2018E — Page 59

5.

ENVIRONMENTAL, SOCIAL AND GOVERNANCE REPORT (CONTINUED)

OUR GREATEST ASSET - HUMAN CAPITAL (Continued)

d.

Anti-Corruption

We are committed to maintaining high ethical standards and business integrity in our operations. We adopt a zero-tolerance approach to corruption or malpractice of any form including bribery, money laundering, extortion and fraud. Our Code of Conduct details the requirements of professional behaviour in which all staff are required to comply. During the reporting year, there were no confirmed cases of non-compliance with the anti-corruption regulations of Hong Kong.

To update our employees of the latest developments in anti-corruption enforcement, we arrange biennial seminars and talks with the Independent Commission Against Corruption (the "ICAC") for relevant staff members, especially for business units that may be exposed to higher corruption risks, such as purchasing and procurement, tendering, sales and marketing. As part of the commitment, representatives from the ICAC were invited to deliver two rounds of seminars to refresh best practice procedures and knowledge on anti-corruption in 2018.

In support of our policies on ethical behaviours, the Company's whistle-blowing policy provides channels for our employees at all levels to report violations or suspected violations and raise concerns of any improper behaviours. To encourage and assist whistle-blowers to raise grievances without fear of reprisal, all whistle-blowing disclosures are treated confidentially and submitted to the Internal Audit Manager for further investigation. Furthermore, our whistle-blowing policy is regularly reviewed by the Internal Audit Manager to evaluate its effectiveness. Please refer to the sub-section of "Risk Management and Internal Controls" in the "Corporate Governance Report" on pages 35 to 38 of this Annual Report for more details.

Hong Kong Ferry (Holdings) Company Limited

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Annual Report 2018