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HONG KONG FINANCIAL INSTITUTIONS NEWSLETTER Issue 13: April / May 2010

Since the global financial crisis of 2008/2009, the global regulatory environment for financial institutions has entered

a new era of development and change. As the world economy recovers, new crises have emerged as well as new

opportunities for growth. In the current era of uncertainty for financial institutions, this newsletter highlights significant

regulatory and legal developments affecting the local financial services sector. Particular focus is paid to changes of

interest to professionals in the areas of asset management including both private equity and hedge funds, banking,

securities, insurance, and listings. The April / May edition of this newsletter is the first to be issued following our

Hogan Lovells merger and reports on some of the key developments since our March edition. This newsletter will be

provided monthly - assuming there is something to report - and covers the following topics.

Contents

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� Asset Management

� Banking

� Securities

� Listings Related

� General

Asset Management

� Singapore funds review

� Tiger Asia trading ban: first ever attempted exclusion in Hong Kong

� SFC bans former portfolio manager for life

Banking

� Islamic finance proposals

Securities

� SFC issues conclusions on regulation of structured products

� SFC clarifies obligations of licensed persons conducting business outside Hong Kong

� Financial advisors, fund managers and traders reminded of dealing and disclosure requirements under

the Takeovers Code

� New stamping procedures for stock borrowing and lending

Listings Related

� Consultations on disclosure of price-sensitive information and inside information

� SFC consultation on submission of routine announcements for comment

� SFC may probe recent Hong Kong IPO due diligence

Hong Kong Financial Institutions Newsletter - Issue 13: April / May 2010 2

� Former directors disqualified for failing to ensure timely disclosure

� SFC orders listed company to sue former directors

General

� Second phase consultation of Companies Ordinance

Asset Management

____________________________________________________________________________________________

� Singapore funds review

The Monetary Authority of Singapore (the "MAS") released on 27 April 2010 a consultation paper aimed at

improving the supervisory oversight of funds, while at the same time improving the quality of fund managers in

Singapore. The consultation is also careful to avoid increasing compliance costs and barriers to entry for funds.

Remarks - At present, funds in Singapore are either licensed or fall within one of several exemptions. The

Singapore regulatory regime for funds has been viewed by the market as an easier environment within which to

establish and operate as compared to Hong Kong, as the current regime allows for funds with less than 30

investors to set up in Singapore without a licence from the MAS.

The reforms will change the system so that retail funds will have to maintain a greater number of qualified staff

in Singapore as well as professional indemnity insurance cover. Further, the proposals will require non-

licensed funds to satisfy higher capital base requirements, in order to increase the viability of start-up funds.

The MAS has qualified this bar on entry by highlighting that the fund is still free to invest the base capital in any

investment of its choosing. The MAS continues to maintain a balance between improving its regulation of its

licensees / registrants while also retaining a "less strenuous" regulatory regime for the funds, where these do

not target the public. It remains to be seen whether the reforms will have a significant impact on the Singapore

alternative fund industry.

The consultation ends on 31 May 2010 and the consultation paper can be viewed HERE.

� Tiger Asia trading ban: first ever attempted exclusion in Hong Kong

The Securities and Futures Commission (the "SFC") has applied for a court order to prohibit Tiger Asia

Management LLC ("Tiger") from dealing in all listed securities and derivatives in Hong Kong for alleged insider

trading in relation to shares in Bank of China Limited ("BOC"). In August 2009, the SFC had commenced

proceedings against Tiger and three of its senior management for a separate allegation of insider dealing and

market manipulation in relation to dealings in shares of China Construction Bank Corporation ("CCB"), seeking

to freeze HK$29.9 million in Tiger assets. The latest filing by the SFC has amended this case to include the

latest allegations and seek a further injunction of up to HK$8.6 million of Tiger assets. Tiger has stated that it

will continue to "vigorously contest the SFC's accusations of wrongdoing".

Remarks - The case against Tiger represents the first time the SFC has sought to prohibit any entity from

trading in the Hong Kong market. According to the filings by the SFC, on three separate occasions Tiger had

been given advance notice of proposed placements of, separately, CCB and BOC shares. Tiger thereafter took

short positions or sold stock in both banks in order to downwardly manipulate their stock price.

One of the more unusual aspects of the case is a notional loss of HK$10 million made by Tiger in one of the

placements of the BOC shares, which the SFC has included as a separate count of insider trading. This

emphasises the dual nature of the insider trading offence under the Securities and Futures Ordinance ("SFO"),

in that the SFC can bring actions for insider dealings in securities which result either in the gain of a profit or the

avoidance of a loss.

