Hong Kong and Macau Legal Perspectives | Introduction to Hong Kong's Legal System (3) — The "ICAC" in Hong Kong Films: Unveiling the "Anti-Corruption Myth" of the Hong Kong Independent Commission Against Corruption

To understand the birth of ICAC, we must go back to Hong Kong in the 1960s and 1970s — at that time, corruption permeated every corner of society: firefighters only put out fires after receiving bribes, police tolerated vice activities like gambling and drugs in exchange for protection fees, and even public hospital nurses demanded tea fees before giving patients hot water. The most sensational case was the 1973 "Godber Case" — Hong Kong's Chief Superintendent Godber was suspected of embezzling over HKD 4.3 million (equivalent to 200 years of income for an ordinary citizen at that time), but he used his position to flee to the UK, sparking large-scale protests across Hong Kong. "Anti-corruption" became the most urgent social demand at that time.

To understand the birth of ICAC, we must go back to Hong Kong in the 1960s and 1970s - when corruption permeated every corner of society: firefighters were only willing to put out fires by charging throat fees, police were allowed to tolerate pornography, gambling, and drugs by charging protection fees, and even public hospital nurses were required to pay tea and water fees before handing over boiling water to patients. The most sensational case among them was undoubtedly the 1973 "Godber Case" - Hong Kong Chief Superintendent Godber was suspected of embezzling over HKD 4.3 million (equivalent to 200 years of income for ordinary citizens at that time), but he used his position to flee to the UK, causing large-scale protests among the people of Hong Kong. "Anti corruption" became the most urgent social demand at that time.

Against this backdrop, on February 15, 1974, the Governor of Hong Kong officially established the ICAC under the ICAC Ordinance (now the ICAC Ordinance of the Hong Kong Special Administrative Region), granting it a special status of being "independent from the government structure and directly accountable to the Governor (or the Chief Executive after the handover)", completely breaking the anti-corruption dilemma of "investigating one's own people."

Against this backdrop, on February 15, 1974, the Governor of Hong Kong officially established the ICAC under the ICAC Ordinance (now the ICAC Ordinance of the Hong Kong Special Administrative Region), granting it a special status of being "independent from the government structure and directly accountable to the Governor (or the Chief Executive after the handover)", completely breaking the anti-corruption dilemma of "investigating one's own people".

The "first battle" after the establishment of ICAC shocked all of Hong Kong: through negotiations with the British government, Godber was extradited from the UK to Hong Kong for trial. Ultimately, Godber was sentenced to 4 years in prison, and all the embezzled funds were recovered. Subsequently, ICAC investigated major cases such as the "Four Great Detectives" (Leoi Lok, Ngaan Hung, etc.) and the corruption syndicate in Yau Ma Tei Fruit Market. From 1974 to 1977 alone, over 2,000 corruption cases were handled, and many senior police and political officials were brought down, quickly reversing Hong Kong's corrupt atmosphere. Four Great Detectives (Leoi Lok, Ngaan Hung, etc.), the corruption syndicate in Yau Ma Tei Fruit Market, and other major cases. From 1974 to 1977 alone, over 2,000 corruption cases were investigated and handled, with many senior police and political officials falling from power, rapidly reversing Hong Kong's corrupt climate.

The "first battle" after the establishment of ICAC shook Hong Kong: through negotiations with the British government, Godber was extradited from the UK to Hong Kong for trial. In the end, Godber was sentenced to 4 years in prison and all the stolen money involved was recovered. Subsequently, ICAC successively investigated and dealt with major cases such as the "Four Great Detectives" (Leoi Lok, Ngaan Hung, etc.) and the corruption group in Yau Ma Tei Fruit Market. From 1974 to 1977 alone, more than 2000 corruption cases were investigated and dealt with, and many senior police and political officials were arrested, quickly reversing the corrupt atmosphere in Hong Kong.

