Introduction
1. This Code of Conduct applies to Lianhe Global licensed by, or registered with the Securities and Futures Commission (“SFC”) for Type 10 regulated activity (providing credit rating services), including as appropriate, representatives. (as defined in Section 167 of the Securities and Futures Ordinance (Cap. 571) (“SFO”).
Independence and Conflict of Interests
It is essential in order for Lianhe Global to function appropriately in the marketplace that Lianhe Global retains an appropriate degree of objectivity when determining credit ratings. A potential and perceived lack of independence and/or existence of conflict of interest present challenges to Lianhe Global’s objectivity and role in the marketplace.
LRGL requires its employees to be in a position of independence and has adopted internal procedures and mechanisms to identify, and eliminate, and/or manage and disclose as appropriate, any actual or potential conflicts of interest that may influence either: (i) the Ratings LRGL assigns; or (ii) the judgement and analyses of the licensed representatives who are involved in the preparation of Ratings in order to ensure that the rating services are undertaken in an objective manner. LRGL’s employees (“Employees”) are strictly prohibited from trading securities (including derivatives) of Rated Entities, their affiliates, or any entity under LRGL’s coverage.
Disclosure of any actual or potential conflicts of interest should be made in a timely manner.
Ancillary and Other Services
Purpose: To avoid forms of conflicts of interests, so as to ensure Lianhe Global’s rating independence, Lianhe Global does not intend to provide ancillary services in its early stage of development. If Lianhe Global intends to provide ancillary services in the future, after it initially receives its SFC Type 10 License, Lianhe Global will ensure it in compliance with paragraph 30 of the Code. Prior to commencing any ancillary services business, Lianhe Global will immediately notify the SFC in writing regarding the specific nature of such ancillary services; and provide details on Lianhe Global’s internal controls, governing regulations and compliance supervision that would support any ancillary business services in the future and apply for any relevant SFC licenses, if necessary.