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China Telecom Global Limited Whistleblower Policy

A. Policy Statement

  • Operating in many countries and regions around the world, China Telecom Global Limited (“CTG”, the “Company”) complies with anti-bribery and anti-corruption laws and regulations applicable in the relevant jurisdictions, and remains committed to the highest standards of transparency, integrity and accountability by adhering to a zero-tolerance policy for any form of bribery and corruption involving suppliers, customers and other counterparties. In the meantime, the Company is committed to upholding the principles of integrity, fairness and honesty in the actions of its employees and encourages employees and business partners to report misconduct and non-compliance to the Company in a responsible and effective manner to ensure the Company's healthy and sustainable growth.

  • In order to further promote the Company's compliance and anti-corruption work, open up the channels of supervision and reporting, improve reporting mechanism and effectively play the role of supervision, the Company has established this Whistleblower Policy (“Policy”) and the following Whistleblower Mailbox (“Mailbox”), so as to detect and correct any wrongdoing or irregularities in the course of business operations, and to ensure confidentiality of the identity of whistleblowers and the reported matters as well.

B. Whistleblowing Guidelines

  • (1) The whistleblower shall report based on facts. The Company guarantees to not punish or retaliate against reports made in good faith, but may take actions against reports that involve fabrication, falsified evidence, or false accusations against others.

  • (2) The Company encourages reports made in detail and using real names of whistleblowers, as these facts may facilitate the Company conduct a more detailed and in-depth investigations of the reported matters and provide feedback. The Company will keep the information of the whistleblower strictly confidential.

  • (3) The whistleblower should, to the extent possible, provide all available evidence or supporting documents of the reported misconduct, corruption, or violations. If it is not possible to provide such information, the Company may utilize all feasible means to collect relevant evidence.

  • (4) Whistleblowers may report matters to the Mailbox by registered mail, local express mail, or express mail. The post office does not require senders to provide their names or addresses. If whistleblowers do not want to disclose their identity, they can choose to report anonymously.

C. Applicable Scope of Matters

  • (1) Violations of company policies by management or employees at all levels and all subordinate units of CTG;

  • (2) Actions by any CTG employees in key positions in the course of business, including but not limited to failure to perform their duties in accordance with the law; violations of policies related to proper uses of powers associated with their positions, ethical practices, or moral behaviors; suspicion of corruption or bribery, abusing power, rent-seeking, “pay-to-play,” favoritism, or wasting company resources; or other illegal and criminal activities;

  • (3) Appeal decision(s) of accountability proceeding(s);

  • (4) Critique or provide suggestions to the regulatory compliance, ethical governance infrastructure, and anti-bribery and corruption related matters of the company, etc.

D. Whistleblowing Channels:

  • (1) Report to Supervision Department
    • Supervision Department, 30/F Everbright Centre, 108 Gloucester Road, Wan Chai, HK

  • (2) Report through Anonymous Whistleblower Mailbox
    • China Telecom Global Limited
    • G.P.O. Box 7792
    • Hong Kong

E. Handling Reports

  • The Supervision Department is the designated department to receive Whistleblower reports, and is fully responsible for managing the reported matters; the Supervision Department is also responsible for processing the receipt of such reports, and categorizing them for subsequent handling strictly in accordance with relevant regulations and procedures, whether the report was made in person or through the Mailbox. All reported information needs to be stored confidentially in the Supervision Department, and only authorized personnel can access such information (e.g., investigator in charge of the matter or specific personnel designated as “need-to-know”). CTG will take strict measures to ensure the reported matters remain confidential.

  • Matters related to violation of policies, the law, ethics and professional rules, and appeal of accountability proceeding dispositions are handled by the Supervision Department. General complaints are categorized and transferred to relevant departments for handling and recordkeeping after the acceptance of these matters by the Supervision Department.

  • Reports and accusations received through other channels must be transferred to the Supervision Department for acceptance and categorization in accordance with relevant rules. Supervision Department shall complete categorizing and referring reported matters to relevant departments within seven days of receiving the report. The Supervision Department and other relevant departments that received referred reports from the Supervision Department should begin investigations of the reported matters within two weeks. Depending on the severity and complexity of the reported matters, their investigations should complete within three to six months.
China Telecom Global Limited
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