annual report 2012
61
Whistle-Blowing Policy
The H-REIT Manager has in place a whistle-blowing procedure where staf of the H-REIT Manager can raise
in confdence, whether anonymously or otherwise, concerns on possible improprieties relating to accounting,
fnancial reporting, internal controls and auditing matters, without fear of reprisals in any form. The AC has
the responsibility of overseeing this policy which is administered with the assistance of Management. Under
these procedures, arrangements are in place for independent investigation of such matters raised and for
appropriate follow up action to be taken.
In January 2013, the AC revised the whistle-blowing policy to allow other persons (apart from staf of the
H-REIT Manager) to make reports under the whistle-blowing policy, in alignment with the guidelines of the
2012 Code. In order to facilitate and encourage the reporting of such matters, the whistle-blowing policy,
including the dedicated whistle-blowing email address at acchairman@cdlht.com and postal correspondence
channel were made available on CDLHT’s website in 2013.
The H-REIT Manager is committed to maintaining procedures for the confdential and anonymous submission
of reports and the anonymity of whistle-blowers concerned will be maintained where so requested by the
whistle-blowers who lodged the report. Investigations into such reports will be handled on a confdential basis
to the extent permissible or deemed appropriate under the circumstances, and involve persons who need to
be involved in order to properly carry out the investigation and will, on a best eforts basis, be carried out in
a timely manner.
As HBT was dormant during FY 2012, the audit committee of the HBT Trustee-Manager was similarly dormant
during this period.
Principle 12: Internal Controls
The H-REIT Manager Board recognises that they have overall responsibility to ensure proper fnancial reporting
for the H-REIT Group and the Stapled Group and efectiveness of H-REIT’s system of internal controls, including
fnancial, operational and compliance controls and risk management policies and systems.
Risk Management
The H-REIT Manager Board has established a RMC which comprises three members, with the majority of the
RMC members being independent, which includes the chairman of the RMC and another member who should
also be a member of the Audit Committee.
The objective of the RMC is to assist the H-REIT Manager Board in the discharge of its duties to maintain an
efective control environment that refects both the established risk appetite and the business objectives.
The RMC reports to the Board at least once a year on the nature and extent of the functions performed by it
and shall make recommendations to the Board on any matters within its scope of duties as it may think ft. The
RMC’s other duties within its written terms of reference include:
•
approving and overseeing the risk management framework designed, established and implemented by
the Management for the identifcation, assessment, management and monitoring of risks, and with the
objective of embedding risk management into existing management processes;
•
reviewing and endorsing the risk appetite and tolerance as determined using the risk limits and/or
parameters established by the Management;
•
ensuring the adequacy and appropriateness of the risk assessment and management processes;
•
reviewing key strategic risks (and gaps) identifed by the Management team; and
•
ensuring that the key strategic risks (and gaps) identifed have been adequately covered/mitigated by
the H-REIT Manager.
The RMC is entitled to the full co-operation and from time to time the assistance of Management and may
require the provision of such information, and access to such personnel, as it deems necessary, and to seek
external professional advice on such matters within its scope of duties as may be appropriate. The RMC may also
invite any other Director, other senior executives and/or external professional advisers to attend its meetings.
Corporate Governance