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 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 2023.

We are subject to the Corporate Governance Code in Appendix C2 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 privacy1.

Our representatives in joint venture, partners, 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 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.

1. Harassment is included under the principle of Diversity and inclusion and respect in the workplace and our Respect in the Workplace Policy.

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 Code of Conduct which include procedures designed to put these general principles into practice.

Our Whistleblowing Policy applies to all employees and to business partners such as suppliers, contractors, agents and other third parties who deal with us to raise concerns about suspected improprieties, 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 were provided anti-bribery and anti-corruption training materials 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.

We report on breaches of all areas of our Code of Conduct for the year under review if they are proven to have occurred. In 2023, there were 59 cases of whistleblowing and five reports of breaches of the Code of Conduct.

Number of breaches to Code of Conduct Principles 2023
Conflicts of interest 1
Procurement 1
Use of information and property 3

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.