CORPORATE

SOCIAL
RESPONSIBILITY
POLICY

CORPORATE SOCIAL RESPONSIBILITY POLICY

This policy comprises
a set of rules adopted
by the PCCW Board
of Directors which
applies throughout
the PCCW Group to
all directors, officers
and employees.
These rules set the
standards for the way
we interact with
society at large and
the environment
around us. They may
be supplemented
from time to time by
additional policy
statements and
guidelines.

The purpose of this policy is to ensure PCCW Limited (PCCW), its

subsidiaries, affiliates, and associated companies, in Hong Kong and
internationally (the PCCW Group), consistently operate in a manner
that minimises detrimental impacts to society and the environment.
Through globalisation and a range of social, ethical and environmental
issues involved in the conduct of international business, the PCCW
Group faces numerous challenges and opportunities in meeting and
exceeding our corporate social responsibilities. As employees of the
PCCW Group we are all identified not only by the PCCW Groups
brands but by the way we interact with society at large and the
environment around us.
PCCWs continual aspirations to achieve and surpass the highest
standards of conduct and corporate social responsibility are essential
components of how we measure our success. Through the PCCW
Corporate Social Responsibility Policy, standards of social behaviour
have been established that seek to meet and exceed minimum legal
standards. This represents the criteria by which PCCW aims to be
judged, both by our colleagues and by our stakeholders. To have such
standards - and to live up to them - is something that includes all our
employees, from the most junior to our most Senior Executives.
This policy clearly sets forth PCCWs social responsibility objectives and
provides guidance on the social responsibilities of all individuals
associated with the PCCW Group.
PCCWs primary responsibility is to ensure the long-term success of the
PCCW Group through the adoption and management of good corporate
social behaviour. In maintaining a successful social behaviour strategy,
the PCCW Group will be able to enhance our customers experience,
continue to be innovative, possess the ability to continually invest in the
delivery of new products and services, contribute to public and
government services, and create jobs for our colleagues and suppliers.
All of these characteristics must be pursued in concert with full
consideration of PCCWs social obligations.
The PCCW Group continues to develop, implement and manage a wide
range of corporate social responsibility programmes covering a broad
spectrum of complex issues. These programmes are often associated
with high technology in the rapidly-changing society in which we
operate. PCCW also participates in multiple philanthropic activities,
supports educational initiatives and promotes environmental best
practices in our day to day operations.
Do take the time to read this document carefully. We are sure you will
find it helpful.
Authorised and approved by the PCCW Board of Directors for
distribution and use throughout the PCCW Group and for public
distribution to PCCW stakeholders and other interested parties.

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INTRODUCTION............................................................................................................. 1
PURPOSE ......................................................................................................................................1
APPLICABILITY ...............................................................................................................................1
BACKGROUND ...............................................................................................................................1
SOCIAL RESPONSIBILITY ..............................................................................................................1
SUSTAINABLE DEVELOPMENT ......................................................................................................1
ABOUT PCCW................................................................................................................ 2
PCCW VALUES ............................................................................................................................2
GOOD CORPORATE CITIZEN ........................................................................................................2
REGULATORY ENVIRONMENT .......................................................................................................2
CIVIC RESPONSIBILITIES ..............................................................................................................3
COMPLIANCE FRAMEWORK ..........................................................................................................3
CORPORATE GOVERNANCE .........................................................................................................3
SOCIAL RESPONSIBILITIES ........................................................................................ 4
POLICY ..........................................................................................................................................4
OVERSIGHT ...................................................................................................................................5
PROGRAMMES ..............................................................................................................................5
ENVIRONMENTAL RESPONSIBILITIES ...................................................................... 5
POLICY ..........................................................................................................................................5
PERFORMANCE .............................................................................................................................5
MONITORING .................................................................................................................................6
COMMUNITY RESPONSIBILITIES ............................................................................... 6
POLICY ..........................................................................................................................................6
SPONSORSHIPS ............................................................................................................................6
CORPORATE VOLUNTEER SERVICES ...........................................................................................6
COMMUNICATION SERVICES.........................................................................................................7
DONATIONS ...................................................................................................................................7
EDUCATION SERVICES..................................................................................................................7
COMMUNITY REQUESTS ...............................................................................................................7
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STAKEHOLDER COMMUNICATION RESPONSIBILITIES.......................................... 7

