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ANNUAL REPORT 2014
Whistle Blowing Policy
The H-REIT Manager and the HBT Trustee-Manager have in place a whistle blowing procedure
where staff of the H-REIT Manager and the HBT Trustee-Manager and other persons can raise in
confidence, whether anonymously or otherwise, concerns on possible improprieties relating to
accounting, financial 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.
The H-REIT Manager and the HBT Trustee-Manager are committed to maintaining procedures
for the confidential 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 confidential 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 efforts basis, be
carried out in a timely manner.
In order to facilitate and encourage the reporting of such matters, the whistleblowing policy,
including the dedicated whistle blowing email address at
and postal
correspondence channel are available on CDLHT’s website.
Principle 13: Internal Audit
Internal Audit (“IA”) plays an important role in monitoring an effective system of internal
controls. The IA function of the Singapore hotels’ operations is performed by the internal audit
team of Millennium & Copthorne International Limited, a related corporation. A summary of
the internal auditors’ reports is extended to the AC, the Chief Executive Officer and the Chief
Financial Officer of the H-REIT Manager and HBT Trustee-Manager. The internal auditors have
been directed to meet or exceed the standards set by internationally recognised professional
bodies including the International Standards for the Professional Practice of Internal Auditing
set by The Institute of Internal Auditors.
The AC reviews the IA plan. Processes are in place such that material control weaknesses
raised in the IA reports are dealt with in a timely manner, with outstanding exceptions or
recommendations being closely monitored and reported back to the AC on a quarterly basis.
The AC reviews the activities of the internal auditors on a quarterly basis and is satisfied that
the IA function is independent of the activities which it audits; is adequately resourced; and
has appropriate standing within the H-REIT Manager and HBT Trustee-Manager to perform its
role and responsibilities effectively. The AC met with the internal auditors separately without
the presence of Management in January 2015. The HBT Trustee-Manager did not have an IA
function in year 2014 as it was only activated during the year.
Principle 14: Rights of Stapled Securities Holders
Being committed to good corporate practices, the H-REIT Manager and the HBT Trustee-
Manager treat all Stapled Securities Holders fairly and equitably. To facilitate the exercise of
Stapled Securities Holders’ rights, the H-REIT Manager and the HBT Trustee-Manager ensure
that all material information relating to the Stapled Group and its financial performance is
disclosed in an accurate and timely manner via SGXNET.
CORPORATE GOVERNANCE
Guideline 13.1
Does the Company have
an internal audit function?
If not, please explain why.
The H-REIT Manager
outsourced the internal
audit function for
H-REIT’s operations to
Millennium & Copthorne
International Limited,
a related corporation.
Please refer to the
explanation under
"Principle 13: Internal
Audit."
Guideline 15.4
(a) Does the Company
regularly communicate
with shareholders and
attend to their questions?
How often does the
Company meet with
institutional and retail
investors?
Please refer to the
explanation under
“Principle 15:
Communication with
Stapled Securities
Holders.”
