Product and may use Work Product alone or in combination with other written or graphic content.
2.6 Contractor agrees to:
a.) provide Client with any notes, research, recordings or other newsgathering material, whether obtained on or off the record, on a timely basis for the purpose of fact-checking or otherwise editing the Work Product to Client standards,
b.) disclose to Client, prior to submission of the Work Product, any familial, contractual, fiduciary or financial relationship to any entities appearing in the Work Product or that could reasonably be expected to give rise to a perception of bias or self-interest,
c.) disclose to Client whether Contractor received or was promised any remuneration or any other form of consideration by a third party in connection with the Work Product,
d.) disclose to Client similar services or like tasks Contractor has or will perform for other organizations including but not limited to work performed for other news organizations or the publication of a book; and
e.) not provide to any third party any draft or prepublication version of the story and will treat all communications with Client editors as strictly confidential.
3. Expenses
3.1 For detailed information please refer to a SOW and Expense Policy attached to these Terms
3.2 Accurate expense claims must be submitted before month end for payment in the proceeding month
4. Contractor’s Warranty and Indemnity
4.1 The Contractor is aware that PRHK’s mission is to provide “Service with Integrity and Professionalism” and agrees to obtain knowledge of and comply with all PRHK’ procedures and work instructions, which form part of its commitment to provide the highest levels of quality and service to customers.
4.2 The Contractor shall indemnify and keep PRHK indemnified against:
a) Any claims made against PRHK by any third party (including for the avoidance of doubt any Client of PRHK or any person engaged by that client) relating to the order set out in the SOW including, without limitation, all costs, damages, fees, judgment, expenses, and liability whatsoever incurred by PRHK in relation to any such claim.
b) All actions, proceedings, costs, claims, demands, awards, fines, orders, and liabilities whatsoever arising in connection with the Contractor’s provision of service pursuant to the SOW.
5. Payment Terms
5.1 Payments shall be made in US dollars or the agreed currency, subject to an authorized invoice or approved expense claim. Payment will be made within 14 days from the Friday of the week in which the invoice is approved for payment by PRHK’s Client. Payment shall only be processed upon submission of a valid corresponding invoice. The rate may be amended by Client upon written notice from time to time.
a) An authorized timesheet has been received and matches the Contractor invoice for authorized and accepted work as set out in the SOW.
b) The invoice and authorised timesheet are received by the first Monday of the first full week of any month.
5.2 PRHK shall be entitled to withhold or reduce any payment due to the Contractor in relation to the following:
a.) Any liability arising directly or indirectly from the Contractor’s breach of any provision of these terms and conditions of business as notified in writing by PRHK to the Contractor;
b.) Any damages suffered by PRHK and notified to the Contractor in writing pursuant to clause 2 of these terms and conditions of business;
c.) The Contractors acknowledgment (whether by credit note, verbal or written confirmation) that PRHK are entitled to withhold or reduce a payment;
d.) Any instance where PRHK shall be required to make a payment to a third party as a result of the Contractor’s breach of these terms and conditions of business.
5.3 Invoices submitted by the contractor after 60 days of completion of a project will not be paid by PRHK.
6. Price
The price at which subcontracted services are agreed between the parties, are contained in the SOW. The payment will be made in HKD
unless stated otherwise.
7. Termination
7.1 Either party giving the other party in writing the period of notice specified in the SOW may terminate an Assignment. Either party may terminate these Terms and any active SOW(s) by providing the greater of thirty days or as required under local law notice to the other party.
7.2 Notwithstanding sub-clauses 7.1 and 7.5 of these Terms, where required by the Client, PRHK may without notice and without liability instruct the Contractor to cease work on any assignments at any time, where:
a.) The Contractor has acted in breach of the rules, regulations, and policies applicable to the Client’s own staff that are applicable to independent contractors;
b.) The Client reasonably believes that the Contractor has not observed any condition of confidentiality applicable to the Contractor from time to time;
c.) The Contractor becomes insolvent, dissolved, or subject to a winding up petition;
d.) For any reason, the Contractor proves unsatisfactory to the Client.
7.3 Failure by the Contractor to give notice of termination as required in the SOW shall constitute a breach of contract and shall entitle PRHK to claim damages for the length of the breached notice period from the Contractor for any resulting loss suffered by PRHK.
