corporate governance - aitken spence hotels

Aitken Spence Hotel Holdings PLC | Corporate Governance Disclosures 2019/202

An Effective BoardThe Board of Directors appointed by the shareholders becomes the conscience guardians and custodians of the Company, providing leadership for determining the strategic course of the Company and discharge of its obligations as a responsible corporate citizen. Consequently, composition of the Board is key to its effectiveness and determines the tone at the top, a sine qua non for sound corporate governance.

Company Secretarial services are provided by Aitken Spence Corporate Finance (Private) Limited, a subsidiary of our parent company, Aitken Spence PLC.

Compliance Framework

Mandatory• Companies Act No.7 of 2007• Sri Lanka Accounting and Auditing Standards Act No. 15 of 1995• Articles of Association• Listing Rules of the Colombo Stock Exchange (CSE)• Central Depository System Rules• Securities & Exchange Commission of Sri Lanka Act No. 36 of 1987 (as amended)• Group Code of Ethics• Inland Revenue Act No. 24 of 2017 • Foreign Exchange Act No. 12 of 2017

Voluntary• Code of Best Practice on Corporate Governance issued by the Institute of Chartered Accountants 2017• Aitken Spence Integrated Sustainability Policy and its Implementation Framework• Codes of regulatory authorities, professional institutions and Trade Associations• United Nations Global Compact (UNGC)• UNWTO Global Code of Ethics for Tourism• GRI Standards• Integrated Reporting Framework• Women’s Empowerment Principles• Social and Environmental Certification Requirements

CORPORATE GOVERNANCE

Composition

Chairman

Executive Directors

Independent Non-Executive Directors

Non-Independent Non-Executive Directors

The Board of

Directors

Related Party Transactions Review

Committee

Remuneration Committee

Nomination Committee

Audit Committee

Group Supervisory Board

Managing Director

Board of Management

Senior Management Committees

Internal Audit

Board Sub Committees of Parent Company

Executive Committees

Board Profiles on pages 16 to 18 of the Annual Report 2019/20

Administration of the Board

Aitken Spence Hotel Holdings PLC | Corporate Governance Disclosures 2019/20 3

Board CompositionThe Board consisted of 9 members throughout the financial year 2019/20. The Directors bring a range of diverse skills, expertise and competencies to the Board to facilitate the effective discharge of Board responsibility. Five out of nine Directors are Non- Executive Directors, who are eminent professionals. All Directors must, by duty, act with independence of mind and in the best interests of the Company. This mandate is enhanced by the presence of five Non-Executive Directors, of whom three are Independent Directors. The Board of Aitken Spence Hotel Holdings PLC is represented by a young female Director, thus resulting in a gender balance in the Board amounting to 11% female and 89% male.

TABLE 1: COMPOSITION OF THE BOARD

Age

30-45 Years

46-65 Years

66-75 Years

>76 Years

4522

2211

%Composition

Executive Directors

Non-Independent Non-Executive Directors

Independent Non-Executive Directors

45

22

33

%

Expertise

0

10

20

30

40

50

%

Bus

ines

s Lea

ders

hip

Acc

ount

ing

& F

inan

ce

Tour

ism

Inve

stm

ent &

Ban

king

Econ

omis

t & S

cien

tist

Gender Diversity

Male

11

89

Female

%

Tenure of Service

0

5

10

15

20

25

30

35

%

< 5

Year

s

< 10

Yea

rs

< 15

Yea

rs

> 20

Yea

rs


Roles & Responsibilities of the Board

• Ensuring formulation and implementation of a sound business strategy.

• Ensuring that the Managing Director and Management Team possess the relevant skills, experience, knowledge and capacity to implement the strategy.

• Approving Budgets and major capital expenditure.

• Establishing effective systems to secure the integrity of information, internal controls, business continuity and risk management.

• Ensuring the compliance of the Group’s statutory and regulatory obligations and safeguarding the Group’s reputation by promoting corporate values and an ethical culture.

• Considering and carefully balancing stakeholder interests in corporate decisions.

• Recognising sustainable business development in Corporate Strategy, decisions and activities.

• Setting up the Company values and standards with emphasis on adopting appropriate accounting policies and fostering compliance with financial regulations.

• Establishing a process of monitoring and evaluating the progress on strategy implementations, budgets, plans and related risks.

Chairman’s Responsibility

• The role of the Chairman and the Managing Director are separate, facilitating a balance of power and authority. The Role of the Chairman is as follows:

• Provide leadership to the Board.

• Facilitate effective discharge of its functions.

• Facilitating participation by both Executive and Non-Executive Directors.

• Ensuring that all Directors are adequately briefed on matters arising at Board Meetings.

• Ensuring that Directors contribute effectively leveraging the collective skills and experience of the Board.

• Ensuring that shareholders are given adequate opportunity to make observations, express their views and seek clarifications at meetings of shareholders.

• Building and maintaining stakeholder trust and confidence.

Managing Director’s Responsibility

• Maintaining a close working relationship with the Chairman, and acting as a sounding board for the Chairman when required.

• Developing Group’s business strategy for approval by the Board.

• Developing and recommending to the Board, budgets that support the Group’s long-term strategy.

• Support the Executive Directors, Board of Management, and Senior Management Committees on the day –to-day management of the Group’s business operations.

• Ensuring that the Group operations are within the approved risk appetite.

• Ensuring compliance with applicable rules and regulations and Corporate Governance principles.

• Ensuring proper succession planning of the Executive Management and assessing their performance.

• Creating an ethical environment and nurturing a culture based on the Group’s values.



The period of service of Mr. R.N. Asirwatham as a Board Member exceeds nine years. Additionally, Mr. R.N. Asirwatham is a Director of the parent company in which majority of the other Directors of the Company are Directors. However, his period of service and his office of Independent Non-Executive Director of the parent company do not compromise his independence and objectivity in discharging his functions as a Director of the Company. Therefore, the Board determined that Mr. R.N. Asirwatham is ‘independent’ of Aitken Spence Hotel Holdings PLC as per the Listing Rules.

The period of service of Mr. C.H. Gomez as a Board Member exceeds nine years. Additionally, Mr. C.H. Gomez is a Director of the parent company in which majority of the other Directors of the Company are Directors. However, his period of service and his office of Independent Non-Executive Director of the parent company do not compromise his independence and objectivity in discharging his functions as a Director of the Company. Therefore, the Board determined that Mr. C.H. Gomez is ‘independent’ of Aitken Spence Hotel Holdings PLC as per the Listing Rules.