After the handover, ICAC continued to play a role under the "One Country, Two Systems" framework: in 2003, it investigated the "Home Ownership Scheme Short Piling Case" (builders cutting corners), in 2012 it handled corruption cases in the Hong Kong Housing Authority, and in 2021 it cracked cross-border money laundering and corruption syndicate cases... Today, "ICAC" is not only the name of an institution but also a symbol of Hong Kong's "integrity and rule of law" — according to a survey by the University of Hong Kong, over 90% of Hong Kong citizens trust the work of the ICAC, ranking among the top globally for anti-corruption agencies. Home Ownership Scheme Short Piling Case The Home Ownership Scheme Short Piling Case (builders cutting corners), in 2012 the Hong Kong Housing Authority corruption case, and in 2021 the cross-border money laundering and corruption syndicate case... Today, "ICAC" is not only an institutional name but also a symbol of Hong Kong's "integrity and rule of law" — according to a survey by the University of Hong Kong, over 90% of Hong Kong citizens trust the ICAC's work, ranking it among the top anti-corruption agencies worldwide.

After the return, ICAC continued to play a role under the framework of "One Country, Two Systems": in 2003, it investigated the "short piling case of public housing" (construction companies cutting corners), in 2012, it investigated the corruption case of the Hong Kong Housing Authority, and in 2021, it cracked the cross-border money laundering and corruption group case... Nowadays, "ICAC" is not only a name for an organization, but also a symbol of Hong Kong's "integrity and rule of law" - according to a survey by the University of Hong Kong, more than 90% of Hong Kong citizens trust ICAC's work, which ranks among the top anti-corruption agencies in the world.

The core of ICAC's efficient anti-corruption efforts lies in its "independent, professional, and clearly defined" organizational structure. According to the Independent Commission Against Corruption Ordinance, ICAC has three functional departments, plus an administrative headquarters, forming a three-in-one anti-corruption system of "investigation, prevention, and education", known as the "three carriages":

The core of ICAC's efficient anti-corruption efforts lies in its independent, professional, and clearly defined organizational structure. According to the Independent Commission Against Corruption Ordinance, ICAC has three functional departments and an administrative headquarters, forming a three in one anti-corruption system of "investigation, prevention, and education", known as the "three carriages":

The Execution Department is the most closely watched department of ICAC, equivalent to the "Anti Corruption Investigation Team", accounting for about 60% of the total number of ICAC personnel. It includes the Investigation Department, Intelligence Department, Cross-border Case Department, etc. Its core function is to "receive reports of corruption, conduct investigations and evidence collection, and make prosecution recommendations" - whether it is bribery of civil servants, commercial bribery of enterprises, election fraud, cross-border corruption, as long as it involves "corruption", "bribery", "abuse of power" and other behaviors stipulated by Hong Kong law, the enforcement department has the right to investigate.

The Execution Department is the most closely watched department of ICAC, equivalent to the "Anti Corruption Investigation Team", accounting for about 60% of the total number of ICAC personnel. It includes the Investigation Department, Intelligence Department, Cross border Case Department, etc. Its core function is to "receive reports of corruption, conduct investigations and evidence collection, and make prosecution recommendations" - whether it is bribery of civil servants, commercial bribery of enterprises, election fraud, cross-border corruption, as long as it involves "corruption", "bribery", "abuse of power" and other behaviors stipulated by Hong Kong law, the enforcement department has the right to investigate.

For example, if citizens discover that a public official has violated regulations by accepting red envelopes, they can report it through the ICAC's 24-hour reporting hotline (2526 6366), online platforms, or in person at the ICAC headquarters. The enforcement department will immediately initiate a secret investigation: retrieving bank statements, surveillance footage, interviewing witnesses, and even conducting surveillance and searches with court authorization. It is worth noting that the investigators in the execution department have undergone strict training, not only proficient in legal and investigative skills, but also required to pass "integrity checks" (including background checks and financial audits) to ensure their own integrity.