POLICY ..........................................................................................................................................7
CUSTOMERS..................................................................................................................................8
SUPPLIERS ....................................................................................................................................8
SHAREHOLDERS ...........................................................................................................................8
EMPLOYEE MANAGEMENT RESPONSIBILITIES...................................................... 8
MANAGEMENT ...............................................................................................................................9
CONTACT POINTS FOR SOCIAL RESPONSIBILITY POLICY ................................... 9
POLICY CHANGES...................................................................................................... 10

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Purpose
The purpose of this PCCW Corporate Social Responsibility policy (the Policy) is to ensure PCCW
Limited (PCCW), its subsidiaries, affiliates, and associated companies, in Hong Kong and
internationally (the PCCW Group), consistently operate in a manner that minimises detrimental
impacts to society and on the environment.
Applicability
The Policy applies to all directors, officers and employees of the PCCW Group. All contractors,
subcontractors and individuals acting in any capacity for or on behalf of the PCCW Group should be
made aware of the Policy.
All stakeholders in supply chains of the PCCW Group businesses are encouraged to adopt this Policy
as a form of best practice for their own respective businesses.
Background
PCCW is committed to the establishment and maintenance of best practice environmental, safety, and
occupational health programmesprogrammes designed to protect the environment and health of our
employees, our customers, and the communities where we operate. PCCW strives to operate in this
manner, not only to comply with laws and regulations, but also to demonstrate responsible
environmental stewardship and maintain a positive relationship with our community stakeholders.
PCCW recognises that operational, economic, environmental, public, and social concerns are all
integrally linked to PCCWs future mission. Meeting the commitment to protect these concerns is a
primary senior management objectiveas well as the individual and collective responsibility of all
PCCW Group employees worldwide.
Social Responsibility
Social responsibility refers to the activities and associated responsibilities the PCCW Group holds
where an impact on society and the environment may be caused (i.e. behaviour of the PCCW Group
concerning our impact on others and the natural environment). This includes issues relating to the
environment, human rights, labour practices, organisational governance, fair business practices,
community involvement and social development, and consumer issues.
Social responsibility is the ability of the PCCW Group to reach agreement on activities that are either
right or wrong and to be held accountable for activities over which the PCCW Group has control.
The PCCW Groups actions must be consistent with the interests of society and sustainable
development, be based on sound ethical behaviour, be in compliance with applicable laws and
governmental regulations and be integrated into the ongoing organisation activities.
Sustainable Development
PCCW must ensure sustainable development (i.e. that meets the needs of the present without
compromising the ability of future generations to meet their own needs) through the adoption of
acceptable balances between the priorities of economic development, social progress and
environmental protection.
PCCW is committed to maintaining the state of the environment where social and economic goals
ensure the achievement of improved quality of life whilst avoiding a scenario whereby the PCCW
Group actions may cause environmental issues that could undermine or threaten human survival.
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The PCCW Group will at all times minimise the extent of any adverse impact our operations may have
on the enjoyment by the community of the worlds natural environments.
Global warming (i.e. predicted rise in global average temperatures resulting in rising sea-levels, coastal
destruction, displaced populations, crop failures, desertification, etc.) is now recognised as a major
environmental issue brought about largely by mankinds inappropriate use or abuse of natural
resources. Minimising factors which contribute to global warming has, and continues to be a critical
consideration in formulation of the PCCW Groups sustainable development strategy.

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PCCW Values
The PCCW Group is the largest and most comprehensive provider of communications services in
Hong Kong and one of Asia's leading players in Information and Communications Technology. The
PCCW Group enables organisations to bring their business to Asia, run operations across the region
and take Asian business to the rest of the world.
PCCW strives to produce award-winning technological innovations, especially in IP-based business
services, Next Generation Fixed Line services, IPTV and Internet-access, media content, large-scale
IT solutions, mobility and wireless, and acts as a primary contributor towards Hong Kong's image as a
centre of technology and business excellence.
Good Corporate Citizen
With the mission of Caring and Serving our Community, PCCW provides:
(a)

a commitment to the community;

(b)

practical financial assistance, sponsored programmes, and free products and services to a wide
range of educational, charitable, cultural, community, and environmental causes in Hong Kong;

(c)

community support through the sponsorship of worthy initiatives in the field of education and IT
development programmes;

(d)

corporate sponsorship in support of innovative and caring community programmes and services
for deprived community groups;

(e)

facilitation services designed to enhance, educate and enable communication requirements with
others among needy people, including equipping this group with an up-to-date knowledge of IT
enabling an enrichment of life; and

(f)

the mobilisation and organisation of our employees to provide corporate community volunteer
services.

