Chinese Contract and Commercial Law - Essay Example

CHINESE CONTRACT AND COMMERCIAL LAW Relationship Between China and Hong Kong Name of Student: Student No: Date: Name of Supervisor: Abstract This essay attempts to decipher the relationship between Hong Kong and China as it pertains to contract law. As they operate under the premise of ‘one country, two systems’ there are some aspects of contract law that could apply in one but not the other. The essay attempts to break down what laws are used in both regions and what international treaties are applicable and the resultant relationship. These treaties include UNIDROIT and CISG as they apply to China and the common law referenced by Hong Kong’s unwritten contract law system. A number of issues are raised to do with how the difference in systems could lead to potential problems in the near future if they have not already and what can be done to mitigate against these issues including ensuring dialogue is carried out, clarifying which laws are applicable where and having a written document to refer to. Contents Abstract 2 Introduction 4 Chinese Contract Law 6 Sources of Chinese Law 9 Basic Principles of Chinese Contract Law 16 Sources of Law in Hong Kong 18 Codifying Contract Law and Attaining Unity 19 Conclusion 23 Recommendations 24 Bibliography 25 Introduction This essay aims to come to an understanding of the operations involved in the operation of two legal systems within the territories of the People’s Republic of China. These two territories have come about due to re-unification of China with Hong Kong in 1997. Their legal systems differ in terms of how they carry out business. Hong Kong is part of Chinese territory and has been for millennia. However, it was a British colony for 150 years and on 1st July 1997, reverted back to China, becoming a Special Administrative Region (HKSAR)1. Hong Kong has however maintains her sovereignty in terms of her capitalistic, legal and social systems while still maintaining national unity, through the principle of ‘one country, two systems’ that China espouses. Basic Law of HKSAR known as the mini-constitution provides for a different legal system in Hong Kong, from that practiced in Mainland China. The Common Law System is used in Hong Kong while the Continental System is used in the Mainland. This could be a potential source of conflict between these two territories but so far, they have managed to cohabit peacefully. The history of China is long and rich and spans millennia of civilization. The history and structure of the legal system in traditional China is characterized by feudalism, emperor rule and imperialism. The existence of legal codes was known in traditional China with the oldest surviving one being the Tang code which was promulgated in the seventh century AD. This was the basis for the development of the subsequent Song, Ming, Yuan and Qing dynasty codes. These codes and statutes are the guidelines for regulation of matters relating to criminal law in contemporary legal systems. The distinction between criminal and civil law had not yet been made in jurisprudence and many times penal consequences were effected on acts that would be covered by civil law in contemporary society. Civil disputes between individuals to do with family or land matters were dealt with using mediation. This was carried out by respected leaders or elders within the village setup who used rules that were customary as well as moral concepts to achieve harmony among affected parties. The emperor had executive, legislative and judicial powers in traditional China and although the laws were binding to all citizens, the emperor remained unbound by them. Being the supreme power when it came to judicial matters, the emperor was at liberty to establish the guilt or innocence of accused parties, determine the penal sentence or change the rulings given by lower courts. How international law should be handled is not covered in the 1982 Constitution as they relate to PRC laws. Practically however, legislation tends to use the integration approach when it comes to linking international and PRC law. If there is a conflict between the PRC and international law, whether in full or in a provision of the treaty, this particular part is not implemented within the law. Exercising powers of prosecution in Mainland China rests with the People’s Procuratorates while in Hong Kong, this is covered by the Department of Justice. The roles and functions of the prosecuting authority in Hong Kong is mainly unwritten and relies heavily on conventions while in Mainland China, the statues govern these roles and functions. Similarities and differences exist in how prosecution is carried out and the safeguarding of victims’ rights done. Civil disputes between individuals to do with family or land matters were dealt with using mediation. This was carried out by respected leaders or elders within the village setup who used rules that were customary as well as moral concepts to achieve harmony among affected parties. The emperor had executive, legislative and judicial powers in traditional China and although the laws were binding to all citizens, the emperor remained unbound by them. Being the supreme power when it came to judicial matters, the emperor was at liberty to establish the guilt or innocence of accused parties, determine the penal sentence or change the rulings given by lower courts. In the early part of the twentieth century, the Qing Empire