Complaint about leaflets promoting Hutchison Global Communications Limited s Business Telephone Line Services

Complaint about leaflets promoting Hutchison Global Communications Limited s Business Telephone Line Services Complaint against : Hutchison Global Communications Limited ( HGC ) Issue : The complainant alleged that HGC engaged in misleading conduct by distributing certain leaflets to promote, market and advertise its business telephone line services. Relevant Instruments : Section 7M of the Telecommunications Ordinance (Cap. 106) (the Ordinance ) Case Opened : June 2004 Case Closed : October 2004 Decision : No breach of section 7M of the Ordinance Outcome : Case Closed Case Reference : T111/04 The Complaint 1. The Telecommunications Authority ( TA ) received an industry complaint concerning three leaflets (see Annex 1, 2 and 3) that were allegedly used by HGC salespersons to promote, market and advertise HGC s business telephone line services. 2. Regarding the leaflet with the headline 和 記 環 球 電 訊 固 網 商 業 電 話 線 服 務 推 廣 計 劃 月 費 由 HK$53 起 (in English translation: The monthly service charge under the promotional plan for the business telephone line of HGC s fixed network from HK$53 up ) ( Leaflet A ), the complainant alleged that HGC did not specify the material terms of the promotional offer. The complainant also alleged that HGC unfairly compared its service charges with those of PCCW-HKT Telephone Limited ( PCCW-HKT ) inasmuch as the comparison table therein was not a like for like comparison. 3. Regarding the leaflet with the headline 月 費 低 至 $53 起 / 和 記 環 球 電 訊 固 網 商 業 電 話 線 服 務 /1810 個 月 電 話 費 半 價 (1-9, 16-24) (In English translation: Monthly charge is as low as from $53 up, 1810 months half price discount for the business telephone line services of HGC s fixed network (1-9, 16-24) ) ( Leaflet B ), the complainant alleged that HGC did not specify the material terms and conditions for the promotional offer and that no information was available to substantiate the message conveyed by the headline. Furthermore, for the same reasons noted in relation to the comparison table in Leaflet A, the 1

complainant alleged that HGC unfairly compared its service charges with those of PCCW-HKT as the comparison table therein was not a like for like comparison. 4. Regarding the leaflet with the heading 和 記 環 球 電 訊 商 業 電 話 線 服 務 4 重 優 惠 (In English translation: Four multiple discount offer for HGC s business telephone line services ) ( Leaflet C ), the complainant alleged that there is no asterisk or any other symbol in the headline referring readers to other terms and conditions in the leaflet, and that the message conveyed by the headline cannot be substantiated. According to the complainant, most of the material terms were missing in the leaflet. The complainant further alleged that the comparison table therein is not a like for like comparison. 5. The grounds for the complainant s allegations can be summarised as follows : Leaflet A 6. The comparison table in Leaflet A purports to specify the discount rates of HGC s business telephone line services. The complainant alleged that the material terms of the relevant offer are not specified. These terms include the requirement to enter into a fixed-term contract, the existence of an early termination penalty, the applicable period for the discount rates and the service charge payable for the months during which the offered discount is not applicable. 7. The complainant further alleged that the comparison table does not reflect a like for like comparison because HGC has not taken into account certain promotional offers by PCCW-HKT in its business line services. There is also no information on the source of PCCW-HKT s quoted tariffs or the applicable period of HGC s special rates. Leaflet B 8. According to the headline of Leaflet B, the monthly service charge for a business telephone line is as low as $53 with a half price discount for 18 months. The complainant alleged that no explanatory terms or conditions are provided in relation to this offer. The only reference to the rate of $53 in the leaflet is in the form of some of the discounted rates shown in the comparison table. The 2