The SFC actions have a further ramification. Tiger is a New York based asset management company with no

physical presence in Hong Kong. It will therefore be interesting to see whether the SFC is able to take action

beyond a trading prohibition against the management team of Tiger or indeed the firm itself.

The SFC press release can be viewed HERE and the 2009 SFC press release can be viewed HERE.

� SFC bans a former portfolio manager for life

The SFC banned a former portfolio manager (Mr Ryan Fong Yen-hwung) from re-entering the securities

industry for life. Mr Fong was sentenced in July 2009 to 12 months in prison and a fine of $1,372,218 for

insider dealing.


In 2005, Mr Fong (then a portfolio fund manager at HSZ (Hong Kong) Limited) received confidential and price

sensitive information from his friend Mr Allen Lam Kar Fai (then a director of investment banking at CLSA

Equity Capital Markets) about a proposed takeover of Media Partners International Holdings Inc. Taking

advantage of the information, he bought Media Partners shares, then sold them after the takeover was

announced, making $4.3 million for an HSZ fund and $1 million himself.

Remarks - The SFC's ban on Mr Fong shows again that even in cases when the culprits have already been

given prison sentences, the SFC will not hesitate to take disciplinary action of its own.

The SFC press release can be viewed HERE.

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Banking ____________________________________________________________________________________________

� Islamic finance proposals

The Panel on Financial Affairs of the Legislative Council (the "FA Panel") considered on 3 May 2010 fresh

proposals to encourage the development of Islamic finance in Hong Kong. The proposals reviewed potential

amendments to the Inland Revenue Ordinance (the "IRO") in order to ensure that Islamic finance practices

enjoy the same tax treatment as more traditional methods of finance. While the FA Panel aims to introduce a

bill to amend the IRO sometime this year, there are already in place procedures to gain exemptions from the

Inland Revenue for certain taxes by way of application. Such examples include profits tax, property tax and

stamp duty.

Remarks - The global Islamic financial industry is reported to have grown into a business worth an estimated

US$1 trillion. Hong Kong has been looking at ways and means to attract the industry since 2007. The current

proposals revolve around in-house findings by the Financial Services branch of the FA Panel to the effect that

Hong Kong's tax regime remains a major impediment to the development of Islamic finance in Hong Kong. This

is due to the asset based nature of Islamic financing transactions, such as the practice of leasing (i.e. Sukuk

financing). The FA Panel has targeted both the IRO and the Stamp Duty Ordinance for amendment to include

such provisions as the expansion of the qualifying debt instrument regime for Sukuk financing as well as further

stamp duty exemptions.

Hogan Lovells has an established and well regarded Islamic Finance practice and we are following this

development with interest. Since 2007 we have advised on more than 200 Islamic finance transactions with an

aggregate deal value in excess of US$40bn. We have also advised on numerous first-of-their-kind

transactions, such as the first convertible Sukuk, the first equity-linked Sukuk, and the first Sharia-compliant

securitization.

The Paper on the proposed amendments to the Ordinances can be viewed HERE.

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Securities ____________________________________________________________________________________________

� SFC issues conclusions on regulation of structured products

The FA Panel on 3 May 2010 considered the SFC's conclusions regarding the regulation of public offerings of

structured products. In April 2010, the SFC released its conclusions to the consultation issued on 30 October

2009. The consultation focused on the split between regulatory regimes for those products which involve equity

or debt capital raising activities, which are regulated under the Companies Ordinance (the "CO") and other

products, which are regulated under the SFO. As our article in Issue Nine of this newsletter discussed the

previous exemptions under the CO (such as the HK$500,000 safe harbour exemption and issues to no more

than 50 persons requirement for private placements) would no longer be available.

Remarks - The proposed reforms clearly reflect the attentions of the government in the wake of the Lehman

Brothers mini-bonds scandal, highlighted by the recent questioning of Amy Yip Yok-tak (CEO of DBS Bank) by

the Legislative Council subcommittee regarding Lehman minibond sales. The reform will rationalise the

regulation of all structured products so that the SFO and the SFC will cover the regulation of all forms of

structured products. Among the proposals, it is worth noting that the definition of structured product has been

left deliberately wide by the SFC, despite comments to the consultation paper that this was unnecessarily the

case. The SFC has however allowed that convertible and exchangeable bonds, as well as subscription

warrants issued for capital raising purposes, be put outside the definition. Some uncertainty remains as to

whether gold-linked deposits and index-linked instruments would also be caught by the new definition.


