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Submissions and Reports

DateTitle
2021/06/17Consultation Paper on Review of Corporate Governance Code and Related Listing Rules
The Chamber welcomes the HKEX’s proposals to enhance its existing framework on corporate governance and related listing rules. At the same time, we recommend that such changes be implemented on an incremental and flexible basis, with consideration given to their potential costs and benefits for businesses, particularly with regard to the impact on small and medium sized issuers.
2021/06/02Protection of Personal Information on the Companies Register
The Chamber welcomes the Government’s proposals regarding amendments to public access to personal information on the Companies Registry. At the same time, we recommend that the public be consulted on the scope of persons authorized to access protected information, and that the proposed timeline for implementation of the new measures be shortened.
2021/05/28Consultation Paper on Listing Regime for Overseas Issuers
The Chamber agrees with the HKEX that the existing listing requirements should be streamlined through the introduction of a common set of core shareholder protection standards (“Core Standards”) especially in respect of overseas issuers. The Chamber has also made a number of observations and recommendations on certain aspects of the Core Standards to facilitate issuer compliance, and enhance the city’s status as a place to list.
2021/03/19Consultation Paper on Real-name Registration Programme for SIM Cards
The Chamber agrees with the Government that there is the need to address the abuse of SIM Cards for criminal purposes, but suggests that consideration should also be given to attendant issues such as data privacy implications and efficacy of a mandatory registration system. In light of the social impact that such regulatory changes may bring, the Chamber recommends that efforts be made to better define the rights and responsibilities of stakeholders, namely, users, operators, and regulators under the proposed programme.
2021/03/16Consultation Paper on Outcome Related Fee Structures for Arbitration
The Chamber agrees with the Law Reform Commission’s proposals to relax the current prohibition of outcome-related fee structures for arbitration to enhance Hong Kong’s competitiveness as an arbitration centre, but suggests that a phased approach be adopted to the implementation of flexible fee structures. Due consideration should also be given to the protection of the interests of smaller businesses opting for such a means of dispute resolution.
2021/01/28Consultation Paper on the Main Board Profit Requirement
The Chamber does not agree with the HKEX’s proposal to increase the profit requirement for a Main Board listing mainly because such a requirement would not be in the interests of smaller businesses in particular those outside of the New Economy. Rather, a comprehensive review of the existing listing requirements for both the Growth Enterprise and Main Boards including those on the transfer from the former to the latter should be carried out to address any intrinsic inefficiencies and promote Hong Kong’s attractiveness as a place to list.
2021/01/27Consultation Paper on Legislative Proposals to Enhance Anti-Money Laundering and Counter-Terrorist Financing Regulation in Hong Kong
In response to the Government’s proposals to expand the scope of the Anti-Money Laundering Ordinance to include virtual asset services providers and dealers of precious metals and stones in Hong Kong, the Chamber has called for greater clarity on such issues as the uneven approach to regulating the two sectors in question, and rationale behind the prescribed penalties, among others. It also raised the issue of whether the Securities and Futures Commission should share regulatory responsibilities with its counterparts such as the Hong Kong Monetary Authority.
2020/12/14Securities and Futures Commission’s Consultation Paper on Proposed Amendments to its Anti- Money Laundering and Counter-Terrorist Financing Guideline (the Guideline) September 2020
The Chamber does not object to the Commission's proposal to amend its guidelines under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, but suggests that any additional compliance requirements should be facilitative and reasonably practicable to achieve.
2020/09/30Consultation Paper on Proposals to Introduce a Paperless Listing & Subscription Regime, Online Display of Documents and Reduction of the Types of Documents on Display
The Chamber supports the HKEX’s proposals to go paperless although, in the process of doing so, consideration should be given to maintaining paper-based options so that some degree of flexibility is provided to the investing public.
2020/09/18Consultation Paper on the proposed application of the United Nations Convention on Contracts for the International Sale of Goods to the HKSAR
The Chamber welcomes measures which are conducive to the development of international trade such as the proposal to apply the UN Convention on CISG to Hong Kong. While there are apparent benefits of doing so, a proper cost-benefit analysis should be conducted to better assess the impact this may have on the Hong Kong business community and our status as a leading international trading centre.
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