Regulatory Environment
PCCW is strongly committed to high standards of ethics and integrity in all aspects of our business and
to ensuring our affairs are conducted in accordance with applicable laws and regulations. When
carrying out their duties all employees of the PCCW Group are required to act impartially and
responsibly, and not give preferential treatment to any organisations or individuals.
All employees of the PCCW Group are required to adhere to this high standard whenever he or she
acts on behalf of the PCCW Group, whether in dealings with other employees, customers, vendors,
government regulators or the general public.

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Civic Responsibilities
As a provider of essential telecommunications services and other services to the public and our
customers, the PCCW Group will at all times strive to provide high service levels in the event of social
disorder, natural disasters, and other emergencies. During such periods the full support of all
employees of the PCCW Group is expected in coping with such emergencies.
PCCW maintains a strong level of community involvement and fully supports community activities.
Employees of the PCCW Group are encouraged to actively maintain a level of involvement in community
affairs and participation in various community functions.
Compliance Framework
The PCCW Board is responsible for the management of the PCCW Group. Key responsibilities include
formulation of the PCCW Groups overall strategies, the setting of management targets and supervision
of management performance. The PCCW Board confines itself to making broad policy decisions and
also exercising a number of reserved powers, while delegating responsibility for more detailed
considerations to the Executive Committee. Some of the reserved powers include:
(a)

those functions and matters as set out in the terms of reference of various committees (as
amended from time to time), in which PCCW Board approval must be sought from time to time;

(b)

those functions and matters in which PCCW Board approval must be sought in accordance with
the PCCW Groups internal policies as amended from time to time;

(c)

consideration and approval of financial statements in interim reports and annual reports,
announcements and press releases of interim and final results;

(d)

consideration of dividend policy and dividend amount; and

(e)

monitoring the corporate governance of the PCCW Group in compliance with the relevant rules
and regulations both in Hong Kong and other jurisdictions in which we operates.

All directors of the PCCW Board have full and timely access to all relevant information, including regular
reports from the PCCW Board committees and briefings on significant legal, regulatory or accounting
issues affecting the PCCW Group.
Corporate Governance
How the PCCW Group is directed and controlled is of concern to a wide spectrum of other organisations
and individuals. From shareholders or donors to employees and those who may depend on the activities
of the PCCW Group in other ways. This Corporate Social Responsibility Policy is part of the overall
PCCW enterprise risk management framework demonstrating the PCCW Groups high level of suitable
regulatory, fiscal and market mechanisms to encourage responsible governance and continuously create
shareholder value.
The PCCW Group:
(a)

systematically builds social responsibility into the processes by which we are directed and
controlled;

(b)

incorporates key elements of sound corporate governance in our management structures and
internal control procedures;

(c)

is committed to high standards of ethics and integrity in all aspects of our business, and to
ensuring our affairs are conducted in accordance with applicable laws and regulations;

(d)

has adopted a Corporate Responsibility Policy that applies to all employees, including directors
and officers, throughout the PCCW Group. The policy sets out standards in the way we go about
our business, plus the corporate responsibilities of the PCCW Groups employees. The policy
includes guidance on obligations to the PCCW Group; civic responsibilities; equal opportunities;

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safeguarding communications, the PCCW Groups information and property; privacy of personal
data; prevention of bribery and conflicts of interest; competition; health and safety at work, and
the environment. The policy also describes procedures to enable employees to raise concerns
with management and directors on a confidential basis;
(e)

has applied the principles and complied with all the applicable code provisions of the Code on
Corporate Governance Practices (the Code) as set out in Appendix 14 of the Rules governing
the Listing of Securities on The Stock Exchange of Hong Kong Limited (Listing Rules) save for
any exceptions as may be explained in the PCCW Annual Reports; and

(f)

has established our own code of conduct regarding securities transactions by directors and
senior management namely PCCW Code of Conduct for Securities Transactions by Directors,
Senior Management, and Nominated Persons on terms no less exacting than the required
standard set out in the Model Code for Securities Transactions by Directors of Listed Issuers as
set out in Appendix 10 of the Listing Rules.