The SFC has yet to issue its conclusions to the attendant consultation on its new code on unlisted products,

which should provide clarity on how the SFC intends to regulate structured products in practice.

The SFC's proposals to the FA Panel can be viewed HERE.

� SFC clarifies obligations of licensed persons conducting business outside Hong Kong

On 1 April 2010, the SFC issued a circular clarifying the licensing obligations of corporations and individuals

conducting business outside Hong Kong. The SFC highlighted in particular its concern that some individuals

licensed under the SFO conducted business only outside Hong Kong (where the SFC has no jurisdiction) while

promoting themselves as licensed by the SFC. This is a concern, because:

• the SFO licence suggests that they are actively regulated by the SFC, but the SFC may only

exercise its powers within Hong Kong; and

• they misled the SFC about their intended business when they applied for licences (because the SFC

will not license individuals unless they will perform regulated functions in Hong Kong).

The SFC reminded individuals that providing false and misleading information for a licence application is a

criminal offence contrary to section 383 of the SFO.

Further, persons conducting business in other jurisdictions should ensure they are licensed in those

jurisdictions if required by the law of the respective jurisdiction. The SFC might question whether the licensed

corporation is fit and proper to continue to be licensed in Hong Kong if any individual (including employees or

agents) conducting business activities overseas on the corporation's behalf, is not licensed in accordance with

the requirements of the overseas jurisdiction or if they conduct themselves in an improper manner.

Remarks - The SFC has taken a public stance on the overseas actions of its licensees by suggesting that it

might take action against corporations whose employees or agents play fast and loose with the SFO licensing

regime in this way. It is not clear why the SFC is taking this point or where it is going. The nine types of

regulated activities under the SFO are broadly defined, and clients are advised to err on the side of caution and

apply for registration in case their incidental activities are caught.

The SFC exercises a prudential regime to enquire into the non Hong Kong activities of regulated firms on the

basis of the assessment of their fitness and their properness. In practice it has been no answer to say that the

activities the SFC has enquired into are outside the defined scope of regulated activities. The reality is that a lot

of regulated firms' activities in Hong Kong are "overseas", that is, outside of the Hong Kong market, and this is

particularly true of alternative fund managers. As Hong Kong has a sourced based profits tax regime, there is a

fiscal incentive to ensure that potential non Hong Kong activities are structured so that they fall outside the tax

net. It is doubted that few who have submitted to regulation by the SFC on the basis of caution would regard

that as playing fast and loose, rather than responsible and compliant.

The Circular can be viewed HERE.

� Financial advisors, fund managers and traders reminded of dealing and disclosure requirements under

the Takeovers Code

In the recent issue of the SFC's Takeovers Bulletin (Issue 12), the SFC reminded financial advisers of the rules

on dealings in listed securities before and during an offer period. Advisers should ensure that compliance and

monitoring systems, and training of personnel, are adequate to meet these requirements.

Remarks - The SFC's bulletin relates to Rules 21 and 22 of the Codes on Takeovers and Mergers and Share

Repurchases (the "Takeovers Code"), which presume that an offeror's financial adviser is acting in concert

with the offeror. If an adviser is part of a multi-service organisation, the presumption covers all entities within the

organisation, including fund managers and principal traders, unless they have exempt status under Practice

Note 9. Dealings by such fund managers and principal traders can have serious consequences, including

having to raise the offer price to the highest price they paid. The SFC's reminder reflects recent concern that

some entities within a financial services group have not complied with dealing and disclosure requirements,

albeit through human error, miscommunication and lack of oversight.

Takeovers Bulletin issue 12 can be viewed HERE, and Practice Note 9 HERE.


� New stamping procedures for stock borrowing and lending

The Stamp Office has revised the registration form for stock borrowing and lending agreements with effect from

1 April 2010. The revised form SBUL2 requires borrowers when registering a stock borrowing to now specify

the date of the first stock borrowing transaction of Hong Kong stock, if the borrowing was already effected as of

the date of registration with the Stamp Office. Transitionary arrangements have been implemented so that

completed SBUL2 forms provided before 30 April 2010 should still be accepted by the Stamp Office. The

corresponding lender's form for notification to the Stamp Office of a transaction (form SBUL26) has also been

revised.

