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OFFICE MANUAL July 2024

1 OLN Office Manual INTRODUCTION PRACTICAL LEGAL SOLUTIONS – ON TIME – NO EXCUSES This Office Manual explains the rules and procedures of work at Oldham, Li & Nie. It is intended as an introduction to the firm for new members of staff and as a point of reference for everyone. The manual should be regarded as being a helpful and constructive reference book. All of us must be familiar with its content. This manual sets out policies generally applicable to all employees of Oldham Li & Nie. Throughout this manual, your employer is referred to as OLN, “we” or “us”. Although this manual is not contractually binding, it is intended to be read in conjunction with your Employment Contract which was issued to you separately. In the event that there is a discrepancy between any of the terms of this manual and those set out in your Employment Contract, the terms of your Employment Contract shall prevail. OLN shall regularly review and update this manual and reserves the right to amend, add, or delete your terms and conditions of employment and any benefit schemes provided by OLN. This manual is the property of OLN. Under no circumstances may this manual (in electronic form or hard copy) be borrowed by or lent to unauthorized persons outside of OLN. OLN welcomes any constructive comments on the Manual and particularly on any additional matters that should be included. If you have any questions, please contact the Office Manager. OLN was founded in 1987 by Gordon Oldham and was then known as Gordon D. Oldham & Co. In 1990 the firm changed its name to Oldham, Li & Nie. OLN is committed to professional excellence and to tailoring its legal services to the needs of the business community and private clients. With years of experience practicing in Hong Kong and a diverse set of global employees, OLN truly embodies an East meets West culture. We pride ourselves on having a practical approach and results oriented outlook. OLN's principal focus is on Corporate and Commercial, Dispute Resolution, Intellectual Property, Employment, Divorce & Family Law, Private Client Services, Tax Advisory. OLN has won numerous awards and consistent recognition for its key practice areas, including being highly regarded by both Chambers Asia and Legal 500. We also have a thriving China practice, carried on from Hong Kong and Shanghai offices and when necessary, with our associate legal network in China.

2 OLN Office Manual TABLE OF CONTENTS Introduction ...................................................................................................................... 1 General Conditions of Employment ............................................................................... 5 Leave & Holidays ............................................................................................................. 8 Termination of Employment ........................................................................................ 11 Equal Opportunities ....................................................................................................... 13 Training ........................................................................................................................... 15 Client Care ...................................................................................................................... 18 Complaints-Handling Procedure .................................................................................. 23 Health and Safety and Office Security ....................................................................... 25 Time-recording ............................................................................................................... 29 Finance and Accounting ............................................................................................... 30 Communication .............................................................................................................. 33 Library ............................................................................................................................. 36 Client Files / Clio ........................................................................................................... 37 Anti-Money Laundering ................................................................................................. 40 Anti-Bribery and Anti-Corruption ................................................................................. 42 Information Security ...................................................................................................... 46 Personal Data and Privacy .......................................................................................... 53 Addendum to Office Manual (1) .................................................................................. 56 Addendum to Office Manual (2) .................................................................................. 57 Addendum to Office Manual (3) .................................................................................. 58

3 OLN Office Manual Employee relations The success of Oldham, Li & Nie depends on all personnel performing their role within the firm as effectively as possible. OLN places great importance on maintaining employee relations in harmony with our successful operation. OLN maintains a working environment free of both discrimination and harassment, while extending equal opportunity to all employees. If we are to succeed in this strategic plan the quality of our service to clients is crucial. Much of our work comes from clients who have instructed us in the past. Other common sources of instructions are referrals from clients and other professionals such as banks, estate agents and accountants. Our record of service and reputation is therefore vital for the future success of the firm. Everyone in the firm plays a part in the impression that clients form of us. The greeting that the client receives in reception, the efficiency with which we deal with telephone calls, the quality of correspondence and the avoidance of any form of delay are all elements of the objectives which we have set for ourselves. Quality OLN strives to provide accurate, reliable and practicable legal advice and services tailored to each client. Our work objective: PRACTIAL LEGAL SOLUTIONS – ON TIME – NO EXCUSES If there is one matter above all about quality of service it is the following: Clients take for granted that the quality of the legal advice will be high. If we are to distinguish ourselves from others, we have to be superior in delivery of this advice. We have to meet our client’s expectations and surpass them in terms of form of delivery, speed of delivery, value, friendliness and accuracy. We have to make the experience of coming to Oldham, Li & Nie superior in every regard to their experiences with other lawyers. This ranges from reception and cups of tea to the quality of advice and delivery of the same! That is why each member of staff is a very important part of the whole experience.

4 OLN Office Manual Management The management of the firm is principally organised through meetings of a Management Committee which usually occurs every four weeks. Any member of staff who feels he or she is able to contribute to the development or better administration of OLN and is prepared to dedicate the time to such is welcome to put themselves forward as a member of the Management Committee. Members of the Management Committee Members of the Staff Representative Ruby Ng Director of Operations Paul Firmin Partner Robert Campbell Office/Services Manager Anna Chan Partner Stephen Peaker Senior Partner Gordon Oldham Senior Partner Terence Siu Financial Controller Felix Wu Credit Control Manager Perry Lam Legal Executive Brenda Leong Senior Secretary

5 OLN Office Manual GENERAL CONDITIONS OF EMPLOYMENT Conditions of employment Your employment is conditional upon the following: • You must possess the knowledge, skills, experience and ability that you represented to us in your employment application or at any interview; • The representations made by you in respect of your previous employment history and work experience must be true and accurate; • You might be required to produce for inspection the originals of any examination or qualification certificates; and • You must have the right to work in Hong Kong. If you are not a citizen or permanent resident of Hong Kong, you must obtain a visa which allows you to work in Hong Kong and ensure that it remains current throughout the duration of your employment in Hong Kong. OLN reserves the right to terminate your employment without notice or payment in lieu of notice if it is discovered that you have misrepresented any of the factors referred to above or if you do not acquire and maintain relevant qualifications or immigration status for your position. Probationary period In general, all new employees must undergo a minimum probationary period of 3 months. OLN may impose a different probationary period is required from the beginning of your employment, this will be specified in your Contract of Employment. At the end of the probationary period your performance will be reviewed. Provided that you and OLN are satisfied, you will be informed in writing of your appointment as a full employee. Until your appointment as a permanent employee you may not entitled to any employee benefits other than those specifically detailed in your Contract of Employment. To be eligible for any type of bonus, you must have completed your probationary period. Temporary and part-time employees If you are a temporary or part-time employee, you are only entitled to the employee benefits that are specifically detailed in your Contract of Employment and not to the additional benefits that may be referred to in this manual. Induction It is important that we welcome new people to the firm as quickly and efficiently as possible. In this way we can minimise the tension that they will feel in being in a new job and ensure that they are confident in their new role in the firm as soon as possible.

6 OLN Office Manual Salary, remuneration and expenses Your salary will be paid monthly in arrears by bank auto-pay, or another method agreed by us. You must inform OLN of any changes to your bank or bank account numbers as soon as practicable. You will be paid or reimbursed for any reasonable expenses properly incurred by you while performing your duties on behalf of OLN, subject to you: (a) producing receipts for such expenses when requested by OLN; and (b) complying with OLN’s rules and policies relating to expenses. OLN shall be entitled at any time during your employment, and in any event on termination, howsoever arising, to deduct from your remuneration any monies due from you to OLN including loans for training costs, advances, the cost of repairing any damage or loss to OLN’s property caused by you, excess holiday and any other monies owed by you to OLN, to the extent permitted by law. OLN may be obliged by law to withhold final payments if you are about to leave Hong Kong after the termination date. OLN will release the final payments upon receipt of a letter of release from the Inland Revenue Department or at such other time as required by law. Hours of work and attendance You must report for duty punctually. We expect your full commitment to your job during your regular workday, personal appointments, including doctors and dentists’ visits should be scheduled outside of working hours whenever possible. Habitual late arrivals, early departures or absence from work without prior notification will be taken into consideration in evaluating performance, and may result in disciplinary action. Administrative leave OLN has the right to require you to take administrative leave and not to attend work and/or perform your duties. Provided that you comply with the instructions issued by OLN during any administrative leave period, you will continue to receive your usual pay and contractual benefits. OLN may ask you to take any unused annual leave during any administrative leave period to the extent possible. During any administrative leave period you must remain readily contactable and available for work. Should you fail to make yourself available for work having been requested to attend, you may forfeit your right to salary, bonus and/or any other remuneration in respect of such period of non-availability. GOOD TIME KEEPING IS IMPORTANT Normal working hours are 9.30 a.m. to 6.00 p.m. with one hour for lunch from 1 p.m. to 2 p.m. It is a matter of courtesy to the clients who expect us to be available when the office opens and to colleagues who may have to cover for late attendance of others.

7 OLN Office Manual Recruitment and references All recruitment (including hiring holiday interns) must take place via the Director of Operations and requires partnership approval. It is the responsibility of the Director of Operations together with the relevant head of department to draft the job description and a person specification. We will often be asked to provide references on personnel who are leaving us or who have previously worked for us. References must be made or copied to HR and should contain the following disclaimer: ‘This reference is a statement of opinion only and should not be relied upon in any decision which the recipient is considering. We accept no liability for any decisions taken or not taken as a consequence of information provided in this reference, whether direct or indirect.’ Our equal opportunities and anti-discrimination policies extend to recruitment procedures generally.

8 OLN Office Manual LEAVE & HOLIDAYS Annual leave OLN’s annual leave year is the calendar year. You are entitled to paid annual leave after satisfactory completion of your probationary period. Your annual leave entitlement is set out in your Contract of Employment. If you join or leave OLN during a year, your annual leave entitlement for that year will be pro- rated based on the number of calendar days you are in service. The portion of annual leave required under Hong Kong law (which increases from year to year) is “statutory annual leave” and any leave granted in addition to that statutory minimum is referred to as “additional annual leave”. Except in the first year, annual leave taken will be reduced against your statutory annual leave balance first. Once you use all of your statutory annual leave, any further leave you take will be reduced against your additional annual leave balance. OLN encourages you to take all annual leave (statutory and additional) by the end of March following the year in which the leave accrues. If you cannot take all annual leave accrued in the previous year by the end of March, you can carry forward the unused annual leave to the end of the year, following which any unused annual leave will be deemed waived by you, subject to applicable law. In other words, you will not be entitled to further carry forward or be paid in lieu of any annual leave that has not been used by the end of the year following which it accrues. OLN reserves the right to compulsorily schedule statutory annual leave in accordance with the Employment Ordinance in order to comply with its statutory obligations. Leave application should be submitted at least seven calendar days in advance. Your Manager will determine whether to grant leave based on operational requirements and other relevant factors. You are encouraged to take annual leave for an unbroken period for at least seven working days consecutively in each calendar year. You are not allowed to take annual leave during your first month of employment. If you take annual leave after the first month but during your probationary period, and leave OLN before the completion of your probation period, you are obligated to repay OLN annual leave pay for any annual leave taken. Advance annual leave (i.e. taking annual leave which has not yet been accrued) is not allowed. On cessation of employment, you will be paid in lieu of accrued but unused statutory annual leave granted under the Employment Ordinance only. You will be obliged to repay any annual leave pay received in excess of your entitlement.