For example, if citizens discover that a public official has violated regulations by accepting red envelopes, they can report it through the ICAC's 24-hour reporting hotline (2526 6366), online platforms, or in person at the ICAC headquarters. The enforcement department will immediately initiate a secret investigation: retrieving bank statements, surveillance footage, interviewing witnesses, and even conducting surveillance and searches with court authorization. It is worth noting that the investigators in the execution department have undergone strict training, not only proficient in legal and investigative skills, but also required to pass "integrity checks" (including background checks and financial audits) to ensure their own integrity.

If the execution department is responsible after the fact, the corruption prevention department is proactive - its core task is to identify institutional loopholes that are prone to corruption and promote the government and enterprises to improve supervision. According to the Regulations of the Independent Commission Against Corruption, corruption prevention department has the right to review the rules and regulations of government departments and public institutions, and may even require private enterprises (such as banks and real estate companies) to provide internal management documents, and propose modification suggestions for links that may trigger corruption (such as bidding processes and approval limits).

If the execution department is responsible after the fact, the corruption prevention department is proactive - its core task is to identify institutional loopholes that are prone to corruption and promote the government and enterprises to improve supervision. According to the Regulations of the Independent Commission Against Corruption, corruption prevention department has the right to review the rules and regulations of government departments and public institutions, and may even require private enterprises (such as banks and real estate companies) to provide internal management documents, and propose modification suggestions for links that may trigger corruption (such as bidding processes and approval limits).

For example, a public hospital in Hong Kong once had the situation of "doctors recommending patients to designated pharmacies to buy drugs and accepting kickbacks". After the intervention of the corruption prevention department, the hospital was promoted to establish a "drug procurement open bidding system" and a "doctor recommended drug filing system", which eliminated the transfer of benefits in the process; For private enterprises, the corruption prevention department will issue the "Guidelines for Business Ethics" to guide them in establishing an anti bribery compliance system (such as supplier integrity review and employee code of conduct), which is also a key reference for many mainland enterprises investing in Hong Kong.

For example, a public hospital in Hong Kong once had the situation of "doctors recommending patients to designated pharmacies to buy drugs and accepting kickbacks". After the intervention of the corruption prevention department, the hospital was promoted to establish a "drug procurement open bidding system" and a "doctor recommended drug filing system", which eliminated the transfer of benefits in the process; For private enterprises, the corruption prevention department will issue the "Guidelines for Business Ethics" to guide them in establishing an anti bribery compliance system (such as supplier integrity review and employee code of conduct), which is also a key reference for many mainland enterprises investing in Hong Kong.

ICAC deeply understands that anti-corruption cannot rely solely on "investigations", but also requires the support and participation of citizens. The responsibility of the Community Relations Department is to "cultivate citizens' awareness of integrity through education and publicity, and encourage the public to report corruption" - from conducting "integrity classes" in primary and secondary schools, to placing anti-corruption advertisements in subways and on television, and even producing easy-to-understand anti-corruption manuals (such as "Merchant Anti-Corruption Guide" and "Civil Servant Integrity Handbook"), all of which are daily work of the Community Relations Department.

ICAC is well aware that anti-corruption cannot rely solely on "investigating cases", but also on the support and participation of citizens. The responsibility of the Community Relations Department is to "cultivate citizens' awareness of integrity through education and publicity, and encourage the public to report corruption" - from setting up "integrity classrooms" in primary and secondary schools, to placing anti-corruption advertisements on subways and television, and even producing easy to understand anti-corruption manuals (such as the "Merchant Anti Corruption Guide" and the "Civil Servant Integrity Manual"), all of which are part of the daily work of the Community Relations Department.

The most classic case is ICAC's "Integrity Education Program": targeting primary and secondary schools in Hong Kong, developing the "Integrity Ambassador" curriculum, teaching students to identify "corrupt behavior" through situational dramas, comics, and other forms; for civil servants, conducting annual "integrity training", clarifying details such as the "upper limit of banquet acceptance" and the "gift registration system"; for enterprises, holding "Business Integrity Forums", inviting judges and lawyers to interpret the "Prevention of Bribery Ordinance" to help enterprises avoid compliance risks. This "universal participation" anti-corruption model has made "integrity" a consensus in Hong Kong society.