made an effort to bring up to date the legal system. It became increasingly obvious that some aspects of the legal system, the extreme measures instituted in criminal proceedings and the dearth of commercial law, for example, were keeping the Chinese legal system from being competitive as compared to other jurisdictions. Chinese Contract Law Any law which will affect a wide range of people in china is enacted by either the NPC or else, its Standing Committee. Other regulations, decisions and resolutions are also enacted by the Standing Committee. The State Council enacts various types of legislation including administrative regulations. They also come up with rules in conjunction with its ministries and commissions. The people’s congress enacts local regulations and local people’s governments are in charge of local administrative rules. As pertains to independent regions, they are allowed to enact independent as well as specific regulations. They also have an innovative concept known as Basic Law, which is used to deal with specific regions such as Hong Kong which had their own legal system before being re-integrated into China. These regions are known as Special Administrative Regions in which the basic law of the previous legal system is kept as long at the laws are not in conflict with those of the PRC Constitution. Under the auspices of Chinese Law, some kinds of contracts do not come into effect unless they are approved or registered by the relevant expert Chinese authorities. These include Sino-international venture contracts, equity pledge agreements and equity transfer agreements that pertain to foreign investment enterprises. Such contracts need validation by the Ministry of Commerce or a local subsidiary. In the event of impasse in approval or registration, protection is extended to foreign investors through Interpretation. This refers to the second judicial interpretation by the Supreme People’s Court as pertains to PRC Contract Law. It is applicable in all contract issues that have arisen since the implementation of Contract Law in 1999, although no final judicial judgement has been given. The Interpretation by the Supreme People’s Court outlines clearly the legal details pertaining to the formation, validity, performance and termination of contracts2. Article 8 of Interpretation states that in the case of such impasse, this can be viewed as a contravention of the principle of good faith and liability will be placed upon the accountable party, should this party which has the responsibility of carrying out the application procedures for approval or registration was derelict in their duties. The Supreme People’s court through judicial procedure may allow the opposing party that is the international partner, to conduct the procedures themselves. In spite of this new regulation however, it is still a challenge for foreign investors to submit Sino-foreign joint venture contracts in practise, for validation by Chinese authorities, if the Chinese partner in the joint venture is uncooperative3. There has been development of international tools that are able to create an overlap between various national contract law systems in order to facilitate trade between partners from these nationalities. These include the United Nations Convention on Contracts for the International Sale of Goods as well as the UNIDROIT4 Principles of International Commercial Contracts. This is a set of comprehensive soft law principles which impact upon domestic contract law reform in many jurisdictions. The new Contract Law of China adopted in March 1999 by the Second Session of the Ninth National People’s Congress, and came into being in October 1999 is the new unified Contract Law of the People’s Republic of China. Other laws abrogated at the same time included the Economic Contract Law of the People’s Republic of China or the Law on Economic contracts, the Law of the People’s Republic Of China On Economic Contract Involving Foreign Interests or the Foreign Economic Contract Law and the Law of the People’s Republic of China on Technology Contracts. These three laws are referred to as the three former contract laws. The structure of the new Contract Law has three parts; General Provisions, Specific Provisions and Supplementary Provisions. There are twenty three chapters with 428 articles. Sources of Chinese Law The first source of law is the Constitution of the People’s Republic of China (1982) otherwise known as Zhonghua Renmin Gongheguo Xianfa. This is the highest source of law in the country. It is the source of the government structure as well as being the embodiment of the codified general government principles and the outline of the People’s basic rights and duties. The constitution is composed of an amalgam of three prior constitutional documents viz the 1954, 1975 and 1978 constitutions How international law should be handled is not covered in the 1982 Constitution as they relate to PRC laws. Practically however, legislation tends to use the integration approach when it comes to linking international and PRC law. If there is a conflict between the PRC and international law, whether in full or in a provision of the treaty, this particular part is not implemented within the law. Precedent is not strictly enforced in case law within the PRC as compared to other common law jurisdictions such as the United States or England. The theory is that every case is unique and decisions reached upon it do not bind other