9 OLN Office Manual Sick leave Sick leave entitlement is accumulated in accordance with the Employment Ordinance as follows: • Two paid sickness days for each completed calendar month during your first 12 months of continuous service; and • Four paid sickness days for each such month thereafter up to a maximum of 120 paid sickness days. You are entitled to statutory sickness allowance (at 80% pay) if you take sick leave for four or more consecutive days, provided that (i) you have accumulated sick leave entitlement in accordance with the Employment Ordinance as summarized above and (ii) you are certified unfit for work by a registered doctor/ a registered Chinese medicine practitioner / a registered dentist. Although you must be absent due to sickness for four or more consecutive days in order to receive statutory sickness allowance, OLN, in its discretion will allow two paid (at basic salary only) sick leave days every month provided that you have submitted supporting medical evidence. This benefit shall not accumulate month-to-month. You must inform your direct manager or the Office Manager at least one hour before the commencement of your scheduled working hours if you intend to take sick leave on the day otherwise, this may be treated as unauthorised absence and you may be subject to disciplinary action. You must submit your sick leave application by filling in and signing the leave application form within 48 hours after resuming work. The original sick leave certificate (showing your full name, date of consultation, diagnosis and sick leave days recommended, doctor’s name and signature) must be submitted to the Director of Operations within 48 hours of you resuming work. Copies will not be accepted. If you cannot submit an original valid sick leave certificate, the sick leave will be treated as unpaid leave and your payroll will be deducted accordingly. OLN reserves the right to require you to undergo a medical examination by a doctor nominated by OLN at any time, in which case OLN will bear the cost of such medical examination. You consent to: (i) the disclosure to OLN of the results of the examination by such doctor; (ii) OLN disclosing your sick leave records to the doctor; and (iii) OLN asking the doctor directly any follow-up questions in relation to the medical report, prognosis or about the examination. You may be granted unpaid sick leave at OLN’s sole and absolute discretion.

10 10 OLN Office Manual Maternity & paternity leave Maternity and Paternity leave will be granted in accordance with the Employment Ordinance and further information can be provided by the Director of Operations. Marriage leave/ Civil partnership leave If you have at least one year of service before your date of marriage or the registration of your civil partnership, you are entitled to three working days leave (paid at basic salary only), to be taken one month before or after the marriage or civil partnership registration date. Any unused marriage leave after the expiration of the one month’s period will be forfeited without payment in lieu. You should submit a copy of your marriage certificate to the Director of Operations within one month after the marriage or civil partnership registration date. Compassionate leave If you have completed your probationary period, you can take compassionate leave according to the following table if a family member passes away: Parents, spouse, children* 3 working days Other family members 1 working day You should take the compassionate leave within two months of the death with the approval of your Manager. The compassionate leave will be paid at your basic salary only. Any unused compassionate leave after the expiration of the two months’ period will be forfeited without payment in lieu. You should submit a copy of the family member’s death certificate to your Manager within one month of taking the compassionate leave. Jury leave If you are called for jury service, you must inform the Director of Operations as soon as possible and provide a copy of the summons. You will be paid in full for the days spent for jury service. If you are excused from jury service, you should report duty in the normal manner. GENERAL HOLIDAYS You are entitled to paid general holidays (i.e. public holidays) as announced by the Hong Kong Government from time to time. In general, the holidays are as follows: • Every Sunday or another substituted rest day • The first week-day in January Lunar New Year's Day • The second day of the Lunar New Year • The third day of the Lunar New Year • Ching Ming Festival • Good Friday • The day following Good Friday • Easter Monday • Labour Day • Birthday • Tuen Ng Festival • The day following Chinese Mid-National Day • Chung Yeung Festival • Christmas Day • The first weekday after Christmas Day If you are asked to work on a public holiday by your Manager, OLN will appoint an alternative day off within 60 days (before or after) the public holiday. OLN has the right to assign a substituted holiday to be taken on one of your days off, provided such day off is not your rest day.

11 11 OLN Office Manual TERMINATION OF EMPLOYMENT Notice Your notice period is stated in your Employment Contract. If you leave your employment without serving or making a payment in lieu of your notice period, OLN will be entitled to deduct from any further sum due to you a sum equal to your average daily wages for the duration of the notice period. Summary dismissal Subject to the Employment Ordinance, OLN may terminate your employment without notice or payment in lieu if you (without limitation): • Willfully disobey a lawful and reasonable order; • Misconduct yourself, such conduct being inconsistent with the due and faithful discharge of your duties; • Are guilty or fraud or dishonesty; • Are habitually neglectful in your duties; • Are persistently late for work; • Sleep during working hours; • Incite civil or commercial unrest; • Are grossly negligent in your handling of Company property; • Steal (or attempt to steal) Company property; • Gamble or partake of alcoholic drink or illegal drugs during working hours or whilst on Company premises; • Act in any manner which is prejudicial to OLN’s interests or destroy or put in jeopardy OLN’s property, the lives of Company employees or their personal safety; • Disclose OLN's Confidential Information; or • Without approval from the Management, provide OLN materials to any person outside OLN. Obligations on termination Prior to your final day of employment (or at any other time, if requested by OLN), you must return all properties that belong to OLN property, including the following items: • Business cards; • Passwords, access cards / codes or information, if applicable; • Company credit card, if applicable; • Company equipment such as mobile phone/camera/laptop/blackberry; • All Confidential Information; and • All Company-issued keys and other physical representations of authority. You must not destroy, erase, tamper with or damage any property that belongs to OLN (including, for the avoidance of doubt, any electronic materials) prior to their return, unless otherwise directed by OLN in writing.

12 12 OLN Office Manual If requested by OLN, you must immediately resign without compensation from any directorship or other offices held by you in OLN and Group, and from any other offices you may hold as nominee or representative of OLN or Group. You will be required to settle all Company accounts, including expense accounts, travel advances etc. During the notice period, you will use your best endeavours to assist OLN to achieve a smooth and orderly handover and transition of your workload and responsibilities. You must participate fully in handing over your work and responsibilities to other employees as may be required. Following your termination date, you will not represent yourself as being in any way connected with the businesses of OLN (except as a former employee in your job applications or to the extent agreed in writing). Garden leave OLN reserves the right to require you to remain away from your place of work or any of its other locations (including not contacting colleagues, clients, etc.) for the duration of your notice period (“Garden Leave”). During any Garden Leave period, you remain an employee of OLN and must continue to comply with all reasonable instructions. You cannot commence alternative employment during this period. OLN will continue to pay your basic salary during any Garden Leave period.

13 13 OLN Office Manual EQUAL OPPORTUNITIES OLN is an equal opportunity employer. We endeavour to ensure that every job applicant and employee has equal employment opportunities compared to people of equal ability. We consider that the diversity of individual talents in our workforce strengthens our creativity, and allows us to develop and best serve our clients. We believe that everyone has the right to work in an environment free of discrimination, harassment, vilification, and victimisation. The firm is committed to providing equal opportunities in employment. This means that all job applicants and employees will receive equal treatment regardless of sex, marital status, race, religion, family status, sexual orientation, colour, nationality, ethnic or national origins, or disability (“protected characteristics”). It is the responsibility of each employee to help to ensure that the work environment is free of discrimination and harassment. Discrimination OLN will not accept direct or indirect discrimination based on the protected characteristics. Direct discrimination is when an employee is treated less favourably solely because of the protected characteristics. Indirect discrimination is when an employee is treated the same way as everyone else but the employee does not or cannot comply with a rule, condition or requirement of employment that applies to everyone because of any of the protected characteristics, in situation where a higher proportion of people who do not have that characteristic do or can comply to it. However, it would not be indirect discrimination if OLN can give a valid reason for such a requirement. Harassment OLN will not accept any kind of harassment based on the protected characteristics. Harassment is behaviour that is not welcome, and which is likely to cause an uncomfortable workplace by humiliating, seriously embarrassing, offending or intimidating someone. You are responsible for your own actions and should not engage in potentially offensive behaviour. Vilification Vilification of an employee because of his/her protected characteristics is unacceptable in this workplace. Vilification is any activity in public that incites hatred, serious ridicule or contempt of a person because of his/her protected characteristics such as disability or race. Such vilification may constitute a criminal offence in serious cases (such as involving threats of harm or property damage).

14 14 OLN Office Manual Victimisation OLN will not disadvantage you for complaining about unlawful conduct in this workplace or for helping someone else to do so. OLN takes reports of discrimination, harassment, vilification and victimization very seriously and will handle such complaints as quickly, confidentially and fairly as possible. Guidelines on sexual harassment Sexual harassment occurs where a person: (a) Makes an unwelcome sexual advance; (b) Makes an unwelcome request for sexual favours; (c) Engages in other unwelcome conduct of sexual nature in circumstances where a reasonable person, having regard to all the circumstances, would have anticipated that the person would be offended, humiliated or intimidated; or (d) Engages, whether alone or together with other persons, in conduct of a sexual nature which creates a sexually hostile or intimidating work environment for the person. (e) Sexual harassment does not need to be intentional to be unlawful. For example, it is irrelevant if you claim that you were only joking or did not mean to cause offence by your behaviour. (f) A relationship or behaviour that is freely accepted by all persons involved is not harassment. However, it cannot be presumed that all persons involved agree. (g) Sexual harassment in the workplace can take many forms. It can be obvious, subtle, direct or indirect. It can include unwelcome physical, verbal or non-verbal behaviour. (h) Depending on whether the behaviour is welcome or not, any of the following could amount to harassment: a. Material that is sexist, sexually explicit, and that is displayed publicly or circulated; b. Verbal abuse or comments that put down or stereotype people generally, or an individual particularly, because of their gender; c. Jokes based on gender; d. Behaviours which create a hostile, demeaning or sexually permeated work environment, even where that behaviour is not specifically targeted at an individual; e. Obscene or threatening communication (phone calls, letters, circulars, faxes, email messages, etc.) How to handle discrimination or harassment If you are being unlawfully discriminated against, harassed, vilified or victimised, you can: (a) Tell the person to stop (as long as you feel comfortable to do so). (b) Inform your Manager / the Director of Operations and request that they take action to prevent further harassment. (c) If the discrimination or harassment involves your Manager, or for other reasons you do not feel comfortable to speak to your Manager, you can contact any Partner of OLN or the Director Operations for further assistance. (d) You should keep record of the accident, with dates, times, witness (if any), what happened, etc.

15 15 OLN Office Manual TRAINING OLN supports all efforts by employees to maximise the job satisfaction and performance through the provision of appropriate training. Training needs are identified in appraisal interviews. All Partners and staff should also discuss any training needs which arise at any other time of the year with HR who also maintains details of external training courses. The firm regards the training and development of all members of staff as being vital to its future and to achieving its overall objectives. It is the policy of the firm to ensure that all personnel are competent to perform all tasks that they are responsible for and are developed in a manner which is appropriate for a forward-looking professional practice. The Director of Operations and the Marketing Team have been appointed as training managers for the firm with the responsibility for planning, co-ordinating and overseeing the firm’s training needs and implementation. All staff share responsibility for the planning, implementing and evaluating of their own training needs. Training will, therefore, be a particularly important subject for discussion at each person’s annual appraisal and will cover also the skills and knowledge required for managing the practice. Fee-earners are expected to provide topical lunchtime talks on their practice and any new developments. External training All staff is therefore encouraged to look out for appropriate courses to develop their professional skills and knowledge, especially if such courses relate to the training needs identified at the time of the annual appraisal. Where a fee is payable to external training, prior approval should be obtained from a Partner. CPD Solicitors who are subject to the CPD must maintain their own training records. Trainee mentoring program To assist with the two-year trainee development program for trainee solicitors, the firm is introducing a trainee mentoring program which will be overseen by a nominated Partner who will act as a mentor to guide the trainees through their work and help ensure that they are engaged and challenged, and possess, by the time they qualify, all the necessary skills to practise as a solicitor.