material terms in relation to this discount offer are not specified in the leaflet. Moreover, the only relevant information found in the leaflet is the manuscript text at the top right-handed corner stating 1 年 生 約 (In English translation: One-year open contract ). The complainant alleged that in the likely event that customers are required to subscribe to a fixed-term contract in order to enjoy the specified discount rates, the headline together with the manuscript text without any explanatory notes or specified material terms, render the leaflet misleading. 9. On the same basis as for Leaflet A, the complainant alleged that the comparison table in the subject leaflet is not a like for like comparison. Leaflet C 10. The headline of Leaflet C is followed by four items: 1 商 業 電 話 線 月 費 低 至 $25.8 2 送 來 電 轉 駁, 來 電 顯 示 等 多 功 能 服 務 3 送 400 分 鐘 IDD 致 電 全 中 國 4 成 功 登 記 即 送 來 電 顯 示 電 話 機 (In English translation: 1. The monthly service charge for business telephone line is as low as $25.8 2. Free value-added services including call forwarding and caller display 3. Free IDD for 400 minutes for calling to the whole of Mainland China 4. Free telephone set with caller display upon successful registration ) 11. The complainant alleged that the principal message conveyed by these items is that the standard monthly service charge for a business telephone line is as low as $25.8. This message is allegedly reinforced by the statement in the square box on the top right-handed corner of the leaflet which states 商 業 電 話 線 月 費 $25.8 (in English translation: Monthly service charge for business telephone line at $25.8 ). However, as indicated in the fine print immediately below the table, the offer is only applicable for 6 months and subscribers are required to sign a fixed-term contract for 12 months. Accordingly, the complainant alleged that the message conveyed by the headline is misleading. Moreover, the complainant alleged that the omission of an asterisk or any other symbol in the headline or the above four items to refer the readers to the fine print below the table renders the headline misleading. 3

12. The complainant further alleged that the following material terms are not specified in the leaflet: (a) the applicable early termination penalty; (b) the restriction on free IDD calls for 400 minutes to the whole of Mainland China; and (c) the service charge payable for the months during which the offered discount is not applicable. 13. The complainant also alleged that the tariffs quoted under the column 一 般 電 訊 公 司 收 費 (In English translation: Charges by other operators ) include the standard rates of PCCW-HKT only, not those of the other operators. Accordingly, the quotation of these tariffs in this context is misleading. Also, based on the same grounds as in Leaflet A, the complainant states that the comparison table is not a like for like comparison. 14. In view of the above points, the complainant alleged that the three promotional leaflets are misleading or deceptive and in breach of section 7M of the Ordinance. TA investigations 15. On the information available to it, the TA was concerned whether the distribution of the subject leaflets constituted a breach of section 7M of the Ordinance, which requires : A licensee shall not engage in conduct which, in the opinion of the Authority, is misleading or deceptive in providing or acquiring telecommunications networks, systems, installations, customer equipment or services including (but not limited to) promoting, marketing or advertising the network, system, installation, customer equipment or service. 16. In order for the TA to investigate any possible breach of section 7M, staff of the Office of the Telecommunications Authority ( OFTA ) requested HGC to provide detailed information concerning the promotional leaflets. HGC was also invited to make any other representations on the complaint it wished to make. HGC s Response 4

Leaflet A 17. HGC stated that Leaflet A does not follow the templates used to promote its business voice services. The salesperson, a Mr. Chan, whose name card appeared at the bottom right-handed corner of the leaflet ( Leaflet Name Card ), was employed by HGC as an account executive from 22 January to 11 July 2003 (the first employment ). He then left and re-joined HGC on 5 February 2004 as Account Manager (the second employment ). 18. HGC produced copies of two of Mr. Chan s name cards, as used by him during his first employment and his second employment. HGC stated that the office telephone number in the Leaflet Name Card is the telephone number used by Mr. Chan in his first employment. The fax number in the Leaflet Name Card was never assigned to him during either his first employment or his second employment. In fact, the subscription to the subject fax number by HGC was terminated on 5 November 2003. The title of Mr. Chan in the Leaflet Name Card was also incorrect. 19. Mr. Chan strongly denied that he had ever prepared or distributed Leaflet A. He informed HGC that he never distributed any leaflets to promote HGC s business voice services. Instead, he conducted his sales activities by visiting customers on site. 20. HGC further stated that Leaflet A could not have been prepared and distributed by Mr. Chan. The promotional offer mentioned in Leaflet A started on 18 August 2003 and finished on 31 July 2004. Since Mr. Chan left HGC on 11 July 2003, it was not possible for him to have sent out the leaflet during his first employment. After he rejoined HGC, Mr. Chan was a sub-team leader and earned override commission from his sub-ordinates instead of earning direct commission from front-line selling. Hence, there was no reason for him to undertake front-line sales activities himself. HGC further stated that there was no reason for Mr. Chan to use a fax number not assigned to him. HGC produced a statement from Mr. Chan in support of the above claims. 21. HGC further stated that Mr. Chan had not generated any sales in relation to the promotional offer mentioned in Leaflet A, which he claims he did not prepare or distribute. 5