Mr. G.P.J. Goonewardena served as an Executive Director of Aitken Spence Hotel Holdings PLC until his retirement on 30th June 2017 which was during the period of two years immediately preceding his appointment as a Non-Executive Director on 30th March 2018. However, his appointment as an Executive Director within two years period immediately preceding his appointment as a Non-Executive Director of the Company does not compromise his independence and objectivity in discharging his functions as a Director of the Company. Therefore, the Board determined that Mr. G.P.J. Goonewardena is ‘independent’ of Aitken Spence Hotel Holdings PLC as per the Listing Rules.

Mr. R.N. Asirwatham Mr. C.H. Gomez Mr. G.P.J. Goonewardene

Independence of Non-Executive DirectorsDirectors exercise their independent judgement, promoting constructive deliberations and objective evaluation of matters set before them. Independence of Directors is determined by the Board, based on annual declarations submitted by the Non-Executive Directors in compliance with the Listing Rules of the CSE and also in line with schedule K of the Code. Annually, the Board discusses the possibility of any impairment of Directors’ independence due to extended Board tenures, and collectively evaluates the re-election of such Board members.

Further, two Directors of the Company, Deshamanya D.H.S. Jayawardena and Miss D.S.T. Jayawardena are related to each other. However, they act in the best interests of the Group using their independent judgement on matters referred to the Board.

Disclosures made by Directors from time to time, regarding their interest in transactions including the related party transactions are formally noted and duly entered into the interest register. Note 49 on page

225 of the Financial Statements of the Annual Report 2019/20 provides a list of companies in which the Directors had transactions during the year under review.


Appointment, Re-Appointment, Re-election and Resignation of DirectorsShareholders re-appoint/re-elect the Directors at the Annual General Meeting (AGM) by voting for resolutions proposed by the Board. The Board is assisted in the selection process by the Nominations Committee of the parent company who recommends nominees to the Board for their consideration and recommendation to shareholders. The Nominations Committee considers the skills and experience required on the Board for effective discharge of its duties.

Separate resolutions are included in the Notice of Meeting on page 260 of the Annual Report 2019/20 for the proposed re-appointment and re-election of the Directors concerned. In compliance with the Articles of Association 1/3rd of the Directors will retire from office at each AGM and are eligible to stand for re-election by the shareholders at the AGM. The Nominations Committee evaluates the contribution made by these Directors to assess their eligibility for re-election.

Casual vacancies are filled by the Board based on the recommendations of the Nominations Committee and the Director so appointed will offer himself/herself for election at the next AGM. Appointments are immediately disclosed to the Colombo Stock Exchange along with a brief resume of the Director.

Directors wishing to resign are required to provide a written communication with the reasons for such resignation which is tabled at the Board meeting. Immediate disclosure of resignation is made to the CSE.

Induction & Training Directors receive a Letter of Appointment outlining the terms of the appointment, duties, responsibilities and expected time commitments. On appointment, Directors are taken through a formal and tailored induction programme coordinated by the Managing Director, where they are enlightened on the Group values and culture, its operating model, policies, governance framework and processes, Group Code of Ethics and operational strategies of the Group. Directors are availed the opportunity to have meetings with the management of each subsidiary and visit hotels where appropriate.


Regular presentations by management, consultants and other experts are conducted to ensure that the Board is apprised of relevant regulatory and industry developments, trends and benchmarks. Additionally, Directors are encouraged and expected to stay abreast of developments in their respective area of expertise, facilitating effective contribution to the Board.

Meetings & MinutesThe Board meets on a quarterly basis and also convenes additional meetings if deemed necessary. Accordingly, the Board met 5 times during the year. The Managing Director in consultation with the Chairman sets the Board agenda with the assistance of the Company Secretaries. The Chairman ensures that Directors have sufficient information on matters included in the agenda to facilitate effective participation of all Directors. Additionally, all Directors have access to the Managing Director and the Senior Management of the Company to clarify any matter and they are available for clarification of matters during the meeting. In an instance of a Director’s non-attendance at the meetings he/she is provided with briefing material for discussion with the Chairman or the Managing Director on a later date, through formally documented minutes of discussions, by clarifying matters from the Company Secretaries or through separate discussions prior to the meeting regarding matters arising from the previous meeting.

Board packs are circulated one week prior to the meeting to allow adequate time for preparation of the same. Minutes of meetings are circulated within 10 days of the meeting to Board members and included in the subsequent Board pack. Company Secretaries maintain all past minutes and board papers and are accessible at the convenience of the Directors.

Directors’ concerns regarding matters which are not resolved unanimously (if any) are recorded in the minutes.


Attendance at Board and Board Committee meetings are given below.

TABLE 2: ATTENDANCE AT BOARD AND BOARD COMMITTEE MEETINGS

Board Audit Committee

Nomination Committee

Remuneration Committee

Related Party Transactions Review Committee

Deshamanya D. H. S. Jayawardena Chairman 5 - 1 - -Dr. M. P. Dissanayake EXE 5 - - - -Ms. D. S. T. Jayawardena EXE 5 - - - -Mr. C. M. S. Jayawickrama EXE 5 - - - 4Mr. J. M. S. Brito* NED 5 7 - - 4Mr. N. J. De Silva Deva Aditya NED 5 9 - - 3Mr. R. N. Asirwatham INED 5 11 1 1 4Mr. C. H. Gomez INED 2 1 - 1 1Mr. G. P. J. Goonawardene INED 5 - - - -Total No. of Meetings 5 11 1 1 4

EXE - Executive DirectorNED - Non-Executive DirectorINED - Independent Non-Executive Director

* Appointed as a member of the Audit Committee and the Related Party Transactions Committee w.e.f. 23.05.2019.

Company SecretariesAitken Spence Corporate Finance (Private) Limited acts as Secretaries to the Board. The Directors have access to advice and services of the Company Secretaries who support the Board and management in ensuring effective governance and good decision making across the Group. The Secretaries ensures Directors receive full and timely information and have access to the resources they need to facilitate effective decision-making. They keep Directors informed of governance, regulation and legislative changes relevant to the discharge of their duties, individually as Directors and collectively as a Board. Secretaries maintain minutes of Board meetings, which are open for inspection by any Director at any time. Appointment and removal of the Company Secretaries is a matter for the Board as a whole.