16 16 OLN Office Manual What is mentoring? • Mentoring is a relationship between two people where one is more knowledgeable and experienced, and can assist the other to grow and learn. • Mentoring is not about: • Becoming dependent or reliant on someone else • A means of advancement • Favouritism or gaining an unfair advantage over staff who do not have access to a mentor Scheme objectives: • To assist in communication • To assist Mentors and Mentees to learn and understand about different areas of the firm • To widen trainee lawyers’ perspective • To provide an additional source of ideas and guidance • To provide easy access to a more experienced person to discuss their personal career and other issues on a confidential basis Key points of the Scheme • It is confidential – the only issues discussed with third parties outside the mentoring relationship will be those agreed by both the Mentor and the Mentee. • The relationship is driven by the Mentee – all mentoring relationships will differ and will be led by the needs of the Mentee. A Mentor will: • Challenge the Mentee – assistance to the Mentee will be “hands off” in terms of action, but ‘hands on’ in terms of helping the Mentee come up with solutions and take action themselves • Offer support and guidance on issues and problems • Be willing to invest time into the Mentor relationship (as a guide meet at least once per month initially) • Give honest feedback • Act as a sounding board • Help the Mentee understand about the system, culture, work etc. • Listen when the Mentee has a problem • Maintain confidentiality • Build trust by being open and honest Mentees: • Can seek help when needed • Will maintain confidentiality • Will help build trust by being open and honest • Must be realistic in the expectation of how the Mentor can help • Must decide how they wish to use the mentoring relationship to help their development • Must be prepared to invest time into the Mentor relationship

17 17 OLN Office Manual How the Scheme works: The duration of the Mentor relationship will be determined by the Mentee but it is envisaged it will cover the course of the two-year trainee solicitor contract. A review of the scheme will be conducted after 6 months. If you have any question, please contact the Director of Operations.

18 18 OLN Office Manual CLIENT CARE Key elements of our service Expertise Our aim is to provide a timely, reliable, accurate and practicable legal service to all clients. PRACTICAL LEGAL SOLUTIONS – ON TIME – NO EXCUSES. All personnel must ensure that they are suitably trained to provide the range and depth of service for which they have responsibility. We must not accept instructions which go beyond our professional expertise. Confidentiality All solicitors are bound by the Law Society’s rules which require confidentiality in all dealings with clients. This means that nobody may reveal to any outsider the nature of instructions provided or advice given to any client, other than in the pursuit of the client’s instructions. In most circumstances it will also be inappropriate to reveal that we are in receipt of instructions from any named client. This is particularly the case in litigation, especially crime or divorce. If you are aware that friends or other people that you know are instructing the firm it may be tempting to reveal this information to others; do not do so. If you are ever in doubt as to whether you should reveal whether we act for a given client, or give out his, her or its address, check with a Partner. Breaches of confidentiality could cause considerable problems for the firm and will be treated by the Partners as a serious disciplinary offence. Commitment Clients seek legal advice for a variety of reasons, but their instructions may require a great deal of sensitivity. All clients are entitled to expect a real commitment from us in handling their instructions, and for us to attach appropriate priority to their requirements. A professional service does not involve becoming emotional, however, and this should be borne in mind in wording correspondence. Courtesy Proper respect must be shown to clients and all others with whom we have dealings. Courtesy extends to arrangements for seeing clients in the office or elsewhere, when delays must be avoided if possible, or at least explained. Communication Clients must be kept abreast of developments which affect them. Most of the complaints made against solicitors relate to poor communication. We have to ensure that such problems do not arise in our dealings with clients. CLIENT CARE The QUALITY of our service to clients is key to our present and future success. We must ensure appropriate expertise in all our dealings for clients. The 'four Cs': Confidentiality Commitment Courtesy Communication

19 19 OLN Office Manual Reception The reception area is the 'shop window' of the firm and the image projected there is likely to be one of the most important elements of developing the right image of the firm. Receptionists are responsible for creating the right perception of the firm. This is to be achieved by ensuring that: • The reception is clean and tidy, that newspapers and magazines are up to date and are neatly arranged; • The firm’s publicity material is made available to clients and is kept in presentable condition; • If there is a delay of over 5 minutes visitors are: • Kept informed of the reasons; • Provided with suitable refreshments, coffee, tea etc.; • Provided with an apology and explanation after 10 minutes’ delay and/or offered a different appointment time. Issues of client confidentiality in the reception area must be borne in mind by all personnel. Any conversations with clients in reception should be limited to appointment times, etc., only. If there is to be any discussion of confidential information an office or meeting room must be used. The reception area might be empty of other clients when such a conversation starts, but this can soon change. Avoid discussing client activities in reception and please keep personal conversations to a minimum. It will often be necessary for secretaries to see clients when they call into the office to make an appointment, to bring in items or even to sign documentation. The Partners should consider where this will occur to avoid breaches of confidentiality and also embarrassment to clients. Fee-earner responsibilities Fee-earners are responsible for ensuring that they or their secretaries: • Advise reception of all appointments; • Make a reservation as soon as possible when meeting rooms are required; • Ensure that clients are not kept waiting; • Ensure that clients are shown hospitality and are provided with appropriate refreshments; • Arrange for clients to be shown to and from any room used for a client appointment. DRESS AND DEMEANOUR It is important that we project a sense of professionalism in our dealings with clients. Everybody should dress in a manner which is appropriate for a professional practice, and in particular avoid casual attire. Please also try to conduct yourself in a way that will reassure clients. This can be achieved by appropriate behaviour around the office and by a smile or a 'good morning' or 'good afternoon' to those clients that you encounter in the office. Please try to be as helpful as possible to all clients of the firm – not

20 20 OLN Office Manual All fee-earners must ensure that reception and their secretary are informed if they leave the premises other than at lunchtime, telling them: • When they are leaving the firm’s office • Their expected time of return • Their whereabouts in the meantime Clients visiting the office by appointment The receptionist should be aware as far as possible, of the appointment, including the name of the clients. This information should be properly entered into the Outlook conference room calendar when a booking is made. This allows the receptionist to be familiar with the name and is in a position to greet such with “Hello Mr…..”. This first encounter is very important. Remember, we never get a second chance to make a good first impression! The fee-earner should not be interrupted during the meeting with a client unless an emergency occurs. It is the fee-earner’s responsibility to ensure that sufficient time is available prior to his or her next commitment to allow the client’s matter to be properly dealt with. Where an unexpected event occurs, the client should be made aware of the general reason for the emergency (without breaching confidentiality). It is essential that the client is not given the impression that another person’s matter is more important than his or hers. It is good practice to discuss with the client in advance how long the meeting is likely to take. Clients visiting the office without an appointment Reception will inform the fee-earner in person or their secretary to ascertain whether the fee- earner is available. If the fee-earner is available a message via the telephone to reception will suffice, with an estimate of the time before the fee-earner will be available. If the fee-earner is not available the fee-earner’s secretary will visit reception and introduce himself or herself by name as the fee-earner’s secretary. The secretary will offer to make an appointment, or arrange for the fee-earner to telephone at an appropriate time. If the matter is urgent and cannot wait then the secretary should report to the head of department (or, in his/her absence, another fee-earner in the same department) to check who is available at short notice to deal with the problem, if anyone. Reception is responsible for organising tea/coffee for the client if appropriate. All cups, glasses, trays and spoons should always be clean and new and served in courteous manner. Telephone calls All incoming calls must be answered promptly. The procedures for telephone answering are as follows: Telephone switchboard The receptionist will give the name of the firm and ‘good morning’ or ‘good afternoon’. The receptionist will ascertain the identity of the caller and the person they wish to speak to.

21 21 OLN Office Manual The call will be put through to the relevant fee-earner’s secretary if applicable. The switchboard should announce who is calling and the person the caller wishes to speak to. The secretary should greet the caller by name. Where the caller requires speaking to someone who is not on the firm’s premises the caller will be told that that person is ‘out of the office’. Alternatives could include ‘out with a client’ or ‘at a meeting’. The switchboard should indicate when the person is expected back before being asked if the caller would wish to leave a message with the relevant secretary. Where possible a detailed written message should be prepared. Individuals’ extensions Any person answering a telephone, whether the call is internal or external, is to answer with his/her name. It may be appropriate on external calls to explain role, e.g. ‘secretary to X’ as well. Any fee-earner who leaves his or her desk is required to divert his or her telephone to a secretary, or another member of the firm, for message-taking purposes. It is not necessary to notify the switchboard, only the person to whom the phone has been diverted. Fee-earners should notify their secretary of the period in the day when they will return any calls which come in when the fee-earner is unavailable. This: • gives a client a time when he/she will call back; • prevents the client from calling again before the stated times; • gives a business-like and efficient impression to the client. Short, local personal telephone calls are allowed but unanswered ringing on mobile phones will not be tolerated. You may also receive incoming personal calls, but please be sure to keep these calls to a reasonable period of time. Long-distance calls should only be made with Partner consent. Voicemail It is the responsibility of reception and those fee-earners who have voicemail to check incoming voicemail messages and respond to them promptly or arrange for a message to be given to callers. Method of addressing clients in correspondence When writing to clients, in the majority of circumstances, the fee-earner will have already met the client or will have made contact in some other way and will know the name of the client. Address the client using their name and not ‘Dear Sir’ or ‘Dear Madam’. Letters to and from other professionals, including other firms of solicitors, are to the firm and not the individual handling the matter. In most cases, therefore, ‘Dear Sirs’ is the appropriate method of address and references to this firm are ‘we’ not ‘I’. Letters should finish “Yours faithfully”. Letters should always be signed “Oldham Li & Nie” save where a Partner wishes to sign his own name.

22 22 OLN Office Manual Office tidiness At the end of each day all members of staff should tidy their work area or office to assist the cleaning staff in their duties. In particular, covers should be put on office equipment and personal belongings should be put away. Also, surplus stationery should, wherever possible, be kept in desk drawers or the proper cabinets provided. These too should be kept tidy and the doors closed at the time you cease work. Everyone is asked to keep the pantry clean and tidy. If refreshments are provided for clients, the fee-earner concerned is to ensure that the conference room or meeting room is left in a tidy state ready for the next meeting and that any crockery used is washed up and put away (by liaising with the tea lady). Reception should be told when any meeting room becomes free.