The most classic case is ICAC's "Integrity Education Program": targeting primary and secondary schools in Hong Kong, the development of the "Integrity Ambassador" curriculum teaches students to distinguish "corrupt behavior" through situational dramas, comics, and other forms; For civil servants, conduct annual "integrity training" and clarify details such as the "upper limit of the amount of banquets accepted" and the "gift registration system"; For enterprises, hold a "Business Integrity Forum" and invite judges and lawyers to interpret the "Prevention of Bribery Regulations" to help enterprises avoid compliance risks. This anti-corruption model of "universal participation" has made "integrity" a consensus in Hong Kong society.

In addition, ICAC also has an administrative headquarters responsible for personnel, finance, logistics and other support work — it is worth mentioning that ICAC's financial budget is independent of the government's general budget, directly approved by the Hong Kong Legislative Council, and all expenditures must undergo independent auditing to ensure that "anti-corruption funds are not misused."

In addition, ICAC also has an administrative headquarters responsible for personnel, finance, logistics and other support work. It is worth mentioning that ICAC's budget is independent of the government's general budget and is directly approved by the Hong Kong Legislative Council. All expenses must undergo independent auditing to ensure that "anti-corruption funds are not abused."

The ICAC in Hong Kong films seems to be "omnipotent", but in reality, its power is not "unlimited" — all powers come from explicit authorization by laws such as the Independent Commission Against Corruption Ordinance and the Prevention of Bribery Ordinance, and are strictly constrained. Specifically, the core statutory powers of ICAC can be divided into four categories:

The ICAC in Hong Kong films seems to be "omnipotent", but in reality, its power is not "unlimited" - all power comes from explicit authorization by laws such as the Independent Commission Against Corruption Ordinance and the Prevention of Bribery Ordinance, and is strictly constrained. Specifically, the core statutory powers of ICAC can be divided into four categories:

According to Article 17 of the Independent Commission Against Corruption Ordinance, ICAC investigators have the right to request any person (including government officials, corporate executives, and bank employees) to provide documents related to corruption cases (such as contracts, account books, bank statements). If they refuse to provide them, they may be sentenced to six months' imprisonment and a fine of HKD 50,000; summon witnesses to the ICAC for questioning, and witnesses must testify truthfully. If they give false testimony, they may be sentenced to 7 years in prison and a fine of HKD 100,000; access all records of public institutions (such as land registration, company registration information), and even request cross-border institutions (such as the Hong Kong Monetary Authority, Interpol) to assist in retrieving overseas evidence (such as overseas bank accounts).

According to Article 17 of the Independent Commission Against Corruption Ordinance, ICAC investigators have the right to request any person (including government officials, corporate executives, and bank employees) to provide documents related to corruption cases (such as contracts, account books, and bank statements). If they refuse to provide them, they may be sentenced to six months' imprisonment and a fine of HKD 50000; Summon witnesses to the ICAC for questioning, and witnesses must testify truthfully. If they give false testimony, they may be sentenced to 7 years in prison and a fine of HKD 100000; Access all records of public institutions (such as land registration, company registration information), and even request cross-border institutions (such as the Hong Kong Monetary Authority, Interpol) to assist in retrieving overseas evidence (such as overseas bank accounts).

For example, when investigating a corruption case involving an official, ICAC can directly request all banks in Hong Kong to provide the account statements of the official and their family members. If abnormal fund flows are found (such as sudden receipt of large anonymous transfers), the source of the funds can be further traced; for cross-border corruption, ICAC can request assistance from jurisdictions such as mainland China and Singapore to freeze assets involved through the Multilateral Convention against Corruption.

For example, when investigating a corruption case involving an official, ICAC can directly request all banks in Hong Kong to provide the account statements of the official and their family members. If abnormal fund flows are found (such as sudden receipt of large anonymous transfers), the source of the funds can be further traced; For cross-border corruption, ICAC can request assistance from jurisdictions such as mainland China and Singapore to freeze assets involved through the Multilateral Convention against Corruption.

