Trading Operations in Schools
Fundamental Principles and Relevant Guidelines
Education Bureau
Jan 2013
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Relevant Requirements
When schools operate / conduct on the school
premises any business / trading operations, or
supply items for the exclusive use of their students,
they should

Obtain prior permission in writing from the
approval authority

Refer to relevant provisions of the Education
Ordinance, Education Regulations and Codes of
Aid to ensure compliance with the necessary
requirements
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Principle 1 – Freedom to Choose

No purchase or acceptance of paid
services should be compulsory
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Principle 2 – Quotation/Tendering
Schools should adopt an open, fair and
competitive system to select goods and services
provided by suppliers/contractors

At regular intervals

Preferably not exceeding three years
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Principle 3 – Acceptance of Donations

Acceptance of donations or advantages from
the suppliers/contractors should be considered
only in very exceptional circumstances with
compelling reasons and should be approved by
School Management Committees (SMCs)
/Incorporated Management Committees (IMCs)

Any
benefits
contributed
by
suppliers/contractors, if any, would rather go to
students direct
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Principle 4 - Use of Profits/Net Income
The profits/net income arising from trading
operations

Should be applied for the purposes of directly
benefiting the students of the schools

Should not be transferred to the respective
Parent-Teacher Associations (PTAs) or School
Sponsoring Bodies (SSBs)
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Guideline 1 - Obtaining Prior Approval
Schools
Approval Authority
Managed Permanent Secretary for Education (including first
by SMC application and subsequent changes to the approved
trading operations)
To follow EDB Circular No. 24/2008 – Trading Operations in
Schools
Managed Incorporated Management Committees
by IMC To follow the following circular and guideline to obtain the approval:
EDB Circular No. 15/2007
Procedures in Aided Schools

- Tendering and Purchasing
Guide to Financial Management for Aided Schools Operated by
IMCs

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Guideline 2 – Prevention of Conflict of
Interest and Bribery

SMCs/IMCs
should
require
SMC/IMC
members and school staff to make declaration
of pecuniary or other personal interests
annually

Schools should built in a probity clause in the
service
contract
to
prevent
the
suppliers/contractors and his employees from
bribery
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Guideline 3 - Involvement of PTAs/SSBs
PTAs/SSBs representing school to conduct
trading operations are requested to

Obtain prior delegation from the SMCs/IMCs

Comply with the principles and guidelines set
out in EDB Circular No. 24/2008
 PTAs or SSBs wishing to undertake trading operations should
be treated as one of the bidders and subject to competitive
bidding. The tendering procedures should be conducted by
schools.
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Guideline 4 - Communication with Parents
Schools are requested to inform / notify parents

Purchase or acceptance of paid services is
voluntary

Prices of goods and services provided by the
suppliers/contractors

Donations and advantages
suppliers/contractors
obtained
from
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Guideline 5 – Profit Limit

No profit would be generated from sale of
textbooks

The profit from sale of exercise books, school
uniforms, stationery, equipment and other items
(other than textbooks) should be limited to 15%
of the cost price at which they are purchased
from the suppliers

The profits should be applied for the purposes
of directly benefiting the students of the
schools
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Guideline 6 - Monitoring Trading Operations
Schools are recommended to set up a committee to:

Conduct quotations/tenders and to select
suppliers /contractors according to the provisions
stipulated in the EDB Circular No. 15/2007

Review regularly the goods/services provided by
the suppliers/contractors

Investigate into
operations, etc.
complaints
about
trading
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Guideline 7 – Proper Records
Schools are requested to

Keep books of accounts and relevant records
on all sales and purchases for inspection by
EDB officers

Update regularly donation
inspection by EDB officers
register
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for
Guideline 7 – Proper Records
Compelling reasons for
accepting the donation
if the donor is one of
the school’s
suppliers/contractors
SMC’s/IMC’s Approval
(School’s reference no. and date)
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Points to Note - Quotation/Tendering
Schools are advised to
 Request
staff
who
are
deployed
by
suppliers/contractors to work in schools frequently /
regularly to undergo Sexual Conviction Record
Check and to allow schools to have access to the
checking results
 Applications for SCRC should be submitted by the staff concerned
voluntarily
 Website of SCRC:
http://twdc.police.gov.hk/ppp_en/11_useful_info/scrc.html
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Provisions and reference materials

Regulations 99A and 99B of the Education Regulations

Ordinance 40BF and 40BG of the Education Ordinance

Prevention of Bribery Ordinance, Cap 201

EDB Circular No. 14/2003 - Acceptance of Advantages
and Donations by Schools and Their Staff

EDB Circular No. 15/2007 - Tendering and Purchasing
Procedures in Aided Schools

EDB Circular No. 24/2008 - Trading Operations in
Schools
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Reference Materials on EDB Homepage
School Administration
 Financial
Management
 Reference Materials
on Trading Operations
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Reference Materials on EDB Homepage
School Administration
 Regulations
Checklist on Common
Administrative Issues in
Aided Schools
Points to Note on
Financial Management
of Aided Schools
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 Thank You 
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