7.4 If the Contractor is unable for any reason to provide services for an Assignment, the Contractor should inform PRHK by no later than 8.00am on the first day of absence to enable alternative arrangements to be made.
7.5 The Contractor acknowledges that the continuation of an Assignment is subject to and conditioned by the continuation of the contract entered into between PRHK and the Client. In the event that the contract between PRHK and the Client is terminated for any reason, the Assignment shall cease with immediate effect without liability to PRHK.
8. Complete Agreement
8.1 This agreement is the entire agreement between the parties and any special terms and conditions are as specified in the SOW. All changes hereto are to be in writing and agreed between the parties.
8.2 If any provision of these terms and conditions of business is held by any Court or other competent authority to be invalid or unenforceable in whole or in part, the validity of the other provisions of these terms and conditions of business and the remainder of the provision in question should not be affected.
9. Confidentiality
9.1 By entering into this contract, the Contractor may from time to time be made aware of confidential information.
9.2 PRHK regards the following categories of information as examples of material that would be considered as confidential:
a.) Client lists or individual names
b.) Pricing and rates structure
c.) Supplier agreements
d.) Technical developments
e.) Employee records and financial records
f.) Written content produced by the Contractor for any Client
g.) Instructions from Clients or PRHK to the Contractor
h.) Any unpublished newsgathering material, details of any advertising, marketing or promotional campaign which Client is to conduct; any information relating to expansion plans, business strategy, marketing plans and sales forecasts of Client; details of the employees and officers of Client; confidential reports or research commissioned by or provided to Client; all trade secrets or other confidential or proprietary information owned, developed, or possessed by Client or its affiliates pertaining to its business or business relationships
The above list is a guide and is not intended to be exhaustive. Neither party shall make any separate public statements regarding these Terms or any of its contents without the prior written consent of the other party. These restrictions shall continue to apply after the termination of these Terms without limitation in time but shall cease to apply to any information or knowledge that subsequently comes into the public domain, other than by way of unauthorized disclosure by Contractor.
9.3 As a condition of this contract, the Contractor will not, during the continuance of this contract, nor after the termination thereof, disclose or in any way make use of or benefit from any of the confidential knowledge, financial or other information including but not limited to the information referred to in paragraph 9.2, or any other products or systems of PRHK, its parent, or associated companies or any other organisation or individual with whom their work brings them into contact.
9.4 All notes, memoranda or any other material whatsoever relating to the business of PRHK shall remain the property of PRHK and shall together with any copies be returned to PRHK on demand and in the event of the termination of this contract.
9.5 The Contractor’s attention is drawn to the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (PDPO). Any data relating to living individuals whether or not employed by PRHK, which is processed or held by the Contractor during PRHK’ business, must be regarded as confidential. It must not be disclosed to any unauthorized person or used for any purpose for which its use is not registered under the above Act.
10. Non-Waiver
10.1 A waiver by PRHK of a breach of a provision of these terms and conditions of business should not be considered as a waiver of a subsequent breach of the same or another provision;
10.2 The rights to terminate these terms and conditions of business given by clause 8 shall not prejudice any other right or remedy of PRHK in respect of the breach concerned or any other breach;
10.3 On termination of these terms and conditions of business for any reason, subject as otherwise provided in these terms and conditions of business and to any rights or obligations which have accrued prior to termination, neither party shall have any further obligation to the other under these terms and conditions of business.
11. Status and Tax Liability
11.1 Contractor acknowledges that it is engaged as an independent Contractor, and Contractor acknowledges, and shall procure that its Personnel acknowledge, that nothing in these Terms shall constitute or suggest a relationship of an employee, agent, director, or partner of PRHK and/or Client; and Contractor and Personnel are therefore not eligible for the benefits provided by PRHK or Client.
11.2 This agreement constitutes a contract for the provision of services and not a contract of employment and accordingly the Contractor shall be fully responsible for and shall indemnify PRHK for and in respect of:
a) Any income tax, statutory contributions (local equivalent) and any other liability, deduction, contribution, assessment or claim arising from or made in connection with either the performance of the Services or any payment or benefit received by the Individual in respect of the Services, where such recovery is not prohibited by law. The Contractor shall further indemnify PRHK against all reasonable costs, expenses and any penalty, fine or interest incurred or payable by PRHK in connection with or in consequence of any such liability, deduction, contribution, assessment or claim;
b) Any liability arising from any employment-related claim or any claim based on worker status (including reasonable costs and expenses) brought by the Individual or any Substitute against PRHK arising out of or in connection with the provision of the Services.