23 23 OLN Office Manual CENTRAL COMPLAINTS REGISTER The central complaints register is kept with the Senior Partner and should include the following:  A complaint reference number;  The date of the complaint;  The name of the client;  The name of the member of staff involved;  A general description of the complaint;  The date of any internal meeting and the names of those present;  The date the file was examined;  The date of any meeting with the client;  An indication of whether the complaint is justified;  Details of any suggestions to resolve the complaint;  The dates of any letters confirming details or suggestions;  The date of any review and the result of the review;  The date of the final letter;  The date the file was closed; and  Any action to be taken internally as a result of the complaint. COMPLAINTS-HANDLING PROCEDURE Although we strive to provide the best service possible to all clients, some may be disappointed or be dissatisfied with the service that we provide. How well we respond to such disappointment is an important element of our standard of service to clients. It is in our interests to deal as effectively as possible with any problems as soon as they arise. Research reveals that that on average a satisfied client may tell five people of their experience, whereas a dissatisfied client may tell 23 people. The importance of dealing with complaints is therefore obvious given that referrals and recommendations remain our most important sources of new work. Our complaints procedure operates at two levels. Initially we hope that clients will raise any difficulties with the fee-earner concerned. In most cases it should be possible to resolve problems or misunderstandings at this level. Don't forget: saying 'sorry' does not always mean that you are necessarily admitting fault or liability and will generally be all that the client requires. Do everything that you can to show to the client that the matter is being addressed as they would wish. Thank them for raising their concerns with you. Do not become defensive and do not try to avoid the client. This will almost certainly make matters worse. If you are unable to satisfy the client informally, you should notify the head of department and provide him / her with a summary of the matter and the nature of the complaint. Our complaints procedure 1. Write to acknowledge the complaint and confirm the details within two days. Confirm the name of the person who will be dealing with the complaint. 2. Record the complaint in OLN’s central register. 3. Investigation of complaint. The Senior Partner will direct and supervise the investigation of any complaint. Investigations may be conducted by correspondence and review of paperwork, or via meetings with relevant parties. 4. Within two days of completing the investigation, the Senior Partner will write to the client to confirm what took place and propose his suggestions for resolving the matter. 5. If the client is still not satisfied, he/she can write again and we will review our decision. This will happen in one of the following ways: a. We will ask The Law Society or another Hong Kong firm of solicitors to review your complaint within five days. b. We will invite you to agree to independent mediation within five days. We will let you know how long this process will take. 6. We will confirm the outcome in writing within five days of the end of the review.

24 24 OLN Office Manual Complaints to Law Society It is possible that a client may complain direct to the Law Society. In such circumstances any communication from the Law Society should immediately be referred to the Senior Partner. Making complaints about other solicitors There may be occasions when a complaint may be made by us, either against another solicitor or through other procedures. The agreement of the Senior Partner is needed before doing so in order that the professional and commercial standing of the firm can first receive proper consideration.

25 25 OLN Office Manual HEALTH AND SAFETY AND OFFICE SECURITY Health and safety at work OLN wishes to ensure that everyone has a safe and comfortable environment in which to work. We are not aware of any unusual hazards to your health and safety and provided reasonable care and common sense is used in carrying out your work, nothing dangerous should be encountered. The Office Manager is the firm’s health and safety manager and has responsibility for advising the Partners on health and safety issues and for monitoring standards and for carrying out the annual review of health and safety risks. Security of offices The offices and building are protected by 24-hour security guards stationed in the lobby and rear cargo area doors. The building management provides a roving security guard checking every floor and fire station on each floor of the building every two hours during normal working hours. St. George’s Building main lobby security guard desk telephone numbers are 2525 2456 and 2524 2914. In case of serious emergency requiring police or fire services, dial 999. In case police assistance is needed and it is not an emergency you may call the Central District police station on Chung Kong Road at 3661 1600 or you may call the Central Service Centre at 3661 1602. General lighting and air-conditioning for the office is controlled by the building guards at the main lobby security desk. When you are the last person TYPHOON AND RAINSTORM POLICY Typhoon Policy Typhoon Signal No. 1 or 3 When Typhoon Signal no. 1 or 3 is hoisted, you are required to work as usual. If you are unable to report duty when Typhoon Signal no. 1 or 3 is hoisted, you should inform your Manager immediately. Typhoon Signal No. 8 or above When Typhoon Signal no. 8 or above is hoisted before office hours, you are generally not required to report duty. When Typhoon Signal no. 8 or above is hoisted or expected to be hoisted during office hours, you should follow the instructions of your Manager to either stay at a safe working place or leave safely in order. As a general rule, if Typhoon Signal no. 8 is lowered two hours or more before the normal closing time, you should report duty within two hours of the Typhoon Signal being lowered, unless otherwise approved by your Manager. You should contact your Manager as soon as possible in case of any difficulty. Rainstorm Policy Amber or Red Rainstorm Warning If Amber or Red Rainstorm Warning is in force before or during office hours, you are required to report duty. Black Rainstorm Warning If Black Rainstorm Warning is in force before office hours, you are generally not required to report duty. If Black Rainstorm Warning is in force during office hours, and you have not yet reported duty, you should stay at a safe place and consult your Manager for further instructions. If Black Rainstorm Warning is withdrawn during your usual working hours, you should report duty within two hours of the withdrawal of the Black Rainstorm Warning, unless otherwise approved by your Manager.

26 26 OLN Office Manual to leave the office you must turn off all the lighting and air-conditioning. Lastly, you must make a double check of suite 503 main door and be sure that you have properly locked the door by pushing and pulling by hand both left and right glass door panels. This ensures operation of the security locks and is used for setting the burglar alarm. If you are working over the weekends, or on public holidays, you may contact the building guards at the main lobby security desk located on the ground floor. Again, if you are the last person leave the office, you must inform the security guards to turn off the air-conditioning. Central heating The heating in the offices is by means of Plenum air return system controlled by zoned thermostats located in selected locations within the office area. Only the Office Manager or Partners are authorised to adjust these controls. If anyone is too cold or too hot, bring the matter to the Office Manager’s attention. First aid There is a first aid box in the Pantry on the 5th floor. Any member of staff who has an accident whilst in the course of their employment should notify the Office Manager who is the assigned First Aid officer. If he is not available, a Partner, or the Director of Operations should be consulted. In the event that you are required to undertake heavy lifting, please contact the Office Manager who will provide or assign someone to assist with heavy lifting in a safe and responsible manner. Any member of staff with serious health problems should inform the Director of Operations. This disclosure of health conditions is solely voluntary and any information shall be kept in strict confidence. Electrical equipment We must use common sense and caution when dealing with electrical equipment as we would in our own homes. If anyone suspects that equipment, plugs or the supply may be faulty he/she must report it at once to the Office Manager or a Partner. The use of power point electrical adaptors is common. No more than one adaptor per power point may be used and never should multiple adaptors be used one into the other as this is a serious fire hazard. At the close of business each day everyone is responsible to ensure all the electrically operated devices at your workstation are properly and completely shut down and turned off. The reasonable use of chargers for mobile phones and other devices is permitted, provided always those charges are turned off and unplugged at the end of the working day. This applies equally to chargers that are connected to computers. Personal fan heaters may only be used if expressly approved by the Office Manager in advance. Fan heaters must also be turned off and unplugged at the end of the working day.

27 27 OLN Office Manual Maintenance checks will be carried out periodically and breaches of this policy will be considered a disciplinary matter. No-smoking policy OLN operates a no-smoking policy. The policy applies to all personnel and clients who should be asked politely not to smoke if they attempt to do so. The no-smoking policy operates throughout OLN’s offices and St. George’s Building. Smoking anywhere in St. George’s Building, including in the emergency exit stairwells is prohibited. Drug and alcohol policy Save in exceptional circumstances OLN generally prohibits you while working from drinking alcohol. OLN strictly prohibits you while working from being under the influence of any illegal drug or narcotic or having, possessing, selling, giving, or circulating illegal drugs or sources of illegal drugs, intoxicants, or narcotics to other employees or to anyone else. Private property All personnel are responsible for the security of their own private property that is brought onto the firm’s premises. Individuals should be responsible for insuring their own property. Fire instructions St. George's Building is protected by a fully automated fire and sprinkler system. In case of fire you will hear a constant fire bell. If this bell sounds everyone is to immediately exit the building. DO NOT use the elevators / lifts. Staff should depart from the building by using the two exit stairwells. One is located by the door leading to the lady’s lavatory and one next to the door leading to the men’s lavatory. Alexander House, ground floor lobby directly across the street from St. George's Building has been selected as the rallying point for all Staff to assemble in case of fire within the office or building. The Office Manager will be responsible for taking a head count at the rallying point. The emergency fire alarm buttons are located next to the entrance to the ladies lavatory and the men’s lavatory. Both buttons are protected with a clear glass cover which must be broken with a heavy object that someone must bring with them to break the glass.

28 28 OLN Office Manual Regarding the water hose reels in stations A and B, Management does not recommend staff to perform the task of firemen and try to use these water hoses. In case of fire, all staff are to leave the premises at once after sounding the alarm. Please do not panic, push or run so fast as to endanger yourself or others. There are overhead water sprinklers throughout the office which will automatically sense fire and turn on the water to douse any flames. The office is also equipped with automatic smoke sensors. In case of fire everyone is reminded that the savings of lives is paramount so do not waste valuable time collecting your personal possessions and/or company property. Smoke inhalation kills more people than actual fires. In case of sudden dense smoke, try to cover your mouth. Stay as low as possible to the floor where the freshest air can be found during fire or with the presence of smoke.

29 29 OLN Office Manual TIME-RECORDING Time-recording is an essential and important tool towards billing your client work and therefore the need to record time accurately and promptly cannot be over stressed. Time sheets Time is recorded in five-minute units with each unit being costed at the hourly expense/charge out rate appropriate to the fee-earner recording the time. Where a number of fee-earners work on the same client matter it is probable that their time will be costed at different rates. Clio will show individual time posting per fee-earner and a running total of unbilled time shown both in terms of hours and minutes and value. Time should be recorded in the Clio system by the next day. Non-chargeable time Clio includes categories for recording non-chargeable time. At the end of the day fee-earners should fully complete and total their time sheets both for chargeable and non-chargeable activities. For a normal full working day the number of units should total a minimum of 72 units.

30 30 OLN Office Manual FINANCE AND ACCOUNTING All matters relating to finance and accounting are handled by the Accounts Department and headed by the Financial Controller. Transfer form A transfer form can be obtained from the Accounts Department, is used for authorising transfers of client and office money. Two copies of the form should be raised, the top copy should be sent to the accounts department for action and the duplicate retained on the client file. On occasion it may be necessary to support the transfer form with a note of explanation. The transferring of monies is directly the responsibility of fee-earners and it should be noted that the accounts department staff have no authority to transfer client money under any circumstances. Only Partners have that authority. Cheque and Telegraphic Transfer requisitions If a fee-earner requires a cheque to be drawn or a bank telegraphic transfer to be made on client general account, client trustee account or office account, the fee-earner is to complete a cheque requisition form, and if a telegraph transfer is to be made instead of a cheque being drawn, this should be indicated on the form. The client name, matter number, payee and brief details of the reason for the cheque, are to be fully completed. The top copy of the requisition form is to be sent to the accounts department and the second copy retained on the client matter file. The accounts copy is also used as the posting form. The accounts department will make the assumption that the cheque will be issued on that day and will affect the ledger posting accordingly. If the issue of the cheque is to be delayed, then the fee-earner must make this clear and liaise with the accounts department. Write-offs The write-off of any debit balance can only be authorised by Gordon Oldham or Stephen Peaker. Petty cash All petty cash transactions are controlled by the Accounts Department. If petty cash is required a Petty Cash Form can be obtained from the Accounts Department is to be fully completed and taken to the Accounts Department for their action. Management reports An aged debt report is produced weekly and is reviewed by the Partners. All fee-earners should take responsibility for their client debtor position and should liaise as necessary with Credit Control Manager to ensure prompt payment. CHEQUES AND CASH Cheques and cash should be passed to the accounts department together with a completed remittance advice form promptly on receipt. Cash is never to be left unattended. Clear instructions must be given as to whether monies are to be paid into the office account or client account. Only the accounts department is authorised to issue a receipt on behalf of the firm if one is required.

