Integrity Policy

3 October 2026 | Business Development Department

Kam Kee Metal Structures Limited (the “Company”) prohibits all forms of bribery and corruption, and conducts business with the principles of integrity, probity and honesty. All sole proprietors / partners / directors* and employees (collectively referred to as “Personnel”) shall comply with this Integrity Policy as well as relevant company rules / guidelines / codes of conduct*.

The Company and its Personnel shall abide by the Prevention of Bribery Ordinance (Cap. 201), the Competition Ordinance (Cap. 619) of Hong Kong, and other integrity‑related legislation of the Hong Kong Special Administrative Region.

Personnel are not allowed to solicit¹ or accept any advantage from persons or organisations having business dealings with the Company, unless prior approval is granted. Such approval shall be consistent with anti‑corruption and integrity principles.

All Personnel are prohibited from offering any advantage to officers or members of government departments or public bodies in the course of business dealings. It is also prohibited for Personnel to offer any advantage, whether directly or indirectly through third parties, to members of any organisation with the intent to influence their decisions in business dealings with the Company.

Personnel shall avoid accepting lavish or frequent hospitality provided by entities having business dealings with the Company.

All Personnel shall avoid situations of actual or perceived conflict of interest. Where such conflict cannot be avoided, the relevant Personnel must declare the matter to the approving authority for determining mitigating actions.

Personnel are prohibited from disclosing confidential information without authorisation or misusing company or client information.

The Company maintains an internal reporting mechanism for Personnel to enquire on integrity‑related matters and report suspected breaches of integrity requirements. Reports received will be handled promptly, prudently and in strict confidence.

Retaliation against personnel who make bona‑fide reports of suspected integrity breaches, or persons participating in inquiries / investigations into such allegations, is strictly forbidden.

Any Personnel found to have breached integrity requirements will be subject to internal disciplinary actions including termination of employment and/or referral to relevant law‑enforcement authorities. The Company will render full assistance to law‑enforcement authorities in criminal investigations.

The Company is committed to partnering with associates / enterprises / organisations that share aligned values, uphold equivalent integrity standards and attach importance to business ethics.

¹ Under the Prevention of Bribery Ordinance (Cap. 201), “advantage” covers any gift, loan, fee, reward, commission, office, employment contract; release from obligation / liability / loan; service and favour; the exercise or forbearance of any right / power / duty, etc.