11.3 PRHK may at its option satisfy such indemnity (in whole or in part) by way of deduction from payments due to the Contractor.
11.4 Neither Contractor nor any Personnel have authority to, and Contractor shall not, and shall ensure that none of its Personnel shall, make any representations or incur any liability or enter into any contracts or arrangements involving either PRHK or Client in any financial or other commitments.
11.5 These Terms does not appoint Contractor or Personnel as agent of either PRHK or Client, nor does it create any partnership or joint venture or in any manner operate to create any obligation on PRHK or Client in respect of any liability of Contractor or Personnel.
11.6 Contractor shall indemnify PRHK and/or Client in respect of any claims that may be made against either of them by any person, firm, company, or government agency relating to the provision of Services by Contractor under these Terms.
11.7 These Terms shall not constitute a contract of employment for any purposes whatsoever, and Contractor will be solely responsible for National Insurance contributions for any Personnel, and for all or any taxes payable in respect of fees and reimbursements paid under these Terms and will indemnify PRHK and/or Client in respect of any claims that may be made against either of them by the relevant authorities.
11.8 During the continuance of these Terms, Contractor shall, and shall procure that its Personnel shall (unless prevented by accident or ill-health) devote such of its time, attention, and abilities to the business of PRHK as may be necessary for the proper provision of its Services as Contractor or Personnel. However, this will not prevent Contractor or Personnel from acting in a similar or any other capacity for any other person, firm, or corporation (but subject to the confidentiality and restriction clauses in these Terms).
11.9 Contractor shall not, and shall procure that none of its Personnel shall, make any recommendations to a Client which would benefit or involve any third party in which the Contractor or Personnel or any person connected with either of them has a financial interest or material interest, unless it has fully disclosed such interest to PRHK and the Client and PRHK gives its written consent. All contractual protections granted to or reserved in these Terms by PRHK, including warranties, limitation of liabilities, remedies, indemnification, and confidentiality, shall accrue to and are for the benefit of Client.
11.10 These Terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the law of England and Wales.
11.11 Each party irrevocably agrees that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms or its subject matter or formation.
SCHEDULE 1
CRIMINAL DISCLOSURE / CONFIDENTIALITY / PDPO
To be completed by all Contractor Personnel who will access client data or premises
The Contractor shall disclose any past or pending criminal convictions prior to the commencement of any engagement under this Agreement. Such disclosure shall form part of the Contractor’s representations and warranties to the Company. All disclosed information shall be treated with the strictest confidentiality and shall be collected, used, and processed solely for the purpose of assessing the Contractor’s suitability for engagement.
Project Recruit HK Limited shall handle all such information in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and all other applicable laws of the Hong Kong Special Administrative Region.
Project Recruit HK Limited may take reasonable steps to verify the accuracy of the disclosed information, which may include requesting that the Contractor provide a Certificate of No Criminal Conviction or other supporting documentation from the Hong Kong Police Force, but only after the Contractor has been shortlisted or conditionally engaged, and only upon obtaining the Contractor’s freely given, specific, and informed written consent.
Any failure to disclose relevant criminal history, or any intentional misrepresentation or omission by the Contractor, shall constitute a material breach of this Agreement and may result in immediate termination of the engagement, forfeiture or withholding of compensation for incomplete or rejected deliverables, and any other remedies available under applicable law or this Agreement.
Project Recruit HK Limited acknowledges that any disclosed criminal history shall be evaluated on a case-by-case basis, taking into account the nature and seriousness of the offence, time elapsed since conviction, relevance to the engagement, evidence of rehabilitation, and overall context.
Do you have any convictions other than those that are considered “spent” (if applicable)?
If Yes, please state these on the associated SOW
Confidentiality
As a supplier to PRHK I shall:
Personal Data (Privacy) Ordinance (PDPO)
The Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) governs the collection, use, storage, and disclosure of personal data in Hong Kong. PRHK is responsible for ensuring that any personal data held by us is accurate, relevant, not excessive, and, where necessary, kept up to date. All personal data will be collected, used, retained, and disclosed fairly and only for legitimate purposes directly related to the operation of our business and the management of your engagement, in accordance with the requirements of the PDPO.
