Internal Controls
The directors are responsible for maintaining and reviewing the effectiveness of the Group's internal controls. Appropriate policies and control procedures have been designed and established to ensure that assets are safeguarded against improper use or disposal, relevant rules and regulations are adhered to and complied with, reliable financial and accounting records are maintained in accordance with relevant accounting standards and regulatory reporting requirements, and key risks that may impact on the Group's performance are appropriately identified and managed. Such procedures are designed to manage, rather than eliminate, the risk of failure to achieve business objectives. These procedures can only provide reasonable, and not absolute, assurance against material errors, losses and fraud.
The key internal control procedures established within the PCCW Group include the following:
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Expenditure Authorisation and Control
Authority to operate the various business units and subsidiaries within the Group is delegated to their respective business unit heads / managing directors within limits set by the Board of Directors of the Company or by the Executive Committee of the Board under powers delegated by the Board. Authorities are delegated downwards within the Group to the point where decisions can be taken most efficiently, with the aim of balancing effective oversight with operational flexibility.
Business Planning and Performance Monitoring
The Group Finance department has established comprehensive management control systems incorporating planning, budgeting and monitoring arrangements for each business unit or subsidiary. The Group Finance department tracks key performance indicators on a monthly basis and regular reviews and assessments of progress against agreed targets are carried out by the Operational Committee in conjunction with operational management.
Integrity of Records and Accounting Procedures
Detailed operational, financial and management reporting procedures and guidelines are established by the Group Finance department for application across the Group. These are designed to ensure that proper controls are in place for the recording of complete, accurate and timely accounting and management information. Regular reviews and audits are carried out to ensure that the preparation of financial statements is carried out in accordance with generally accepted accounting principles, the Group's accounting policies and the laws and regulations applicable in each country of operations.
If you have any concerns regarding accounting, internal account controls, or auditing matters, you may address your concerns in writing to the Audit Committee of the Board of Directors at:
Chairman of the Audit Committee,
HKT Limited
C/o: Director of Group Internal Audit
P.O. Box 9896 GPO
Hong Kong SAR
Or by calling +852 2883 3366
We will respect the confidentiality of those who raise concerns, subject to our obligations to investigate the concerns and any obligation to notify third parties such as regulators and other authorities. The Company believes its process and procedures in this regard are fully compliant with its obligations as a foreign private issuer under rule 10A-3(b) of the US Securities Exchange Act of 1934 (amended).
If you have any concerns regarding accounting, internal account controls, or auditing matters, you may address your concerns in writing to the Audit Committee of the Board of Directors at:
Chairman of the Audit Committee,
HKT Limited
C/o: Director of Group Internal Audit
P.O. Box 9896 GPO
Hong Kong SAR
Or by calling +852 2883 3366
We will respect the confidentiality of those who raise concerns, subject to our obligations to investigate the concerns and any obligation to notify third parties such as regulators and other authorities. The Company believes its process and procedures in this regard are fully compliant with its obligations as a foreign private issuer under rule 10A-3(b) of the US Securities Exchange Act of 1934 (amended).
Statement of Anti-Bribery and Corruption Policy
HKT is committed to preserving a culture free of bribery and corruption while upholding the highest standards of conducting business in a legal and ethical manner. In furtherance of this commitment, the Company adopts a zero-tolerance policy towards bribery and corruption in any form and at any level, in association with any aspect of the Company’s activities.
The Group Anti-Bribery and Corruption Policy (the “ABC Policy”) and Anti-Bribery and Corruption Procedure Manual (the “Procedure Manual”) are established to form the fundamental components of an Anti-Bribery and Corruption (“ABC”) framework. This policy statement (the “Statement”) cites the key principles of the ABC Policy and Procedure Manual.
Click here to download the Statement.
The Group Anti-Bribery and Corruption Policy (the “ABC Policy”) and Anti-Bribery and Corruption Procedure Manual (the “Procedure Manual”) are established to form the fundamental components of an Anti-Bribery and Corruption (“ABC”) framework. This policy statement (the “Statement”) cites the key principles of the ABC Policy and Procedure Manual.
Click here to download the Statement.
Whistleblower Policy
HKT encourages any person, including employees, customers, suppliers, contractors and other interested persons who, in good faith, have reasonable cause to believe that anyone acting for or on behalf of HKT has previously, is now, or may be intending to act improperly in a manner contrary to HKT’s corporate governance commitment, to raise those concerns to HKT.
The Whistleblower Policy has been adopted by HKT’s Board of Directors and sets out HKT’s policy and general procedures for the receipt of, and subsequent dealing with, notifications of suspected or actual improper conduct involving HKT Group company or any of its directors, employees, and any of its suppliers, contractors, agents, and other third parties who are acting for or on behalf of HKT. These shall apply equally to all such notifications, including those made by customers, employees, and any HKT’s suppliers, contractors, agents, or other third parties. Click here to download the policy document.
The Whistleblower Policy has been adopted by HKT’s Board of Directors and sets out HKT’s policy and general procedures for the receipt of, and subsequent dealing with, notifications of suspected or actual improper conduct involving HKT Group company or any of its directors, employees, and any of its suppliers, contractors, agents, and other third parties who are acting for or on behalf of HKT. These shall apply equally to all such notifications, including those made by customers, employees, and any HKT’s suppliers, contractors, agents, or other third parties. Click here to download the policy document.
Group Internal Audit
Group Internal Audit was established to provide independent assurance to the Board and executive management on the adequacy and effectiveness of internal controls for the Group. The director of Group Internal Audit reports directly to the Audit Committee, the Group Managing Director and the Group Chief Financial Officer.
Group Internal Audit adopts a risk-and-control based audit approach. The annual work plan of Group Internal Audit covers major activities and processes of the Group's business and service units. All audit reports are communicated to the Audit Committee and key members of executive and senior management. Audit issues are tracked and followed up for proper implementation, with progress reported to the Audit Committee, executive and senior management periodically.
Group Internal Audit adopts a risk-and-control based audit approach. The annual work plan of Group Internal Audit covers major activities and processes of the Group's business and service units. All audit reports are communicated to the Audit Committee and key members of executive and senior management. Audit issues are tracked and followed up for proper implementation, with progress reported to the Audit Committee, executive and senior management periodically.
UK Tax Strategy
This tax policy sets out our group’s approach to UK tax related governance and risk management, as well as our attitude towards tax planning and the approach in dealing with HMRC. Periodic review and update will be performed. Click here to download the policy document.
Code of Conduct
This Code of Conduct (the “Code”) comprises a set of rules adopted by HKT’s Board of Directors and applies to all employees, including directors and officers, across the HKT Group.
This Code is established to set out the important principles to achieve and to adhere to high professional standard and ethical behaviour in all aspects of its business, and to ensure that its affairs are conducted in accordance with applicable laws and regulations, as well as taken into consideration of social and environmental needs for achieving sustainable business and strategic long-term success. Click here to download the Code.
This Code is established to set out the important principles to achieve and to adhere to high professional standard and ethical behaviour in all aspects of its business, and to ensure that its affairs are conducted in accordance with applicable laws and regulations, as well as taken into consideration of social and environmental needs for achieving sustainable business and strategic long-term success. Click here to download the Code.
Corporate Social Responsibility Policy
This policy comprises a set of rules adopted by the Executive Committee and applies to all employees, including directors and officers, throughout the Group. This policy is intended to be a clear and simple guide to set out standards for the way in which we should conduct our business to minimise negative impact on society and the environment. Click here to download the policy document.