Compliance Standards for MPF Approved Trustees 《強積金核准受託人合規標準》

Purpose, Compliance Programme and Policy (Standards 1 and 2) 目的、合規計劃及政策（標準１及２）

The MPFA developed these eight standards to help approved trustees build good corporate governance, proper risk management and a positive compliance culture into their operations. Detailed explanatory notes and examples accompany each standard to support a structured approach to compliance monitoring. [MPFA Compliance Standards for MPF Approved Trustees](https://www.mpfa.org.hk/en/-/media/files/information-centre/legislation-and-regulations/others/compliance_standards_first_edition.pdf)

Standard 1 concerns the overall compliance programme: the trustee should have a working framework for checking whether statutory obligations are met and following up breaches. A list of legal requirements without arrangements for monitoring compliance and addressing breaches is insufficient.

Standard 2 concerns the compliance policy, which sets the organisation's direction for promoting a positive compliance culture and sound compliance practices. The trustee's Board of Directors should endorse it, and management, staff and service providers should have ready access to it; endorsement by the compliance manager alone or access restricted to senior management is insufficient.

Compliance Resources, Training and Communication (Standards 3 and 4) 合規資源、培訓及溝通（標準３及４）

Standard 3 requires compliance resources to be both adequate and independent. Sufficient resources without independent monitoring, or nominal independence without sufficient resources, would fall short; compliance reporting should also be timely, accurate and complete.

Standard 4 connects compliance culture with employees' actual work. Relevant staff should understand their roles in meeting the trustee's statutory obligations, so training and communication should reach staff with relevant responsibilities beyond the compliance department.

Complaints Handling and Ongoing Review (Standards 5 and 6) 投訴處理及持續檢討（標準５及６）

Standard 5 covers complaints from both scheme members and participating employers. The trustee should have procedures for managing both proactively and promptly; handling member complaints while excluding complaints from participating employers would fall short.

Standard 6 concerns the effectiveness of the compliance programme itself. The trustee should have measures for maintaining and reviewing the programme to monitor whether it works effectively; establishing it is followed by an ongoing need to maintain and assess its operation.

Board Reporting and Management of Specific Obligations (Standards 7 and 8) 董事局匯報及具體責任管理（標準７及８）

Standard 7 calls for reporting arrangements that give the Board, including independent directors, timely and accurate information to oversee compliance in the trustee's operations. Assigning daily compliance work to designated staff does not remove the Board's monitoring responsibility.

Standard 8 focuses on practical compliance measures covering the identification, monitoring, supervision and reporting of statutory obligations. For examination purposes, distinguish Standard 1's overall compliance framework from Standard 8's measures for managing identified obligations.