22. HGC also confirmed that every standard promotional leaflet used by HGC s marketing team must be approved by its Sales Department and Legal Department. Its salespersons and sales agents are all instructed not to change the format of approved leaflets. Any salesperson or sales agent in breach of this policy will be subject to disciplinary actions. Leaflet B 23. HGC stated that Leaflet B was distributed around March to April 2004 and about 30 to 40 copies were distributed. 24. According to HGC, the subject salesperson, Ms. Yeung, would only send the leaflet to those customers whom she had initially contacted by telephone. She would explain the details of the offer to those customers over the phone, and in doing so would explain the services available, the contract period, the promotional price, the early termination penalty and other details. If customers were interested in the offer, Ms. Yeung would ask for their fax number and write down their names next to the words 致 : 尊 貴 客 戶 (in English translation: To: Privilege customer ). She would then fax the leaflet to those customers. In the event that a customer was interested to sign a contract after receiving the leaflet, Ms. Yeung would provide them with a detailed contract and explain to them its terms before signing. 25. HGC stated that the copy of Leaflet B submitted by the complainant to OFTA had been modified by removing the customer s name written by Ms. Yeung next to the words 致 : 尊 貴 客 戶 (in English translation: To: Privilege customer ). In this respect, HGC specifically drew the TA s attention to marks appearing above the words slowing down of economy in the first line of the main text of the sample leaflet. Leaflet C 26. HGC stated that it had difficulties locating Mr. Cheung, whose name appeared in Leaflet C. When HGC succeeded in calling the mobile phone number that appeared in the leaflet, it discovered that the surname of the person answering the phone was not Cheung. The person that answered was a salesperson that worked for an independent contractor, with which HGC had intended to enter 6

into a sales arrangement. HGC hired the services of this contractor on a trial basis without entering into any formal agency agreement. 27. According to HGC, the sales agent denied ever having a staff member called Mr. Cheung with the mobile phone number that appeared in the leaflet. The sales agent admitted that one of its staff does have that mobile phone number, but his name is not Mr. Cheung. HGC therefore submitted that Leaflet C had not been distributed by HGC or with HGC s authority. 28. HGC further stated that in view of the seriousness of this event, HGC had as a precautionary measure terminated the trial arrangement with the sales agent. TA s Findings Leaflet A 29. The TA notes that the complainant is unable to produce the original of Leaflet A or any evidence proving how, where or in what quantities it was allegedly distributed. The complainant claimed that it had obtained a faxed copy of the leaflet from customers trying to use it to negotiate better prices. 30. The TA accepts that the telephone number in the Leaflet Name Card is the previous telephone number used by Mr. Chan during his first employment. Despite claiming that the fax number shown had never been assigned to Mr. Chan, HGC confirmed that it did subscribe to the number and only terminated this subscription on 5 November 2003. The mobile phone number in the Leaflet is the mobile phone number used by Mr. Chan during his second employment. 31. The TA further notes that the promotional offer mentioned in the leaflet started from 18 August 2003 and was still available at the time that Mr. Chan rejoined HGC. 32. Taking into account the significance of the dates mentioned in paragraphs 30 and 31, the TA considers it unlikely that Mr. Chan had prepared and distributed Leaflet A. The promotional offer in question started on 18 August 2003, at which time Mr. Chan had already terminated his first employment for over one month. It is therefore difficult to assert that he may have prepared and 7

