Anti-Bullying & Anti-Harassment Policy

Effective 5 October 2026. Last updated 5 October 2026.

Asian Value Investor is committed to maintaining a professional, respectful, and inclusive workplace. This policy establishes our zero-tolerance stance toward all forms of bullying, harassment, and discrimination.

1. Purpose

Asian Value Investor (“Icarus Asia”) is committed to maintaining a professional, respectful, and inclusive workplace for every member of its team, regardless of role, seniority, or employment status. This policy sets out Icarus Asia's zero-tolerance stance toward all forms of bullying, harassment, and discrimination, and establishes clear procedures for reporting, investigating, and resolving such conduct.

This policy applies to all employees, contractors, interns, freelancers, and visitors who interact with Icarus Asia personnel in any professional capacity, whether in the office, at external events, through digital communications, or on social media.

2. Scope

This policy applies to all conduct that occurs:

On Icarus Asia premises or at any Icarus Asia-organized event;
Outside Icarus Asia premises where the conduct relates to work or involves Icarus Asia personnel;
Through any communication channel, including email, messaging platforms, social media, and phone; and
During business travel, client meetings, press events, or industry conferences.

3. Definitions

3.1 Bullying

Bullying is repeated, unreasonable behavior directed at an individual or group that creates a risk to health and safety. It includes, but is not limited to:

Persistent personal criticism unrelated to legitimate performance management;
Publicly humiliating, ridiculing, or belittling a colleague;
Deliberately excluding or isolating an individual from team activities;
Spreading malicious rumours or misinformation;
Deliberately withholding information necessary for someone to perform their duties; and
Intimidation through aggressive tone, body language, or repeated negative messaging.

3.2 Harassment

Harassment is any unwanted conduct related to a protected characteristic—including gender, race, ethnicity, nationality, age, religion, disability, marital status, sexual orientation, or pregnancy—that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, or offensive environment. Examples include:

Offensive jokes, slurs, or derogatory remarks;
Displaying or sharing offensive images, videos, or materials;
Unwelcome physical contact or invasion of personal space;
Repeated unwanted communication of a personal nature; and
Making threats or engaging in coercive behavior.

3.3 Sexual Harassment

Sexual harassment is a form of harassment involving unwanted conduct of a sexual nature. This policy applies without distinction as to the gender, sex, or sexual orientation of either party. It includes, but is not limited to:

Unwelcome sexual advances, propositions, or persistent flirtation;
Requests or pressure for sexual favors, whether explicit or implied;
Sharing, displaying, or distributing sexually explicit materials in the workplace or via Icarus Asia communications;
Making sexually suggestive remarks, innuendo, or gestures;
Unwanted physical contact of a sexual nature; and
Any other conduct of a sexual nature that violates a person's dignity or creates a hostile environment.

3.4 Same-Sex Harassment

Icarus Asia expressly recognizes that sexual harassment and bullying can and does occur between individuals of the same gender or sexual orientation. Same-sex harassment is treated with the same seriousness and subject to the same investigation procedures and disciplinary consequences as any other form of harassment under this policy.

3.5 Harassment by Persons in Authority

This policy applies equally to all employees regardless of seniority or hierarchical position. Egregious conduct by a supervisor—including the use of positional power to coerce, intimidate, demean, or sexually harass a subordinate—will be treated as an aggravating factor in any disciplinary determination.

No seniority, tenure, editorial standing, or professional reputation shall be accepted as justification, mitigation, or excuse for conduct that violates this policy.

3.6 Prohibited Romantic and Personal Relationships

Icarus Asia maintains a strict policy prohibiting romantic liaisons, intimate relationships, and personal entanglements between colleagues that could compromise professional integrity. The following is expressly prohibited:

Any romantic or intimate relationship between two members of staff where one holds supervisory, editorial, or managerial authority over the other;
Any romantic or intimate relationship that gives rise to a conflict of interest, bias, or preferential treatment;
Any attempt to leverage a personal relationship to influence hiring, promotion, or editorial decisions; and
Any conduct that blurs professional and personal boundaries in a manner that disrupts the operation of the newsroom.

Violations may result in mandatory reassignment, demotion, or termination. Where conduct involves coercion, abuse of authority, or criminal behavior, Icarus Asia will pursue all available remedies under Hong Kong law.

3.7 Victimization and Retaliation

Victimization occurs when a person is treated less favorably because they have raised a complaint in good faith, provided evidence in an investigation, or supported a colleague who has done so. Retaliation against anyone who exercises their rights under this policy will be treated as a separate disciplinary matter.