Many people mistakenly believe that ICAC can "arrest people at will", but in reality, its arrest and search powers are strictly limited:

Many people mistakenly believe that ICAC can "arrest people at will", but in reality, its arrest and search powers are strictly limited:

Arrest: There must be a "reasonable suspicion" (such as obtaining preliminary evidence of corruption), and the suspect must be transferred to a court within 48 hours of arrest for the judge to decide whether to approve bail;

Arrest: There must be a "reasonable suspicion" (such as obtaining preliminary evidence of corruption), and the suspect must be transferred to a court within 48 hours of arrest for the judge to decide whether to approve bail;

Search: A "search warrant" must be applied to the court, specifying the location and scope of the search (such as "limited to the suspect's office and residence"), and independent witnesses (such as community representatives) must be present during the search to prevent abuse of power.

Search: A "search warrant" must be applied to the court, specifying the location and scope of the search (such as "limited to the suspect''s office and residence"), and independent witnesses (such as community representatives) must be present during the search to prevent abuse of power.

In 2018, during an investigation into a bribery case involving a real estate company, the ICAC was ruled by the High Court to have violated the search procedure due to "the search warrant not clearly specifying the types of documents to be searched," and the related evidence was inadmissible in court — this case also reflects the Hong Kong judiciary's checks and balances on the ICAC's powers.

In 2018, during an investigation into a bribery case involving a real estate company, ICAC was found by the High Court to have violated the search procedure due to "the search warrant not clearly indicating the type of documents to be searched", and the relevant evidence could not be presented as evidence in court - this case also reflects the checks and balances of ICAC's power by the Hong Kong judiciary.

To prevent corrupt individuals from transferring stolen funds, the ICAC Ordinance grants ICAC the "asset freezing power": during the investigation period, ICAC may apply to the court to freeze the bank accounts, properties, stocks, and other assets of the persons involved, with a maximum freezing period of 2 years; if the case is ultimately convicted, the court may order the confiscation of the involved assets (including the proceeds of corruption and related gains).

To prevent corrupt individuals from transferring stolen funds, ICAC Ordinance grants ICAC the "asset freezing power": during the investigation period, ICAC may apply to the court to freeze the bank accounts, properties, stocks and other assets of the persons involved, with a maximum freezing period of 2 years; If the case is ultimately convicted, the court may order the confiscation of the assets involved (including the proceeds of corruption and related gains).

For example, in 2020, a Hong Kong public official was frozen by ICAC for accepting HKD 10 million in bribes from a developer, resulting in the freezing of three properties and HKD 20 million in bank deposits. The court not only sentenced him to 5 years in prison, but also confiscated all assets involved — this power effectively deterred the act of "transferring assets after corruption."

For example, in 2020, a Hong Kong public official was frozen by ICAC for accepting HKD 10 million in bribes from a developer, resulting in the freezing of three properties and HKD 20 million in bank deposits. The court not only sentenced him to 5 years in prison, but also confiscated all assets involved - this power effectively deterred the act of "transferring assets after corruption".

ICAC is responsible for "investigating corruption" but does not have the authority to directly initiate prosecutions — after the investigation is completed, ICAC must transfer the case materials to the Department of Justice, which independently decides whether to prosecute (i.e., the principle of "separation of investigation and prosecution"). This system design aims to "prevent ICAC from acting as both 'investigator' and 'prosecutor'" and ensures the objectivity of prosecution decisions.

ICAC is responsible for investigating corruption, but does not have the authority to directly prosecute. After the investigation is completed, ICAC needs to transfer the case materials to the Department of Justice, which will independently decide whether to prosecute (i.e. the principle of "separation of investigation and prosecution"). The purpose of this system design is to prevent ICAC from acting as both an 'investigator' and a 'prosecutor', ensuring the objectivity of prosecution decisions.