Conflicts of InterestsDirectors abstain from voting where there is a conflict of interest and generally excuse themselves from the discussion. In the event of conflicts and concerns that cannot be resolved unanimously, Director’s dissent is recorded in the Board minutes. In urgent circumstances necessitating decision making through circular resolutions, efforts are made to provide all relevant information required to enable Directors to clearly understand the issue/s and potential consequences.

Board EvaluationThe Board carries out a self appraisal of the Board and its Committees annually with each Director appraising their own performance with reference to their key responsibilities as outlined in the Nominations Committee Report on page 113 of the Annual Report 2019/20. This serves to identify areas for improvement and gaps pertaining to Board administration and processes.

Directors’ RemunerationThe Remuneration Committee of Aitken Spence PLC serves as the Remuneration Committee of Aitken Spence Hotel Holdings PLC. It comprises of three Non-Executive Directors all of whom are determined by the Board as independent.

The Remuneration Committee makes recommendations to the Board with the consultation of the Chairman and the Managing Director regarding the remuneration of Executive Directors and the Senior Management within agreed terms of reference and in accordance with the remuneration policy of the Group. No Director is involved in determining his or her own remuneration.

The Committee considers the skills, attributes and experience of the Executive Directors and the operating environment in determining the level of remuneration. Executive Directors’remuneration comprises

a fixed portion and a variable portion in the form of a performance bonus linked to achievement of corporate and individual goals and targets.

Remuneration of Non-Executive Directors reflects the time commitment and responsibilities of their role. They are remunerated based on their attendance at Board and/or Committee meetings.

Directors’ remuneration in respect of the Company and the Group for the Financial Year ended 31st March 2020 are disclosed on page 165 of the Financial Statements of the Annual Report 2019/20.

Accountability & AuditThe Board goes beyond regulatory requirements to provide shareholders with a comprehensive and balanced assessment of the performance of the Group. This Annual Report complies with the requirement of widely accepted standards, codes and frameworks which have been voluntarily adopted to ensure that our corporate reporting is in line with international best practices. Our sign off processes ensure that the report provides a balanced review of the Group’s performance with high levels of transparency.

Quarterly financial statements and other price sensitive announcements, press releases and regulatory reports also provide a balanced assessment of the matters discussed.



Risk & Internal ControlThe Board is responsible for setting in place a process to identify, measure, monitor and manage the principal risks of the Group and determining the level of risk it is willing to accept in relation to its strategic goals. The Board is also responsible for setting in place a system of internal controls to safeguard the assets and investments of the Group and shareholders. The Group Internal Audit division reviews the risk management processes and the internal controls according to an annual audit plan approved by the Audit Committee. The Audit Committee also reviews the Internal Audit Reports and exercises oversight to ensure that recommendations included are implemented in a timely manner, minimizing risk. The following reports provide further information in this regard:

• Risk Management Report -page 38 to 43 of the Annual Report 2019/20

• The Board of Directors’ Statement on Internal Controls -page 121 to 122 of the Annual Report 2019/20

• Audit Committee -page 109 to 111 of the Annual Report 2019/20

Audit CommitteeThe Audit Committee of our parent serves as the Audit Committee of the Company as permitted by Section 7.10.6 of the Listing Rules of the Colombo Stock Exchange as both the parent company and the subsidiary company are listed companies.

TABLE 3: COMPOSITION OF THE AUDIT COMMITTEE

Audit CommitteeMr. R. N. Asirwatham (Chairman) Independent Non-Executive DirectorMr. G. C. Wickremasinghe Independent Non-Executive DirectorMr. C. H. Gomez Independent Non-Executive DirectorMr. N. J. De Silva Deva Aditya/Mr. A.L. Gooneratne (Alternate Director to Mr. N.J. De Silva Deva Aditya in the parent company’s Directorate)

Non-Executive Director

Mr. J.M.S. Brito (Appointed w.e.f 23.05.2019)


Composition of the Audit Committee is in line with Section 7.10.6 (a) of the Listing Rules of the Colombo Stock Exchange where majority of the Non-Executive Directors are determined to be independent. The Audit Committee met 11 times during the year and the report of its activities is given on pages 109 to 111 of the Annual report 2019/20.

As the Company belongs to the tourism segment of Aitken Spence Group, all policy decisions pertaining to the Company are taken by the parent company. Therefore, it is necessary that Board sub committees of the parent company look into the matters of the subsidiary company in order to make sure that the policies and decisions of the subsidiary are in conformity with that of the parent company.


Related Party Transactions Review CommitteeThe Related Party Transactions Review Committee of Aitken Spence PLC functions as the Related Party Transactions Review Committee of the Company and provides feedback to the Board of Aitken Spence Hotel Holdings PLC on relevant material matters in line with its mandate. The composition of the Committee is given below which complies with Section 9.2.2 of the Listing Rules of the CSE.

TABLE 4: COMPOSITION OF THE RELATED PARTY TRANSACTIONS REVIEW COMMITTEE

Related Party Transactions Review Committee Mr. R. N. Asirwatham (Chairman) Independent Non-Executive DirectorMr. G. C. Wickremasinghe Independent Non-Executive DirectorMr. C. H. Gomez Independent Non-Executive DirectorMr. N. J. De Silva Deva Aditya/Mr. A.L. Gooneratne (Alternate Director to Mr. N.J. De Silva Deva Aditya in the parent company’s Directorate)


Mr. J.M.S. Brito (Appointed w.e.f 23.05.2019)


The Related Party Transactions Review Committee met 4 times during the year and the report of its activities is given on pages 114 to 115 of the Annual report 2019/20.

Remuneration CommitteeThe Remuneration Committee of Aitken Spence PLC acts as the Remuneration Committee of the Company as permitted by Section 7.10.5 (a) of the Listing Rules of the Colombo Stock Exchange. The Company has complied with the policies and procedures set out by the Group Remuneration Committee. The composition of the Committee is given below which complies with the requirement of Section 7.10.5 (a) of the Listing Rules of the CSE.

TABLE 5: COMPOSITION OF THE REMUNERATION COMMITTEE

Remuneration Committee Mr. G. C. Wickremasinghe (Chairman) Independent Non-Executive DirectorMr. R. N. Asirwatham Independent Non-Executive DirectorMr. C. H. Gomez Independent Non-Executive Director

The Remuneration Committee met one time during the year and the report of its activities is given on page 112 of the Annual report 2019/20.