4. Prohibited Conduct

The following conduct is strictly prohibited:

Any act constituting bullying, harassment, sexual harassment, or prohibited romantic conduct as defined in Section 3;
Discriminatory treatment on the basis of any protected characteristic;
Using professional authority to coerce or pressure subordinates;
Sharing, forwarding, or posting offensive content through Icarus Asia systems or personal accounts where it implicates Company personnel;
Making false allegations in bad faith with the intent to harm a colleague; and
Retaliating against any person who has raised or supported a complaint under this policy.

5. Responsibilities

5.1 All Staff

Treat colleagues, clients, sources, and external partners with respect and professionalism;
Speak up if they witness behavior that may constitute bullying or harassment;
Cooperate fully and honestly in any investigation; and
Complete any required training related to workplace conduct.

5.2 Managers and Editors

Model professional conduct at all times;
Address concerns promptly and without bias;
Ensure team members are aware of this policy and reporting channels; and
Refrain from any action that could be perceived as favoritism, victimization, or abuse of authority.

5.3 Human Resources

Maintaining this policy and ensuring it is current and accessible;
Providing guidance to staff and management on policy application;
Overseeing investigations into formal complaints; and
Maintaining confidential records of all complaints and outcomes.

6. Reporting Procedures

6.1 Informal Resolution

Where appropriate, an informal approach may be taken first—directly communicating to the individual that their behavior is unwelcome, or approaching a trusted line manager for guidance. HR can provide coaching support for informal resolution.

6.2 Formal Complaint

A formal written complaint may be submitted at any time to:

The Head of Human Resources ([email protected]);
Any member of the senior leadership team; or
A designated third-party reporting channel.

Complaints should include a factual description of the incident(s), dates, witnesses (if any), and supporting documentation. Anonymous complaints will be accepted, though the ability to investigate may be limited.

6.3 Urgent Situations

Where a complainant believes they are in immediate danger or where criminal conduct may be involved, they should contact local law enforcement in Hong Kong (Emergency: 999) without delay.

7. Investigation Process

Upon receipt of a formal complaint, Icarus Asia will follow these steps:

Acknowledgment: HR will acknowledge receipt within two (2) business days.
Appointment of Investigator: An impartial investigator—internal or external—will be appointed. For complaints involving senior management, an independent external investigator will be engaged.
Interim Measures: Temporary reassignment or remote working arrangements may be implemented to protect all parties.
Investigation: Both parties will be interviewed separately. Witnesses and relevant evidence will be reviewed.
Findings: A written findings report will be prepared and shared with HR and senior leadership.
Outcome: Icarus Asia will aim to conclude investigations within twenty (20) business days, subject to complexity.

All proceedings will be treated with the strictest confidence to the extent permitted by law.

8. Disciplinary Action

8.1 Progressive Warning Framework

First Warning: A formal written warning with mandatory conduct training.
Second Warning: A second written warning with possible enhanced supervision, performance improvement plan, or temporary reassignment.
Third Consecutive Warning: A formal disciplinary hearing, which could potentially include termination of employment.

Three consecutive formal warnings may result in termination. All decisions will be made in accordance with the Hong Kong Employment Ordinance (Cap. 57).

8.2 Gross Misconduct

Certain acts may warrant immediate suspension and summary dismissal without prior warnings, including:

Physical assault or threats of physical violence;
Sexual assault or conduct constituting a criminal offense;
Severe, targeted harassment causing demonstrable psychological harm; and
Deliberate falsification of evidence or intimidation of witnesses during an investigation.

9. Confidentiality

All parties involved in a complaint—including the complainant, the respondent, witnesses, HR, and management—are required to maintain strict confidentiality throughout and after the process. Information may only be disclosed on a need-to-know basis or as required by law. Breach of confidentiality may itself constitute a disciplinary matter.

10. Non-Retaliation

Icarus Asia prohibits retaliation against any individual who, in good faith:

Files a complaint under this policy;
Participates in or supports an investigation;
Refuses to participate in conduct that violates this policy; or
Exercises any other right protected under applicable law.

11. Applicable Legal Framework

This policy is designed to operate in compliance with Hong Kong's applicable legislation, including:

Sex Discrimination Ordinance (Cap. 480);
Disability Discrimination Ordinance (Cap. 487);
Family Status Discrimination Ordinance (Cap. 527);
Race Discrimination Ordinance (Cap. 602);
Employment Ordinance (Cap. 57); and
Personal Data (Privacy) Ordinance (Cap. 486).

12. Policy Review and Updates

This policy will be reviewed annually, or following any significant change in applicable law or Icarus Asia structure. All staff will be notified of material updates. The most current version of this policy will be maintained on the Icarus Asia website.

Questions or concerns about this policy? Contact HR at [email protected]