"Who supervises the supervisors?" This is a common problem faced by all anti-corruption agencies. The key to ICAC's integrity lies in its establishment of a "multi-level, all-round" supervision system to ensure that power is not abused:

Who will supervise the supervisors? This is a common problem faced by all anti-corruption agencies. The key to ICAC''s ability to maintain integrity lies in its establishment of a "multi-level, all-round" supervision system to ensure that power is not abused:

According to the ICAC Ordinance, Hong Kong has established the "ICAC Complaints Committee" (referred to as the "Complaints Committee"), composed of 7-9 independent individuals (including judges, lawyers, scholars, business representatives, etc., all appointed by the Chief Executive and must not have any interest connection with ICAC). The Complaints Committee's responsibility is to "handle public complaints against ICAC personnel (such as abuse of power, violent law enforcement) and independently investigate and verify."

According to ICAC Ordinance, Hong Kong has established the "ICAC Complaints Committee" (referred to as the "Complaints Committee"), which is composed of 7-9 independent individuals (including judges, lawyers, scholars, business representatives, etc., all appointed by the Chief Executive and not affiliated with the ICAC). The responsibility of the Complaints Committee is to 'receive public complaints about ICAC personnel (such as abuse of power, violent law enforcement), and independently investigate and verify'.

For example, if citizens believe that ICAC investigators damaged private property during a search, they can file a complaint with the Complaints Committee. The Complaints Committee has the authority to review ICAC's investigation records, summon relevant personnel to testify, report investigation results to the Chief Executive, and disclose them to the public (except for confidential information). In 2023, the Complaints Committee received 32 complaints, of which 2 were confirmed to have procedural flaws, and ICAC disciplined the relevant personnel (including warnings and reassignment).

For example, if citizens believe that ICAC investigators damaged personal property during a search, they can file a complaint with the Complaints Committee. The Complaints Committee has the right to review ICAC's investigation records, summon relevant personnel to testify, report the investigation results to the Chief Executive, and make them public to the public (except for confidential information). In 2023, the Complaints Committee received a total of 32 complaints, of which 2 were found to have procedural flaws, and ICAC imposed disciplinary actions (including warnings and job transfers) on the relevant personnel.

The Hong Kong courts have the "final review power" over ICAC's investigative actions — whether arrest, search, or asset freezing, ICAC must obtain court authorization; if ICAC's actions violate legal procedures (such as warrantless searches or illegal surveillance), the court may rule the related evidence invalid or even dismiss the case.

The Hong Kong court has the "final review power" over ICAC's investigative actions - whether it is arrest, search, or asset freeze, ICAC needs to obtain court authorization; If ICAC's actions violate legal procedures (such as unlicensed searches or illegal listening), the court may rule that the relevant evidence is invalid or even dismiss the case.

Hong Kong Legislative Council passes "financial approval" and "inquiry mechanism" to supervise ICAC:

The Hong Kong Legislative Council supervises ICAC through "financial approval" and "inquiry mechanism":

Financial supervision: ICAC's annual budget must be submitted to the Legislative Council's Finance Committee for review. Legislative Council members may question the use of the budget (such as investigation funds and publicity expenses), and ICAC must respond item by item;

Financial supervision: The annual budget of ICAC needs to be submitted to the Finance Committee of the Legislative Council for review. Legislative Council members may raise questions about the use of the budget (such as investigation funds and publicity expenses), and ICAC needs to answer them item by item;

Policy supervision: The Legislative Council may establish a "special committee" to investigate ICAC's work (such as the effectiveness of anti-corruption policies), and ICAC must cooperate by providing relevant documents and testimony.

Policy supervision: The Legislative Council may establish a "special committee" to investigate the work of ICAC (such as the effectiveness of anti-corruption policies), and ICAC needs to cooperate by providing relevant documents and testimony.