31 31 OLN Office Manual Credit control The firm's credit control procedures are based upon the following main principles: • Money on account from the client must be obtained in respect of fees and disbursements. Failure to do so will result in the fee earner becoming liable for all fees so incurred; • Wherever possible interim bills will be raised monthly; • In accordance with the terms of our retainer letter, our invoices are due and payable immediately on presentation, i.e. on delivery to the client; • Fee-earners remain closely involved in the credit control process and ultimately have the responsibility to obtain payment of our fees, notwithstanding any action taken by others such as the accounts department or credit control department staff. A matter is not completed until the bill has been paid; • There will be a process of escalating severity of correspondence to the client, finalising in court proceedings being taken against the client; • The credit control procedures will automatically be activated for all client debts unless under exceptional circumstances a Partner intervenes to prevent some or all of the procedures from taking place; • Except under exceptional circumstances, court proceedings will be taken, if necessary, one month after delivery of the invoice, irrespective of the client; • The procedures reflect the guidance and requirements of the recovery of professional fees as contained in The Guide to the Professional Conduct of Solicitors 1999, chapter4; • The credit control procedures will be actioned as a priority task and it will be handled by the Credit Control Manager. Once private client bills have been posted on to the ledgers, two copies will be filed in the accounts department in date order on two binders. Within one binder, the bill will be stamped by a date chop when paid. Within the other binder, when a bill has been paid, it will be transferred to a paid binder with the bills filed in bill number order. This method of filing will greatly assist with the credit control procedures as it will immediately identify those unpaid bills that require hastening action at whatever stage. In particular, as bills are paid and removed, there will be a residue of bills remaining that justify special attention. Any bill that remains unpaid for three months is regarded as being a potential problem. The escalating procedure for private client debts should be as follows. • Step 1: Bill sent to client with copy retained on the client file, and a copy passed to the accounts department for posting action and for subsequent filing in the unpaid bills binder. • Step 2: After one month the Credit Control Manager sends a statement to the client. • Step 3: After six weeks the Credit Control Manager sends a reminder letter to the client. • Step 4: After two months the Credit Control Manager liaises with the fee-earner to progress the debt directly with the client, either by telephone or by letter. The fee-earner is to advise the credit control Manager of the action taken. Please note that the fee-earner can take the matter up with the client earlier but must always advise the Credit Control Manager. • Step 5: After two and a half months a letter threatening court proceedings is to be sent to the client, signed by a Partner. • Step 6: After three months from the date of the issue of the bill, if payment has not been received or alternative payment arrangements have been agreed with the client, court proceedings will commence against the client on the authority of a Partner.

32 32 OLN Office Manual Reserving and write-off of debts At the end of each financial year, all debts that have been outstanding for 24 months or more will be automatically reserved in the firm’s accounts. This will have the effect of reducing the profits for that year by the amount of the reserved debts. The reserved debts will remain on the individual client ledger account and can continue to be hastened for payment. If payment or part- payment is received then the profit costs will be reinstated as if it was a new bill. Both the Credit Control Manager and the fee-earner must liaise closely when this occurs. Any existing reserved debts from the previous financial year will normally be written off but only on the authority of an equity Partner. Such write-offs will have no effect on profits as the reduction will have taken place at the reserving stage. There will be times when a bill should be written off without the need to be first reserved, e.g. following bankruptcy. Again, write-offs can only be authorised by an equity Partner.

33 33 OLN Office Manual COMMUNICATION Incoming mail All incoming post whether addressed to individual employees or not and whether marked PRIVATE and CONFIDENTIAL or not is to be opened. No member of staff may use the firm's address for personal communications without the permission of the Partners which will be given only in exceptional circumstances. Hand deliveries A considerable amount of post is received by hand delivery. Hand-delivered post can be received at Reception at any time during the day and where deliveries are clearly marked urgent, they are to be passed direct to the appropriate Partner or addressee without delay. All incoming mail should be machine time / date stamped by the Receptionist with the time and date of arrival. Post is not to be left in the Reception area or anywhere else unactioned. Any post that is not clear as to whom it is far should be immediately passed by the Receptionist to the Office Manager for his review and action. Unidentifiable mail When it is not possible to identify the intended recipient of an incoming letter, for example, because there is no reference, it should be given to the Office Manager. Outgoing mail Secretaries are responsible for sending outgoing post and placed on the Outgoing delivery tray located near the pantry no later than 5:00 pm daily to avoid any last-minute rushes in sending the post out. Post to be sent by Regular Mail is all to be sent via first-class service and where overseas letters are to be sent the AIRMAIL chop should be clearly affixed. Registered Mail means the outgoing mail on arrival at recipient address must be signed for but no receipt will come back to OLN. Double Registered Mail means the outgoing mail on arrival at the recipient address must be signed for & a copy of that signature receipt will be returned to OLN by the post office. Registered Mail should be used in preference to sending stamped addressed envelopes to clients or other addressees. This service is more cost effective than normal postage rates and must be logged in the daily postal log book as well as clearly noted in the client file in order to calculate/include said postage cost as a disbursement in the final client billing.

34 34 OLN Office Manual DX OLN is a member of the “dx” system, a privately-operated postal system to which most professionals belong. OLN’s dx account number is 009125. oln The DX exchange is at Two Chinachem Plaza, 68 Connaught Road, Central. The DX system is cheaper and often more reliable. It should be used in preference to the Post Office whenever possible. The DX address must be shown clearly on the envelope and the firm’s sticker must be put on to the envelope by the secretary in the top left-hand corner. Telephone directories The firm’s internal telephone directory is available for all members of staff. Internal numbers can be dialed directly. This directory shall be updated when required Fax There are two fax machines located on the 5th floor. Whilst there is no restriction on using fax for transmitting correspondence or documents the facility should be used with common sense. Any machine malfunction must be brought to the Office Manager’s immediate attention. No one is to attempt to repair or use any object of any kind to try and dislodge jammed paper. Paper clips, staples or any foreign matter should be kept clear of the fax machines and never be removed from document bundles near this equipment. Jammed staples and paper clips are the most frequent cause of malfunction of the equipment. You should check the transmission report shortly after you send your fax. You must be aware that clients may instruct us that no faxes are to be sent. Before sending a fax, check the client file. The Office Manager will inform the relevant secretary that a fax has been received and it is that secretary’s responsibility to collect the fax unless it is agreed that the fax can be distributed through the normal internal mail distribution system. Shredder There is one paper shredding machine located outside of the 5thfloor pantry. Paper clips, staples or any foreign matter should be kept clear of the shredder machine and never be removed from document bundles near this equipment. Jammed staples and paper clips are the most frequent cause of malfunction of the equipment whilst there is no restriction on using the shredder machine, the facility should be used with common sense and the power switch on the top of the machine should be turned off after use.

35 35 OLN Office Manual Notice boards The notice boards located in the Pantry provide an easy means of conveying information relating to the firm or general topical information that may be of interest to staff. There is also a separate White Board in the Panty used solely by the Firm’s Clerks for noting Court appearances. No one is to tamper with the White Board other than the Clerks or Partners. If anyone would like to display an item on the boards, please refer to the Office Manager. Please keep the notice boards tidy and uncluttered.

36 36 OLN Office Manual LIBRARY The firm maintains a legal reference library on the 5th Floor. Most legal resources can be found online and, therefore, OLN’s legal reference library is fairly small. If you require a particular book, a request should be made to the Office Manager. When making a request, bear in mind that a comprehensive library is located at the High Court. Do not hold onto any books longer than you require. Certain fee earners keep their own books in their office. Fee earners are happy to share these books; however, you should ask prior permission and return the book promptly. Internet Searches 1. http://www.judiciary.hk (Hong Kong Judiciary) - website with useful information on court services & facilities and recent judgments. 2. http://www.hklii.hk (Hong Kong Legal Information Institute) – contains all Hong Kong case- law, Ordinances and Regulations 3. British and Irish Legal Information Institute (“BAILII”) 4. http://www.lexology.com/(Lexology) –free daily/weekly legal updates. 5. http://www.mondaq.com/ (Mondaq) - your free legal updates. 6. http://uk.practicallaw.com/country/hong-kong-prc (Practical Law HK Home Page) - useful country specific guide relating to many topics such as arbitration procedures, restructuring and insolvency, lending and taking security and an overview of public mergers and acquisitions in HK.

37 37 OLN Office Manual CLIENT FILES / CLIO Acceptance and rejection of instructions The firm is not obliged to accept all possible instructions. We may not decline instructions on grounds of discrimination. The circumstances where it would be permissible to decline instructions could include: • the work is not of a specialisation that we offer; • resources would be inadequate to perform the work to the satisfaction of the client, or the quality of our service to other clients would be placed in jeopardy; • it would be economically unviable for us to do the work and it is not felt appropriate to accept the instructions under our pro bono policy; • unsatisfactory past experience with that client, such as their previous refusal to pay a bill or offensive or threatening behaviour to a representative of the firm; and • there is, or could reasonably be suspected to be, a conflict of interest in relation to the instructions and existing clients or instructions received. Wherever there is doubt as to whether instructions should be accepted the matter should be referred to Paul Firmin. Guideline for opening of a new file All client files should be opened via Clio and a corresponding paper file should also be opened. When opening a file, all of the mandatory information required by Clio should be included. This information should also be recorded on the front of the paper file. Carefully note points about special instructions (e.g. CONFLICT CHECK Prior to accepting any instructions, you must ensure that OLN does not have a conflict via Clio. Conflict of interest must be considered whenever a new matter is opened. An entry must be made to the file opening form identifying if the matter is on behalf of a new client in order that the accounts department can check if a conflict might exist. It has to be recognised that this is not a foolproof system and that common sense for checking conflicts, as through enquiries to a colleague, will also often be necessary. Any additional checks for conflict must be noted on the file summary sheet which appears on all matter files. Where a conflict is found or believed to exist any doubts as to the propriety of accepting instructions should be considered by the designated supervisor if possible or, if not, another Partner. If it is felt that instructions should be declined the client should be informed of this as soon as possible and he/she should be offered such explanation and recommendation as in all the circumstances is professionally appropriate.some clients DO NOT want letters or invoices faxed to their office or home for confidentiality reasons. Other clients DO NOT want matters posted to their office preferring certain documents be sent only to their homes and/or vice-versa. Client information form and mandatory information No new client file should be opened unless: (i) a retainer letter and client information form has been sent to the client; (ii) the Know Your Client checklist (“KYC Checklist”) has been completed in the Clio system; and (iii) consideration is given to requesting costs on account.

38 38 OLN Office Manual You must follow up with your client to ensure that a signed retainer letter and client information form is returned. Once a signed retainer letter is returned, this must be uploaded onto Clio together with the client ID. The Know Your Client Checklist (“KYC Checklist”) will need to be completed in the Clio system when opening a new client matter. Gazetted UNATMO Terrorist List check: the current list of terrorist suspects issued under the UNATMO as gazetted by the HK Gov’t should be checked to confirm the prospective client is not included in the list. Client ID You must obtain from every new client the following documents: Individual client (i) Identity (usually a Hong Kong ID card or Passport copy); (ii) Address (usually a bill issued to the client’s home address by a utility company or government department). Corporate client (i) Legal status documents (for Hong Kong companies, these may be obtained from the companies registry); (ii) Identity of the person giving instructions (usually a Hong Kong ID card or Passport copy); (iii) Evidence of due authority of such person to instruct OLN The supporting documents for the following are optional but should be obtained for verification in the event you have doubt on the relevant information provided by the client: (iv) Office address; (v) Identity of directors; (vi) Identity of major beneficial owner(s). New matters New matters often develop from current matters and it is not always apparent when an issue is first raised as to whether a distinct new matter will develop. Fee-earners must be aware of the need not to run separate matters under the same file and must be prepared to open a new file, perhaps transferring any papers to a colleague, as soon as it becomes clear that the issue is something other than a minor incidental issue related to the matter in hand. Similarly, general files for commercial clients must not be used as a means of bypassing the normal file opening procedures. File references All files must be traceable through being under the control of the person nominated as the fee- earner dealing with that matter. If the file is, for any reason, transferred or loaned to another fee-earner a tracer card must be entered into the filing cabinet where that file or any part of it should be stored recording the whereabouts of the file in question.

