Materiality

HKEX Mandatory Disclosure Requirement, Aspect B8
For the purposes of Swire Properties’ SD 2030 Strategy and sustainability reporting, materiality is defined as any factor that has a present or future impact on our ability to achieve our SD vision. We believe that balancing internal and external viewpoints is critical to defining and managing SD issues that are significant to our business and our stakeholders.
In 2023, to gain a deeper understanding of the aspects that are important to the Company’s business continuity and development, and to remain in line with the Corporate Sustainability Reporting Directive (“CSRD”) requirements, we began conducting a new materiality assessment and stakeholder engagement exercise based on the concept of “double materiality”. Proposed by the European Commission’s Guidelines on Reporting Climate-related Information, double materiality encourages a company to assess materiality based on a topic’s implications for the company’s financial performance (financial materiality); on communities and the environment (impact materiality); and the interconnectivity between the two. This “financial-and-impact-based” double materiality will allow us to better assess the integration of sustainability within our business, understand our sustainability impact and align with global best practices in reporting.
Amongst the 590+ responses received, 90% of our surveyed stakeholders perceive Swire Properties as a leader in sustainability. Both internal and external stakeholders recognise decarbonisation, occupational health and safety, and climate adaptation and resilience as issues with significant impacts on the company, environment and society. Furthermore, there is a growing recognition of the importance of biodiversity since the last materiality assessment and stakeholder engagement.

Our Stakeholder Engagement Framework

As set out in our SD 2030 Strategy, communication and engagement with employees, investors, tenants, customers, suppliers, regulators, NGOs, community representatives, and our many other stakeholders is an integral part of Swire Properties’ daily operations.
We regularly engage with our stakeholders to understand their priorities, expectations and perceptions regarding SD issues. When we first introduced our SD 2030 Strategy in 2016, we engaged extensively with senior managers and employees from across the business and consulted external sustainability experts. Our SD Communication and Engagement Committee continues to gather the support of our employees and other stakeholders to further integrate SD 2030 across our business.
In the past, we measured the materiality of a particular topic based on the level of importance to stakeholders. This was based on feedback from external stakeholders, and the importance to our business continuity and development as reflected by feedback from internal stakeholders. In 2023, we embraced the concept of double materiality, taking into consideration the issues’ impacts on the organisation (internal materiality) and the organisation’s impact on these issues (external materiality). This approach considers the interconnectedness between our business activities, stakeholder expectations and the environment. It enables us to identify and prioritise material issues that may have significant consequences for our stakeholders, while also aligning with long-term sustainability goals and addressing systemic risks.
Embracing this more robust and data-driven approach to materiality will strengthen our ability to proactively manage risks, seize opportunities and foster sustainable practices that contribute to the wellbeing of our stakeholders, our organisation and the world at large.
The development of this double materiality approach is discussed in the Our Evolving Approach to Stakeholder Materiality section.

Our Stakeholders

GRI 102-40, 102-42, 102-43
Swire Properties’ stakeholders comprise internal and external interest groups that have a significant impact on our business, or that experience significant impacts from our operations. We regularly engage with these stakeholders through the appropriate channels. While the stakeholder groups remained the same in 2023, the number of stakeholders increased.
Stakeholder Groups and Methods of Engagement
Employee Groups
Community / NGOs
Tenants
Customers / Consumers
Suppliers
Regulators / Government
Industry Experts / Academia
Joint Venture Partners
Shareholders and Investors
Media
Employee Groups
Community / NGOs
Tenants
Customers / Consumers
Suppliers
Regulators / Government
Industry Experts / Academia
Joint Venture Partners
Shareholders and Investors
Media
Employee Groups
  • Surveys and interviews
  • SPLinks intranet and the employee newsletter CornerStone
  • Training sessions
  • Competitions and team-building activities or events
  • Virtual and in-person forums
  • Employee townhalls
  • “WeChat Work” mobile application
Community / NGOs
  • Community events
  • Joint projects
  • Working committees and consultations
  • Multi-stakeholder meetings and seminars on specific issues
Tenants
  • SD-themed tenant engagement programmes
  • Swire Properties Tenant Portal
  • Joint projects
  • Community events
  • Surveys and interviews
  • Multi-stakeholder meetings and seminars on specific issues
Customers / Consumers
  • Surveys
  • Customer service mobile applications
  • Community events
  • Joint projects
  • Customer relationship management programme
Suppliers
  • Supplier screenings and assessments
  • Joint projects
  • Surveys
  • Forums
Regulators / Government
  • Joint projects
  • Working committees and consultations
  • Interviews
  • Community events
Industry Experts / Academia
  • Joint projects and research funds
  • Multi-stakeholder forums and partnerships
  • Seminars
Joint Venture Partners
  • Surveys and interviews
  • Multi-stakeholder meetings and seminars on specific issues
  • Joint projects
Shareholders and Investors
  • SD benchmarks and indices
  • Interviews and meetings
  • Newsletters
  • Events
  • Investor Day
Media
  • Annual gatherings
  • Interviews
  • Feedback and responses to media enquiries
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Our Evolving Approach to Stakeholder-driven Materiality