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Policy
The PCCW Group must:
(a)
proactively consider the interests of society at large and the economic development of host
communities;
(b)
enhance positive and minimise negative impacts on society;
(c)
serve society in an ethical and lawful manner;
(d)
contribute to a sustainable world;
(e)
ensure sustainable development as part of our societal role;
(f)
operate in an environmentally friendly manner;
(g)
consider social impacts resulting from potential environmental consequences of actions;
(h)
operate in conformance with international labour practices;
(i)
provide a working environment which applies and conforms to recognised occupational safety
and health standards;
(j)
promote positive ethical behaviour throughout our sphere of influence (i.e. towards the
environment, community, customers, employees and investors);
(k)
integrate social responsibilities within core management systems and decision-making
processes;
(l)
identify and understand material issues, and respond to these issues;
(m)
consider the social impacts of services/products throughout the full life cycle, including any
withdrawal impacts;
(n)

respect internationally recognised conventions and declarations, in addition to the widely

recognised instruments derived from them;

(o)

respect the rule of law;

(p)

recognise the rights of stakeholders to be heard and of the PCCW Groups responsibility to
respond;

(q)

ensure activities respect, promote and advance internationally recognised principles for
organisational governance; and

(r)

not indulge in any form of corruption, including extortion and bribery.

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Oversight
Through the PCCW Groups Social Responsibility Committee, the PCCW Group endeavours to
maintain strict oversight of our social responsibilities. Through this oversight the PCCW Group
continuously seeks to determine, via various different internal and external means, more efficient and
effective ways of improving and positively contributing to the societal world in which the PCCW Group
functions.
Programmes
Through our dedicated and experienced employees, the PCCW Group operates a number of different
programmes and initiatives (including those discussed in this Policy) all of which strive to contribute to
the creation of a better societal world.

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Policy
The PCCW Group must:
(a)
aim to exemplify best industry practice and give high priority to the protection of the
environment by ensuring our activities and initiatives respect, promote and advance
internationally recognised environmental principles, commitments and responsibilities;
(b)
ensure our business complies with the letter and spirit of all relevant environmental legislation
and mandatory standards and where none exist to follow good practice;
(c)
consider the environmental impacts of our products and services throughout their full life cycle,
including any disposal impacts;
(d)
ensure resources are not wasted and that, so far as is reasonably practicable, materials and
goods are reused or recycled with the disposal of any remaining waste occurring in a
responsible manner;
(e)
minimise the extent to which we use carbon dependant sources of energy (e.g. diesel
generators) and other natural resources (e.g. water);
(f)
identify and evaluate our businesses environmental effects and controls and manage those
effects which have been identified as significant;
(g)
communicate to our contractors and suppliers of goods and services PCCWs Corporate
Social Responsibility Policy pertaining to performing operations in an environmentally
responsible manner;
(h)
foster open communications with neighbours living and working in areas local to PCCW
facilities and support appropriate environmental initiatives within the community;
(i)
embrace sustainable development through good environment management; and
(j)
support new technology which has the potential to provide long-term environmental benefits.
Performance
The PCCW Group is committed to good environmental performance as a fundamental element of our
commitment to corporate social responsibility and recognises that a responsible approach to
environmental issues is critical to our continuing success.
The PCCW Group endeavours to supply our shareholders, stakeholders, customers, employees,
suppliers and all interested parties with transparent and straightforward information about the PCCW
Groups approach to environmental issues.