Code of Ethics and Professional ConductAitken Spence Hotel Holdings PLC complies with the Group’s Code of Ethics which is designed to guide all employees with regard to conduct within and outside the workplace which may concern the employees in relation to their position in the Company. It clearly expresses how an employee should act with integrity under different circumstances. The Board ensures that Directors and all employees strictly comply with the Group code of ethics in exercising their duties, communications, role modeling and in any other circumstances, so as to uphold the Group’s image. Strict disciplinary actions are initiated for any violation of the Group code of ethics.

Shareholder RelationsAt the close of the financial year 2019/20, the Company had 3,659 shareholders. National Institutions and individuals held 99.68% of shares while Foreign Investors held the remaining 0.32%. Aitken Spence PLC is the largest shareholder owning 71.21% of shares at close while the 20 largest shareholders held 92.05%.

The Company encourages effective communication with shareholders who are engaged through multiple channels of communication, including the Annual General Meeting (AGM), Annual Report, Interim Financial Statements, a dedicated investor relations page on the Company’s website, press releases, social media platforms and announcements to the Colombo Stock Exchange. The Board recognises its responsibility to present a balanced and understandable assessment of the Group’s financial position, performance and prospects and is committed to fair disclosure, with emphasis on the integrity, timeliness and relevance of the information provided.

The Annual General Meeting is the principal forum for engaging with shareholders and 50 shareholders holding 77.67% of shares attended and voted at the meeting held on 28th June 2019.

External AuditorsThe External Auditor is appointed subject to the provisions of the Companies Act No. 7 of 2007. The Audit Committee makes recommendations to the Board for the appointment, re-appointment or removal of the External Auditor inline with professional and ethical standards and regulatory requirements. Further, it monitors and reviews the External Auditor’s independence, objectivity and effectiveness of the audit process considering relevant professional and regulatory requirements.

In assigning of non-audit services to External Auditors, the Audit Committee ensures that the external auditor has the necessary skills and experience for the assignment and ascertains that independence and objectivity in carrying out his duties and responsibilities will not be impaired.

On the recommendation of the Board, the shareholders approved the reappointment of Messrs. KPMG (Chartered Accountants) as the External Auditors for 2019/20 at the last AGM in compliance with Section 163 (3) of the Companies Act No. 07 of 2007.


Internet of Things & Cyber SecurityThe Company engages with customers across several social media platforms, the corporate website and through online aggregators with an increasing number of bookings originating from online engagements. We are also custodians of significant information assets which we have a responsibility to safeguard. Therefore, IoT and cybersecurity are key concerns for the Board and receive significant attention on the agenda. We have implemented a state of the art Property Management and Reservations software and Enterprise Resource Planning software across the Group which are reviewed regularly.

Intelligent automation has caught significant attention in the sector. This will bring in competitive advantages in productivity, accuracy, speed and cost of a transaction. Hence Robotic Process Automation and seamless integrations using advance integration platforms has been introduced in bringing in Intelligent Automation. Additionally, the sector expanded its Enterprise Resource Planning (ERP) capability by extending the use of the ERP to all operational hands in enhancing visibility and decision making. The digital drive has enabled agilcybere and online access to enable digital processing, with less paper handling.

We have also implemented IT policies across the Group which provide for adequate systems and controls and disaster recovery capability to facilitate safeguarding of the Group’s information assets. The Company is also compliant with the payment card industry data security standards using tools and services from a leading specialist third party provider. The Chief Information Security Officer (CISO) supported by Group IT of the AS Group is responsible for ensuring the security of interacting sources and third party platforms which are necessary for our business. CISO is a member of the IT Steering committee and reports to the CFO of Aitken Spence PLC, who is a member of the Group Supervisory Board and IT Steering Committee. Cybersecurity is discussed at the monthly IT Steering Committee meetings and subsequently at the Audit Committee meetings, with matters escalated to the Board of Aitken Spence Hotel Holdings PLC, where deemed necessary considering risk, impact and other prudential measures. It

is also reviewed by the Board through the Audit Committee minutes. The information security division conducts regular vulnerability assessments on all IT related systems and a dedicated central IT team is in place to support all IT related matters of the Group.

Environment, Society and Governance Reporting (ESG Reporting) The Company has a proud history of being a pioneer in ESG reporting in the country and awards won affirm high levels of commitment to transparency and a passion for excellence in ESG reporting. We are the only company to have won all three awards for Corporate Reporting in the country in 2019 in the Leisure sector as set out alongside. The following reports address the requirements of the Code.

TABLE 6: ESG REPORTING

Principle as per Code Reference

Principle 1 - Reporting of Economic Sustainability

Financial Capital – page 58 to 63 of the Annual Report 2019/20

Principle 2 - Reporting on the Environment

Natural Capital - page 90 to 96 of the Annual Report 2019/20

Principle 3 - Reporting on Labour Practices

Human Capital - page 72 to 77 of the Annual Report 2019/20

Principle 4 - Reporting on Society

Social & Relationship Capital - page 83 to 89 of the Annual Report 2019/20

Principle 5 - Reporting on Product Responsibility

Principle 6 - Reporting on Stakeholder identification, engagement and effective communication

Shareholder Relations of this Report

Principle 7 - Sustainable reporting to be formalised as part of the reporting process and to take place regularly

About this report - page 5 of the Annual Report 2019/20

Awards for ESG Reporting in 2019/20

Winner - Hotel Sector at 55th Annual Report Awards 2019 conducted by CA Sri Lanka

Gold Award Winner - Leisure & Connected Services Category - ACCA Sustainability Reporting Awards 2019

Best Integrated Report - Hotels & Travel Sector - CMA Excellence in Integrated Reporting Awards 2019



Declarations by Board, CEO & CFO & Governance DisclosuresThe Annual Report includes the following reports of the Board and its Committees providing key declarations on effective discharge of their duties.

• Annual Report of the Board of Directors - page 117 to 120 of the Annual Report 2019/20

• The Board of Directors’ Statement on Internal Control - page 121 to 122 of the Annual Report 2019/20

• Responsibility for preparation and presentation of Financial Statements - page 133 of the Annual Report 2019/20

• Reports of the Board Committees - page 109 to 115 of the Annual Report 2019/20

• Corporate Governance Report - this Report

The Board has obtained a declaration from the Managing Director and the Assistant Vice President-Finance to affirm that the financial records of the entity have been properly maintained and that the financial statements comply with the Sri Lanka Financial Reporting Standards giving a true and fair view of the financial position and performance of the Group. Further, they also confirm that the systems of risk management and internal control operate effectively.

