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 2022.

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.


The Group complies with the anti-corruption laws of the countries in which we do business. Our Corporate Code of Conduct sets out the Group policy on conflicts of interest, competition and anti-trust, and bribery. Business units within Swire are required to establish their own Codes of Conduct which include procedures designed to put these general principles into practice.

Our Whistleblowing Policy applies to all 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, via a designated third-party service provider, or to relevant line management or Human Resources with no fear of retaliation.

All new employees take part in induction programmes that include anti-corruption training. Additionally, 100% of our directors completed anti-bribery and anti-corruption training over the past two years. Our operating companies also implement their own anti-corruption training programmes for employees and directors. Their approaches to implementing anti-corruption practices and training are outlined in their respective sustainability reports.

In 2022, there were 29 cases of whistleblowing and three reports of breaches of the Code of Conduct.

All cases have been investigated. As at 31 December 2022, two cases have been resolved and the investigation of one case remains in progress. None of the three breaches of the Code of Conduct in 2022 were 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. During 2022, Swire Pacific did not have any breaches related to Bribery, Business ethics, Competition and antitrust, Conflicts of Interest, Gambling, Health and safety and the environment, Political activities and contributions, or Privacy.

Number of breaches to Code of Conduct Principles 2021 2022
Bribery 3 0
Conflicts of interest 1 0
Diversity and inclusion and respect in the workplace 2 2
Procurement 0 0
Use of information and property 0 1

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.

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