We conduct our affairs in accordance with high ethical standards and our values of integrity, endeavour, excellence, humility, teamwork and continuity.
We must act with probity, transparency and accountability in order to achieve our long-term objectives. Doing this will maximise long-term shareholder value and benefit employees, those with whom we do business and the communities in which we operate. Our core principles include a commitment to sustainable development.
Our approach to corporate governance can be found in our Corporate Governance Code, our Memorandum and Articles of Association, our Board Diversity Policy and the Swire Pacific Annual Report 2021.
We are subject to the Corporate Governance Code in Appendix 14 to The Rules Governing the Listing of Securities on The Stock Exchange of Hong Kong Limited (Hong Kong Listing Rules).
For details of our governance of sustainability matters, see Our Approach to Sustainable Development.
Our Corporate Code of Conduct requires employees to maintain the highest standards of business ethics and to deal appropriately with each other, those with whom we do business, and the communities in which we operate. The Code of Conduct includes operating principles covering business ethics, conflicts of interest, bribery, procurement, record keeping, whistleblowing, health and safety, the environment, equal opportunities, diversity and respect in the workplace and privacy.
Our representatives in joint venture and associated companies and contractors who are hired to conduct business on our behalf are expected to act in accordance with the Code of Conduct, and influence those with whom they are working with to follow similar standards of integrity and ethical behaviour.
The Code of Conduct and anti-bribery training is included in the induction programme of all employees. Our conditions of employment require compliance with the Code of Conduct.
We have policies and procedures for employees and others who deal with us to raise concerns about suspected or report actual improprieties including potential misconduct, malpractice or unethical behaviour. Confidential reports can be made to the Group Internal Audit Department or via a designated third-party service provider.
In 2021, there were six reports regarding breaches of the Code of Conduct. While there were 24 cases of whistleblowing, there were no convicted cases of corruption. All cases have been investigated and resolved. None of the six breaches of the Code of Conduct in 2021 was material to the Group’s financial statements or overall operations.
The number of breaches to specific principles within the Code of Conduct is shown below. Between 2020 and 2021, Swire Pacific did not have any breaches related to Business ethics, Competition and antitrust, Bribery, Political activities and contributions, Gambling, Health and safety and the environment.
|Code of Conduct Principles||2020||2021|
|Conflicts of interest||2||1|
|Diversity and inclusion and respect in the workplace||0||2|
We operate in different jurisdictions with different legal and regulatory requirements. It is our policy to comply in full with all applicable laws and regulations, including those governing the environment, employment (including laws prohibiting child or forced labour), health and safety, products (including their advertising and labelling), bribery, privacy and discrimination. We have policies, codes, guidelines and practices in place to ensure that the Company and its subsidiaries comply with all applicable laws and regulations. Emerging regulations are closely monitored to ensure we are prepared for any changes.
The Audit Committee is responsible for reviewing the Code of Conduct and Swire Pacific’s compliance with the Corporate Governance Code set forth in the Hong Kong Listing Rules.
We have reviewed laws and regulations relating to sustainability to identify those where significant investment or expenditure would be required to ensure compliance. We have concluded that there are no such individual laws or regulations which currently have a material impact on the Group.
Swire Pacific, as a normal business activity, will lobby government entities either directly or through trade associations to promote policies that encourage business and achieve workable legislation. All our public policy work must meet the ethical standards set out in our Code of Conduct and (where relevant) reflect our public sustainability commitments.