Anti-Fraud Policy

The Manager is committed to upholding a high level of ethical and moral standards in conducting business. An Anti-Fraud Policy has accordingly been adopted with the objective of defining the roles and responsibilities of directors, senior management and employees in preventing, detecting and reporting fraud. In particular, all department heads of the Manager and the Property Manager are required to conduct fraud risk assessment in their respective areas.

The Manager’s Whistleblowing Policy encourages employees and business partners to report any actual or suspected improprieties, misconducts, malpractices and irregularities without fear of reprisals. Confidentiality is well respected in all circumstances.

All concerns should be reported to the Internal Audit Department via one of the following channels:

  • Dedicated hotline: 3669 2834
  • By email:
  • By post in a sealed envelope clearly marked “To be opened by addressee only” at:

    Internal Auditor
    Henderson Sunlight Asset Management Limited
    30/F, Dah Sing Financial Centre,
    248 Queens Road East,
    Wan Chai, Hong Kong

If the complaint is lodged against the Internal Auditor, the report should be made by post to the Chief Executive Officer of the Manager at the same address who will report to the Chairman of the Audit Committee.

It is encouraged that the reports are not being made anonymously in order to facilitate further investigations and follow-up.