GRI 3-1, 3-2
HKEX Mandatory Disclosure Requirement
In 2020, we initiated a materiality review to understand our stakeholders’ perceptions of the progress of our SD 2030 Strategy and their evolving expectations and priorities for the future. These perceptions helped further align our business practices, improved our decision-making and accountability, and guided the refinement of our strategy and focus areas in response to the latest local, regional and global developments.
In 2021, we continued this process, adopting a combined qualitative and quantitative approach to assessing materiality. Throughout the COVID-19 pandemic, we gathered stakeholders’ feedback to gain greater understanding of the pandemic’s effects on their businesses, the real estate industry and our operations. The findings provided insights into ways of providing support to our stakeholders during challenging times.
Swire Properties is continuing to build on and refine our approach to materiality. In 2023, we began an in-depth materiality assessment and stakeholder engagement exercise based on the concept of double materiality. Led by an independent consultant, the five-phase, mixed-method project aimed to deliver a broad and deep range of insights.
Phase 1: Impact Metrics and Megatrends
The first phase was a comprehensive review to identify key issues and metrics. We first revisited previous materiality assessment metrics and reviewed how well we had addressed the previously identified material issues.
We then identified industry sector, local and global megatrends to understand the larger trends shaping our industry and the world, and to anticipate upcoming challenges and opportunities.
Megatrends
Megatrend
Description
Significance to Swire Properties
New legislation and reporting measures
Global recognition of the climate crisis has led to countries setting net-zero commitments and passing legislation to meet targets.
Regulatory pressures and investor attention are driving an increased focus on ESG disclosures and solutions in the real estate sector, pushing the sector towards more sustainable and energy-efficient practices.
Growing focus on biodiversity and nature
There is a growing focus on the need for businesses to create action plans to mitigate human influence on climate, biodiversity and nature.
The real estate sector is a significant contributor to biodiversity loss. While nature-related impacts are lower for companies investing in urban areas, the biodiversity impact associated with procuring building materials across supply chains must be considered.
Accelerating to net-zero
Companies moving into the net-zero energy transition will outperform others in the medium term as economies adapt and investor preferences shift towards more sustainable offerings.
Buildings account for about 39% of global energy-related carbon emissions. As such, the built environment has a critical role to play in reducing these emissions through innovative technologies and approaches.
Building climate resilience
With hundreds of cities predicted to suffer from extreme heat and sea level rises by 2050, high-level collaboration is happening across cities, regions and industries to build more climate-resilient communities.
Delaying action on climate resilience and adaptation will lead to reduced building performance, a higher potential for damage and larger insurance premiums. Investing in resilience provides opportunities to innovate and strengthen communities and social cohesion.
Improving circularity in design and use
The most sustainably progressive cities and companies consider how to address circularity through the full lifecycle of a building, including construction, maintenance and demolition.
Construction waste and operational waste account for a huge proportion of total waste disposal. Designing out waste across the building lifecycle and emphasising durability, recycling and circular thinking in operations and across the supply chain are becoming increasingly important.
Tackling social inequality
Inequality – a lack of diversity, equity and inclusion – is a critical challenge that erodes social cohesion, diminishes trust in key institutions, fuels civil and personal conflict, and threatens economic growth.
As stakeholders’ social inclusion expectations increase, it will become more important to level up from equality measures that focus on acquiring and retaining talent, and move towards those that focus on workplace inclusivity, respond to societal issues like racism and make services equitable and accessible to all communities.
Cost-of-living crisis redefines value
A combination of the current cost-of-living crisis and post-pandemic changes in consumer behaviour, such as the increased demand for flexible workspaces and a lower willingness to commute, has led to a re-evaluation of what households and businesses can afford, presenting a challenge to all industries.
The trend for flexible office spaces and short leases is remaining, as the COVID-19 pandemic changed how, where and why we use different types of properties. There is also a broader demand that wellbeing should be a central part of the real estate value proposition, including components such as access to nature, accessible public spaces, natural light, and improved indoor air quality. This increases the importance of placemaking – creating walkable, liveable and vibrant communities.
More active supply chain management
There are now high expectations that companies understand and proactively manage their full supply chain. Each party is responsible for agreeing and aligning on key issues from working conditions to carbon emissions. Reporting requirements increasingly require the disclosure of Scope 3 emissions, meaning that the entire supply chain must be addressed.
Supply chain volatility, poor construction industry labour conditions and a growing focus on Scope 3 emissions make supply chain collaboration, coordination and alignment essential, as each function must measure, access and track the same ESG data. Capturing real-time operational data will improve transparency and visibility across the entire supply chain, while green product certifications help assure effective supply chain practices across the value chain.
Phase 2: One-to-one Stakeholder Interviews
Twenty-two in-depth interviews were conducted, engaging a wide range of stakeholders including our senior management, business partners, industry associations, tenants, investors, and academia. The interviews provided valuable insights into the strengths that we may leverage, key focus areas, areas of opportunity, and the current and future sustainability landscape.
Phase 3: Online Stakeholder Surveys
Employees, business partners, industry associations, tenants, investors, academia, peers, media, and government representatives were invited to provide feedback through an online survey. The survey asked about stakeholder views on the relative importance of different ESG issues for Swire Properties, how well we are performing on these issues, and the Company's future priorities. The survey received 591 responses.
Phase 4: Analysis and Reporting
The data collected from the one-to-one interviews, online surveys and findings from industry benchmarks, indices ratings and disclosure frameworks were analysed.
This analysis informed the development of our new double materiality matrix, a visual representation of issues that are important to stakeholders, the issues’ level of impact on us, and our impact on these issues. This matrix provides a comprehensive understanding of how these issues and metrics impact the Company inwardly and outwardly at present and in the future and will inform the direction of our SD 2030 Strategy. The findings were also shared with our Risk department and will inform our CRR and ERM process processes.
Phase 5: Internal Validation and Engagement
A validation workshop was conducted with senior management to present and endorse the double materiality findings. The results were then presented to the ESG Steering Committee and the Board and will be integrated into the Company’s strategic planning and decision-making processes in the future. The findings were also shared with all governance bodies responsible for overseeing sustainability and ESG-related matters.