The Board further acknowledges its responsibility of ensuring the integrity of this Annual Report, which is in the opinion of the Board, addresses all the concerns that are mentioned to the Company’s ability to create sustainable value and reflects a fair presentation of the integrated performance of Aitken Spence Hotel Holdings PLC.

TABLE 7: COMPLIANCE WITH THE COMPANIES ACT NO. 07 OF 2007

Section Requirement Reference Compliance Status

168 (1) (a) Any change during the accounting period in the nature of business of the Company or any of its subsidiaries and the classes of business in which the Company has an interest

Refer Annual Report of the Board of Directors on pages 117 to 120 of the Annual Report 2019/20

√

168 (1) (b) Financial Statements of the Company and the Group for the accounting period completed and signed.

Refer Financial Statements on pages 130 to 234 and Annual Report of the Board of Directors on pages 117 to 120 of the Annual Report 2019/20

√

168 (1) (c) Auditors’ report on Financial Statements of the Company and the Group

Refer Financial Statements on pages 130 to 234 and Annual Report of the Board of Directors on pages 117 to 120 of the Annual Report 2019/20

√

168 (1) (d) Change of accounting policies during the accounting period


√

168 (1) (e) Particulars of entries in the interest register made during the accounting period


√

168 (1) (f) Remuneration and other benefits paid to the Directors during the accounting period


√

168 (1) (g) Total amount of donations made by the Company during the accounting period


√

168 (1) (h) Directorate of the Company and the Group as at the end of accounting period along with the changes occurred during the accounting period


√

168 (1) (i) Amounts payable to the Auditors as audit fees and fees payable for other related services provided by them


√

168 (1) (j) Relationship or interest of the Auditors with the Company or any of its subsidiaries


√

168 (1) (k) Annual Report of the Board of Directors be signed on behalf of the Board


√



TABLE 8: COMPLIANCE WITH THE CONTINUING LISTING REQUIREMENTS - SECTION 7.6 ISSUED BY THE COLOMBO STOCK EXCHANGE - CONTENTS OF ANNUAL REPORT

Section Requirement Nature of Compliance by Aitken Spence Hotel Holdings PLC

Compliance Status

7.6 i) Names of Directors of the entity Refer Corporate Information on page 251 of the Annual Report 2019/20

√

7.6 ii) Principal activities of the entity and its subsidiaries during the year under review

Refer Group Directorate on pages 248 to 250 of the Annual Report 2019/20

√

7.6 iii) 20 largest holders of voting and non-voting shares and the percentage of shares

Refer Investor Information on pages 241 to 245 of the Annual Report 2019/20

√

7.6 iv) The public holding percentage, float adjusted market capitalisation, the options of compliance with the minimum public holding requirement


√

7.6 v) Directors and CEO’s holding in shares of the entity at the beginning and end of each year


√

7.6 vi) Information pertaining to material foreseeable risk factors

Refer Risk Management on pages 38 to 43 of the Annual Report 2019/20

√

7.6 vii) Details of material issues pertaining to employees and industrial relations

Refer Human Capital of integrated Management Discussion & Analysis on pages 72 to 77 of the Annual Report 2019/20

√

7.6 viii) Extents, locations, valuations and the number of buildings of the entity’s land holdings and investment properties

Refer Note 17.3.1 to the Financial Statements on page 176 and Real Estate Holdings of the Group on page 247 of the Annual Report 2019/20

√

7.6 ix) Number of shares representing the stated capital Refer Investor Information on pages 241 to 245 of the Annual Report 2019/20

√

7.6 x) Distribution schedule of the number of holders and the percentage of their total holding


√

7.6 xi) Ratios and market price information Refer Investor Information on pages 241 to 245 of the Annual Report 2019/20

√

7.6 xii) Significant changes in the entity’s or its subsidiaries fixed assets and the market value of land

Refer Note 17 Financial Statements on pages 174 to 177 of the Annual Report 2019/20

√

7.6 xiii) If during the year the entity has raised funds either through a public issue, rights issue and private placement

The Company had no public issue, rights issue or private placement during the year under review

N/A

7.6 xiv) Employee share options/purchase schemes As at date, the Company has no share options/ purchase schemes made available to its Directors or employees

N/A

7.6 xv) Corporate governance disclosures Refer Corporate Governance on pages 98 to 108 of the Annual Report 2019/20

√

7.6 xvi) Related party transactions Refer Not 49 to the Financial Statements on pages 225 to 232 of the Annual Report 2019/20

√


TABLE 9: COMPLIANCE WITH THE CONTINUING LISTING REQUIREMENTS - SECTION 7.10 ISSUED BY THE COLOMBO STOCK EXCHANGE - CORPORATE GOVERNANCE RULES FOR LISTED COMPANIES

Section Requirement Disclosure Compliance Status

7.10.1(a) Non-Executive Directors (NED)- At least two or one third of the Directors, whichever

is higher, should be Non- Executive Directors

Refer Board Composition of this Report √

7.10.2(a) Independent Directors- Two or one-third of Non-Executive Directors,

whichever is higher, should be independent

Refer Independence of Non-Executive Directors of this Report

√

7.10.2(b) Independence of Directors- Each Non-Executive Director should submit a

declaration of Independence/ Non-Independence


√

7.10.3(a) Disclosure relating to Directors- The names of Independent Directors should be

disclosed in the Annual Report


√

7.10.3(b) Independence of Directors- The Board shall make a determination annually as

to the Independence or Non-Independence of each Non-Executive Director


√

7.10.3(c) Disclosure relating to Directors- A brief resume of each Director should be included

in the Annual Report including the Director’s areas of expertise.