39 39 OLN Office Manual The fee-earner who is handling a matter on behalf of a client has responsibility for receipt, use, safeguarding and return of any items provided by that client or their representative and for their safe return, custody or onward transmission at the end of the matter, together with advice, if appropriate, on storage and retrieval procedures. Closing client files Files must be closed electronically via Clio and physically. A File Closure Form (FCF) must be completed and signed by the fee-earner when the matter closes. This is passed to the accounts department with a photocopy retainer with the file. Files may only be closed once the accounts department has confirmed there are no outstanding financial matters requiring attention. Upon the Accounts Department signing the FCF with photocopy file cover attached the file is passed to the Office Manager for placement in a Crown Pacific box within the office. It is the responsibility of the fee-earner concerned to decide upon the minimum retention period for closed files and the following guidelines are given. The destruction year is to be recorded on the FCF. See below. Storing closed client files Closed client files storage with Crown. Crown Pacific collect boxes between 1100 and 1300 hours. If a closed client file is required, details are to be given to the Office Manager. Cut off time for recovery of a box is 4 p.m. A fee is charged each time a file is retrieved and, therefore, you should be considerate when retrieving files and only receive files that are absolutely necessary. Usual destroy dates It is the fee-earner's responsibility to determine the destroy date when archiving a file and to mark the FCF accordingly. The Rules are: • Wills: No destruction date • Trusts: 25 years • Conveyancing: 15 years • Tenancy: 7 years from the expiry of the tenancy • Trademarks: 15 years • Others: 7 years • Crime: 3 years from expiry of appeal period

40 40 OLN Office Manual ANTI-MONEY LAUNDERING Money laundering Money laundering has been defined as ‘the process by which the identity of “dirty money” (i.e. proceeds of crime) and the true ownership of such funds is changed so that the money appears to originate from a legitimate source’. As solicitors we are an attractive target for such activities. We risk loss of professional reputation, being required to repay monies from our own funds and criminal penalties if we offend the law in this area. The criminal offences comprise: • Assistance: including the situation where we suspect money laundering; • Tipping off: taking steps to prejudice due process by warning the client; • Failure to report: for certain activities this is also an offence. The policy of the firm in such circumstances is to co-operate fully with the proper authorities and not to assist clients to achieve their aims if they appear to be involved in such activities. The firm’s Anti-Money Laundering Officer (AML Officer) to whom report should be made as soon as any suspicions arise, is Paul Firmin. He will: • Investigate fully the circumstances of each case reported to him; • Undertake the reporting to the proper authorities; • Keep under review the effectiveness of our policy and procedures in this area; • Ensure that all personnel are appropriately trained with regard to money laundering. In appropriate cases we must insist on evidence of identity from new private clients. This should be from an identity card or a passport. The evidence taken must be noted on the file. The signs to watch for are: • Unusual settlement requests: settlement by cash of any large transaction involving the purchase of property or other investment should give rise to caution. Payment by way of third-party cheque or money transfer where there is a variation between the account holder, the signatory and a perspective investor should give rise to additional enquiries; • Unusual instructions: care should always be taken when dealing with a client who has no discernible reason for using the firm’s services, e.g. clients with no existing connections with any member of the firm; or clients whose requirements do not fit into the normal pattern of the firm’s business and could be more easily serviced elsewhere; • Large sums of cash: always be cautious when requested to hold large sums of cash in your client account, either pending further instructions from the client or for no other purpose than for onward transmission to a third party; • The secretive client: be extremely wary of a personal client who is reluctant to provide details of his or her identity. Be particularly cautious about the client you do not meet in person;

41 41 OLN Office Manual • Suspect territory: caution should be exercised whenever a client is introduced by an overseas bank, other investor or third party based in countries where production of drugs or drug trafficking may be prevalent. To minimise the risks of liability: • Verify the identity and bona fides of your client: meet the client or clients where possible and get to know them; • Question unusual instructions: make sure that you discuss them fully with your client, and note all such discussions carefully on the file; • Discuss any aspects of the transaction which worry you with your client: for example, if you suspect that your client may have submitted a false mortgage application or references, or if the lender’s valuation exceeds the actual price paid, discuss this with your client and, if you believe they intend to proceed with a fraudulent application, you must refuse to continue to act for the buyer and the mortgagee; • Check that the true price is shown in all documentation: check that the actual price paid is stated in the contract, transfer and mortgage instructions. Ensure that your client understands that, where you are also acting for the lender, you will have to report all allowances and incentives to the mortgagee; • Do not witness pre-signed documentation: no deed should be witnessed by a solicitor or staff unless the person signing does so in the presence of a witness. If a deed is pre-signed, ensure that it is re-signed in the presence of a witness; • Do not backdate documents: backdating is intended to deceive third parties and is usually a criminal offence; • Verify signatures: consider whether signatures on all documents connected with a transaction should be examined and compared with signatures on any other documentation; • Conduct a company search: where a private company is the seller or the seller has purchased from a private company in the recent past and you suspect that there may be a connection between OLN and the seller or the buyer which is being used for improper purposes, then consideration should be given to making a search in OLN’s register to ascertain the names and addresses of the officers and shareholders which can then be compared with the names of those connected with the transaction and the seller and buyer. If you have any doubts or concerns about suspicious activity, the matter should be referred to Paul Firmin.

42 42 OLN Office Manual ANTI-BRIBERY AND ANTI-CORRUPTION Introduction Bribery and corruption are significant problems in most parts of the world. They undermine the rule of law and damage social and economic development. The firm refuses to engage in any form of bribery or corruption. • A bribe is a financial or other inducement or reward offered, promised or given with the intention of inducing a person to act improperly, or to reward them for doing so. Bribery covers both giving and receiving a bribe, or soliciting a bribe. A bribe can comprise anything of value and may be in the form of money, goods, a right in action, property, privilege, an object of value, advantage or merely a promise to act in some way or influence another person to act in a particular way, for example to induce a government official to issue a permit or a licence. Gifts, hospitality, charitable or political donations or providing a job or training opportunity will be bribes where they are given or received with the intention of inducing a person to act improperly. • Facilitation payments are typically small, unofficial payments made to secure or expedite a routine action, usually (but not always) by public officials. They may be requested, for example, in connection with matters such as issuing permits, licences, immigration controls, providing services or releasing goods held in customs. • Kickbacks, which are similar to facilitation payments, are typically payments made in return for a business favour or advantage. Facilitation payments and kickbacks are considered to be bribes. Bribes, including facilitation payments and kickbacks, are illegal and OLN absolutely prohibits such acts. Anti-Bribery and Anti-Corruption Policy In the course of your work for OLN you must: • Comply with all applicable laws and regulations concerning anti-bribery and anti-corruption. • Not to offer or make any bribe, unusual payment or inducement of any kind to anyone, including public officials, clients or potential clients and not assist anyone else to do so. • Refuse any kind of bribe, unusual payment or inducement offered to you and do so in a manner that is not open to any misunderstanding or which might give rise to false expectation and not assist anyone else to accept such a payment or inducement. • Make an internal report if (a) you are offered any bribes, unusual payments or inducements; or (b) you become aware of any bribes, unusual payments or inducements offered or given to or made by a partner, associate or member of staff. • Not to offer or accept gifts or hospitality, if to do so might affect your (or the recipient's) objective judgement, improperly influence a decision or create a sense of obligation, or if there is a risk that the gift or hospitality could appear improper or its purpose could be misunderstood by others and not assist anyone else to offer or accept such gifts or hospitality.

43 43 OLN Office Manual Gifts, Hospitality and Promotional Expenses In connection with your work for OLN you may only give or receive gifts or corporate hospitality1 for the purpose of: • establishing or maintaining good business relationships; • improving or maintaining OLN image or reputation; or • marketing or presenting OLN services effectively. The giving or accepting of gifts and hospitality for any of these purposes is allowed only if the following requirements are met: • it complies with all applicable local law and regulation – in some countries the giving or receiving of gifts or hospitality may be unlawful in certain circumstances; • it is not made with the intention of obtaining or retaining business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits; • the gift or hospitality is given on behalf of the firm, not on an individual basis and is done openly, not secretly; • it does not include cash or a cash equivalent (such as gift certificates or vouchers); • it is appropriate and proportionate in the circumstances, taking account of the reason for the gift, the nature of the relationship with the third party, its timing and value; • it is reasonable and would be perceived by others to be reasonable; • it is recorded and/or approved in accordance with OLN internal policy where the value of the gift or hospitality exceeds the applicable thresholds set out below. The firm’s default thresholds are as follows: • hospitality and associated expenses (given or received) with a value equal to or greater than HK$1,000 or equivalent per head either as an individual item or as an aggregate value over the previous 12 months require prior approval; and • gifts (given or received) with a value equal to or greater than HK$1,000 or equivalent per head either as an individual item or as an aggregate value over the previous 12 months require prior approval. If you have any doubt or questions about how to deal with promotional expenses, gifts or corporate hospitality please consult Paul Firmin. ______________________ 1 Including promotional expenses, i.e. costs incurred to promote our services to clients, prospective clients and other third parties, e.g. to provide inexpensive items branded with the firm’s corporate logo at conferences, seminars etc.

44 44 OLN Office Manual Charitable and Political Donations The firm may make donations for a charitable purpose, which may include supporting public health, public education or social needs, provided that the donation: • is made to reputable and registered charitable organisations engaged in genuine charitable activities; • is not intended to influence a particular business decision by the recipient, or otherwise to gain a commercial advantage; • is appropriately recorded in the firm register of gifts and hospitality; and • is approved in accordance with the Gifts and Hospitality Policy. The firm does not make contributions to political parties. Working with Associated Persons Improper activities of third parties acting for or on behalf of the firm can subject the firm to liability under anti-corruption laws which do not always differentiate between acts made by a company or by someone acting on its behalf. The firm may be liable if a person associated with it bribes another person intending to obtain or retain business or secure a business advantage for the firm. For that reason, we need to be certain that we only deal with intermediaries, whether they interact with government officials or with private sector clients, who are reputable and apply the same standards of business conduct as the firm does itself and that we engage them on remuneration terms that are reasonable in relation to the services they are performing. The categories of persons for which the firm may be liable may extend to any individual or an entity that performs services for or on behalf of the firm ("associated persons"). Specific examples of associated persons include business consultants, agents, other local or foreign law firms, financial advisors, intermediaries, accounting firms who may interact with clients, prospective clients or government officials in connection with matters we advise on or seek instructions. You must ensure that: • you do not authorise or facilitate an associated person to make a bribe or other improper payments on the firm's behalf or for its benefit, or knowingly permit any such payment to be made; • any fee or compensation paid to an agent or intermediary is appropriate and justifiable remuneration for legitimate series provided; • the firm does not do business with any associated person who is known, or reasonably suspected, to be paying bribes; • you undertake appropriate and proportionate risk-based due diligence on the potential associated person before engaging them; and • any arrangements with and any business conducted by associated persons are kept under regular review.

