Submissions and Reports

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.

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.

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.

The Chamber has made a follow-up response to the Financial Services and the Treasury Bureau based on the latest draft of the Companies (Corporate Rescue) Bill. The response provides further suggestions on the appointment of a provisional supervisor during the corporate rescue procedure and reiterates points made in the Chamber’s earlier submission.

In response to the Financial Services and the Treasury Bureau’s invitation, the Chamber has submitted its views on the Government’s latest proposals to introduce a statutory corporate rescue procedure and insolvent provisions in Hong Kong. The Chamber believe there is a pressing need to provide companies in financial difficulties with an alternative to liquidation especially under the sustained difficulties that Hong Kong has been experiencing since the middle of last year.

The Chamber welcomes the opportunity to comment on the HKEX’s proposed introduction of corporate WVR structures. Prior to committing our support for this proposal, we recommend that the HKEx provide further elaboration on the necessity for establishing such a regime as well as the effectiveness of investor safeguards raised in the consultation paper.

The Chamber has expressed reservations over the Hong Kong Exchanges and Clearing Limited’s proposed relaxation of existing requirements on listed companies regarding the appointment of company secretaries.

The Chamber welcomes the Hong Kong Exchanges and Clearing Limited‘s efforts to improve the quality of ESG reporting through this consultation exercise. We believe that such enhancements should be supplemented by further investments in education and training to promote better understanding of the intentions behind and benefits of ESG reporting .

The Chamber supports the updating of Hong Kong’s laws to allow the implementation of the Madrid Protocol domestically.

The Chamber has called for clarification of a few matters outstanding from the last round of consultation in 2016. The Chamber has also suggested that instead of a selective approach, all antitrust (competition) matters should be excluded from the Convention.