In addition, registered borrowers now need only complete a return of stock borrowing transactions (form

SBUL1) where the transaction fails to meet reliefs granted under S.19(12) and S.19(12A) of the Stamp Duty

Ordinance.

The revised forms can be viewed on the Inland Revenue Department's website HERE, along with explanatory

notes to the changes in stamping procedure and registration of stock borrowing transactions.

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Listings Related ____________________________________________________________________________________________

� Consultations on Disclosure of Price-sensitive Information and Inside Information

On 29 March 2010 the Financial Services and the Treasury Bureau (the "FSTB") issued a consultation paper

proposing the requirement to disclose price sensitive information by listed corporations be codified into the

SFO. In line with the FSTB's paper, the SFC issued a consultation paper with draft Guidelines on how the

disclosure requirements would work in practice based on the legislation, relevant cases, and similar guidance

issued in the EU, the UK and Australia (taken as representing "international practices"). Both consultations end

on 28 June.

The SFO does not currently require listed companies to disclose price-sensitive, or "inside", information, but

there is such a requirement in the Listing Rules of the Hong Kong and Exchanges Clearing Limited (the

"HKEx"). Some observers have complained the HKEx requirements lack sufficient teeth, but that sentiment is

limited. The reforms will give the HKEx disclosure requirements a statutory backing, and give the SFC further

enforcement powers to pursue infractions. Current possible sanctions include causing a false market in

securities, which of course is the real fault, and which remains difficult to prosecute.

Remarks - At the heart of the proposed reforms is a requirement to disclose "inside information", defined the

same way as "relevant information" in the SFO's insider dealing regime. A listed company must, as soon as

practicable after the information comes to its knowledge, disclose to the public any specific information about

the company, its shareholders or directors, or its listed securities or their derivatives which is not generally

known to the market (that is, persons accustomed or likely to deal in the company's securities) but which would,

if generally known to the market, be likely to materially affect the listed securities' price. Examples of "inside

information" include changes in performance or financial condition; takeovers and mergers; and legal disputes

and proceedings. Rumours, media speculation and market expectations are not the same as information.

Where disclosure is prohibited by law or court order in an overseas jurisdiction, the SFC may, upon written

application, grant an exemption waiving the disclosure requirement. If inside information is uncovered while

preparing required periodic disclosure documents or audited accounts, it must be disclosed separately and

immediately. Disclosure cannot be deferred until the report is released.

Having first cast the net wide, the proposals then establish "safe harbours" which constitute exceptions to the

general requirement. The most important of these will likely be those for (1) ongoing negotiations whose

outcome may be prejudiced by premature disclosure, and (2) trade secrets. To rely on these, a listed company

must not only take reasonable steps to preserve confidentiality, the confidentiality must in fact be preserved.

The proposals also require a listed company to respond to market rumours in certain circumstances. So these

safe harbour provisions may often provide only temporary relief from the obligation to disclose. A release of

information from any source, even inadvertently, means that confidentiality is lost, the safe harbour will no

longer apply, and the listed company must disclose the inside information immediately.

A concern is that this would allow the SFC an ability to prosecute and obtain criminal convictions for mere

'technical' breaches or poor corporate governance. A common weakness encountered in corporate governance

is that discussions regarding non-disclosure are seldom dealt with in a formal way or contemporaneously

minuted.


The FSTB's proposals can be viewed HERE and the SFC's consultation paper on the draft guidelines HERE.

� SFC consultation on submission of routine announcements for comment

An SFC consultation paper issued on 21 April 2010 proposes to amend Rule 12.1 of the Takeovers Code so

that certain routine announcements would no longer have to be submitted to the SFC for comment before

publication. The consultation ends on 19 May.

Currently all documents issued under the Takeovers Code, such as announcements and circulars, must be

submitted to the SFC for comment before publication, and may not be issued until the SFC confirms it has no

further comments. Since the SFC normally has no comments on certain routine documents, it is now proposed

that documents on a "Post-Vet List" (to be posted on the SFC website) will not have to be submitted for

comment, but would instead be filed immediately after publication. The initial Post-Vet List would be:

• appointment of independent financial advisers under Rule 2.1;

• despatch of circulars under Rule 8 or Rule 25;

• delay in despatch of circulars under Rule 8.2 or Rule 8.4;

• appointment and resignation of directors of the offeree company under Rule 26.4 and Rule 7; and

• placing and top-up transactions under Note 6 on dispensations from Rule 26.

