Ethics
Corporate Code of Conduct
GRI 2-15, 406
HKEX KPI B7.2
HKEX KPI B7.2
Our Corporate Code of Conduct applies to every employee 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
- Anti-Bribery
- Political activities and contributions
- Gambling
- Procurement
- Keeping of records
- Use of information/company property
- Whistleblowing
- Health and safety
- Environment
- Diversity and inclusion and respect
- Use of social media
- Privacy
- Business ethics
- Conflicts of interest
- Competition and antitrust
- Anti-Bribery
- Political activities and contributions
- Gambling
- Procurement
- Keeping of records
- Use of information/company property
- Whistleblowing
- Health and safety
- Environment
- Diversity and inclusion and respect
- Use of social media
- Privacy
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 2023, there were no confirmed cases of breach of the Code. In 2023, Swire Properties began obtaining third-party assurance regarding the number of confirmed cases of breach of our Corporate Code of Conduct, in accordance with the International Standard on Assurance Engagement (“ISAE”) 3000. This assurance covers our operations in Hong Kong, the Chinese Mainland and the U.S.A., further demonstrating our commitment to upholding integrity and ethical conduct throughout our organisation.
Our adherence to the principles and requirements of ISAE 3000 covers the accuracy and integrity of the number of confirmed cases of breach of the Code, and the effectiveness of our internal processes in terms of managing and reporting any breaches. The assurance provider reviews the structure and design of these processes and examines the Company’s incident reporting mechanisms to ensure that they are well-established, clearly communicated and accessible to employees.
Additionally, the assurance process reviews the monitoring and investigation procedures that the Company has in place and evaluates the corrective and disciplinary actions taken in response to breaches. By evaluating the effectiveness of our internal processes, we hope to gain insights that will further strengthen our compliance mechanisms and reinforce a culture of ethical behaviour within the Company.
As part of the annual employee performance and development review process, all employees are required to sign a statement on an annual basis in agreement to undertake and regularly review the Code.
Whistleblowing Policy
GRI 2-26
HKEX KPI B7.2
HKEX KPI B7.2
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 contact either our Human Resources and Administration department, their immediate supervisor, or the Swire Group Internal Audit department, or make a report through our whistleblowing platform which is hosted by a third-party service provider and includes a 24-hour hotline service. Third parties that deal with Swire Properties, such as customers and suppliers, are also encouraged to report their concerns either directly to GIAD or through 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 2023, we received a total of 13 whistleblowing reports. All whistleblowing cases have been evaluated and fully resolved. There were no reports of human rights violations and breaches of Corporate Code of Conduct in the reporting period.
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 the Company refers the matter to the relevant regulators or law enforcement authorities.
Anti-Bribery and Corruption Policy and Practices
GRI 205
HKEX Aspect B7, KPI B7.1, B7.2, B7.3
HKEX Aspect B7, KPI B7.1, B7.2, B7.3
In late 2022, Swire Properties issued a new standalone Anti-Bribery and Corruption Policy, setting out the standards of behaviour expected from Swire Properties staff and the compliance procedures adopted by the Company, and reaffirming our commitment to providing guidance to all relevant parties about compliance with global anti-bribery laws. Our Corporate Code of Conduct was also updated to reflect the new policy.
According to the policy, all employees of the company must comply 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 2023, there were no concluded legal cases regarding corrupt practices brought against the Company or its employees.
All our employees are required to confirm on an annual basis that they have read and have agreed to be bound by our Corporate Code of Conduct, 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 anti-bribery refresher training on an annual basis as a minimum.
In 2023, in light of the new policy, our Training team devised and launched a new anti-bribery e-training course to replace the existing course. This training was mandatory for all staff in all our locations across the globe, translating to approximately 11,660 hours of anti-bribery-related training provided to employees across the Company in 2023. Additionally, anti-bribery and anti-corruption training materials were provided to Board of Directors over the past two years.
