The Client Code of Conduct serves as a foundational document for organizations operating in Hong Kong's regulated business environment. It is primarily used when establishing and maintaining professional relationships with clients, ensuring compliance with Hong Kong's regulatory requirements, particularly those mandated by the SFC and HKMA. This document becomes necessary when organizations need to demonstrate their commitment to maintaining high professional standards, protecting client interests, and ensuring transparent business practices. The Code of Conduct typically includes detailed provisions on client classification, service delivery standards, data protection, conflict management, and complaint handling procedures. It is particularly relevant for financial institutions and professional service firms operating under Hong Kong's regulatory framework, where clear guidelines for client interactions are essential for maintaining regulatory compliance and building trust.
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1. Introduction: Purpose and scope of the Code of Conduct, including its application and enforcement
2. Definitions: Key terms used throughout the document
3. General Principles: Fundamental principles of business conduct including integrity, due skill and care, and treating customers fairly
4. Client Classification: Categories of clients and their respective treatment (e.g., professional vs. retail clients)
5. Service Standards: Standards of service delivery and client interaction
6. Communication Standards: Guidelines for all forms of communication with clients
7. Confidentiality and Data Protection: Obligations regarding client data protection and privacy
8. Conflicts of Interest: Procedures for identifying, preventing, and managing conflicts of interest
9. Complaints Handling: Procedures for receiving, investigating, and resolving client complaints
10. Anti-Money Laundering: Client due diligence and AML compliance requirements
11. Record Keeping: Requirements for maintaining client records and documentation
12. Amendments and Updates: Process for updating the Code of Conduct
1. Electronic Trading Services: Include when offering online trading or digital services to clients
2. Research Services: Include when providing investment research to clients
3. Asset Management: Include when offering portfolio management services
4. Credit and Lending: Include when offering credit facilities or margin trading
5. Cross-border Services: Include when providing services to clients in multiple jurisdictions
6. Social Media Policy: Include when maintaining social media presence or allowing staff social media interaction with clients
1. Fee Schedule: Detailed breakdown of all applicable fees and charges
2. Service Level Standards: Specific metrics and standards for service delivery
3. Document Requirements: List of required documentation for different types of services or client categories
4. Complaint Form Template: Standard form for filing complaints
5. Privacy Policy: Detailed policy regarding handling of personal data
6. Risk Disclosure Statement: Comprehensive disclosure of risks associated with different services
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