Double Materiality Matrix

Please select (single option):
Tier 1 Issues
(the most important material issues with the highest potential impact on business success)
Tier 2 Issues
(important material issues with a high potential impact on business success)
Tier 3 Issues
(relatively less important material issues, as perceived by stakeholders, that can impact business success)
Click on the Materiality Matrix to view and learn more about the material issues in each Tier
Tier 1 Issues
(the most important material issues with the highest potential impact on business success)
Tier 2 Issues
(important material issues with a high potential impact on business success)
Tier 3 Issues
(relatively less important material issues, as perceived by stakeholders, that can impact business success)
Places
People
Partners
Performance (Environment)
Performance (Economic)
All Pillars
The top material issues in the matrix are consistent with the focus areas of our SD 2030 Strategy and have been addressed in this report in accordance with the relevant Global Reporting Initiative Standards. The matrix will also inform future reviews of our SD 2030 Strategy, allowing us to continuously drive meaningful impact within the organisation and deliver positive value to our stakeholders.

Discussion of Top Material Issues

Material Issues
Internal Materiality
External Materiality
Green Building
Implementing green building strategies can lead to operational cost savings through reduced energy and water consumption and lower waste management expenses. Green buildings can generate financial opportunities by attracting high-quality tenants that prioritise ESG matters. Investing in green building initiatives allows us to comply with evolving environmental regulations and standards, ensuring long-term compliance and reducing the risk of sanctions or legal issues.
Stakeholders, including tenants and investors, are becoming increasingly committed to decarbonisation and usually have their own decarbonisation targets in place. This has created a positive demand for real estate solutions from like-minded companies that can help them achieve their targets.

Green building practices and certifications, such as LEED, are crucial to external stakeholders as they demonstrate a commitment to sustainability.
Climate
Swire Properties takes proactive measures to mitigate climate risks and build climate resilience across our portfolios. We incorporate sustainable design features into new developments, adopt adaptive measures for extreme weather events, and implement disaster preparedness plans. We believe this can enhance climate resilience, minimise potential disruptions, improve occupant safety and wellbeing, and safeguard assets.
Our stakeholders, including tenants, investors and the community, are concerned about climate resilience as they recognise the increasing risks associated with climate change such as extreme weather events, rising sea levels and extreme temperature events.