distributed a promotional leaflet to promote a service which would only be available after he left his employment and in relation to which he would not receive any commission on any sales. Moreover, the TA accepts that it would be impossible for Mr. Chan to anticipate his new mobile phone number, to which he had not subscribed at the material time, and to use it as one of his contact numbers under Leaflet A, assuming that Leaflet A could somehow have been distributed during the period of his first employment. 33. Presumably the leaflet was distributed at the time of Mr. Chan s second employment. In this scenario, it is difficult to explain why Mr. Chan would use his previous office number, which was no longer assigned to him by HGC, as one of his contact numbers. Moreover, it is nonsensical that he would use an obsolete fax number as part of his contact details. The TA accepts the explanation in Mr. Chan s statement that he had no incentive to distribute any promotional leaflets to promote HGC s business in his second employment given his entitlement to override commission via his sub-ordinates. 34. Taking into consideration that there is no evidence to prove the distribution of the subject leaflet by HGC or by Mr. Chan and noting the unexplained peculiarities found in the Leaflet Name Card, the TA cannot conclude, on the balance of probabilities, that the subject salesperson had distributed the leaflet or that any other HGC representative had done so. 35. It cannot be ruled out, for instance, that a customer or third party prepared the subject leaflet with the intention of using it as a bargaining device. By peppering the document with the name of an HGC representative and actual contact details, the apparent veracity of the document might pass a casual or even a more detailed assessment by a competing operator. 36. For completeness, it is noted that Leaflet A is deficient in several respects and that HGC did not contend otherwise. Had there been evidence that HGC could in some way have been held liable for the production and/or distribution of this document, it would be likely that a breach of the law would have been found. As it is, given the TA s powers only to investigate the practices of telecommunications licensees in cases of this kind, it is not possible to determine conclusively the actual facts behind this particular matter. Leaflet B 8

37. The TA notes that there is handwriting on Leaflet B and that some marks appear above the words slowing down of economy on the first line of the main text of the leaflet. This handwriting indicates modification of the information in the original printed version of the leaflet by someone. It also seems that some words right above the words 致 : 尊 貴 客 戶 (in English translation: To: Privilege customer ) had been covered before the leaflet was submitted to OFTA. 38. Based on the detailed description of the practices of the subject salesperson in this case, the TA accepts, on the balance of probabilities, that the salesperson would only fax the leaflet to those specific customers after she had spoken to them on the telephone. Accordingly, the TA views the leaflet as supplemental information, instead of promotional material in the usual sense. 39. The TA has carefully considered the nature of the telephone calls made by the subject salesperson and concludes that it is likely that all of the alleged deficiencies in Leaflet B were consistently and adequately addressed in these calls. In the particular circumstances of this case both the calls and the subsequent, targeted distribution of the subject leaflet constituted an interdependent communication of information. Had the leaflet been the first element of this communication, the TA would have been much more concerned given its previously stated view that misleading or deceptive promotional material cannot be cured by subsequent follow-up action by sales or hotline staff. 40. In other words, the target audience of Leaflet B were unlikely to have been misled by its contents given the prior information provided by the subject salesperson. The same leaflet distributed to another audience would not be viewed in the same way under section 7M. 41. Accordingly, the TA does not consider there to be sufficient basis on the information provided to conclude that a breach of section 7M occurred as a result of the distribution of Leaflet B. Leaflet C 42. As with Leaflet A, the TA observes that the complainant is unable to produce the original of Leaflet C or any evidence proving its distribution. The complainant 9