In 2022, the Legislative Council questioned the "insufficient anti-corruption publicity of ICAC for private enterprises," ultimately promoting ICAC to increase the distribution of the "Integrity and Compliance Guidelines" for small and medium-sized enterprises — reflecting the Legislative Council's role in "correcting and improving" ICAC's work.

In 2022, the Legislative Council raised a question on the insufficient anti-corruption publicity of ICAC for private enterprises, ultimately leading to an increase in the circulation of ICAC's "Integrity and Compliance Guidelines" for small and medium-sized enterprises. This reflects the Legislative Council's role in "correcting and improving" ICAC's work.

ICAC has an internal "Disciplinary Committee" and has established a strict "Code of Conduct for ICAC Personnel": investigators are prohibited from accepting any gifts (even souvenirs worth HKD 100), from having private contact with individuals involved in cases, and even from disclosing case information to family members during investigations — violations may result in dismissal or even criminal charges.

The ICAC has an internal "Disciplinary Committee" and has established a strict "Code of Conduct for ICAC Personnel": investigators are prohibited from accepting any gifts (even souvenirs worth HKD 100), from having private contact with individuals involved in the case, and even from disclosing case information to family members during the investigation period - any violation may result in dismissal or even criminal charges.

In addition, all financial status of ICAC personnel must be regularly declared (including salaries, investments, real estate, etc.). If abnormal income is found, an internal investigation will be immediately initiated. This strict discipline ensures the integrity of ICAC personnel themselves.

In addition, all financial status of ICAC personnel must be regularly reported (including salaries, investments, real estate, etc.), and if any abnormal income is found, an internal investigation will be immediately initiated. This strict discipline requirement ensures the integrity of ICAC personnel themselves.

From the "iron-blooded image" in Hong Kong films to the "honest guardian" in reality, ICAC's success is not accidental — its core "code" lies in "independent status, professional ability, and strict supervision." For mainland enterprises and individuals who want to invest, work, or live in Hong Kong, understanding ICAC is not only necessary to "avoid legal risks" but also key to "integrating into Hong Kong's legal environment":

From the "iron blooded image" in Hong Kong films to the "honest guardian" in reality, the success of ICAC is not accidental - its core "code" lies in "independent status, professional ability, and strict supervision". For mainland enterprises and individuals who want to invest, work or live in Hong Kong, understanding ICAC is not only a need to "avoid legal risks", but also a key to "integrating into Hong Kong''s legal environment":

For enterprises, it is necessary to be familiar with ICAC's "Guidelines for Business Ethics", establish anti-bribery compliance systems (such as supplier audits and employee training), and avoid crossing corruption red lines due to "not understanding local rules" (such as giving valuable gifts to public officials).

For enterprises, it is necessary to be familiar with the ICAC's "Guidelines for Business Ethics", establish anti bribery compliance systems (such as supplier audits and employee training), and avoid crossing the red line of corruption due to "not understanding local rules" (such as giving valuable gifts to public officials).

On a personal level, if corrupt behavior is discovered, it can be reported through ICAC's formal channels (specific evidence should be provided, such as transfer records and chat screenshots), and the informant's information will be strictly confidential.

On a personal level, if corrupt behavior is discovered, it can be reported through the formal channels of ICAC (specific evidence should be provided, such as transfer records and chat screenshots), and the informant's information will be strictly confidential.

In terms of cross-border cooperation, in the construction of the Guangdong-Hong Kong-Macao Greater Bay Area, ICAC has established a cross-border anti-corruption cooperation mechanism with mainland supervisory authorities (such as the Guangdong Provincial Supervisory Commission). Enterprises need to pay attention to the alignment of anti-corruption policies in both regions (such as standards for identifying cross-border commercial bribery).

In terms of cross-border cooperation, in the construction of the Guangdong Hong Kong Macao Greater Bay Area, ICAC has established a cross-border anti-corruption cooperation mechanism with mainland supervisory authorities (such as the Guangdong Provincial Supervisory Commission), and enterprises need to pay attention to the connection between anti-corruption policies in the two places (such as the identification standards for cross-border commercial bribery).