45 45 OLN Office Manual Prior to engaging any associated persons on behalf of the firm, you should consider undertaking appropriate due diligence on the other party adopting a risk-based and proportionate approach. You should be aware of any conduct of the associated person that causes any concerns during your due diligence review or during the engagement of the associated person, some red flags of such concerns include but are limited to: • unusual payment requests (such as requests for over-invoicing, up-front payments or unusual commissions), requests for payments in a third-party country, to a third party, to a bank account, in cash or otherwise untraceable funds; • requests for political or charitable contributions; • comments or suggestions that bribery has occurred, will or should occur, or routinely occurs; • unethical practices, such as falsifying documents or providing incomplete or inaccurate background information; • a relationship between the associated person and a public official; • a prior request by the associated person to have a firm prepare false documentation; • a refusal or hesitancy by the associated person to promise in writing to abide by the firm’s Anti-Bribery and Anti-Corruption Policy; • convictions of or charges against the associated person for violation of local or laws or regulations relating to the award of government contracts; • a desire of the associated person to keep representation of the firm secret; and/or • other suspicious conduct on the part of the associated person that would raise questions in the eyes of a prudent person. An appropriate due diligence review on associated persons should cover at least background investigation including publicly available records, ultimate beneficial owners of the associated person, any history of bribery or corruption incidents of the associated person and its key officials, assessment of the business reputation of the associated person and review of any anti-bribery and anti-corruption policies of associated persons to assess the risk of such associated persons engaging in such activities. If you suspect any bribery or corruption action has or may have taken place, you are requested to immediately speak to Paul Firmin and seek further guidance. Subject to any special circumstances or discretion which must be exercised cautiously and to be determined by Paul Firmin having discussed with the relevant partner in charge of the specific matter, OLN’s policy is to immediately terminate the engagement of any associated persons who have or are suspected to have engaged in any bribery, corruption activities. Internal Reporting You must immediately report any actual or suspected breach of the Anti-Bribery and/or Anti-Corruption Policy of the firm or any concerns you have about your own or other’s compliance with this Policy to Paul Firmin.

46 46 OLN Office Manual INFORMATION SECURITY Entry to office Access to office areas is restricted to authorised persons. You will be given an office security card on your first day of work. Upon entering and exiting the office premises you need to swipe your security card through the entry security scanners or key in your assigned 5-digit access code on the key pads located on 5th or 3rd Floor main entrances to the office. The data held on the entry security scanner system can be used to provide details of your access and departure times to/from the office. Where there is concern that you may not be fully in compliance with OLN’s procedures, we will monitor the information provided by the system and take any appropriate action. The records may also be used to ascertain your whereabouts in the event of an emergency in the office. Office security cards must not be loaned or given to another person. Your security card remains OLN’s property and must be returned at any time if requested or when leaving OLN's employment. In the event you have lost your office security card, you must report to the Office Manager immediately. OLN reserves the right to charge you for a replacement card if you have lost your office security card multiple times. You should keep all access cards and passwords for entry to the premises of the firm physically secured and confidential. Desk You should keep the desk tidy and must not leave confidential files or documents on the desk unattended. You should keep the confidential files or documents in desk drawers or proper cabinets provided, preferably locked. Company information and documents • Information of Firm and Client You should not disclose any information related to the firms or the clients to any unauthorised persons. You must not distribute to others or attempt to collect the materials of the Firm (e.g. precedents, advice and clients’ information or documents) by any means including copying to external equipment, emailing outside the Firm or printing. • Documents on server You shall only access the documents on server on a need-to-know basis, preferably with the authorisation by the relevant owners. • Confidential documents All confidential documents should be marked with “Confidential” and kept in a proper place such as desk drawers or cabinets preferably with locks. Softcopies of confidential documents on the server shall be restricted by means of logical access control (e.g. protected by password or encrypted). All confidential documents should be encrypted when transmitted over network, e.g. by email or by file transfer (FTP).

47 47 OLN Office Manual • Copyright and Intellectual Property The firm owns the copyrights of all the documents, correspondence and advice drafted by the staff in the course of business. You must keep these documents, correspondence and advice confidential and not disclose to unauthorised persons. Unauthorised disclosure of confidential information concerning the Firm’s affairs or a client’s affairs is a serious breach of the rules of professional conduct. Computer • Use of Computer You should only use such for legitimate business purposes. Data stored in the computer is not necessarily private and can be accessed by the system controller (Office Manager or Accounts Manager) and by the Partners. • User ID and password You will be assigned with a user ID and password to access the computer. Both user ID and password should be kept confidential and not be shared with others. You are responsible for the security of your passwords and accounts. The password will be at least eight characters long and a combination of at least one number and one alphabet. You should change the password regularly, i.e. every three months. The computer is configured to allow three consecutive unsuccessful log-in trials. Extra unsuccessful login will disable your user account and please contact the system controller to reactivate your account. • Screensaver, lock or log off Screen saver with password protection (set to 10 minutes) has been configured at your computer. You should input the password to reactivate the computer. If you are going for lunch or going to leave the computer for a certain period of time, the computer should be locked or log off to prevent illegal access attempt. Monitors are suggested to be turned off to save energy. You should switch off your computer before leaving work for the day or before a prolonged period of inactivity. • Software The Firm provides licensed software to meet all legitimate software needs. If you require using software that is not currently provided by the Firm’s computer systems, you should make an application to the system controller (Office Manager or Financial Controller) following the approval by a Partner. You must not make copies of the Firm’s software, upload or transmit any software or files, commercial, copyrighted or otherwise, belonging to parties outside of the Firm, or the Firm itself, without approval from the system controller. No unauthorised or unlicensed application software shall be installed or used. Installation of all authorised software shall be done under the control of system controller. Anti-virus software shall always be enabled on the computers. • External Equipment Use of any portable storage device such as USB thumb drives, memory cards and external hard disks shall be prohibited without authorisation. Such devices must be checked by the system controller for virus before they are connected to any computers.

48 48 OLN Office Manual Internal LAN and Internet • Personal PC You should not connect any personal PCs to OLN’s network without authorisation from the system controller (Office Manager or Financial Controller). • Use of Internal LAN and Internet Any personal use of the office LAN and Internet (e.g. visiting chat rooms or public forum, sharing and downloading music and videos or playing games) is not allowed. You should not use the computer to browse non-business websites. You must not make or post indecent remarks, proposals, or materials on the Internet. Postings to newsgroups from a Firm email address are discouraged unless it concerns the Firm’s business-related matters and you have obtained authorisation from a Partner beforehand. Your use of the Internet and intranet may be subject to monitoring for security and/ or network management reasons. The Firm may also reasonably limit your use of these resources. • Files and software downloaded from Internet You should only download software and files from a known and trusted source. Files and software downloaded from the Internet shall be screened and verified with anti-virus software before use. Email • Ownership You shall only use the firms’ email system for legitimate business purposes. Messages sent out on the firm’s email system are not necessarily private and can be accessed by the system controller (Office Manager or Financial Controller) and by the Partners. You are responsible for exercising good judgment regarding the reasonableness of personal use. If you are uncertain, consult your supervising Partner. • Proper demeanour on email usage You must not send an email message from another person’s account unless you have specific permission from that person to do so. You may send and receive reasonable personal messages but not chain letters, junk email or any message which may be perceived as harassing, abusive, menacing, defamatory, obscene or discriminatory. Emails from suspicious sources shall not be opened or forwarded. Large attachments in personal email, such as music, videos and photos are not allowed. You should discourage friends from sending such attachments to your Firm email address as these can interfere with and cause delays in business-related emails.

49 49 OLN Office Manual • Disclaimer on email All external emails should contain the following disclaimer:- “The information in this email is confidential and may be legally privileged. The contents may not be disclosed or used by anyone other than the addressee. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. Oldham, Li & Nie cannot accept responsibility for the accuracy or completeness of this email as it has been transmitted over a public network. If you suspect that the email may have been tampered, intercepted or amended, please call the sender.” Printer and photocopier The printer and photocopier belong to the firm and you should only use it for legitimate business purposes. You have to be aware of the Copyright issue for the use of printer and photocopier. Printouts and hardcopies of confidential data must not be left unattended. Use of OLN’s IT facilities Access to OLN’s information technology facilities and systems (e.g. computers, laptops, email, Internet access, etc.) is provided to you for use in connection with Company business. Personal use should be minimised and be of reasonable duration and frequency and not adversely affect your proper performance of work. You should give careful thought of the appropriate medium, the substance, and the distribution of electronic messages to avoid overburdening OLN’s systems. You should not access any offensive information or sites on the Internet using OLN’s systems or while at work. In addition, if you receive any e-mails that are or could be considered offensive to any other employees, you should not forward them on within OLN. You should not send, post, display or download information that contains offensive, derogatory, or obscene language or images, nor may the systems be used to harass or defame any person. OLN has the right at any time to access monitor and disclose all business or personal messages sent and received via its communications and information systems, including voice mails, e-mail messages and any other type of data or voice communication or record, subject to its obligations under the Personal Data (Privacy) Ordinance. OLN only carries out these monitoring activities to the extent reasonably necessary, using what it considers the least intrusive means, and with the least impact on the privacy of the employees concerned. Employees are expected to comply fully with OLN’s Information Security policies and procedures and failure to do so could result in disciplinary action, with serious violations (e.g.: theft of IP or confidential information) liable to prosecution. Computer software You must comply with OLN’s rules relating to the installation and use of computer software. In particular, you must not install any software or software package if the rights of use have not been properly obtained.

50 50 OLN Office Manual Use of Internet The Internet is not a secure system under either OLN’s or the addressee’s control. As a result, security is not assured and should not be anticipated when using the e-mail system or Internet access to communicate outside of OLN. You should therefore be cautious in transmitting information or documents over the Internet, as the content, recipient, and attachments to any transmission may be disclosed to others than the intended recipients. You must not download, copy, access or transmit to third parties the works of others (such as by using social media or email or otherwise) without their permission, as this may infringe copyright. You should scan with anti-virus software all documents downloaded from the Internet or other sources to prevent importing computer viruses into OLN system. You must comply with the security measures as announced by the IT Department from time to time to avoid propagation of viruses. Guidelines on using social media You are not permitted to access social media on OLN IT devices and OLN discourages use of social media on personal devices during work hours. When using social media (including but not limited to professional and social networking sites such as LinkedIn, Facebook, or Weibo; bookmarking sites; and social news and information sites such as Twitter, YouTube, Flickr), it is important to understand that anything you post to social media sites - including material which may appear to be personal or unrelated to the Firm - has the potential to be associated with the Firm. The information you post to social media sites is easily accessible by clients, prospective clients, business Partners, competitors, and others. For this reason, good judgment and caution must be exercised to ensure that your comments and actions do not present reputational or other risks to OLN, clients, business Partners, or competitors. You should abide by the following guidelines: (a) Be respectful You should express yourself to others with respect and dignity. You should avoid using statements, photographs, video or audio that could reasonably be viewed as discriminatory, obscene, threatening or intimidating, intended to harm someone’s reputation or that might constitute harassment or bullying. (b) Be responsible You should not share any information that could damage the Firm interests or reputation or those of its clients or employees, or expose the Firm to any legal risks, including risks to intellectual property rights Your use of social media should not affect on your effectiveness and productivity at work. (c) Be clear When speaking on social media, make sure to express yourself in your own name and clearly state that you do not speak on behalf of OLN or Group. You should avoid any implication that your views have the Firm’s endorsement.