courts. Practically however, the lower people’s courts tend to try and mimic and the interpretations of laws reached by Supreme People’s Courts5. The higher courts also have the power to use the finality of their appellate decisions to bind lower courts as pertains to the initial judgment or order. The United Nations Commission on International Trade Law (UNCITRAL)6 was established by the General Assembly in 1966 with the mandate to further the progressive harmonization and unification of the law of international trade. The Commission is composed of thirty-six member States elected by the General Assembly for terms of six years. The current UNCITRAL members from the Americas are Argentina, Brazil, Colombia, Honduras, Mexico, Paraguay, United States of America, and Uruguay. The Secretariat of UNCITRAL is the International Trade Law Branch of the United Nations Office of Legal Affairs located in Vienna. The Commission has established three working groups to perform the substantive preparatory work on topics within the Commission's program of work and carries out its work at annual sessions UNCITRAL has been particularly active in the following areas: international sale of goods, international transport of goods, international commercial arbitration and conciliation, international payment, cross-border insolvency, construction and more recently e-commerce and procurement. Among the most recognized UNCITRAL instruments in these areas are the following: The United Nations Convention on Contracts for the International Sale of Goods (Vienna, 1980). This Convention establishes a comprehensive code of legal rules governing the formation of contracts for the international sale of goods, the obligations of the buyer and seller, remedies for breach of contract and other aspects of the contract. The Convention entered into force on 1 January 1988. The United Nations Convention on the Carriage of Goods by Sea, 1978 (the "Hamburg Rules"). This Convention establishes a uniform legal regime governing the rights and obligations of shippers, carriers and consignees under a contract of carriage of goods by sea, and was prepared at the request of developing countries and entered into force on 1 November 1992. Discharge of contracts occurs when parties perform their contractual commitments. It has been decreed by several courts that contractual parties should adhere to principles of good faith or ‘fair dealing’ in the performance of their contractual duties as is illustrated in several cases such as Renard Constructions (ME) Pty Ltd v Minister for Public Works (1992)7, Hughes Aircraft Systems International v Air services Australia (1997)8, Burger King v Hungry Jack’s Pty Ltd [2001]9, GEC Marconi Systems Pty Ltd v BHP Information Technology Ltd [2003]10, and Royal Botanic Gardens and Domain Trust v South Sydney City Council (2002)11. When the new Contract Law was drafted the Chinese legislators used the UNIDROIT Principles of International Commercial Contracts12. Several articles in the new Contract Law especially those in the General Provisions are based on the UNIDROIT principles in terms of: Scope of Application The UNIDROIT scope of application is limited to international commercial contracts and the preamble clearly stipulates that this. There is further emphasis on the fact that commercial contracts have a wide range of meaning including transactions in exchange of goods/services or supply of the same, but also other economic transactions such as concession agreements, investment and professional service contracts. There has been development of international tools that are able to create an overlap between various national contract law systems in order to facilitate trade between partners from these nationalities. These include the United Nations Convention on Contracts for the International Sale of Goods as well as the UNIDROIT13 Principles of International Commercial Contracts. This is a set of comprehensive soft law principles which impact upon domestic contract law reform in many jurisdictions. ‘A contract for the sale of goods’ can be defined through articles 30 and 53 of the CISG. The former states that ‘The seller must deliver the goods, hand over any documents relating to them and transfer the property in the goods, as required by the contract and this Convention.’ While article 53 states that: ‘The buyer must pay the price for the goods and take delivery of them as required by the contract and this Convention.’ The bilateral nature of the legal transaction is what defines a contract of sale and it implies that both contracting parties are obligated and commit themselves to a performance. Failure of a contracting party to fulfill its obligations as outlined in the contract can result in the non-breaching party to seek remedy under CISG. The main remedies outlined as provided by CISG are that: The right to require performance. Article 25B outlines when a fundamental breach has occurred which involves significant failure to meet expectations, etc. Conformity of goods as outlined in article 35A and 35B which covers the quality, quantity and description of goods as outlined in the contract. Article 47A which provides for fixing additional time to meet the requirements for performance. This is the buyer’s right. Article 49A covers the buyer’s right to avoid contract and what the grounds for avoidance are. Section 84A covers the seller’s obligation to refund price and what interest must then be paid.14 According to