Internal Controls

Expenditure Authorization 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,
PCCW 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).

Business Ethics

PCCW is committed to maintaining a high standard of corporate governance, the principles of which serve to uphold a high standard of ethics, transparency, responsibility and integrity in all aspects of business and to ensure that affairs are conducted in accordance with applicable laws and regulations.

We have adopted a Corporate Responsibility Policy and a Corporate Social Responsibility Policy that apply to all employees, including directors and officers, throughout the PCCW Group.

Whistleblower Policy

PCCW 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 PCCW has previously, is now, or may be intending to act improperly in a manner contrary to PCCW’s corporate governance commitment, to raise those concerns to PCCW.

The Whistleblower Policy has been adopted by PCCW’s Board of Directors and sets out PCCW’s policy and general procedures for the receipt of, and subsequent dealing with, notifications of suspected or actual improper conduct involving PCCW 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 PCCW. These shall apply equally to all such notifications, including those made by customers, employees, and any PCCW’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 PCCW 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.

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 [pdf - 162KB]

Corporate Responsibility Policy

This policy comprises a set of rules adopted by PCCW’s Board of Directors and applies to all employees, including directors and officers, throughout the PCCW Group. This policy is intended to be a clear and simple guide to set out standards for the way in which employees should conduct our business in the following areas: civic responsibilities, equal opportunities, preservation of company information and property, privacy of personal data, prevention of bribery, conflicts of interest and ensuring health and safety at work. This policy also describes procedures to enable employees to raise concerns with management and directors on a confidential basis.

Click here to download the policy document

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 PCCW 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 minimize negative impact on society and the environment.

Click here to download the policy document