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ALVA HOTEL BY ROYAL (the “Hotel“) is committed to delivering highest possible quality service to customers and stakeholders, upholding a high level of integrity, and adhering to good corporate governance standards. Accordingly, the Hotel is dedicated to compliance with Hong Kong’s competition law and policy regime, which promotes fair competition and a level playing field for the benefit of both businesses and consumers in Hong Kong.
The Hotel will not engage in activity that has the effect of unlawfully limiting competition. All forms of anti-competitive or deceptive conduct or unfair advantage through manipulation, concealment, collusion, misrepresentation of material fact or otherwise are strictly prohibited.
Employees of the Hotel are encouraged to compete vigorously in the marketplace; however, each employee has the responsibility to comply with and promote competition law, and encourage their business partners to do so. It is the policy of the Hotel that all employees should be vigilant of situations where competitors and/or suppliers appear to be behaving in an anti-competitive manner and report suspected infringements according to this compliance policy or the competition law compliance code of conduct of the Hotel.
In addition to the general commitment of the Hotel to adhere to all applicable competition law and policy regimes on competition, the Hotel strives to uphold the following key fair competition principles:
A set of competition law compliance code of conduct containing further detail on applicable competition rules is developed and available for the Hotel. Employees of the Hotel are expected to familiarise with and adhere to the code of conduct, including revisions as may be made from time to time.
The Hotel has appointed specific personnel in the management of the Hotel to act as the Hotel’s designated compliance officer(s) and be responsible for the Hotel’s compliance with competition law in Hong Kong.
Absolute compliance with competition laws is of paramount importance to the Hotel. The consequences of violation to competition laws are very serious for the Hotel (including but not limited to heavy fines, significant management costs and bad publicity associated with a competition investigation) as well as for any employee who is involved in the violation. Failure to comply with competition law or with this compliance policy is a serious matter and may result in disciplinary action, up to and including termination of employment. Individuals may also face pecuniary penalty or director disqualification orders.
The Hotel will therefore endeavour to ensure that competition law compliance will be achieved through implementing effective competition compliance code of conduct throughout its business.
GENERAL WHISTLEBLOWING AND COMPLAINT POLICY FOR SUSPECTED BREACH OF COMPETITION LAW
ALVA HOTEL BY ROYAL (the “Hotel“) is committed to high standard of openness, probity and accountability. In line with that commitment, the Hotel expects and encourages its customers, suppliers and other stakeholders who have concerns about any suspected anti-competitive conduct within the Hotel or relating to the Hotel’s operations to come forward and voice those concerns. Your report and assistance serve as a powerful tool to help the Hotel uncover such anti-competitive conduct.
If you are aware of suspected anti-competitive practices that you think are wrong, you can help us investigate such practices by voluntarily providing us with information. This information can be, for example, facts concerning anti-competitive conduct, its circumstances and the individuals involved. They can concern past, ongoing or planned anti-competitive behaviour.
– To encourage and assist any customers, suppliers and other stakeholders of the Hotel to raise concerns about any suspected anti-competitive conduct and disclose related information confidentially.
– To provide reporting channels and guidance on whistleblowing to customers, suppliers and other stakeholders to raise concerns about any suspected anti-competitive conduct rather than neglecting it.
– To reveal suspected anti-competitive practices before these activities cause disruption or loss to the Hotel.
3. RESPONSIBILITY FOR IMPLEMENTATION OF POLICY
The designated compliance officer(s) of the Hotel (the “Compliance Officer(s)”) and the management of the Hotel (the “Management”) have overall responsibility for this policy.
The primary responsibility for monitoring and reviewing the operation of this policy and any recommendations for action resulting from investigation into complaints lies with the Compliance Officer(s).
The Compliance Officer(s) shall initiate review and update of this policy from time to time. The updated policy shall be submitted to the Management for approval.
The Management and the Compliance Officer(s) shall periodically review and discuss the effectiveness of this policy.
4. REPORTABLE CONCERNS REGARDING BREACH OF COMPETITION LAW
Activities that constitute a breach of competition law may include, but not limited to the following:
(a) Price fixing;
(b) Market sharing or allocation;
(c) Output limitation;
(d) Bid rigging;
(e) Collective boycott of particular business partners;
(f) Exchange, or facilitating the exchange, of commercially sensitive information between competitors and competing business partners; and
(g)Misuse of market position.
Whistleblower is not required to make absolute proof of the matter reported but would need to specify reasons for the concerns. If a report is made in good faith then, even if it is not confirmed by an investigation, your concerns would be valued and appreciated. Good faith means that the reporting person has held a reasonable belief that the complaint made is true and honest, and not made for personal interest or any ulterior motive.
5. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS
Whistleblowers making appropriate complaints under this policy are assured of protection against victimisation or unwarranted disciplinary action, even if the concerns turn out to be unsubstantiated.
The Management must ensure that customers, suppliers and other stakeholders feel easeful to make reports without fear of reprisals. Any kinds of retaliation against a whistleblower will be considered as misdemeanors.
However, if a whistleblower makes a false report maliciously, with an ulterior motive, or for personal gain, the Hotel reserves the right to take appropriate actions against the relevant person to recover any loss or damage as a result of the false report.
6. MAKING A REPORT
If you are aware of any potential anti-competitive conduct which you wish to report, you may report it to your contact at the Hotel or, if appropriate, directly to the Compliance Officer(s), by phone or in person.
Whistleblowers are encouraged to come forward and report as much specific information as possible for assessment and investigation.
It is understood that a whistleblower may wish to report anonymously. However, anonymous reporting is not encouraged because it will be much more difficult for the Hotel to investigate and follow up because the Hotel will not be able to obtain further information from you and make a proper assessment.
The Hotel will make every effort to keep your identity confidential. In order not to jeopardise the investigation, you should also keep the fact that you have made a report, the nature of your concerns and the identity of those involved confidential.
Under certain circumstances where the whistleblower’s identity has to be disclosed according to laws and regulations, the Hotel will endeavour to inform you that your identity is likely to be disclosed to the extent permitted by the relevant laws/regulations and as the Hotel considers appropriate.
8. INVESTIGATION PROCEDURES
All whistleblowing cases reported will be recorded by the Compliance Officer(s). The Compliance Officer(s) and other suitable personnel in the Management will evaluate every report received to decide if a full investigation is necessary. If an investigation is warranted, the Compliance Officer(s) and/or other personnel designated by the Management will look into the matter.
Where applicable, the Compliance Officer(s) may consult external legal advisers to determine the appropriate course of actions. If the Hotel considers appropriate, the case may also be referred to the relevant regulatory authorities.