Annual Report 2021

abide by anti-corruption regulations in Hong Kong. The Code of Conduct also lays down rules against soliciting or accepting any unfair advantages, our employees would receive the Code of Conduct upon their employment and are required to acknowledge their understanding on and commitment to abide by the code requirement. Risk assessment on and controls against corruption and malpractice are always included in the risk management processes while sufficient segregation of duties is always ensured in the design of sales and procurement approval processes. In addition, we provide regular trainings to business directors and staff regarding anti-corruption practice, and 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 Assistant Director of Audit, Risk Management & Corporate Services for any malpractice, non-compliance, criminal offence and other material matters in operations. The matters escalated to the 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 the private data of employees and customers, respecting 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 securely kept, accessible only by designated staff. 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 have integrated our control and risk mitigation measures into our daily operations through policies and procedures. During the COVID-19 pandemic, we have been closely monitoring for updates on social distancing measures and other anti-epidemic measures enforced by the Government. The mode of operations of our various businesses were adjusted accordingly to ensure full compliance, and more importantly, to safeguard the health and safety of our employees and guests. During the reporting period, there was no non-compliance case in relation to the Prevention and Control of Disease Ordinance. Our Community Material Topics No Material Topics identified in this Aspect The Group has been actively assuming corporate social responsibility. We bring together knowledge, resources, experience and effort of our employees, business partners and community organizations to nurture the next generation, promote a harmonious community and care for our environment. Meanwhile, in the midst of the pandemic, the Group has further collaborated with various parties in unity to bring good to the community. 043 Environmental, Social and Governance Report Miramar Hotel and Investment Company, Limited Annual Report 2021