claimed that it obtained a faxed copy of this leaflet from customers trying to use it to negotiate better prices. 43. The TA notes that the existence of a signed contract between HGC and the subject sales agent in relation to the sales arrangement for HGC s services is not a pre-condition to finding HGC liable for the distribution of a misleading or deceptive leaflet. Even for an informal trial arrangement, HGC may be held liable for the conduct of the salesperson employed by the sales agent when acting within HGC s authority. 44. The TA notes in the present case, however, that there is insufficient evidence to prove the distribution of the subject leaflet by HGC or with its authority. First, the TA notes that it has not been possible to identify, let alone find, the salesperson named on Leaflet C. At most, the information available can prove that there was a salesperson with the same mobile phone number employed by the sales agent concerned. Secondly, the TA cannot find any evidence to prove that any salesperson had prepared the subject leaflet. Unfortunately, the complainant is unable to produce any evidence in relation to this issue and the TA s powers to compel further evidence from non-licensees is limited. As with Leaflet A, the TA must find that there is insufficient evidence to prove a breach of section 7M over a promotional leaflet which on its face is misleading or deceptive. 45. Had there been any evidence that a salesperson was using aliases in their promotional activities, then the TA would be very concerned if the result of this was to evade prosecution under section 7M. Where an agent works for a number of telecommunications operators at the one time, the use of several different names can assist them to identify which operator s offer a caller may be inquiring about. There was no evidence to indicate such a practice in this case, and in any event the key evidentiary issue was proving the actual distribution of the leaflet. HGC was unable to confirm this issue and the TA could not compel anyone else to confirm it. 46. Accordingly, the TA is of the view that there is insufficient evidence to establish the present complaint against HGC. Conclusion 10

47. Based on the above findings and taking into consideration all the circumstances and facts of the above cases, the TA does not consider the complaints against HGC to be established under section 7M of the Ordinance. 48. The TA does, however, wish to record its concern in relation to the circumstances surrounding Leaflets A and C. While technically there can be found no breach of the law in either case, the facts identified during our investigations were not expected and are likely to lead HGC to investigate possible ways of avoiding similar incidents in the future. In this latter regard, the TA notes the high degree of cooperation that HGC demonstrated during this investigation and the seriousness it placed on trying to get to the bottom of the facts in each case. 49. The case concerning Leaflet B is more straightforward in one sense, but in another it relies heavily on the degree of detail the TA accepts was given by the subject salesperson to customers prior to them receiving their personally addressed leaflet. While the TA does not wish to influence the general marketing strategies of any licensee, it would observe that some practices involve higher risks than others in terms of verifiable legal compliance. In this regard, it would have been preferable for all concerned if Leaflet B was in itself complete in all material particulars so that no complaint could be made against it in the first place. 50. Lastly, the TA notes the lack of evidence provided by the complainant in the above cases. While sufficient in itself to justify the initial investigation undertaken by OFTA staff, this lack of evidence turned out to be a critical deficiency in the TA s attempts to establish the above cases one way or the other. This was not necessarily the fault of the complainant. Nevertheless, it demonstrates the importance of complainants as information sources in fact-intensive investigations of this kind. TA s Action 51. The TA does not consider the complaint established. This case is therefore closed. 11