As a contractor, you have the right under the PDPO to request access to and correction of your personal data that is held by us.
To enable PRHK to keep you informed and updated by letter, email, text message, or phone, we seek your consent to be contacted through these communication channels for administrative, operational, and engagement-related purposes.
Disclosure Declaration
In accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”), I give my express consent to the following:
(a) PRHK may disclose relevant contents of my personnel file to authorised employees, agents, or clients strictly for legitimate business, operational, engagement-related, or employment-related purposes. (b) PRHK or the client to verify any of the details provided in my application or personnel records; and
(b) PRHK or the Client may verify any of the information provided by me in my application, onboarding documents, or personnel records, including through independent third-party verification where appropriate and with my consent where required by law.
(c) PRHK may retain copies of background verification records, supporting documents, or equivalent certifications where applicable, for compliance, audit, operational, or statutory purposes and only for as long as is necessary for those purposes or as required under applicable law.
All personal data will be collected, used, stored, retained, and disclosed in accordance with the PDPO, and only for purposes directly related to my engagement, assignment, or employment with PRHK.
SCHEDULE 2
STANDARDS AND SAFEGUARDS
To be completed by all Contractor Personnel who will access client data or premises
Quality Charter
To provide the best service to you and our clients we require everyone who works with us to agree to the following conditions:
Policy Statement on Equal Opportunities
Diversity and Equal Opportunity is about those human qualities that are different from our own and outside the groups to which we belong. Diversity not only includes race, ethnicity, and gender, but also ability/disability, education, age, class, and many other differences.
PRHK is committed to a policy of equal opportunities for all. We do not discriminate on grounds of race, colour, creed, ethnic or national origin or on grounds of sex, marital status, disability, or age.
It is the specific responsibility of all representatives of PRHK, to ensure that this policy is fully implemented, and they are aware of their responsibilities and the legal obligations that fall upon them and upon this company. All representatives of PRHK will comply with the legislation relating to sex and race discrimination. Discrimination against any person on the grounds of their ethnic origin, their sex or marital status will be regarded as serious misconduct and may result in dismissal.
Company Property and Copyright
All written material, whether held on paper, electronically or magnetically which was made or acquired by you during the course of your contract with us, is the property of our Client and, where appropriate, either the Client’s or our copyright. At the time of termination of your contract with us, or at any other time upon demand, you shall return to us any such material in your possession.
Any work produced and submitted by you to the Client shall be the property of the Client. Any work produced and submitted by you to the Client is work made for hire under applicable copyright laws, specially commissioned by Client. Any contribution you make to the work and all rights, title, and interest in the copyright thereon shall be the sole and exclusive property of the Client and shall be copyrighted solely in the name of the Client. To the extent that the work is not considered a work for hire, you assign to the Client the ownership of such work, including but not limited to, all copyright and intellectual property rights. These rights include, but are not limited to, the sole and exclusive right to print, publish, sell, copy, distribute, and license others to use the work in any form or medium, now, or hereafter existing, or in any language, during the full term of the copyright therein and throughout the world.
Password Protection
Passwords are an important aspect of computer security. A poorly chosen password may result in unauthorised access and/or exploitation of a company’s resources. All Contractors with access to company systems are responsible for taking appropriate steps to select and secure their passwords. Passwords must not be shared with anyone. All passwords are to be treated as sensitive, confidential information.
Monitoring
We reserve the right to monitor all email/IM and Internet activity on the PRHK or client network by you for the purposes of ensuring compliance with our policies and procedures and of ensuring compliance with the relevant regulatory requirements, and you hereby consent to such monitoring. Information acquired through such monitoring may be used as evidence in disciplinary proceedings.
Use of Social Networking Sites
Any work-related issue or material that could identify an individual who is a client or work colleague, which could adversely affect the Company, a client, or our relationship with any client, must not be placed on a social networking site. This means that work-related matters must not be placed on any such site at any time either during or outside of working hours and includes access via any computer equipment or mobile device.
SCHEDULE 3
ANTI-BRIBERY / WHISTLE BLOWERS POLICY AND PERSONAL HARRASSMENT POLICY
To be completed by all Contractor Personnel who will access client data or premises
ANTI-BRIBERY POLICY
Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us, and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by associates or by third parties acting for or on behalf of the Company.