Refer Board profiles of the Directors on the pages 16 to 18 of the Annual Report 2019/20

√

7.10.3(d) Appointment of new Directors- Provide a brief resume of any new Director

appointed to the Board

Upon the appointment of a new Director to the Board, the Company informs the Colombo Stock Exchange with a brief resume of such a Director containing the nature of his expertise, relevant interest, other directorships held, memberships in Board Committees and the nature of appointment. There were no new appointments to the Board of the Directors during the year under review

√

7.10.5 Remuneration Committee- A listed company shall have a Remuneration

Committee

Refer Remuneration Committee Report on page 112 of the Annual Report 2019/20

√

7.10.5(a) Composition of Remuneration Committee- Shall comprise of Non-Executive Directors, a

majority of whom shall be Independent


√

7.10.5(b) Functions of Remuneration Committee- The Remuneration Committee shall recommend the

remuneration of the Chief Executive Officer and the Executive Directors


√

7.10.5(c) Disclosure in the Annual Report relating to Remuneration- The Annual Report should set out;

a) Names of the Directors comprising the Remuneration Committee

b) Statement of Remuneration policyc) Aggregate remuneration paid to Executive and

Non-Executive Directors

Refer Remuneration Committee Report on page 112 and Note 12 and 49.2 in the Financial statements on pages 165 to 234 of the Annual Report 2019/20

√

7.10.6 Audit Committee- A listed company shall have an Audit Committee

Refer Audit Committee Report on pages 109 to 111 of the Annual Report 2019/20

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Section Requirement Disclosure Compliance Status

7.10.6(a) Composition of Audit Committee- Shall comprise of Non-Executive Directors, a

majority of whom are Independent- Chief Executive Officer and the Chief Financial

Officer should attend Audit Committee Meetings- The Chairman of the Audit Committee or one

member should be a member of a professional accounting body


√

7.10.6(b) Audit Committee Functions- Should be as outlined in Section 7.10 of the Listing

Rules


√

7.10.6(c) Disclosure in the Annual Report relating to Audit Committeea) Names of the Directors comprising the Audit

Committeeb) The Audit Committee shall make a determination of

the independence of the Auditors and disclose the basis for such determination

c) The Annual Report shall contain a Report of the Audit Committee in the prescribed manner


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9.3.2 Related Party Transactions Review Committeea) Details pertaining to Non-Recurrent Related Party

Transactions b) Details pertaining to Recurrent Related Party

Transactionsc) Report of the Related Party Transactions Review

Committeed) Declaration by the Board of Directors as an

affirmative statement of compliance with the rules pertaining to Related Party Transactions, or a negative statement otherwise

Refer Related Party Transactions Review Committee Report on pages 114 to 155 of the Annual Report 2019/20

√


TABLE 10: COMPLIANCE WITH THE REQUIREMENTS OF THE CODE OF BEST PRACTICES ON CORPORATE GOVERNANCE ISSUED BY THE INSTITUTE OF CHARTERED ACCOUNTANTS OF SRI LANKA

Reference to ICASL Code

Corporate Governance Principle

How we Comply Compliance Status

A. DirectorsA.1 The BoardA. 1.1 Board Meetings Refer to Meetings & Minutes of this Report √A1.2 Role of the Board Refer an Effective Board of this Report √A. 1.3 Compliance with laws and

access to independent professional advice

In discharging its duties, the Board seeks independent professional advice from external parties when necessary at the Company’s expense. All Directors are further encouraged to attend seminars/training programmes relevant and useful to them in enhancing their business acumen and professionalism in carrying out their duties.

√

A 1.4 Access to advice from the Company Secretary

Indemnifying the Board, Directors and key management personnel

Refer Company Secretaries of this Report

In accordance with section 218 of the Companies Act No. 07 of 2007 Directors are indemnified against the liabilities which may arise in respect of the duties they perform within the organisation.

√

A 1.5 Independent judgment of the Directors

Refer Independence of Non-Executive Directors of this Report √

A 1.6 Dedicating adequate time and effort

All Directors devote sufficient time to the affairs of the Company to facilitate discharge of their duties effectively. Board papers are circulated at least one week prior to the meeting providing sufficient time to review and call for any further information required to contribute effectively to the deliberations at the Board Meeting.

√

A.1.7 Calls for resolutions One third of the Directors may call for a resolution to be presented to the Board in the best interests of the Company.

√

A 1.8 Training of Directors Refer Induction & Training of this Report √A.2 Chairman and Chief Executive Officer (CEO)

Clear division of responsibilities. No one Director with unfettered power.

Roles of the Chairman and the Managing Director are segregated in line with best practices in Corporate Governance ensuring that no one Director has unfettered power and authority. The Chairman leads the Board, preserving good corporate governance and ensuring that it works effectively, acting in the best interest of the Group. The Managing Director leads the Executive Management and is accountable to the Board for exercise of delegated authority and for the performance of the Group. Their roles and responsibilities are set out of this Report

√

A. 2.1 Combining roles of Chairman and CEO

Not applicable

A. 3 Chairman’s Role Please refer Role of Chairman of this Report √A. 4 Financial Acumen All Directors have a sound knowledge of finance ensuring a

sufficiency of financial acumen as apparent from their Board profiles. Additionally, three Directors are members of reputed professional accounting bodies ensuring a sufficiency of knowledge on matters of finance within the Board.

√






A.5 Board BalanceA.5.1/A5.2/A.5.3 & A.5.5

Presence of Non-Executive Directors

Independence of Non-Executive Directors

The Board comprises of five Non-Executive Directors namely Mr. J.M.S. Brito, Mr. R.N. Asirwatham, Mr. N.J. De Silva Deva Aditya, Mr. C.H. Gomez and Mr. G.P.J. Goonewardena. The period of service of Mr. R.N. Asirwatham and Mr. C.H. Gomez as Board Members of the Company exceed nine years. Additionally, Mr. R.N. Asirwatham and Mr. C.H. Gomez are Directors of the parent company in which majority of the other Directors of the Company (ASHH PLC) are Directors. However, their period of service and their office of Independent Non-Executive Director of the parent company do not compromise their independence and objectivity in discharging their functions as Non- Executive Directors of the Company. Hence, Mr. R.N. Asirwatham and Mr. C.H. Gomez are determined by the Board to be independent Directors.

Mr. G.P.J. Goonewardena served as an Executive Director of the Company until his retirement on 30.06.2017 which was during the period of two years immediately preceding his appointment as a Non-Executive Director on 30.03.2018. However, his appointment as an Executive Director within two years period immediately preceding his appointment as a Non-Executive Director of the Company does not compromise his independence and objectivity in discharging his functions as a Non- Executive Director of the Company. Hence Mr. G.P.J. Goonewardena is determined by the Board to be an Independent Director.

√

A.5.4 Annual Declaration of Independence by the Non-Executive Directors

Each Non-Executive Director submits a signed declaration annually with regard to his independence/non-independence against specified criteria.

√

A.5.6 Alternate Director to a Non-Executive Director

During the year under review, there were no appointments of alternate Directors.

N/A

A.5.7/5.8 Senior Independent Director Although the Chairman is not an Independent Director, a Senior Independent Director has not been formally appointed.

