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Annual Report 2015
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 ARC 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 ARC, the CEO and the CFO 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 ARC 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 ARC on a quarterly basis.
The ARC 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. In FY 2015, at the request of the ARC, the internal auditors
performed an audit of the H-REIT Manager. The ARC met with the internal auditors separately
without the presence of Management in January 2016.
Principle 14: Rights of Stapled Security Holders
Being committed to good corporate practices, the H-REIT Manager and the HBT Trustee-
Manager treat all Stapled Security Holders fairly and equitably. To facilitate the exercise of
Stapled Security 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.
All Stapled Security Holders are entitled to attend and vote at general meetings in person or by
proxy. The rules including the voting procedures are set out in the notice of general meetings.
In accordance with the H-REIT Trust Deed and HBT Trust Deed, Stapled Security Holders may
appoint one or 2 proxies to attend and vote at general meetings in their absence. The proxy
forms must be deposited with the H-REIT Manager and HBT Trustee-Manager not less than forty-
eight (48) hours before the time set for the general meetings.
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".
CORPORATE GOVERNANCE