The SFC could still require that documents on the Post-Vet List be submitted for comment "if considered

necessary or appropriate".

Remarks - The SFC cites as reasons for this proposed change lowering compliance costs and burdens for

parties issuing routine announcements, and promoting self-discipline among them and their financial advisers.

Another benefit is that information in the announcements will reach the market faster, without the delay

occasioned by having to submit it to the SFC for comment.

The SFC has in the past conducted similar streamlining of other announcements or circulars required to be

vetted by the SFC (such as the streamlining of the SFC's pre-vetting of advertisements in relation to SFC

authorised funds). It is not expected that such proposals which are targeted at reducing the burden on pre-

vetting of documents with the SFC will be met with strong disapproval from the market.

The consultation paper can be viewed HERE.

� SFC may probe recent Hong Kong IPO due diligence

At a recent conference in Shanghai, the head of the SFC hinted that the SFC may be launching a probe into a

number of last year's IPOs in Hong Kong following recent problems with certain companies very soon after they

had floated on the HKEx. As the SFC supervisory regime has been implemented for a few years, the SFC may

view this as an appropriate time to review progress in this area.

Remarks - The SFC actions regarding Hontex International Holdings Company Ltd highlights the potential for

abuse, although the facts remain disputed. In the Hontex case, the SFC has alleged that the company misled

investors about its finances, particularly in a key sentence in the prospectus stating that sales and profits of the

company had increased by a significant factor. Those figures are now in question after the Independent

Commission Against Corruption charged a senior manager of KPMG with offering to bribe a subordinate

HK$100,000 as a reward for preparing the accountant's report for the Hontex global offering. The SFC has

also applied to court for an order to recoup the net proceeds raised by Hontex in its IPO and has successfully

sought an injunction to freeze assets of Hontex and four of its wholly owned subsidiaries valued at

approximately HK$997 million.

It is curious that the authorities were in a position to take action against the newly listed company only a few

weeks after the entry was approved and implemented. However, frequently allegations of fraud do surface at

the time of a listing, and often traced to former staff or business rivals. These complainants may be in a position

to know of wrongdoing, but they are often suspect in terms of motivation. Happily, in the cases we have dealt

with, the authorities have been satisfied that the allegations of manipulation have been unfounded. However,

there are too many cases where financial performance is manipulated by aspiring issuers which goes

undetected until the well dries up following the listing.

The SFC press release relating to the case of Hontex can be viewed HERE.

� Former directors disqualified for failing to ensure timely disclosure


The SFC on 17 March 2010 obtained High Court orders disqualifying two former executive directors of Warderly

International Holdings Ltd, Ms Ellen Yeung Ying Fong and Mr John Lai Wing Chuen, for failing to ensure timely

disclosure of material information. Ms Yeung and Mr Lai are disqualified from being directors or being involved

in any company's management, without leave of the court, for five years effective 7 April 2010. A similar SFC

action against four other former Warderly directors is still pending.

This was the first time directors have been disqualified for this type of misconduct. (Under the SFO, a director

can be disqualified for up to 15 years if the director is wholly or partly responsible for the company's affairs

having been conducted in a manner involving defalcation, fraud or other misconduct.)

Warderly was listed in December 2002. Its main business is designing, manufacturing and selling household

electrical appliances to Europe. Trading was suspended on 14 May 2007 after its 30 April 2007 financial

statements showed a loss of over $700 million and liabilities exceeding assets by $367,380,000. The SFC

alleged that it should have disclosed its substantially depleted financial position as these events happened:

• banks and creditors brought legal proceedings in Hong Kong and the Mainland to recover overdue loans;

• strikes in its Mainland factory substantially disrupted operations;

• it appointed a financial adviser for a proposed debt restructuring and re-organisation, and a management

committee to solve its financial problems;

• external accountants appointed on a bank loan syndicate's request reported on its deteriorating finances;

and

• it was forced to raise money by way of loans at penalty interest rates to stay afloat.

It will be delisted in May 2010 if it does not submit a viable resumption proposal.

Remarks - These first successful disqualifications and pending similar actions send a clear message to the

market that directors must ensure their companies report disclosure of material information on a timely basis or

face action by the SFC.