(HGC s Logo) Hutchison Global Communications 和 記 環 球 電 訊 Annex 1 - Leaflet A 和 記 環 球 電 訊 固 網 商 業 電 話 線 服 務 推 廣 計 劃 月 費 由 HK$53 起 在 現 香 港 經 濟 發 展 放 緩, 要 節 省 開 支 同 時 又 要 提 高 質 素 及 競 爭 能 力, 是 各 行 各 業 之 首 要, 現 和 記 環 球 電 訊 特 別 為 貴 商 戶 提 供 一 系 列 電 話 費 之 優 惠 計 劃 今 優 惠 內 容 : 1. 為 貴 商 戶 保 留 原 有 之 商 用 電 話 號 碼 2. 貴 商 戶 不 用 繳 付 任 可 按 金 接 駁 費 或 手 續 費 3. 貴 商 戶 無 須 更 換 原 用 之 電 話 系 統 4. 如 新 客 戶 一 律 免 安 裝 費 5. 可 代 貴 商 戶 免 費 電 話 線 搬 遷 6. 提 供 低 廉 而 高 質 素 之 直 撥 長 途 電 話 服 務 7. 每 月 統 一 發 單, 無 須 預 繳 未 用 之 月 費 服 務 Service PCCW 香 港 電 訊 和 記 環 球 電 訊 節 省 商 業 直 線 - Business Direct Line $ 128.80 $ 53.00 $75.80 傳 真 線 - Fax Line $ 168.80 $ 53.00 $115.80 自 動 跳 線 - Hunting Line $ 148.00 $ 58.00 $90.00 城 訊 通 Centrex/Citinet $ 152.00 $ 59.00 $93.00 商 業 電 文 線 - Business Datel Line $ 137.80 $ 58.00 $79.80 ** 還 有 其 它 先 進 話 音 功 能 不 能 盡 錄, 歡 迎 查 詢 申 請 手 續 簡 易, 無 須 費 用 : 只 要 付 上 貴 商 戶 商 業 登 記 証 及 近 期 電 話 費 單 之 副 本, 本 公 司 會 代 辨 所 有 登 記 手 續 如 有 任 可 查 詢, 請 致 電 : Contact Person: XXX Chan Mobile Number: XXXX 12 HGC Hutchison Global Communications Hutchison Global Communications Limited 4/F, Somerset House Taikoo Place 979 King s Road Quarry Bay, Hong Kong xxx Chan Account Executive Business Market Tel +852 xxxxxxxx Fax +852 xxxxxxxx Mobile +852 xxxxxxx xxxchy@hgc.com.hk

(In English translation) (HGC s Logo) Hutchison Global Communications Hutchison Global Communications The monthly service charge under the promotional plan for the business telephone line of HGC s fixed network from HK$53 At present, the development of HK economy is slow. It is the prime concern of every industry to enhance the quality and its competitiveness at minimum expenses. Now, HGC specially offers to you a series of discount plans for telephone service charges. Discount: 1. Retain existing business telephone numbers 2. No deposit, connection fee or handling fee 3. Do not require to change the existing telephone system 4. No installation charge for new customer 5. No charge for any relocation 6. Provide non-expensive high quality IDD service 7. Single monthly billing and no need to prepay any charge Service PCCW HGC Save Business Direct Line $ 128.80 $ 53.00 $75.80 Fax Line $ 168.80 $ 53.00 $115.80 Hunting Line $ 148.00 $ 58.00 $90.00 Centrex/Citinet $ 152.00 $ 59.00 $93.00 Business Datel Line $ 137.80 $ 58.00 $79.80 **Still have other advanced voice value-added functions, welcome for inquiry Simple application procedures,no charge: Just submit your business registration certificate and copy of recent telephone bill, we will do all the registration procedures for you. For inquiry, please call: Contact Person: xxx Chan Mobile Number: XXXX 13 HGC Hutchison Global Communications Hutchison Global Communications Limited 4/F, Somerset House Taikoo Place 979 King s Road Quarry Bay, Hong Kong xxx Chan Account Executive Business Market Tel +852 xxxxxxxx Fax +852 xxxxxxxx Mobile +852 xxxxxxxx xxxchy@hgc.com.hk

