Corporate Code of Conduct
HKEX KPI B7.2
Our Corporate Code of Conduct (“the Code”) applies to every employee, officer and director of the Company and its subsidiaries. It sets out the operating principles underpinning our management approaches to a range of issues, including:
- Business ethics
- Conflicts of interest
- Competition and antitrust
- Political contributions
- Record keeping
- Use of Company information and property
- Health and safety
- Equal opportunities and diversity
- Use of social media
Under the Code, all our employees have a responsibility to report concerns about any suspected or actual improprieties relating to the Company and/or its subsidiaries. Employees found to be in breach of the Code will be subject to disciplinary action. In 2020, there were no reported cases regarding breaches of the Code.
Our Whistleblowing Policy sets out our policy on whistleblowing, including the protection of whistleblowers from reprisal or disadvantage.
If an employee wishes to report concerns, they are to contact either our human resources and administration department, their immediate supervisor, the Swire Group Internal Audit Department (“GIAD”) or make a report through our whistleblowing platform hosted by a third-party service provider, which includes a 24-hour hotline service. Third parties who deal with Swire Properties, such as customers and suppliers, are also encouraged to report their concerns either directly to GIAD or via the whistleblowing platform. Anonymous reports may be submitted.
We also ensure that our contractors are aware of our Whistleblowing Policy and the different reporting platforms that are available to them.
In 2020, we received a total of six whistleblowing reports. All cases were related to operational issues and they have been evaluated and fully resolved.
We are committed to the fair treatment of any person who makes a genuine and appropriate report. In addition to making every effort to keep the identity of whistleblowers confidential, all reported information is treated in confidence, except where Swire Properties is required by law or regulation to disclose it, for legal or audit purposes, or where Swire Properties refers the matter to the relevant regulators or law enforcement authorities.
HKEX Aspect B7, KPI B7.1, B7.2, B7.3
We have a strict policy of compliance with anti-bribery laws in every applicable jurisdiction. Our employees are not permitted to offer or accept advantages for the purpose of influencing business decisions, to make any form of payment to officials, or to grant, guarantee or accept loans from any person or organisation with whom we have business dealings.
To avoid the perception of improper conduct, our employees are expected to exercise caution when making or soliciting contributions to charitable causes and when providing entertainment and corporate hospitality or reimbursing bona fide expenses for legitimate business purposes. In 2020, there were no concluded legal cases regarding corrupt practices brought against the Company or its employees.
Our employees in Hong Kong, the Chinese mainland, Singapore and Jakarta are required to confirm on an annual basis that they have read and have agreed to be bound by the Code, which includes our anti-bribery practices. It is compulsory for our employees in Hong Kong and the Chinese mainland (including those who have been seconded to other offices) to receive an anti-bribery refresher training at least once every two years.
In 2020, approximately 5,300 hours of anti-bribery related training were conducted for employees across the Company. Additionally, 100% of our directors completed anti-bribery and anti-corruption training in 2020.
We are committed to ensuring that our marketing and communications materials comply with relevant government regulations and industry guidelines, including the Residential Properties (First-hand Sales) Ordinance in Hong Kong and the Consent Scheme of the Hong Kong Lands Department.
We respect property rights, including intellectual property rights, and require our employees to comply with applicable legal requirements relating to the collection, holding, processing, disclosure and use of personal data, and to respect the privacy of others and the confidentiality of information received in the course of business.
Please refer to the Partners section of this report for information about our Data Management and Protection Policy (Customer Data).
We are committed to complying with all applicable competition and antitrust laws, including the Competition Ordinance in Hong Kong.
To help our employees understand the legal requirements of the Competition Ordinance in Hong Kong, we have guidelines in place on dealings with competitors and third parties, avoiding abuse of market power and participating in trade associations and industry bodies. We have also developed and implemented a Competition Law e-training programme for the relevant Hong Kong employees.
In 2020, there were no legal actions related to anti-competitive behaviour brought against Swire Properties.
Information and Cyber Security
Under our risk management framework, the Board and management are responsible for identifying and analysing the risks related to information and cyber security, and for determining how such risks should be managed and mitigated.
We are committed to conducting regular audits to ensure compliance with our Information and Cyber Security Policy and Data Privacy and Security Policy. We have adopted a cyber security framework that is aligned with National Institute of Standards and Technology (NIST), and we regularly conduct independent information security governance assessments to identify opportunities for improvement.
We also have a cyber incident response plan in place that outlines clear procedures and guidance for handling cyber security incidents and that addresses potential threats from cyber-attacks that may disrupt our business. In 2020, a cyber incident simulation exercise was conducted with our incident response team members. To further mitigate these risks, we also include data protection obligations in contracts with third-party data processors.
Finally, we regularly implement comprehensive trainings for our employees related to information security and cyber security. In 2020, we offered 4,680 hours of such training.