The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How Roma Group promotes operational integrity

Roma Group is mainly engaged in the provision of valuation and technical advisory services in Hong Kong, offering a diverse range of services that include natural resources valuation and various specialised valuation and consultancy services, from business and intangible assets valuation to work of art valuation. Maintaining the highest level of openness, integrity and accountability is, thus, a top priority.

This case study is based on the 2017/2018 Environmental, Social and Governance Report by Roma Group published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Roma Group does not tolerate any corruption, bribery, extortion or money-laundering  Tweet This! and strictly abides by the Prevention of Bribery Ordinance of Hong Kong, and other local laws and regulations concerning anti-corruption. In order to promote operational integrity Roma Group took action to:
  • implement an internal control mechanism
  • adopt a whistle-blowing policy
  • raise employee awareness of ethics and compliance

What are the material issues the company has identified?

In its 2017/2018 Environmental, Social and Governance Report Roma Group identified a range of material issues, such as customer satisfaction and responsibility, intellectual property protection, customer privacy, employee remuneration and benefit. Among these, promoting operational integrity stands out as a key material issue for Roma Group.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Roma Group engages with:

Stakeholder Group                Method of engagement





·      Channels for employees feedback (form, suggestion box, etc.)

·      Regular performance evaluations

·      Intranet

·      Departmental meeting





·      Customer service function

·      Customer manager

·      Customer meetings and company visits

·      Social media platform

Communities, NGOs and the media


·      ESG report

·      Donation and work with charities

·      Participation in charity events

·      Press conferences and interviews

Government and regulatory bodies ·      Announcements and circulars

·      Regular seminars and trainings



·      Annual general meeting

·      Annual report, interim and quarterly reports

·      Announcements and circulars

Suppliers and consultants


·      Conferences for suppliers and consultants

·      Communication channels with consultants (email, meetings, etc.)

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Roma Group carried out a stakeholder survey among employees, management, investors, suppliers, consultants and customers.

What actions were taken by Roma Group to promote operational integrity?

In its 2017/2018 Environmental, Social and Governance Report Roma Group reports that it took the following actions for promoting operational integrity:

  • Implementing an internal control mechanism
  • Roma Group has in place a strict internal control mechanism and has also established an Audit Committee and an internal audit function. The Audit Committee is directly authorised by the Board to make sure the Group’s financial statements and accounts comply with the requirements of accounting standards, GEM (Growth Enterprise Market) Listing Rules and relevant laws and regulations. In addition, Roma Group implements various policies on conflict of interests which are included in the staff handbook for employees, for them to perform their duties with the highest level of integrity and professional attitude. Employees must report any activities and situations that may lead to conflict of interest to the human resource department and management. Management determines whether such activities constitute a conflict of interest or are appropriate from the Group’s perspective, and provides action guidelines to the employees. Employees failing to report potential conflicts of interests may have to face disciplinary actions.
  • Adopting a whistle-blowing policy
  • Roma Group implements a whistle-blowing policy, to handle and prevent any corruption, conflict of interest, suspected or actual fraud and other misconducts. Whistle-blowers may directly send an email to the chairman of the Audit Committee and use an anonymous email address at their discretion to report incidents. The whistle- blowing channel is also published on the Group’s website. The chairman of the Audit Committee may request to convene Board meetings, to investigate reported incidents. Subsequently, the Board may decide whether to engage external consultants (including but not limited to lawyers and certified public accountants), to handle an incident. The whistle-blowing policy also protects whistle-blowers from unfair treatment, ensuring they will not face unjustified dismissal or disciplinary actions.
  • Raising employee awareness of ethics and compliance
  • Roma Group frequently invites representatives from regulators or professionals to hold lectures on corporate governance for both employees and management, so that they may prevent any potential corruption by learning about the latest cases of corruption pitfall and cases of moral practices in corporate governance. During the reporting period, Roma Group did not identify any material non-compliance with laws and regulations on the prevention of bribery, extortion, fraud and money laundering, nor any concluded legal cases concerning corrupt practices brought against the Group or its employees.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 205-3 Confirmed incidents of corruption and actions taken


 Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption


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1) This case study is based on published information by Roma Group, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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