The Hong Kong Exchanges and Clearing Limited has implemented the Severe Weather Trading (“SWT“) arrangement effective 23 September 2024. ORSO scheme employers are advised to check with their service providers on the services which remain available on a SWT day and review their scheme documentation to ensure it accommodates the SWT arrangement.
In support of this initiative, companies in the banking and securities industry have been updating their systems and workflows to ensure technical and operational readiness for the SWT arrangement, including but not limited to capabilities to handle investment instructions submitted electronically on a SWT day. Given the change, ORSO employers are recommended to reach out to their service providers (e.g. trustee and investment managers) to confirm the extent to which their services will remain uninterrupted during adverse weather.
ORSO employers should also review their scheme documentation to ensure it accommodates the SWT arrangement. In particular, in ORSO trust deeds, a ‘business day’ is often defined with reference to days on which banks in Hong Kong are open for business. This definition will likely need to be amended as bank branches will remain closed on a SWT day. Other changes may be necessary to align with the scope of activities which may be carried out on a SWT day, having regard to the capabilities of the service providers to maintain their services during the period. Further, where the scheme documentation is not regularly updated, ORSO employers may take this opportunity to conduct an overall review to ensure it reflects the current operational arrangements and complies with the evolving regulatory landscape.
We have extensive experience advising on ORSO scheme-related matters. Please do not hesitate to reach out for further assistance.