Policy
It is prohibited, directly or indirectly, for any associate or person working on our behalf to offer, give, request or accept any bribe, i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or Company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
Suspicion
If we suspect that you have committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may result in the cessation of our business arrangement with you.
Reporting
If you, as an associate or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to your PRHK contact. You may be asked to give a written account of events.
Gifts and Hospitality
We realise that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly. As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.
WHISTLE BLOWERS POLICY
Under certain circumstances, associates are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work.
Qualifying Disclosures
The Procedure
Treatment by others
Bullying, harassment, or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.
PERSONAL HARRASSMENT POLICY
Policy
Examples of Personal Harassment
Personal harassment takes many forms, and associates may not always realise that their behaviour constitutes as harassment. Personal harassment is unwanted behaviour by one associate towards another and examples of harassment include:
These examples are not exhaustive and disciplinary action at the appropriate level will be taken against associates committing any form of personal harassment.
SCHEDULE 4
ANTI-MONEY LAUNDERING (AML) AND COUNTERING THE FINANCING OF TERRORISM (CFT) POLICY
To be completed by all Contractor Personnel who will access client data or premises
These Anti-Money Laundering (“AML”) and Counter-Terrorist Financing (“CFT”) Policy and Procedures are adopted by PRHK in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”), the Organized and Serious Crimes Ordinance (Cap. 455) (“OSCO”), the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405) (“DTROP”), and the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575) (“UNATMO”) of Hong Kong, as well as applicable regulatory guidance.
PRHK is committed to preventing its business operations, services, systems, and personnel from being used for money laundering, terrorist financing, or any other illicit financial activity. PRHK will implement appropriate and proportionate measures to identify, assess, and mitigate related risks in accordance with applicable laws, regulatory requirements, and best-practice guidelines issued by competent authorities in Hong Kong.
All Contractor Personnel must familiarise themselves with and comply with PRHK’s AML/CFT requirements, including any training, reporting obligations, and internal procedures communicated by PRHK.
To these ends:
AML Procedures
The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing Contractors are verified to a reasonable level of certainty. This will include all individual clients, all directors and shareholders with a stake holding of 25% or more of client companies, all partners of client partnerships, and every board member of client charities. Identities will be verified either online or face-to face or by a combination of both.
The following documentation may be presented by the individual:
In person
Not in person
As in person but additionally:
Other forms of identity confirmation, such as evidence of a long-standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty.
If the business fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.
2. RISK ASSESSMENT AND ONGOING MONITORING
The business shall take a risk-based approach in monitoring the financial activities of its clients. This will be carried out whilst preparing the accounts or tax returns or conducting any other business with the client. The business will actively not accept high-risk clients that are identified as follows:
The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date, or information held evidencing the customer’s identity are kept up to date.
The following are examples of changes in a client’s situation that may be considered suspicious:
A sudden increase in business from an existing customer;
Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners. No action need be taken if there is no cause for suspicion.
3. MONITORING AND MANAGING COMPLIANCE
PRHK will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:
PRHK will also monitor any developments in the MLR and the requirements of the MLR supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance.
4. SUSPICIOUS TRANSACTION REPORTING
In Hong Kong, a Suspicious Transaction Report (STR) will be filed with the Joint Financial Intelligence Unit (JFIU) of the Hong Kong Police Force as soon as there is knowledge or reasonable suspicion that any transaction may involve the proceeds of criminal conduct, money laundering, or terrorist financing.
PRHK is responsible for assessing whether a suspicion of illegal or suspicious activity is sufficient to warrant the submission of an STR. All Contractor Personnel and staff are required to immediately report any such suspicions to the designated Compliance Officer or management representative.
Further guidance on STR submission and procedures can be found on the JFIU website:
https://www.jfiu.gov.hk
5. RECORD-KEEPING
Records of all identity checks will be maintained for up to 5 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data, or information held in evidence of customer identity are kept up to date.
Copies of any STR, together with any supporting documentation filed will be maintained for 5 years from the date of tiling the STR.
All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.
SCHEDULE 5:
TRAVEL AND EXPENSE POLICY
This policy is designed to provide Expense reimbursement requirements with our Client.
GENERAL REQUIREMENTS
FLIGHTS
RAIL
GROUND TRANSPORTATION
CAR RENTAL AND PERSONAL CAR USAGE/MILEAGE REIMBURSEMENT
HOTELS
MEALS
(Last updated: 17 October 2025)
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