The SFC press release can be viewed HERE

� SFC orders listed company to sue former directors

On 18 March 2010, the SFC obtained a court order directing Rontex International Holdings Ltd (now "Siberian

Mining Group Company Ltd.") to bring, within 60 days, legal proceedings for compensation against three of its

former executive directors, Mr Cheung Keng Ching, Ms Chou Mei and Mr Kevin Lau Ka Man. Rontex may use

the SFC’s evidence in the proceedings, must give the SFC quarterly progress reports, and may settle with the

directors (subject to court approval).

This is the first time the SFC has obtained a High Court order directing a listed company to bring a civil action

seeking recovery for damages caused by its directors’ misconduct.

The court also disqualified Mr Cheung and Ms Chou from being a director or being involved in any company's

management, without leave of the court, for five years from 18 March 2010 (except for a private company they

use to conduct a business). Mr Lau (who consented to the orders) was disqualified for four years.

Rontex was listed on 8 November 2002. It was then sourcing, manufacturing and selling garments, and trading

baby and party products and other items to South America and Canada. The court found the directors had, in

four investments by Rontex or its subsidiaries from 2002 to 2005 which resulted in about $19 million damages:

• breached their fiduciary duty and/or duty of care owed to Rontex;

• failed to ensure shareholders received all the information on Rontex they might reasonably expect; and

• failed to exercise reasonable skill, care and diligence in entering into imprudent transactions for Rontex.

Remarks - The SFC is starting to use section 214 of the SFO to obtain compensation from directors for damages to their companies for which have legal liability. (See also the article on "Former directors disqualified for failing to ensure timely disclosure.") The rationale, broadly similar to that for U.S. shareholder derivative suits, is that shareholders should not have to pay for losses caused by directors' misconduct.


The SFC press release can be viewed HERE.

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General ____________________________________________________________________________________________

� Second phase of consultation on Companies Ordinance

The FSTB on 7 May 2010 commenced the second phase of consultations considering the Companies Bill (the

"Bill"). The consultation addresses the latter half of the Bill, which examines issues such as business

facilitation, share capital, accounting and auditing. As discussed in Issue Eleven of this newsletter, the previous

consultation addressed mainly corporate governance issues, such as the 'headcount test' for restructuring or

privatising a company and the codification of director's fiduciary duties.

The main heads of discussion in the current consultation include the following major proposals:

• greater disclosure of company information, and the addition of requirements for forward looking statements to be prepared as part of the directors report;

• review of the prohibition against a private company providing financial assistance for the purchase of shares in itself;

• broader powers for the Financial Secretary to investigate or enquire into a company's affairs, as well as allowing the Companies Registrar to obtain documents, records and other information in specific instances;

• drop a previous proposal that companies be required to prepare directors' remuneration reports at shareholders request;

• enhancing auditors' rights to obtain information necessary to perform their duties; and

• requiring directors who have refused to register a share transfer to provide reasons for the refusal.

Remarks - The reforms represent efforts to enhance the company's reporting requirements in the interests of greater corporate transparency, while streamlining the burdens for private companies. Of particular note are the proposals for greater penalties for failure to comply and aid regulators. These include penalties of up to seven years jail time and a fine of HK$1 million for those who provide false information to inspectors appointed by the FS, and sanctions for those who refuse to co-operate of up to 12 months jail time and a HK$200,000 fine. In addition, auditors who resigned and failed to provide clear reasons for doing so could be fined up to HK$150,000.

The consultation ends on 6 August 2010. A copy of the consultation paper can be viewed HERE.

Back to top >>

If you would like to discuss any of the matters in this newsletter or wish to have further information on our financial

institutions practice in Hong Kong, please contact the person at Hogan Lovells whom you usually deal with or:

Tim Fletcher, Partner, T: +852 2840 5011, [email protected]

Simon Yu, Consultant, T: +852 2840 5020, [email protected]

Joey Tse, Senior Associate, T: +852 2840 5051, [email protected]

Joanna Yau, Associate, T: +852 2840 5621, [email protected]

"Hogan Lovells" or the "firm" refers to the international legal practice comprising Hogan Lovells International LLP, Hogan Lovells US LLP, Hogan

Lovells Worldwide Group (a Swiss Verein), and their affiliated businesses, each of which is a separate legal entity. Hogan Lovells International LLP is

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Atlantic House, Holborn Viaduct, London EC1A 2FG. Hogan Lovells US LLP is a limited liability partnership registered in the District of Columbia.

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LLP. Where case studies are included, results achieved do not guarantee similar outcomes for other clients. New York State Notice: Attorney

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