Article 45 (1) (b) and 61 (1) (b) of the CISG, the injured buyer and seller are able to claim damages stated in articles 74-77 under the proviso that the opposing party fails to honor their part of their agreement. These articles are made up of Section II of Chapter V of Part III, that provide for what damages are liable to the aggrieved parties. These provisions are exhaustive and eliminate the need for recourse to the domestic law. Article 74 outlines the general formula that can be used in all cases where the injured party is permitted to receive some compensation. It encompasses damages resulting form breach of contract including loss of profit as a result of the breach in the cases where these losses were predictable by the breaching party at the conclusion of the contract. The type of contract signed between the parties would determine whether or not this constitutes a fundamental breach of contract. If the contracting parties had agreed that in case one party breaches the contract then the other is free to terminate the contract, then strict adherence to the contract is critical and any contractual deviation would fall under the aegis of fundamental breach. This is outlined in Article six of the CISG. In the absence of explicit profession of this proviso, the duty of strict compliance is implied in the language of the contract, the prevailing conditions, tradition, usage or a way to resolve the issue15. Article 81 in Section V of Part III, Chapter V outlines the effects of avoidance and article 84 outlines the consequences of avoidance of contract. This involves the seller being liable for any interest accrued on payments that it has received. However article 82 outlines some quid pro quos that set limits to the right to avoid by the buyer. These limits include the proviso that in order to avoid contract the buyer must return the goods already delivered more or less in the same condition as they were in when received unless they invoke an exception to this rule as laid out in article 82 (2) a, which provides for the above not to apply if it is impossible for the goods to be returned in the condition that they were received. Article 84 gives guidelines as to the liability of both parties. The seller must pay interest on money received and the buyer must account for any benefits accrued from the goods or part of them. The CISG provides that if a fraud is committed prior to the conclusion of a contract or in the course of its performance, then the claims would accrue on the date on which the fraud was discovered.16 Basic Principles of Chinese Contract Law The basic principles of the new Contract Law are laid out in Articles 3-7 that is equality17, party independence18, fairness19, good faith20, and public interest21. These basic principles are also enshrined in the UNIDROIT principles. Article 4 of the new Contract Law for example states that: “The parties shall have the right voluntary to enter into a contract in accordance with the law. No entity or individual may illegally interfere with such right. “ This is similar to article 11 of the UNIDROIT Principles which highlights the freedom of the contract saying that: “[t]he parties are free to enter into a contract and to determine its content. “ Article 8 of the new Contract Law which outlines the effectiveness of a contract states that: “A contract established in accordance with the law shall be legally binding on the parties. The parties shall perform their respective obligations in accordance with the terms of the contract. Neither party may unilaterally modify or rescind the contract. The contract established according to law shall be under the protection of law. “ This is similar to article 1.3 of the UNIDROIT Principles which state that: “A contract validly entered into is binding upon the parties. It can only be modified or terminated in accordance with its terms or by agreement or as otherwise provided in these Principles.“ The bilateral nature of the legal transaction is what defines a contract of sale and it implies that both contracting parties are obligated and commit themselves to a performance. This performance is pursuant to the other party also fulfilling their obligations22. Sources of Law in Hong Kong Employment law in Hong Kong is derived from local legislation such as ordinances, regulations and Codes of Practise as well as common law. Jurisprudence from other territories such as England and other common law jurisdictions are taken into account. Before re-unification with China, the decisions of English law courts were applicable in Hong Kong. Since then however, the English courts are simply a reference point for Hong Kong jurisprudence. When resolving disputes, there is a hierarchy of courts of justice in Hong Kong. In order from the highest to the lowest, these are: a. Court of Final Appeal; b. High Court: • Court of Appeal, which hears appeals on all matters from the Court of First Instance and the District Court; and • Court of First Instance; c. District Court, which has limited civil jurisdiction over claims of up to HK$_ million; and d. Small Claims Tribunal which has a limited civil jurisdiction over claims of up to HK$50,000. Codifying Contract Law and Attaining Unity The legal system in Mainland China is very similar to that of continental Europe viz, France, Germany as well as Japan and Taiwan. All these jurisdictions prefer codes of law which promote legislative uniformity rather than simply legal systems. Contract