CORPORATE GOVERNANCE & SUSTAINABILITY CORPORATE GOVERNANCE Accountability and Audit example from the Board down. The Company has a Financial Reporting Corporate Code of Conduct, which is posted on its website. The Board acknowledges its responsibility for: The Company is committed to developing and maintaining high professional and ethical standards. These are • the proper stewardship of the Company’s affairs, reflected in the rigorous selection process and career to ensure the integrity of financial information development plans for all employees. The organisation • preparing annual and interim financial statements and prides itself on being a long-term employer which instills other related information that give a true and fair view of in individuals, as they progress through the Group, a the Group’s affairs and of its results and cash flows for thorough understanding of the Company’s ways of thinking the relevant periods, in accordance with Hong Kong and acting. Financial Reporting Standards and the Hong Kong Channels of communication are clearly established, Companies Ordinance allowing employees a means of communicating their views • selecting appropriate accounting policies and ensuring upwards with a willingness on the part of more senior that these are consistently applied personnel to listen. Employees are aware that, whenever • making judgements and estimates that are prudent the unexpected occurs, attention should be given not only and reasonable to the event itself, but also to determining the cause. • ensuring that the application of the going concern Through the Company’s Corporate Code of Conduct, assumption is appropriate employees are encouraged (and instructed as to how) to Risk Management and Internal Control report control deficiencies or suspicions of impropriety to The Board acknowledges its responsibility to establish, those who are in a position to take necessary action. The maintain and review the effectiveness of the Group’s risk Company has a Whistleblowing Policy and system for management and internal control systems. This employees and those who deal with the Group to raise responsibility is primarily fulfilled on its behalf by the Audit concerns, in confidence and with anonymity, where Committee as discussed on pages 105 to 106. desired, about actual or suspected cases of impropriety in any matter related to the Group. The policy is available on The foundation of strong risk management and internal the Company’s website. control systems is dependent on the ethics and culture of The Company has an Anti-Bribery and Corruption Policy the organisation, the quality and competence of its which sets out the Company’s policy and systems that personnel, the direction provided by the Board, and the promote and support compliance with applicable anti- effectiveness of management. bribery and corruption laws and regulations, and enhances Since profits are, in part, the reward for successful risk the provisions relating to bribery and corruption in the taking in business, the risk management and internal Company’s Corporate Code of Conduct. The policy is control systems are designed to manage rather than available on the Company’s website. eliminate the risk of failure to achieve business objectives Risk assessment: The Board of Directors and the and can only provide reasonable and not absolute management each have a responsibility to identify and assurance against material misstatement or loss. analyse the risks underlying the achievement of business The key components of the Group’s control structure are objectives, and to determine how such risks should be as follows: managed and mitigated. Culture: The Board believes that good corporate The Company has implemented the three lines of defence governance reflects the culture of an organisation. This is model of risk governance which is designed to minimise more significant than any written procedures. conflicts of interest and ensure independent oversight of The Company aims at all times to act ethically and with risk management. Details of the three lines of defence integrity, and to instill this behaviour in all its employees by model are set out in the section of this annual report headed Risk Management. 104