Stakeholders value efforts to enhance infrastructure resilience and adopt adaptive measures to ensure business continuity in the face of climate-related challenges.
Energy Efficiency
Swire Properties strives to reduce energy consumption in all our portfolios. We invest in best-in-class energy efficiency, perform retro-commissioning and technical upgrades across our portfolios, extensively apply innovative low-carbon and energy-efficient technologies, and are increasing our adoption of renewable energy. Energy efficiency efforts are crucial to delivering on our near-term 1.5°C-aligned science-based targets and transitioning to net-zero before 2050.
Energy efficient operations bring environmental and economic benefits. Stakeholders, including tenants, regulators, and environmental groups, expect organisations to reduce energy consumption and greenhouse gas emissions. Energy efficient buildings contribute to mitigating climate change, help lower operational costs and enhance overall sustainability performance.
Decarbonisation
Swire Properties was the first real estate company in Hong Kong and the Chinese Mainland to support the Business Ambition for 1.5°C campaign and set ambitious 1.5°C-aligned science-based targets to fight climate change. We have committed to achieving net-zero emissions by 2050 and support Hong Kong’s carbon neutrality pledge. The transition to net zero will bring us closer to this commitment by saving costs through energy efficiency improvements and by providing opportunities for innovation and market differentiation. Through proactively addressing decarbonisation, we can future-proof our operations, mitigate regulatory risks and position ourselves as an industry leader in sustainable development.
Investors and regulatory bodies are increasingly concerned about organisations’ carbon footprints. Companies are expected to actively reduce greenhouse gas emissions and transition to low-carbon practices in line with the Paris Agreement.

Exploring technological innovations, digitalisation, deploying energy-efficient technologies, and increasing renewable energy adoption are crucial if organisations are to align with global climate goals and demonstrate environmental leadership.
Occupational Health & Safety
Health and safety is an indispensable part of our business. We are committed to providing and maintaining a healthy and safe environment for all our employees, customers, contractors and members of the community during their association with the Company. Occupational health and safety directly impact the wellbeing of employees and the overall productivity and reputation of the Company. Prioritising a safe and healthy work environment helps minimise accidents, injuries and potential liabilities. It also fosters employee satisfaction, engagement and retention, leading to higher productivity and reduced turnover costs.
Employees, local communities, business partners and regulatory bodies consider occupational health and safety to be important. They expect organisations to prioritise the wellbeing of their employees and those with whom they work by providing safe working conditions. Demonstrating a strong commitment to occupational health and safety protects employees, enhances an organisation’s reputation, attracts and retains talent, and reduces the risk of legal and reputational issues. It is a fundamental aspect of responsible and sustainable business practices.

List of Material Issues

Material Issues
SD 2030 Strategy Focus Areas
GRI Standards
Impacts and Boundaries
Change in Importance
Future Trend
Employee Groups
Community/ NGOs
Suppliers
Tenants
Consumers/ Customers
Regulators/ Government
Joint Venture Partners
Ind. Experts/Academia
Shareholders/Investors
Media
Decarbonisation
GRI 305 Emissions (2016)
Energy Efficiency
GRI 302 Energy (2016)
Green Building Construction and Renovation
GRI 417 Marketing and Labelling (2016)
Occupational Health and Safety
GRI 403 (2018)
Climate Adaptation and Resilience
GRI 201 Economic Performance (2016)
GRI 305 Emissions (2016)
Resource and Circularity
GRI 306 Waste (2020)
Corporate Governance
GRI 205 Anti-corruption (2016)
GRI 206 Anti-competition Behavior (2016)
Talent Attraction, Retention and Development
GRI 401 Employment (2016)
GRI 404 Training and Education (2016)
GRI 405 Diversity and Equal Opportunity (2016)
GRI 406 Non-discrimination (2016)
Tenant and Customer Engagement
N/A
Responsible Supply Chain Management
GRI 301 Materials (2016)
GRI 308 Supplier Environmental Assessment (2016)
GRI 414 Supplier Social Assessment (2016)
Renewable Energy
GRI 302 Energy (2016)
Long-term Financial Performance and Value
GRI 201 Economic Performance (2016)
Technology, AI and Innovation
Integral to multiple focus areas
N/A
Biodiversity
GRI 304 (2016)
Stakeholder Engagement and Collaboration
Integral to multiple focus areas
N/A
Cyber Security and Data Governance
GRI 418 (2016)
Employee Wellbeing
GRI 403 Occupational Health & Safety (2018)
Risk Management
GRI 201 Economic Performance (2016)
Community Investment and Engagement
GRI 413 Local Communities (2016)
Visitor/Occupant health and Wellbeing
GRI 416 Customer Health and Safety (2016)
Anti-Bribery and Anti-Corruption
GRI 205 (2016)
Contribute to Local Economic Development
GRI 203 (2016)
Social Inclusion
GRI 413 (2016)
Water Conservation
GRI 303 (2018)
Labour Practices and Human Rights
GRI 408 (2016)
GRI 409 (2016)
Indoor Air Quality
GRI 416 Customer Health and Safety (2016)
Diversity and Equal Opportunities
GRI 405 (2016)
GRI 406 (2016)
Local Revitalisation
GRI 203 Indirect Economic Impacts (2016)
Level of importance increased compared to the previous stakeholder engagement exercise
Level of importance decreased compared to the previous stakeholder engagement exercise
Level of importance remained broadly the same compared to the previous stakeholder engagement exercise
Level of likelihood that the material issue will become increasingly important in the future