(HGC s logo) Hutchison Global Communications 和 記 環 球 電 訊 Annex 2 - Leaflet B 1 年 生 約 (in handwriting) 月 費 低 至 $53 起 和 記 環 球 電 訊 固 網 商 業 電 話 線 服 務 18 10 個 月 電 話 費 半 價 (1~9, 16~24) 致 : 尊 貴 客 戶 In view of the slowing down of economy, most of the companies look for cost reduction while selecting the high quality and comprehensive service in order to maintain competitiveness, Therefore, Hutchison Global Communications offers the following saving scheme for selective commercial customers. 在 現 今 香 港 經 濟 發 展 放 緩, 要 節 省 開 支 同 時 又 要 提 高 質 素 及 競 爭 能 力, 是 各 行 各 業 之 首 要, 現 和 記 環 球 電 訊 特 別 為 貴 商 戶 提 供 一 系 列 電 話 費 之 優 惠 計 劃 優 惠 內 容 : 1. Maintain existing telephone numbers 為 貴 商 戶 保 留 原 有 之 商 用 電 話 號 碼 2. No Deposit or any Handling Fee 貴 商 戶 不 用 繳 付 任 可 按 金 接 駁 費 或 手 續 費 3. Maintain existing telephone system 貴 商 戶 無 須 更 換 原 用 之 電 話 系 統 4. No Installation Charge for New Customer 如 新 客 戶 一 律 免 安 裝 費 5. No Installation Charge for any Relocation 可 代 貴 商 戶 免 費 電 話 線 搬 遷 6. Provide in-expensive high-quality IDD services 提 供 低 廉 而 高 質 素 之 直 撥 長 途 電 話 服 務 7. Monthly billing ; no need to prepay any charge 每 月 統 一 發 單, 無 須 預 繳 未 用 之 月 費 服 務 Service PCCW 香 港 電 訊 和 記 環 球 電 訊 推 廣 價 商 業 直 線 Business Direct Line $ 128.80 $ 106.00 $53 商 業 直 線 + 飛 線 / 電 話 待 接 $ 144.80 $ 106.00 $53 傳 真 線 Faxline $ 168.80 $ 106.00 $53 自 動 跳 線 - Hunting Line $ 148.00 $ 106.00 $58 自 動 跳 線 + 飛 線 $ 159.00 $ 106.00 $58 城 訊 通 - Centrex/Citinet $ 152.00 $ 108.00 $54 商 業 電 文 線 - Business Datel $ 137.80 $ 106.00 $58 Just to give us a copy of Business Registration Certificate and latest telephone bill, we shall arrange all necessary process for your company, 申 請 手 續 簡 易, 無 須 費 用 : 只 要 付 上 貴 商 戶 之 商 業 登 記 証 之 副 本 及 近 期 電 話 費 單, 本 公 司 會 代 辨 所 有 登 記 手 續 Feel free to contact xxxx Yeung for more details 如 有 任 何 查 詢, 請 致 電 聯 絡 楊 小 姐 Tel: xxx Fax: xxx 和 記 環 球 電 訊 優 惠 月 費 低 至 $53 14

(In English translation) (HGC s logo) Hutchison Global Communications Hutchison Global Communications 1 year open contract (in handwriting) Monthly charge is as low as from $53, 18 10 months half price discount for the business telephone line services of HGC s fixed network (1-9, 16-24) To : Privilege customer In view of the slowing down of economy, most of the companies look for cost reduction while selecting the high quality and comprehensive service in order to maintain competitiveness, Therefore, Hutchison Global Communications offers the following saving scheme for selective commercial customers. (in Chinese version) Discount:: 1. Maintain existing telephone numbers (in Chinese version) 2. No Deposit or any Handling Fee (in Chinese version) 3. Maintain existing telephone system (in Chinese version) 4. No Installation Charge for New Customer (in Chinese version) 5. No Installation Charge for any Relocation (in Chinese version) 6. Provide in-expensive high-quality IDD services (in Chinese version) 7. Monthly billing ; no need to prepay any charge (in Chinese version) Service PCCW HGC Promotional Price Business Direct Line $ 128.80 $ 106.00 $53 Business Direct Line + Call $ 144.80 $ 106.00 $53 Forwarding/Call Waiting Faxline $ 168.80 $ 106.00 $53 HGC s discount monthly charge Hunting Line $ 148.00 $ 106.00 $58 as low as $53 Hunting Line + Call Forwarding $ 159.00 $ 106.00 $58 Centrex/Citinet $ 152.00 $ 108.00 $54 Business Datel $ 137.80 $ 106.00 $58 Just to give us a copy of Business Registration Certificate and latest telephone bill, we shall arrange all necessary process for your company. Simple application procedure, no charge: Just submit your business registration certificate and copy of recent telephone bill, we will do all the registration procedures for you. Feel free to contact xxx Yeung for more details (in Chinese version) Tel: xxx Fax: xxx 15