Remuneration Policy
HKEX Aspect B1
Swire Properties is committed to providing fair and competitive staff compensation programmes that will attract, motivate, retain and reward employees at all levels, including our Executive Directors and senior management. Our Remuneration Policy documents key remuneration principles developed to support the Company’s strategy and is aligned with the Company’s corporate values. This policy ensures that the Company has a consistent, transparent and clear approach to remuneration considerations.
The policy is founded on the following key principles:
- That compensation is competitive in the market.
- That pay is based on individual performance.
- Equity and fairness in pay.
- Transparency of employee performance.
- The Company’s affordability.
- The Company’s financial and individual performance.
- Options for pension schemes are provided as part of retirement benefits.
The Remuneration Committee reviews and approves remuneration proposals that concern our Executive Directors and senior management, making reference to the Remuneration Policy and the Board’s corporate goals and objectives. The remuneration proposals of our Executive Directors and senior management are reviewed annually based on market data and peer comparison prepared by independent external consultants. No Executive Director or senior manager takes part in any discussion about his or her own remuneration. The remuneration of individual Executive Directors and senior managers by band is disclosed in the Annual Report of the Company.
Human Rights Policy
HKEX Aspect B4, KPI B4.1, B4.2
We conduct our businesses in a manner which respects the human rights and dignity of our employees, those employed in our supply chains and the communities in which we operate, in line with the principles and guidance contained in the United Nations Guiding Principles on Business and Human Rights.
Our Human Rights Policy, is informed by the International Bill of Human Rights and by the International Labour Organisation’s Declaration of Fundamental Principles and Rights at Work. The policy sets out the expectations for which our operations and supply chains should operate. The policy addresses diversity and inclusion practices, labour standards, health and safety, and employment conditions. Well-established channels are provided to our employees and stakeholders to report human rights-related issues.
The Swire Group Internal Audit department (“GIAD”) conducts regular assessments of the Company’s adherence to the principles of the policy. Our business units are required to provide annual self-declarations on any non-compliance with human rights-related issues, including but not limited to child and forced labour, workplace discrimination and workplace health and safety within our operations and along our supply chain.
Product Responsibility
HKEX Aspect B6, KPI B6.3, B6.5
We are committed to ensuring that our marketing and communications materials comply with the 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 our business operations.
Please refer to the Partners section of this report for information about our Data Management and Protection Policy.
Competition Law
GRI 206
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 conducting dealings with competitors and third parties, avoiding the 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 our relevant Hong Kong and Chinese Mainland employees.
In 2023, there were no legal actions related to anti-competitive behaviour brought against Swire Properties.
Information and Cyber Security
GRI 418
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 complying with our Information Security Policy and Guidelines. We have adopted the National Institute of Standards and Technology (“NIST”) cyber security framework, and we regularly conduct independent information security governance assessments to identify opportunities for improvement. This year, we set our NIST cyber security maturity assessment target and made progress towards achieving it.
We also have a cyber incident response plan in place that outlines clear procedures and guidance for handling cyber security incidents and addresses potential threats from cyber-attacks that may disrupt our business. Scenario-based paper drills are conducted every year for continuous awareness training purposes.
This year, we also began developing and implementing our Digital Project Governance (“DPG”) policy, which applies to digital and information technology projects. The policy ensures that these projects comply with our applications and cloud architecture, cyber security, data privacy and operational standards by design and by default.
We regularly implement security and cyber security awareness training for our employees. In 2023, we offered approximately 8,690 hours of such training. We also offered an awareness programme to ensure that staff understand key concepts relating to information security.
In terms of compliance certification, in view of the increasing importance of and demand for privacy data security management, Swire Properties obtained an ISO 27701 certification extension, on top of our existing ISO 27001 Information Security Management System certification, covering all managed sites in Hong Kong, the Chinese Mainland and the U.S.A. We also continued to prioritise continuous governance and control over the handling of personal data and sensitive information to minimise our risk exposure.
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