law is thought of as having independence from both the traditions of common law and continental law. The former constructs its contract law from combined precedent of case law and statutes while the latter classifies contract law under civil and commercial law. Obtaining a uniform law and constructing a legal framework form a system must entail forging logical connections between various branches and these are some of the driving forces behind codification of laws in China. Under the model of continental law, a foundation of law must first be established before there is descent into specifics the legal reform movements that were forged by the Qing Dynasty in China embody this process. In the early part of the twentieth century, the Qing Empire made an effort to bring up to date the legal system. It became increasingly obvious that some aspects of the legal system, the extreme measures instituted in criminal proceedings and the dearth of commercial law, for example, were keeping the Chinese legal system from being competitive as compared to other jurisdictions. The Law Reform Bureau was incepted in 1904 and it was tasked with translation of foreign codes and drafting of new laws. The Imperial Constitutional Outline was promulgated in 1908, but before the new laws could be implemented, the Qing Empire was overthrown in 1911. However, the incoming government did implement some of the laws that were based on drafts produced in the reform movement initiated by the Qing Empire. More recently, the passage of the Code of General Principles of Civil Law (GPCL)23 that took place in 1986 which covers the half of the Code of Civil Law which is aimed at addressing all legal relationships of a civil or commercial nature within the People’s Republic of China. It covers the general principles and specific rules that need to be articulated. In this era in Chinese history where legal guidelines are necessary to navigate the various legal relationships that are incepted on a daily basis within the country, a thorough code of civil law which is well-thought out and done with extensive consultation is necessary yet has not yet come to fruition. This has resulted in China only having a civil law code that is made up of general principles. . July 1st 1921 saw the establishment of the Communist Party of China (CPC) and there followed shortly after, a period of upheaval that was named the ‘New Democratic Revolution’. This revolution embodied three crucial struggles that the CPC underwent. These were the Second Revolutionary Civil war from 1927 to 1937, the War of Resistance against Japan from 1937 to 1945 and the Third Revolutionary Civil War from 1945 to 1949. The People’s Republic of China was founded by the CPC in 1949. The highest organ of state power as outlined in Article 57 of the Constitution of the People’s Republic of China (1982) is the National People’s Congress (NPC). This body is partly made up of a Standing Committee that is a permanent entity within the National People’s Congress according to Articles 57 as well as 65-69. The NPC is a unicameral entity that has the authority to establish laws within China as laid out in article 58. The term of office for individual deputed to the NPC is five years according to article 60. They are mandated to amend the constitution, are able to carry out enactment of laws, election of the president and vice president of the PRC, election of the president of the Supreme People’s Court, mediate on questions of war and peace as well as various powers of removal according to articles 62-63. When not in session, the NPC is represented by the Standing Committees in enactment of amendments and additions to laws passed by NPC according to article 89. At a more local level, legislation is enacted by the people’s congresses of provinces, municipalities, independent regions as well as cities. This is enshrined in the constitution under articles 95-111. The local regulations must still comply with constitutional standards as well as the regulations enacted by the NPC and the people’s congresses above them in the hierarchy. A typical bill goes through four stages in the NCP; presentation, examination, passing of the bill and publication. In the 1970s and 1980s, there was an increasing open door policy in China, precipitating extensive economic reforms. Prior to this, a code of contract law was not possible. Rules of contract law were created in China without a basis in contract theory. Before that, contract law had no place in the planning of the economy and the state-controlled market. They only became necessary when economic reform began to take place. Three laws were developed to cater for this including the Economic Contract Law of the PRC in 198124 which is applicable to contracts between Chinese parties. In 1985, the Foreign Economic Contract Law25 was passed, which was done to deal with those contracts involving foreign nationals or entities. In 1987, the final law known as Technology Contract Law26 was passed which monitored the transfer of technology between Chinese entities. These are the foundation for a number of by-laws and regulations that govern contract law in the PRC. There is however still lack of one common law which may cause confusion and may escalate into a serious issue which could threaten conduction of commerce within the PRC. There are three thousand Basic People’s courts at the level of the county while these are further broken down into 20,000 smaller units