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The PCCW Group acknowledges that despite the marginal environmental impact our business
activities have on the environment, it is essential for the PCCW Group to not become complacent and
to constantly consider ways and means of further conserving energy and natural resources, and
reducing all waste and pollution in our business practices.
Monitoring
The PCCW Group closely monitors and complies with all pertinent environmental legislative and
regulatory requirements.
To minimise environmental impact, the PCCW Group will continually address key environmental areas
in a sustained and measured manner based on best practice. Examples include:
(a)
achieving optimum consumption of energy and water supplies through energy-efficient
processes;
(b)
using environmentally effective methods to reduce waste production;
(c)
recycling material where such options are available for use;
(d)
ensuring non-recyclable materials are disposed of in an environmentally responsible manner;
(e)
ensuring environmental best practices are communicated to all employees;
(f)
encouraging environmental responsibility with suppliers; and
(g)
committing to continuous improvement by way of monitoring the environmental impacts of
business activities and measuring the performance of our environmental initiatives.

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Policy
The PCCW Group must:
(a)
invest in community affairs and functions;
(b)
respect cultural and social differences;
(c)
ensure activities respect, promote and advance internationally recognised principles for
community involvement;
(d)
strive to have a positive impact on people, cultures and communities in which we operate;
(e)
be respectful of local and indigenous people, their values, traditions and culture; and
(f)
ensure communities in which we operate are informed, in a timely manner of, and are involved
in the organisational developments which affect them.
The PCCW Group is committed to supporting the community through a diverse range of initiatives such
as providing sponsorships of worthy educational initiatives and offering volunteer services.
Sponsorships
PCCW will consider community requests for supporting meaningful causes which serve the interests of
needy people or which benefit the community at large. The sponsorship can be in the form of cash,
goods or services.
Corporate Volunteer Services
The PCCW Groups corporate volunteer services focus on caring for the elderly, providing socially
supportive communication assistance for those with disabilities, and cultivating IT knowledge and skills
for deprived groups.

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Communication Services
The PCCW Group will provide information and communication technology services to a variety of
social-service programmes that benefit people in need.
Donations
The PCCW Group will carefully consider and evaluate how we contribute to funds or causes. Such
donations may be in the form of gifts or grants. Where the PCCW Group provides such donations, we
will not seek any form of return compensation.
Education Services
The PCCW Group will provide financial support to different educational programmes where these
programmes demonstrate a role in developing the community. Examples of education services that
the PCCW Group may contribute to include those activities associated with computer literacy and
Internet familiarity.
Community Requests
Any applicant, association, institute or organisation seeking sponsorship may write to PCCWs Head of
Group Communications for community support which need not be limited to financial sponsorship. The
proposal request should outline purpose and objectives, target beneficiaries, project implementation
plan and breakdown of the services being requested. Criteria used to evaluate applications will include
the appropriateness of the scope and nature of the project, and the degree to which it benefits the
people of Hong Kong. Applications are considered on their individual merits.

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Policy
The PCCW Group must:
(a)
identify and engage our stakeholders;
(b)
make due provision for the interests and needs of all our stakeholders;
(c)
communicate our commitments and performances relating to social responsibility;
(d)
ensure our activities respect, promote and advance internationally recognised principles for
consumer rights and obligations;
(e)
be responsible for direct and indirect impacts associated with our distribution of goods and
services;
(f)
be held accountable to our stakeholders for our actions and omissions;
(g)
respond, whether positively or negatively, to legitimate stakeholder claims;
(h)
be transparent about our actions and communicate progress made with regards our social
responsibility performances; and
(i)
fully, accurately and in a timely and verifiable manner, consistently disclose our material
information to appropriate regulators, stakeholders and the public.
The PCCW Group has multiple different stakeholders including; customers, suppliers, shareholders,
partners, governments, non-government organisations, and employees, amongst a wide range of
others. Stakeholder perspectives provide a very worthwhile form of feedback facilitating an additional
channel of communication to allow the PCCW Group to better understand and contribute to our
corporate social responsibilities.

