INTRODUCTION... 1 PURPOSE...1 APPLICABILITY...1 BACKGROUND...1 SOCIAL RESPONSIBILITY...1 SUSTAINABLE DEVELOPMENT...1

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 Group s brands but by the way we interact with society at large and the environment around us. PCCW s 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 PCCW s social responsibility objectives and provides guidance on the social responsibilities of all individuals associated with the PCCW Group. PCCW s 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 customer s 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 PCCW s 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. PUBLIC AVAILABILITY November 2008 Page i

TABLE OF CONTENTS Page 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 PUBLIC AVAILABILITY November 2008 Page ii

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 PUBLIC AVAILABILITY November 2008 Page iii

INTRODUCTII ION 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 programmes programmes 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 PCCW s future mission. Meeting the commitment to protect these concerns is a primary senior management objective as 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 Group s 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. PUBLIC AVAILABILITY November 2008 Page 1

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 world s 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 mankind s 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 Group s sustainable development strategy. ABOUT PCCW 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) (b) (c) (d) (e) (f) a commitment to the community; 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; community support through the sponsorship of worthy initiatives in the field of education and IT development programmes; corporate sponsorship in support of innovative and caring community programmes and services for deprived community groups; 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 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. PUBLIC AVAILABILITY November 2008 Page 2

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 Group s 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 Group s 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 Group s 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 Group s employees. The policy includes guidance on obligations to the PCCW Group; civic responsibilities; equal opportunities; PUBLIC AVAILABILITY November 2008 Page 3

safeguarding communications, the PCCW Group s 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) (f) 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 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. SOCIAL RESPONSIBI ILITIES 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) (o) (p) (q) (r) respect internationally recognised conventions and declarations, in addition to the widely recognised instruments derived from them; respect the rule of law; recognise the rights of stakeholders to be heard and of the PCCW Group s responsibility to respond; ensure activities respect, promote and advance internationally recognised principles for organisational governance; and not indulge in any form of corruption, including extortion and bribery. PUBLIC AVAILABILITY November 2008 Page 4

Oversight Through the PCCW Group s 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. ENVIRONMENTAL RESPONSIBI ILITIES 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 PCCW s 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 Group s approach to environmental issues. PUBLIC AVAILABILITY November 2008 Page 5

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. COMMUNITY RESPONSIBI ILITIES 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 Group s 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. PUBLIC AVAILABILITY November 2008 Page 6

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 PCCW s 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. STAKEHOLDER COMMUNICATI ION RESPONSIBI ILITIES 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. PUBLIC AVAILABILITY November 2008 Page 7

Customers The PCCW Group must be responsive where individuals choose to engage one of our many feedback and communication s 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 Group s 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 PCCW s 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. EMPLOYEE MANAGEMENT RESPONSIBI ILITIES Employee development is a significant area impacting PCCW Group s 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; PUBLIC AVAILABILITY November 2008 Page 8

(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. CONTACT POINTS FOR SOCIAL RESPONSIBI ILITY POLICY 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 Page 9

POLICY CHANGES 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 Page 10