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3. What are the penalties for non-compliance by employers? 

An employer who fails to comply with section 6(1) can be fined for HK$3,000,000 on summary conviction and HK$10,000,000 on conviction on indictment. If he does so intentionally, knowingly or recklessly, he can be imprisoned for 6 months or 2 years respectively on top of the fines.