Swire Pacific is committed to ensuring that its affairs are conducted in accordance with its corporate and governance culture and values of integrity, endeavour, excellence, humility, teamwork, continuity and high ethical standards, which form a coherent set of principles that are relevant across the Company’s business and underpin everything it does. This reflects its belief that, in the achievement of its long-term objectives, it is imperative to act with probity, transparency and accountability. By so acting, Swire Pacific believes that shareholder value will be maximised in the long term and that its employees, those with whom it does business and the communities in which it operates will all benefit.
Our approach to corporate governance can be found in our Corporate Governance Code, our Articles of Association, our Board Diversity Policy, and the Swire Pacific Annual Report 2025. We are subject to the Corporate Governance Code in Appendix C1 to The Rules Governing the Listing of Securities on The Stock Exchange of Hong Kong (Hong Kong Listing Rules).
Business Ethics
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 Corporate Code of Conduct includes operating principles covering business ethics, conflicts of interest, bribery, money-laundering, fraud, procurement, record keeping, whistleblowing, health and safety, the environment, diversity, inclusion and respect in the workplace, and data privacy.
Our 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 Corporate Code of Conduct, and influence those with whom they are working to follow similar standards of integrity and ethical behaviour. The Corporate Code of Conduct and anti-corruption and anti-bribery training are included in the induction programme of all employees. All colleagues are required to complete annual training encompassing four essential modules: Corporate Code of Conduct (which covers anti-corruption and anti-bribery), Data Privacy Protection, Cybersecurity Awareness, and Diversity, Equity and Inclusion (DEI). These modules help reinforce our core values, ensure regulatory compliance, strengthen our defence against emerging digital threats, and cultivate an inclusive workplace environment.
Our conditions of employment require compliance with the Corporate Code of Conduct. Our Supplier Code of Conduct includes a mechanism for reporting pursuant to our Whistleblowing Policy.
Anti-corruption
Our Anti-fraud and Anti-corruption Policy applies to all who work for and with Swire Pacific or its subsidiaries, and sets out their obligations under laws that counter bribery and corruption, fraud, money laundering and criminal or terrorist financing. We are committed to acting responsibly and in compliance with all applicable Anti-Financial Crime Laws at all levels of the organisation, and take a zero-tolerance approach to any breach of the laws and regulations that we are required to abide by. Our Corporate Code of Conduct applies to all our operating companies and they may in turn adopt additional appropriate procedures designed to put these general principles into practice.
Our Whistleblowing Policy applies to all our operating companies and their respective employees and 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, a designated third-party service provider, or to the People Department with no fear of retaliation.
All new employees take part in induction programmes that include anti-corruption and anti-bribery training. Additionally, 100% of our Directors were provided anti-corruption and anti-bribery training materials over the past two years. Our operating companies also implement their own anti-corruption and anti-bribery training programmes for their respective employees and directors; their approaches to implementing anti-corruption and anti-bribery practices and training are outlined in their respective sustainability reports, where applicable.
In 2025, there were 18 valid cases of breaches of the Corporate Code of Conduct reported through Group Internal Audit Department's channels. There were no active or concluded legal cases regarding corrupt practices brought against Swire Pacific or its employees.
Legal Compliance
We have businesses which operate in various jurisdictions with different legal and regulatory requirements. It is our policy to comply 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), anti-corruption and anti-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 Group's policies including 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.
Public Policy and Political Contributions
Swire Pacific, as a normal business activity, will engage with government entities either directly or through trade associations to promote policies that encourage business and achieve workable legislation. All our public policy work must be subject to the standards of business ethics under our Corporate Code of Conduct, which prohibits direct political contributions by Swire Pacific or employees on our behalf.