貿易通2019 年年報

Tradelink Electronic Commerce Limited Annual Report 2019 44 Corporate Governance Report (Continued) 企業管治報告書 （續） (3) 風險管理及內部監控（續） 根據高級管理人員確認、內部核數師及審 核委員會的審閱，董事會認為於報告年度 內風險管理及內部監控系統屬充分及有 效。二零一九年內未發現重大監控缺陷、 缺點或重大留意範疇。 董事會亦認為本集團在會計、內部審核及 財務匯報職能的資源、僱員資歷及經驗， 培訓課程及有關預算屬足夠。 本集團根據上市規則及香港法例第 571 章 《證券及期貨條例》（「證券及期貨條例」）處 理及發放內幕消息。董事會按照高級管理 人員的建議，確定及釐定若干資料是否需 要根據上市規則及證券及期貨條例披露為 內幕消息。一旦若干信息經確定為內幕消 息，其將在可行情況下儘快以公告方式披 露。 本公司已分別就董事、一般僱員及可能持 續接觸內幕消息的員工買賣本公司股份訂 立內部政策。全體員工及董事於擁有未經 發佈的內幕消息時，均不得買賣本公司證 券。就可能持續接觸到內幕消息的董事及 員工而言，彼等必須獲預先批准方可買賣 本公司證券。 於報告期內，董事及被高級管理人員鑒定 為相關員工已獲知會本公司證券交易禁止 交易期間。所有內幕消息均以公告方式及 時披露。於透過公告方式披露前，內幕消 息會保密，並只向真正需要知道的僱員透 露及交由彼等處理。包含內幕信息的文件 以密碼保護。 此外，每位員工皆須遵守本集團的道德及 行為守則，並預期達到最高道德及專業行 為標準。 (3) Risk Management & Internal Controls (Continued) Based on the confirmation from Senior Management, the reviews from the Internal Auditor and the Audit Committee, the Board considered that the risk management and internal control systems are adequate and effective for the reporting year. There were no significant control failings, weakness or significant areas of concern identified during 2019. The Board also considered the resources, staff qualifications and experience, training programs and budget of the Group’s accounting, internal audit and financial reporting functions were adequate. The Group handled and disseminated inside information in compliance with the Listing Rules and the Securities and Futures Ordinance (Chapter 571 of the Laws of Hong Kong) (“SFO”). The Board, with the recommendation of Senior Management, would identify and determine whether certain information needs to be disclosed as inside information under the Listing Rules and the SFO. Once certain information has been determined as inside information, it would be disclosed as soon as practicable by way of announcements. The Company has in place separate internal policies for dealing in the Company’s shares by Directors, general staff and those staff who are likely to be in constant exposure to inside information. All employees and Directors are not allowed to deal in the securities of the Company when they possess unpublished inside information. Pre-clearance on dealing in the Company’s securities is mandatory for Directors and those staff who are likely to be in constant exposure to inside information. During the reporting period, Directors and relevant employees, as identified by Senior Management, were notified of the periods when dealings in the securities of the Company were prohibited. All inside information was disclosed timely by way of announcements. Before the disclosure of inside information by announcements, it was kept confidential and would only be disclosed to, and handled by, those employees who had a genuine need to know. Documents containing inside information are protected by passwords. In addition, every employee is subject to the Code of Ethics and Conduct of the Group and is expected to achieve the highest ethical and professional standards of behavior.