(HGC s logo) 和 記 環 球 電 訊 和 記 環 球 電 訊 商 業 電 話 線 TO: ADMIN MANAGER 優 惠 期 至 2 月 15 日 Annex 3 - Leaflet C 商 業 電 話 線 月 費 $25.8 和 記 環 球 電 訊 商 業 電 話 線 服 務 4 重 優 惠 只 需 在 2 月 15 日 前 申 請 商 業 電 話 服 務, 便 可 享 有 以 下 4 項 至 激 優 惠, 優 惠 期 有 限, 請 即 行 動 1 商 業 電 話 線 月 費 低 至 $ 25.8 2 送 來 電 轉 駁, 來 電 顯 示 等 多 功 能 服 務 3 送 400 分 鐘 IDD 致 電 全 中 國 4 成 功 登 記 即 送 來 電 顯 示 電 話 機 服 務 -Service 一 般 電 訊 公 司 收 費 和 記 環 球 電 訊 商 業 直 線 Business Direct Line $ 128.80 $ 25.8 傳 真 線 Faxline $ 168.80 $ 27.6 自 動 跳 線 Hunting Line $ 148.00 $ 29.6 城 訊 通 Centrex/Citinet $ 152.00 $30.4 1) 6 個 月 商 業 電 話 線 優 惠, (1 至 3, 13 至 15 個 月 ) 2) 以 上 服 務 計 劃 需 簽 12 個 月 合 約 正 價 月 費 : 商 業 直 線 :$106, 傳 真 線 :$106, 自 動 跳 線 :$118, 城 訊 通 電 話 線 :$118! 豁 免 新 線 安 裝 費 用 及 搬 遷 電 話 線 費 用! 光 纖 接 入, 質 素 保 證! 保 留 原 有 號 碼, 無 須 上 門 駁 線 及 更 換 電 話 系 統! 登 記 手 續 簡 便, 無 須 任 何 費 用 及 預 繳 只 需 附 上 1) 商 業 登 記 副 本 及 2) 電 話 線 月 費 賬 單, 傳 真 到 FAX: xxxx 即 可 登 記 登 記 請 致 電 張 先 生 : TEL: xxxx 公 司 名 稱 : 聯 絡 人 姓 名 : 地 址 : 聯 絡 電 話 : 如 欲 取 消 本 公 司 傳 真 推 廣, 請 以 傳 真 方 式 (Fax: xxx) 與 我 們 聯 絡, 以 便 日 後 停 止 傳 送 取 消 傳 真 號 碼 : 16

(In English translation) (HGC s logo) Hutchison Global Communications Monthly charge for Business Telephone Line $25.8 HGC s business telephone line TO: ADMIN MANAGER Promotional Period to 15/2 Four multiple discount offer for HGC s business telephone line services Only require to apply before 15/2 for business telephone line, you will enjoy the following 4 super discounts. Limited promotional period, act now 1. The monthly service charge for business telephone line is as low as $25.8 2. Free value-added services including call forwarding and caller display 3. Free IDD for 400 minutes for calling to the whole of Mainland China 4. Free telephone set with caller display upon successful registration Service Charge of other operators HGC Business Direct Line $ 128.80 $ 25.8 Faxline $ 168.80 $ 27.6 Hunting Line $ 148.00 $ 29.6 Centrex/Citinet $ 152.00 $30.4 1) 6-month discount for business telephone line, (1 to 3, 13 to 15 months) 2) an requirement to enter into 12-month contract for the above promotional plans Standard monthly charges: Business Direct Line $106, Faxline $106, Hunting Line $118, Centrex/Citinet $118! Waive installation charge for new line and relocation of telephone line! Fiber Optic connection, warranted quality! Retain the original numbers, no need to re-connection or change telephone system! Simple registration procedure, no prepay or any other charge Just submit 1) copy of business registration certificate and 2) monthly telephone bill, fax to xxxx for registration For registration, please call Mr. Cheung: TEL: xxxx Company Name: Name of Contact Person: Address: Contact No.: If do not want to receive the promotional leaflets from this company, please contact us by fax (Fax: xxx) and we will stop delivering the message to you. Cancellation Fax No.: 17