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Customers
The PCCW Group must be responsive where individuals choose to engage one of our many feedback
and communications channels. At times consulting interest organisations may serve as proxies for
groups of customers.
Customers have legitimate interests in the PCCW Group and represent the interests of the community
as a whole. As our largest audience, the PCCW Group has defined and interpreted our social
responsibilities and the approach by which our strategies, policies, practices, and implementation
processes are accepted, rejected or modified; in large based on input received from both existing and
potential customers.
Suppliers
The PCCW Group will ensure that our processes applicable to supplier activities, with whom the
PCCW Group interacts commercially or in any other manner, respects, promotes and advances
international principles for fair business practices and human rights.
The PCCW Group will encourage our suppliers to accept these same fair business principles and
consider this acceptance as an important factor when determining future decisions pertaining to the
engagement of new, or remaining within existing relationships.
Shareholders
PCCW encourages two-way communication with our institutional, retail and private investors, as well
as financial and industry analysts. Extensive information on the PCCW Groups activities is provided in
the annual and interim reports, and circulars, which are sent to shareholders.
In addition to dispatching corporate documentation to shareholders, financial and other information
relating to the PCCW Group and our business activities is disclosed on PCCWs website
(www.pccw.com), in order to promote effective communication.
Regular dialogue takes place with the investment community. Enquiries from individuals on matters
relating to their shareholdings and the business of the PCCW Group are welcomed and dealt with in an
informative and timely manner. Shareholders are also encouraged to attend the annual general
meetings of PCCW where directors are available to answer questions on the business of the PCCW
Group.

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Employee development is a significant area impacting PCCW Groups societal role. The PCCW Group
must:
(a)
ensure all our activities respect, promote and advance internationally recognized human rights;
(b)
ensure all relevant employees are provided with cultural and human rights training and
guidance;
(c)
not be complicit in human rights abuses;
(d)
ensure work performed on our behalf, either directly or indirectly, is performed within the
appropriate legal and institutional framework;
(e)
respect the principle of freedom of association;
(f)
not employ children nor practice any form of forced labour;
(g)
not practice unfair discrimination in our employment practices;
(h)
maintain a duty to provide decent conditions of work for all our employees;
(i)
invest in our employees skills development;
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(j)
(k)
(l)

encourage good industrial relations;

ensure individuals performing work for the PCCW Group do so within a recognized
employment relationship or, alternatively, are legitimately self employed; and
ensure work done on our behalf is performed in a healthy and safe working environment.

Management
Through the recognition of an employer/employee relationship the PCCW Group will ensure
organizational activities have a positive impact by providing both labour protection (i.e. compliance with
laws and regulations that govern work including wages, working time, and health and safety) and social
recognition (i.e. medical care, income replacement in the event of injury, or retirement provisions).
PCCW recognizes and values the importance of maintaining good and harmonious relations with all
employees. A Joint Staff Council (JSC) has been in place for years to serve as a structured channel of
communications between management and employee representatives on matters of mutual concern.
JSC membership is composed of representatives of management and other full time regular
employees (all elected by staff) of PCCW and its wholly owned subsidiaries in Hong Kong. The JSC
enables:
(a)

a better understanding by employees of the Company's policies and decisions;

(b)

promotion of a co-operation spirit;

(c)

improvement in the overall efficiency of the Company;

(d)

enhancement of services to customers; and

(e)

increased level of well-being for employees.

Regular formal and informal meetings with employees occur through the JSC.
Employees are
encouraged to voice any worries or anxieties they have in a confidential and professional way, and to
have a 2-way communication on issues including: the Company's plans and policies, operational
efficiency, career development and training, working conditions, pay and benefits, social and
recreational facilities.
Through various supporting documents, including the Human Resources Policy Manual and Employee
Handbooks, the PCCW Group provides a framework within which relations between management and
employees can be represented collectively to help ensure the positive social impact of employment.
To ensure a more healthy and able workforce the PCCW Group will maintain health policies and
supporting health service plans available to all employees.

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Head of Group Communications
PO Box 9896
GPO Hong Kong
Phone: 2888 2888 Fax: 2877 8877
www.pccw.com/eng/AboutUs/CommunityandEnvironment.html

PUBLIC AVAILABILITY

November 2008

Reference: CRP-POL-02

Version 1.1

Status: Approved

Page 9
Approved by: PCCW Board of Directors
Maintained by: Risk Management

CORPORATE SOCIAL RESPONSIBILITY POLICY

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Changes to PCCW Group policies and any associated documents will occur from time to time. Any
changes to the policy documents and/or their associated documents will be communicated via publication
on the PCCW web site.
The versions published on the PCCW web site at the time of reference will be the authoritative version of
these documents and will supersede any previously published versions of the same documents.

PUBLIC AVAILABILITY

November 2008

Reference: CRP-POL-02

Version 1.1

Status: Approved

Page 10
Approved by: PCCW Board of Directors
Maintained by: Risk Management