known as people’s tribunals that are set up in villages and towns. The Intermediate Courts number 376 and Higher People’s Courts number thirty one and they are found in the provinces27. Furthermore, there are other special courts such as those which deal with rail transport, forestry, the People’s Liberation Army (PLA) and maritime issues. The jurisdiction for these courts is provided for in the constitution as well as the 1979 Organic Law of the People’s courts, the Law of Criminal Procedure, the Law of Civil Procedure and the Law of Administrative Procedure. Any law which will affect a wide range of people in china is enacted by either the NPC or else, its Standing Committee. Other regulations, decisions and resolutions are also enacted by the Standing Committee. Conclusion The purpose of this essay was to outline the potential issues that could arise due to the differences in contract law practiced in Mainland China as opposed to Hong Kong. The history of commercial litigation within the two territories has been divergent for at least a century and a half when Hong Kong was ruled by the British. As a result of this colonialism, Hong Kong’s commercial law is based more in line with British Common Law than the continental law that is practiced in China. However, China was an early signatory of the CISG giving common ground for it to work in harmony with other jurisdiction in the carrying out of duties of commerce. The Chinese constitution gives proviso for use of international treaties within its borders so long as it is in line with China’s own constitution. The Hong Kong judicial system has no hard and fast legislation to deal with the same, but substantial authority is placed in the decisions reached by the British Courts. The question arises as to what the procedure is once there is a conflict of interest between Chinese Law and Common Law. The CISG has proviso for resolution of disputes but it is unknown whether under the Basic Law, Hong Kong is also obligated under the terms of the guidelines to follow the CISG-recommended path. Due to its capitalistic leanings, Hong Kong is an attractive draw for foreign investment in the territories and seeing as China is interested in attracting as much foreign investment that may translate into job creation and other advantages; it is in their best interest to foster these relationships. As a result, there is an informal impasse between China and its Hong Kong territory when it comes to contract law. The fact that China has yet to enact a concrete guideline for conducting business in this arena is another potential bottleneck that could cause issues at some point. As reforms continue to be carried out, it would behove China to look into this issue with some urgency. Recommendations Further reform needs to be carried out to Chinese contract law to lay out the fundamentals of dispute resolution and carrying out business in the region. A joint task force consisting of the mainlanders and Hong Kong stakeholders should be formed to map out the way forward for Sino-Hong Kong commercial relations. A clarification needs to be made about how culpable Hong Kong is when it comes to CISG and UNIDROIT principles. Bibliography Constitution of the People's Republic of China (Adopted On December 4, 1982) Vinck, I. (2009) New Interpretations of the PRC Contract Law. China Newsletter. Taylor Wessing. August International Institute for the Unification of Private Law (UNIDROIT), see M. J. Bonell, An International Restatement of Contract Law: The UNIDROIT Principles Of International Commercial Contracts, 3rd edition, Ardsley, New York 2005. Ronald C. Brown, Understanding Chinese Courts And Legal Process:  Law With Chinese Characteristics 82 (1997).  UNCITRAL's website at: . Renard Constructions (ME) Pty Ltd v Minsiter for Public Works (1992) 26 NSWLR 234 at 263. Hughes Aircraft Systems International v Airservices Australia (1997) 146 ALR 1 Burger King v Hungry Jack’s Pty Ltd [2001] NSWCA 187 GEC Marconi Systems Pty Ltd v BHP Information Technology Ltd [2003] FCA 40 (particularly paras [915]-[922]) Royal Botanic Gardens and Domain Trust v South Sydney City Council (2002) 186 ALR 289 The UNIDROIT Principles of International Commercial Contracts, UNIDROIT (Rome), 1994. International Institute for the Unification of Private Law (UNIDROIT), see M. J. Bonell, An International Restatement of Contract Law: The UNIDROIT Principles Of International Commercial Contracts, 3rd edition, Ardsley, New York 2005. Enderlein, F. (1996) Rights and Obligations of the Seller Under the UN Convention on Contracts for the International Sale of Goods. Sarcevic, P. & Volken, P. eds. Dubrovnik Lectures, Oceana Welser, R. (1985) The breach of the seller and their sanction (in the UNCITRAL sales law in comparison to the Austrian law 120. Code Of the General Principles Of Civil Law (P.R.C.), Translated In 34 Am. J. Comp. L. 715 (1986) [Hereinafter C. Civ. L.]. Economic Contract Law (P.R.C.), Translated In 22 I.L.M. 330 (1983) [Hereinafter Econ. Cont. L.]. Foreign Economic Contract Law (P.R.C.), translated in 24 I.L.M. 799 (1985) [hereinafter FOREIGN ECON. CONT. L.]. Technology Contract Law (P.R.C.), translated in China Law (visited Feb. 15, 13) http://www.qis.net/chinalaw/prclaw2I.htm>[hereinafter TECH. CONT. L.]. Evena Chan, 1998 One Country, Two Systems: the decisions to investigate and prosecute in China and Introduction the Special Administrative Region of Hong Kong [HKSAR] Workshop No. 202. Read More