The Zubin Foundation Code of Conduct

Code of Conduct

Our Mission and Values

The mission of The Zubin Foundation is to improve the lives of ethnically diverse individuals in Hong Kong by reducing suffering and providing opportunities. The focus of The Zubin Foundation is on important, often marginalised, social issues where people in Hong Kong are denied dignity, respect and sometimes life itself. Hong Kong is our home, and our vested interest is to have a more inclusive and stronger Hong Kong.

The Zubin Foundation is a values-driven organisation, and our aims are:

  1.  Value for Life – we value life and believe that all lives must be treated with dignity and respect.
  2. Integrity – we value honesty; and integrity is about being honest to our beliefs.
  3. Diversity, Equity and Inclusion – we appreciate the importance of diversity of thought, and seek to be inclusive in our engagement and work.
  4. Professionalism – our work will be delivered to the highest possible professional level.
  5. Transparency – we believe that a transparent organisation is critical for building trust and partnerships in the community.
  6. Collaboration – we seek to collaborate with partners – individuals, organisations, companies and the government, both at home and abroad.

Our Code of Conduct
This Code of Conduct applies to everyone who works with and represents The Zubin Foundation, including our board members, employees, volunteers, agents, and contractors (referred to collectively as “Personnel”). In performing our duties, we must always act lawfully, ethically, and in the best interests of The Zubin Foundation and the communities we serve. This Code of Conduct sets out basic guiding principles rooted in our values. We encourage you to speak with anyone in Management if you have a question about this Code of Conduct, are unsure how to act in a particular situation, or have any ethical concerns.

Compliance with Laws, Rules and Regulations

We must follow all applicable laws, rules, and regulations of Hong Kong at all times.

Conflicts of Interest
We are expected to use our judgment to act, at all times, in the best interests of The Zubin Foundation. A “conflict of interest” exists when your personal or family interests interfere, or appear to interfere, with the Foundation’s interests. This can arise from relationships, external business activities, or the receipt of personal benefits due to your role.

Anti-Bribery, Corruption, and Theft
Upholding our value of Integrity, The Zubin Foundation maintains a zero-tolerance policy towards bribery, corruption, and theft. All individuals acting on our behalf must act with impartiality and objectivity.

  • Legal Compliance: You must be aware that dishonesty, theft, and corruption on the part of our Personnel are criminal offences and may lead to prosecution under:

    • Section 9 of the Prevention of Bribery Ordinance (Cap. 201);
    • Sections 17, 18D and 19 of the Theft Ordinance (Cap. 210); and
    • Section 161 of the Crimes Ordinance (Cap. 200).
  • Specifically, you must not:
    • Solicit or accept any “advantage” (as defined below) in connection with your work;
    • Solicit or accept any hospitality, entertainment, or inducement that could impair, or be seen to impair, your impartiality or objectivity;
    • Commit, or aid in, any offence under the ordinances listed above.
  • Definition of an “Advantage”: The term “advantage” is defined broadly under the Prevention of Bribery Ordinance (Cap. 201). It includes, but is not limited to:

    • Any gift, loan, fee, reward, or commission.
    • Any office, employment, or contract.
    • Any payment, release, or discharge of a loan or obligation.
    • Any other service or favour (such as insider information, preferential treatment, or intangible benefits).
    • Important Note: The value of the advantage is not the primary issue; the solicitation or acceptance of any advantage in the context of your work may be an offence, regardless of its monetary worth. There may be limited, specific contexts where accepting a modest token (e.g., a small promotional item) or customary business courtesy is permissible. However, you must never assume an advantage is acceptable. If you are offered any advantage, or are uncertain, you must seek prior guidance and approval from Management or the Founder. Full and immediate disclosure is your essential safeguard.

Safeguarding and Professional Boundaries with Beneficiaries
Our work is centred on the dignity and respect of the people we serve, in line with our core value of Value for Life. All relationships with beneficiaries must be professional, appropriate, and protective.

  • You must maintain clear professional boundaries. Inappropriate personal relationships with beneficiaries are prohibited.
  • You must not engage in, facilitate, or condone any form of exploitation or abuse, including but not limited to slavery, forced labour, servitude, forced marriage, or sexual slavery and exploitation.
  • Physical, sexual, emotional, or financial abuse of beneficiaries is strictly forbidden.
  • You have a duty to report any concerns or suspicions of exploitation or abuse against a beneficiary immediately to Management or the Founder.

Discrimination and Harassment
The Zubin Foundation provides equal opportunity in all aspects of employment and engagement and will not tolerate any illegal discrimination or harassment of any kind. We are committed to a culture of respect that embraces our value of Diversity, Equity and Inclusion.

Health and Safety
The Zubin Foundation strives to provide a clean, safe and healthy work environment. Each of us shares responsibility for maintaining this by following safety and health rules, reporting accidents or unsafe conditions, and refraining from violent or threatening behaviour. You must report to work in a condition fit to perform your duties, free from the influence of illegal drugs or alcohol.

Recordkeeping, Reporting, and Financial Integrity
In line with our values of Professionalism and Transparency, The Zubin Foundation’s books, records, accounts, and financial statements must be maintained accurately, reflect transactions properly, and conform to applicable law and internal controls. All reports must contain full, fair, accurate, timely, and understandable disclosure.

Questions; Reporting Violations
We encourage open communication. You should speak with anyone in Management if you have a question about this Code of Conduct or wish to report a suspected violation.

The Zubin Foundation prohibits retaliation against anyone who, in good faith, reports a concern or suspected violation. All reports will be treated confidentially to the extent possible.Personnel who violate this Code of Conduct will be subject to appropriate disciplinary action, which may include termination of employment or engagement.


This Code of Conduct is a living document that reflects our shared commitment to ethical excellence. Thank you for upholding these standards and the values of The Zubin Foundation in all that you do.

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