Mr Asirwatham in his capacity has the lead Independent Director acts as a sounding board to the Chairman on matters of concern.

A.5.9 Chairman meeting with the Non-Executive Directors

Informal discussions take place on matters that require the attention of the Non-Executive Directors.

√

A.5.10 Recording concerns In the event of a matter not being unanimously resolved at a Board meeting, the concerns expressed are recorded in the Board Minutes. Minutes of the Board Meetings are circulated to all Directors and adopted at a subsequent Board Meeting.

√

A.6 Supply of InformationA.6.1 Obligation of the

Management to provide appropriate and timely information

Directors have unrestricted access to management and organisation information, as well as the resources required to carry out their duties and responsibilities effectively. All Board members receive information regarding operations and performance of the Group on a monthly basis.

√

A.6.2 Timelines -

Timely provision of Board Papers

Board meeting minutes

Refer Meetings and Minutes of this Report √





A.7 Appointments to the BoardA.7.1 / A.7.2 Nomination Committee

and the assessment of composition of the Board

The Nomination Committee of Aitken Spence PLC serves as the Nomination Committee of the Company. The members of the committee are composed of the chairman and two Independent Non-Executive Directors. The Nomination Committee Report provides further information on page 113 of the Annual Report 2019/20

√

A.7.3 Disclosure of Appointment of a New Director

Upon the appointment of a new Director to the Board, the Company informs the Colombo Stock Exchange with a brief resume of such a Director containing the nature of his expertise, relevant interest, other directorships held, memberships in Board Committees and the nature of appointment.

There were no new appointments to the Board of Directors during the year under review.

√

A.8 Re-electionA.8.1 /A.8.2 Re-election Except the Chairman and the Managing Director all the other

Directors are subject to retirement by rotation in terms of the Articles of Association of the Company. The retiring Directors and all the Directors who are over 70 years of age whose tenure of office is determined in terms of the Companies Act No.7 of 2007, submit themselves for re-election /re-appointment by the shareholders of the Company at the forthcoming Annual General Meeting of the Company.

√

A.8.3 Resignation Refer Appointment, Re-appointment, Re-election and Resignation of the Directors’ of this Report

√

A.9 Appraisal of Board PerformanceA.9.1/A.9.2/

A.9.3/A.9.4

Appraisals of the Board and the sub committees

Refer Board Evaluation of this Report √

A.10 Disclosure of Information in Respect of DirectorsA.10.1 Profiles of the Board of

Directors and other related information

The names of the Directors of the Board and their profiles are given on pages 16 to 18 of the Annual Report 2019/20

√

A.11 Appraisal of Chief Executive OfficerA.11.1/A.11.2 Setting of the annual targets

and the appraisal of the CEOThe performance evaluation of the Chief Executive Officer carried out by the Chairman, in line with the financial and non-financial objectives set out in consultation with the Board at the commencement of each financial year.

√

B. Directors’ RemunerationB.1 Remuneration Procedure

B.1.1 Set up a Remuneration Committee with agreed terms of reference

Refer Directors’ Remuneration on page 112 of the Annual Report 2019/20

The Report of the Remuneration Committee on page 112 of the Annual report 2019/20 gives the composition of the Committee and a description of its activities during the year.

√

B.1.2 Remuneration Committee to consist of Non-Executive Directors only

Refer Remuneration Committee on page 112 of the Annual Report 2019/20

√

B.1.3 List names of Remuneration Committee in Annual Report

Refer Remuneration Committee on page 112 of the Annual Report 2019/20

√





B.1.4 Determination of the remuneration of the Non-Executive Directors

Remuneration of Non-Executive Directors reflects the time commitment and responsibilities of their role. They are remunerated based on their attendance at Board and/or Committee meetings.

No Director is involved in determining his or her own remuneration.

√

B.1.5 Consultation with the Chairman and the Managing Director

The Remuneration Committee consults the Chairman and the CEO on the proposals of the Committee regarding Executive Director remuneration and that of the Corporate Management Team. No Director is involved in determining his/her own remuneration.

√

B.2 The Level & Makeup of RemunerationB.2.1/B.2.2/B.2.3/B.2.4

The level and makeup of the remuneration of Directors and comparison of remuneration with other companies

The Remuneration Committee is responsible for evaluating the performance of the Managing Director, Executive Directors and the individual and collective performance of the Directors and Senior Management. Remuneration packages are structured to attract, retain and motivate them taking into consideration their roles and responsibilities, skills, experience, attributes. The Committee also considers external factors such as cost of living, inflation and industry norms.

√

B.2.5 Performance based remuneration

Performance based remuneration of employees, including Executive Directors and Senior Management, is directly linked to the achievement of agreed targets and goals by the company and the individual .

√

B.2.6 Executive share options As at date, the Company has no share option available to its Directors.

N/A

B.2.7 Designing schemes of performance based remuneration

Refer the Report of the Remuneration Committee on page 112 of the Annual Report 2019/20.

√

B.2.8/B.2.9 Early Termination of Directors

The Remuneration Committee determines the remuneration of Directors in the event of early termination.

√

B.3 Disclosure of RemunerationB.3.1 Disclosure of Remuneration Refer the Report of the Remuneration Committee on page 112

and the Financial Statements on pages 130 to 234 of the Annual Report 2019/20.

√

C. Relations with ShareholdersC.1 Constructive use of AGM and Conduct of MeetingsC.1.1 Dispatch of Notice of

AGM and related papers to shareholders

Notice of Meeting, the Agenda for the Annual General Meeting and the Annual Report are circulated to shareholders within the stipulated time in the Articles of Association and the Code.

√

C.1.2 Separate resolution for substantially separate issues.

Separate resolutions are proposed for substantially separate issues to provide shareholders the opportunity to deal with each significant matter separately.

√

C.1.3 Accurate recording and counting valid proxy appointments received for general meeting

All proxy appointments received are duly recorded and counted in respect of each resolution, where a vote has been taken by a show of hands. In the event the appropriate number of shareholders give their intimation in writing and request for a poll, the procedure involved in voting would be circulated. In the absence of such intimation, all issues at the AGM will be passed by a show of hands.

√

C.1.4 Availability of Chairman of Board Committees at the Annual General Meeting

The Chairmen of the Board Committees are present to answer any queries of the shareholders directed to them by the Chairman of the Company.