51 51 OLN Office Manual (d) Be aware Do not circulate confidential or sensitive information online (in particular confidential information about OLN, its clients or employees). You should remember that NOTHING is guaranteed private on the Internet. Remember, you may lose your memory but the internet never will. The net forgets nothing and retains everything. Keep that in mind before participating online. (e) Be cautious You should verify the information and the content you post online. Without knowing it, you may be sharing content that goes against OLN’s values and ethics. You should never use your Company login name or password on any social media sites. Guidelines on using e-mail Followings are some tips that can help you use e-mail more effectively and efficiently: (a) Watch you tone and use of words (b) Never express anger in e-mail (c) Be concise, but not curt (d) Use standard spelling and syntax (UK English) (e) Save important e-mails (f) Proof-read (g) Double check if the e-mail is going to the right person (h) Do not jump rank (i) Use the CC copy sensibly, copying only person(s) who need to be copied (j) Respond within 24 hours to at least acknowledge receipt, such that the sender understands what the progress is, even though there may not be a definite answer to the sender's questions. Company information on personal devices All documents, manuals, hardware and software provided for your use by OLN, and any data or documents (including copies) produced, maintained or stored on OLN’s computer systems or other electronic equipment (including mobile phones if provided by OLN), remain the property of OLN and may be accessed at any time. You agree that any Company information (including information about third parties that relates to OLN’s business) which is on your personal device (e.g. smartphone, tablet, personal computer or handheld device) remains OLN’s property and OLN may access such device to monitor compliance with its policies, protect its business information and ensure compliance with its legal and regulatory obligations as wells as contractual obligations to third parties. You agree that OLN’s devices and any such personal devices may be accessed or imaged for these purposes and the information may be transferred to third parties or other companies within OLN or Group in connection with these purposes, including transfer outside Hong Kong. Intellectual Property All intellectual property made, originated or developed by you at any time during the course of your employment with OLN (whether or not made, originated or developed during normal working hours) shall belong to and vest in OLN to the fullest extent permitted by law (“Employment IP”). For the avoidance of doubt, Employment IP does not include those works originated, conceived, written or made by you (i) wholly outside your normal working hours; and

52 52 OLN Office Manual (ii) which are wholly unconnected with your employment. To the extent that any of the Employment IP does not vest in OLN, you assign all rights, title and interest in the Employment IP to OLN. All records, documents, papers (including copies and summaries thereof), drawings, models and other works of a similar nature made or acquired by you in the course of your employment shall be and at all times remain the absolute property of OLN. You will waive in favour of OLN all rights granted by the Copyright Ordinance in connection with your authorship of any copyright works in the course of your employment with OLN, including without limitation any moral rights and any right to claim an additional payment relating to the use or exploitation of those works. Your wages are full compensation for your services and all present and future uses of copyright works made by you in the course of your employment; and you are not entitled to make any claims with respect to those copyright works. If you make any inventions that do not belong to OLN under the Patents Ordinance, you must forthwith exclusively license or assign (as determined by OLN) to OLN your rights in relation to such inventions and deliver to OLN all documents and other materials relating to them. OLN will pay to you such compensation for the license or assignment of any inventions that do not belong to OLN, as OLN will determine in its absolute discretion, subject to the Patents Ordinance. Contact with Press In order to better protect OLN’s interest and avoid misunderstanding, you must not have any interviews with or make any statements to any representative of the press, television, radio or other media on any matter connected with or relating to OLN unless prior approval is obtained from a member of the Management Committee.

53 53 OLN Office Manual PERSONAL DATA AND PRIVACY Policy OLN recognises its responsibilities in relation to the collection, holding, processing or use of personal data of its job applicants and employees under the Personal Data (Privacy) Ordinance. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by OLN is accurate. OLN will take all practicable steps to ensure the security of the personal data and to avoid unauthorised or accidental access, erasure or other use. OLN is committed to protecting the security of any personal data provided online and all practicable security measures have been adopted accordingly. If you have any queries, please consult the Data Protection Officer. To comply with the notifications requirements of the Personal Data (Privacy) Ordinance, OLN has prepared a Personal Information Collection Statement pertaining to recruitment, which is printed as part of your job application form. OLN has also prepared a Personal Information Collection Statement pertaining to employment, which is appended to your Employment Contract. Purposes From time to time, it is necessary for you to provide us with your personal data for purposes related to your employment or prospective employment with us, including: (a) The processing of your employment applications (which may include obtaining background checks and medical evaluations) (b) Human resources management purposes, such as: the planning and implementation of staffing and training, promotions, transfers, secondments and other career related matters; the review, implementation and administration of our employee benefits and entitlements; determining and reviewing salaries, incentives, bonuses and other payments; management of absences including for sickness, and payroll administration (c) Our provision of references in relation to your employment to any future employers; (d) Monitoring compliance with internal rules of OLN; including without limitation any code of business conduct and ethics, and conducting investigations related to compliance with Company policies or applicable laws; reporting any non-compliance to OLN and its agents and service providers; (e) Carrying out a matching procedure for human resources-related purposes or in response to a request for a matching procedure from any government departments or other appropriate governmental or regulatory authorities in Hong Kong or overseas; and (f) Other purposes directly relating to any of the above. Please note that it is mandatory for you to provide your personal data. If you are unable to supply your personal data as requested, OLN may be unable to provide you with employee benefits or take other actions related to your employment (such as providing your next employer with a reference letter) where use of your personal data is required.

54 54 OLN Office Manual Transfer of personal data Personal data will be kept confidential but, subject to the provisions of any applicable law, and only in connection to the purposes set out above, may be: (a) Made available to appropriate persons in our affiliated organisations, locally and overseas, and in this regard, you consent to the transfer of your data outside of Hong Kong; (b) Supplied to any agent, contractor or third party who provides administrative, telecommunication, computer or other services to any group company in Hong Kong or overseas and who has a duty of confidentiality to us; examples of such persons include: external auditors, hotline administrators, legal advisors, medical practitioners, trustees, insurance companies, actuaries and any consultants/agents appointed by OLN or any of its affiliates to plan, provide and/or administer employee benefits; (c) Supplied to persons seeking employee references; (d) Disclosed to any government departments or other appropriate governmental or regulatory authorities in Hong Kong or overseas such as the Inland Revenue Department and the Labour Department (and in this regard you consent to the transfer of your data outside of Hong Kong if necessary); (e) Made available to any actual or proposed purchaser of all or part of the business of OLN or, in the case of any merger, acquisition or other public offering, the purchaser or subscriber for shares in OLN and their advisors; (f) Made available to third parties in the form of Company marketing materials and/or directories which may be published online or otherwise, identifying the names, office telephone numbers, email addresses and other contact information for key officers, senior employees and their secretaries, assistants and support staff for promotional and/or administrative purposes; and/or (g) Used, disclosed or transferred for any purpose directly related to your employment/ prospective employment with any affiliates of OLN. Access to and correction of personal data You have the right to request access to any of your personal data which OLN holds, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request OLN to inform you of the type of personal data held by OLN. Requests for access and correction or for information regarding policies and practices and kinds of data should be addressed in writing to Human Resources. OLN's obligation to provide access to personal data shall be subject to the right of refusal and exemptions set out in the Personal Data (Privacy) Ordinance. A reasonable fee (which depends upon the complexity of the data requested) may be charged to offset our administrative and actual costs in complying with your access requests. Nothing in this statement shall limit your rights under the Personal Data (Privacy) Ordinance. OLN may retain the personal data of unsuccessful applicants for a maximum period of two years. The data may be retained for a longer period if there is a subsisting reason that obliges OLN to retain it, and OLN may refer the application to other vacancies within the group.

55 55 OLN Office Manual OLN may retain your personal data for a maximum period of seven years from the date when employment with OLN ceases. The data may be retained for a longer period if there is a subsisting reason that obliges OLN to retain it, or the data is necessary for OLN to fulfil its contractual or legal obligations.

56 56 OLN Office Manual ADDENDUM TO OFFICE MANUAL (1) The Retainer letter to be signed by client, and Client Information form to be completed before file is opened. Consideration to be given to requesting cost on account in every case. Every invoice to be sent out must contain the name of the client, the client’s full correspondence address, the client’s email address, the name of the contact person, and the telephone number and fax number of the client. Invoices are due immediately on presentation (as stated at the bottom of the invoice). Interest will accrue at 2% per month in the event that the invoice is not settled within 30 days, from the date of the invoice. Reminder letters to be sent out by the Credit Control Officer when invoice is unpaid after 30 days from date of invoice. This is by default and no consultation will be made with the introducer or handler. 15 days after the reminder letters have gone out, the Client Services Manager to telephone each and every client with an outstanding invoice requesting payment immediately. If the invoice is still unpaid 15 days after the Client Services Manager’s telephone call, then legal proceedings will be issued, unless otherwise countermanded by the Senior Partner. Please note that failure to adhere to the above instructions may lead to disciplinary action being taken against the offending handler. Published on 20 October 2022

57 57 OLN Office Manual ADDENDUM TO OFFICE MANUAL (2) There are five matters that are required when on-boarding a new client or opening a new file matter. These are: (1) the client signing a Retainer letter, (2) the client completing and signing a Client Information Form, (3) obtaining a copy of the client’s Hong Kong ID card or passport, (4) obtaining proof of address of the client, and (5) obtaining costs on account. This addendum deals specifically with the last of these items – costs on account. As stated on page 31 of this manual, money on account from the client must be obtained in respect of fees and disbursements. Failure to do so will result in the fee earner becoming liable for all fees so incurred. This applies to all Partners, Associates, Of Counsel, Consultants, and Registered Foreign Lawyers (Fee Earners) in OLN. Only the Equity Partners, Gordon Oldham and Stephen Peaker (Equity Partners) have the authority to dispense or waive the requirement that costs on account are to be obtained from every client and on every client matter. Accordingly, in respect of every matter on which a Fee Earner is engaged, whether as a handler or introducer, it is their duty to ensure that costs on account have been obtained at all stages of their engagement. If they have not, or the costs on account initially received have been exhausted, then costs on account or further costs on account must be obtained in respect of the work to be done on the file. It is therefore the duty of all Fee Earners when embarking on work on a client’s file (whether they be the initial handler or a subsequent handler) to check whether there are costs on account sufficient to cover the cost of the work they envisage doing. Fee earners do not have the authority to make the decision themselves to dispense with the requirement to obtain costs on account. Only the Equity Partners have the authority or right to dispense with this requirement. It cannot be stressed enough that costs on account on all client files must be maintained from the outset and throughout our engagement. If costs on account have not been obtained on a file on which you are working, it is your duty and responsibility to (1) ascertain this fact and (2) bring this to the attention of an Equity Partner in writing. Only after they have been informed, and you are instructed to proceed in any event, is a Fee Earner absolved from this duty and responsibility. Published on 15 June 2023

58 58 OLN Office Manual ADDENDUM TO OFFICE MANUAL (3) OLN will not act for any client or prospective client who has been sanctioned by the US Treasury Department’s Office of Foreign Assets Control (OFAC). The firm therefore requires all its solicitors to conduct an OFAC sanctions list search to determine whether a prospective new client has been sanctioned. The link to OFAC’s sanctions list is Sanctions List Search (treas.gov). Any queries or doubts arising should be referred to the firm's Compliance Partner. Published on 15 August 2023