Annual Report 2019

of non-compliance with any laws and regulations in relation to advertising and labelling, such as trade description ordinance. (II) Intellectual Property Rights We respect intellectual property and work hard to protect ours, while taking a variety of control measures to avoid unintentionally infringing the intellectual property rights of others. We review registration of trademarks and domains during the business development stage and register our own trademarks and domains to protect our business interest. All our registered trademarks and domains are maintained in a log for regular review and renewal. Protection terms of our intellectual property are included in our contract with our business partners. Also, use of all copyrighted assets, such as songs, artworks, photos, software, would be supported by valid agreement or license subscriptions. System restriction is also set up to prevent unauthorized installation of pirated software in company’s computers. During the reporting period, there was no confirmed case of non-compliance with any laws and regulations in relation to intellectual property rights, such as trade mark ordinance, copyright ordinance, patents ordinance. (III) Anti-corruption We strive to uphold the highest standard of business ethics and integrity. We do not tolerate any form of corruption or malpractice such as bribery, money laundering, extortion and fraud. Expected professional conduct at the workplace is outlined in the Group’s Code of Conduct, which requires all employees to abide by anticorruption regulations in Hong Kong. The Code of Conduct also lays down rules against soliciting or accepting any unfair advantages. Risk assessment on and controls against corruption and malpractice are always included in the risk management processes while we always ensure sufficient segregation of duties in the design of sales and procurement approval processes. In addition, we provide regular trainings to business directors and staff regarding anti-corruption practice, which we work with the Independent Commission Against Corruption (“ICAC”) to hold anti-corruption courses for key staff to further enhance their understanding of various issues of anti-corruption drives, and integrate relevant practices into our daily operations. Whistleblowing Policy and Procedures have been established since 2013. It encourages employees to directly bring to the attention of senior management and/or Director of Audit, Risk Management & Corporate Services for any malpractice, non-compliance, criminal offence and other material matters in operations. The escalated matters to management are assured of confidentiality and the employee will be protected from being disciplined if nothing improper is found after investigation. During the reporting period, there was no confirmed case of corruption and non-compliance with any rules and regulations as regards anti-corruption such as the Prevention of Bribery Ordinance. (IV) Data Protection and Privacy The Group is committed to protecting private data of employees and customers and ensuring their legal right to privacy. Control procedures were established to ensure compliance with the requirements of relevant laws and regulations, such as of Personal Data (Privacy) Ordinance and General Data Protection Regulations. Information collected from job applicants will be kept for only 6 months with their consent. Information collected from our sales and promotional activities is used only for business development and customer relationship management purposes, with customers being provided the choice of opting out of any direct marketing messages. All collected personal data are treated as confidential and kept securely, accessible by designated staff only. During the reporting period, there was no substantiated complaint received concerning breaches of customer privacy and losses of customer data. (V) Legal and Regulatory Compliance The Group is committed to achieving high standard of professional ethics, good corporate governance and compliance with all applicable rules and regulations in conducting businesses. We have established effective risk management and internal control processes to identify and manage new legal and regulatory requirements. Major risks and internal controls in regard to business, financial, legal and regulatory compliance are periodically reviewed and assessed. We integrate our control and risk mitigation measures into our daily operations through policies and procedures. Environmental, Social and Governance Report Miramar Hotel and Investment Company, Limited Annual Report 2019 041