√






C.1.5 Summary of Notice of General Meetings and procedures governing voting at General Meetings

In the event the appropriate number of shareholders give their intimation in writing and request for a poll, the procedures involved in voting would be circulated. In the absence of such intimation, all issues at the Annual General Meeting will be passed by a show of hands.

√

C.2 Communications with shareholdersC.2.1 to C.2.7 Communications with

ShareholdersRefer Shareholder Relations of this Report √

C.3 Major & Material TransactionsC.3.1 & C.3.2 Disclosure of Major

TransactionsDuring the financial year there were no major transactions, which materially altered the Company’s net asset base or the consolidated Group’s net assets base.

In the unlikely event that the net assets of the Company fall below half of shareholders’ funds, the shareholders of the Company would be notified and an Extraordinary General Meeting would be called to propose the way forward in terms of the necessary statutory and regulatory requirements.

√

D. Accountability & AuditD.1 Financial ReportingD.1.1 Board’s responsibility in

presenting a balanced Annual Report

Refer Accountability & Audit of this Report. √

D.1.2 Interim and price sensitive reports to public and regulators

In preparing annual and quarterly Financial Statements, the Company complies with the requirements of the: • Companies Act No. 07 of 2007, • Sri Lanka Accounting Standards and • Listing Rules of the Colombo Stock Exchange. The annual and interim Financial Statements were published within the time periods prescribed by the Listing Rules of the Colombo Stock Exchange.

√

D.1.3 CEO/CFO Declaration The Statement of Financial contains a declaration by the Managing Director and the Assistant Vice President - Finance.

√

D.1.4 Directors’ Report declarations

Refer Annual Report of the Board of Directors on pages 117 to 120 of the Annual Report 2019/20.

√

D.1.5 Statements on responsibilities for preparation of financial statements and internal control

Refer the following:

• Statement of Directors’ responsibilities on page 116 of the Annual Report 2019/20

• Statement on Internal Control on page 121 to 122 of the Annual Report 2019/20

√

D.1.6 Management discussion & analysis

Refer Capital Reports on page 58 to 96 which provides a comprehensive management discussion and analysis of the Group’s operations

√

D.1.7 Serious loss of capital In the unlikely event that the net assets of the Company fall below half of shareholders’ funds, the shareholders of the Company would be notified and an Extraordinary General Meeting would be called to propose the way forward.

√

D.1.8 Related Party transactions Refer the following disclosures on Related Party Transactions:

• Relates Party Transactions Review Committee Report – Pages 114 to 115 of the Annual Report 2019/20

• Annual Report of the Board of Directors – Pages 117 to 120 of the Annual Report 2019/20

• Note 49 in the Financial Statements of the Annual Report 2019/20

√





D.2 Risk Management & Internal ControlD.2.1 Monitor, review and report

on financial, operational and compliance risk and internal control systems

The following reports provide details on compliance with these requirements:

• Risk Management Report - page 38 to 43 of the Annual Report 2019/20

• Directors’ Statement on Internal Controls - page 121 to 122 of the Annual Report 2019/20

• Audit Committee Report – page109 to 111 of the Annual Report 2019/20

√

D.2.2 Confirm assessment of the principal risks of the company

√

D.2.3 Internal Audit √D.2.4 Require Audit Committee to

carry out reviews of & Board responsibility for disclosures

√

D.2.5 Compliance with Directors’ responsibilities as set out by the Code

√

D.3 Audit CommitteeD.3.1 Establish an Audit

Committee comprising wholly of Non-Executive Directors of which at least 2 must be independent

Audit Committee comprises 5 Non-Executive Directors of whom 3 are independent. Refer Audit Committee Report on pages 109 to 111 of the Annual Report 2019/20.

√

D.3.2 Written Terms of Reference for Audit Committee

The Audit Committee has a written Terms of Reference which is summarized in the Audit Committee Report on pages 109 to 111 of the Annual Report 2019/20.

√

D.3.3 Disclosures The Audit Committee Report with required disclosures are given on pages 109 to 111 of the Annual Report 2019/20

√

D.4 Related Party Transactions Review CommitteeD.4.1/D.4.2/

D.4.3

Related Party Transactions Review Committee

Refer

• Related Party Transactions Review Committee of this Report

• Report of the Related Party Transactions Review Committee on page 114 to 115 of the Annual report 2019/20

√

D.5 Code of Business Conduct & EthicsD.5.1 Board declaration for

compliance with CodeRefer Code of Ethics and Professional Conduct of this report √

D.5.2 Price sensitive information Material and price sensitive information is promptly disclosed to the CSE by the Company Secretaries.

√

D.5.3 Monitor Share purchase by Directors/ KMPs

Immediate disclosures of Directors pertaining to acquisition/disposal of relevant interest in shares issued by the Company are obtained from the Directors in accordance with Section 200 of the Companies Act No. 7 of 2007 and necessary disclosures are made to the CSE within two marketsdays. Also refer the Related Party Transactions Review Committee Report of the Annual Report 2019/20.

√

D.5.4 Chairman’s statement Refer the Chairman’s Message and The Board of Directors’ Statement on Internal Controls on pages 121 to 122 of the Annual report 2019/20

√






D.6 Corporate Governance disclosuresD.6.1 Corporate Governance

disclosuresRefer this Report √

E. Institutional InvestorsE.1 Institutional InvestorsE.1.1 Institutional investors Aitken Spence Hotel Holdings PLC conducts regular discussions

with Institutional Investors. The Annual Report provides a balanced review of the Group’s performance supporting analysis and objective decision making. Shareholders are provided an opportunity to comment, discuss and seek clarifications on any relevant issue with the Chairman and Board at the AGM, on conclusion of formal proceedings or by prior appointment.

√

E.2 Evaluation of Governance Disclosures

Institutional investors are provided sufficient information to deliberate on matters related to the structure and composition of the Board, facilitating evaluation of the same.

√

F. Other InvestorsF.1 Investing and divesting

decisionThe Company provides sufficient relevant and material financial and non-financial information in its Annual Report to facilitate meaningful analysis and obtaining independent annual advice regarding their investment.

√

F.2 Encouraging shareholder participation

Refer Shareholder Relations of this Report √

G. Internet of things and cybersecurityG.1/G.2/G.3/ G.4/ G.5

Internet of things and cybersecurity

Refer Internet of Things & Cybersecurity of this Report √

H. Environment, Society & GovernanceH Environment, society and

governanceRefer Environment, Society and Governance Reporting (ESG Reporting) of this Report

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corporate governance - aitken spence hotels

Documents