Responsible supply chain management is critical to mitigating financial risk, maintaining business continuity, and protecting our reputation. It is integral to protecting and empowering workers in our supply chain and helping to ensure the sustainable availability of natural resources.
As a Group, we source from thousands of suppliers in countries across the globe. They provide goods and services including aircraft parts, fuel, food products, packaging materials, cleaning services, office supplies, and uniforms. We advocate inclusive, ethical and sustainable procurement practices. We aim to source all key materials responsibly and sustainably, in a way that does not degrade nature and ensures that the people who produce them are treated with dignity and respect. This is what our investors, those with whom we do business, and the communities in which we operate expect. Consumers are demanding responsible products and looking for supply chain transparency.
Our Approach
The Group does not have a central procurement function. Each operating company is responsible for its own procurement. They are guided by Group policies and guidelines that set out the Group’s expectations of suppliers.
All staff involved in making procurement decisions must adhere to the Swire Pacific Sustainable Procurement Policy in conjunction with the respective procurement policies of each operating company, the Swire Pacific Supplier Code of Conduct, and the Swire Pacific Human Rights Policy. These policies are reviewed regularly, and their effective implementation is subject to scrutiny by our Group Internal Audit Department.
Our Sustainable Supply Chain Working Group is chaired by the Group-level sustainability function and convenes senior procurement managers from our operating companies to share best practices, develop the policies, guidelines and due diligence processes applicable to procurement teams, and to shape team member roles and responsibilities in operating company supplier programmes. External supply chain service and subject matter specialists are invited to help build expertise.
At the operating company level, our businesses determine appropriate supplier ESG programmes for their industries. This includes, for example, having sustainability criteria in tender documents or contractual agreements, and excluding suppliers identified as not complying with our policies.
Our Sustainable Procurement Policy references sustainability-related guidance such as ISO 26000 Guidance on Social Responsibility, ISO 14001 Environmental Management Systems and ISO 45001 Occupational Health and Safety Management Systems. It was developed with reference to the guidance outlined in ISO 20400:2017 Sustainable procurement - Guidance.
The Sustainable Procurement Policy requires our operating companies to incorporate relevant sustainability consideration in our supplier selection and contract renewal evaluation process, where feasible. Under the policy our operating companies should adopt a due diligence process to monitor their supplier sustainability performance. Where necessary, suppliers are required to develop and adopt remedial measures. Preference should be given to suppliers that have adopted international recognised management systems and guidance related to sustainability, and that provide products and services which can significantly contribute to our sustainable development objectives. Preference should be given to products which do not adversely affect the environment, including on ecosystems and biodiversity, and that can help us reduce our environmental impact.
Supplier Code of Conduct (SCoC)
Our Supplier Code of Conduct (SCoC) sets out the Group’s requirements for responsible sourcing. It applies to all suppliers and contractors of all Group subsidiaries, while suppliers of associated, and joint venture companies are encouraged to comply with it. Suppliers are expected to cascade the SCoC’s requirements to their own suppliers such that they apply to multiple tiers in our supply chain.
The SCoC is based on the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work and the Ethical Trading Initiative (ETI) Base Code. It requires regulatory compliance, prohibits forced or child labour, and sets out our expectations on health and safety, environmental matters, compensation and working hours, human rights, and ethics and reporting.
We monitor and assess compliance with the SCoC and other sustainability performance criteria. Where gaps are identified, we may require suppliers to undergo audits and to develop and adopt appropriate corrective action plans to ensure compliance, with a focus on those deemed high risk.
Grievance mechanisms are established. Individuals within our supply chain who suspect or have witnessed actual improprieties can raise concerns in confidence through either of our dedicated whistleblowing channels: directly to the Group Internal Audit Department or through EthicsPoint, a third-party service provider. This sets out our expectation that suppliers should be prepared to be open and transparent in order to verify compliance with the SCoC.
Human Rights Policy
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.
Our Human Rights Policy is guided by the The United Nations Global Compact Principles and the ILO’s Declaration on Fundamental Principles and Rights at Work. The policy covers aspects of diversity and inclusion, health and safety, labour and employment practices (including issues related to child labour, forced labour, human trafficking and discrimination).
We respect internationally recognised human rights standards, unless otherwise conflicted with applicable local laws and regulations. We seek to include in our agreements with suppliers and contractors, provisions which encourage them to adhere to our Human Rights Policy and we expect our business partners and third parties who deal on our behalf to adhere to its principles.
Our Supply Chain by Division
Our supply chains
Swire Properties’ principal suppliers perform or assist in the planning, design, construction, marketing, sale, leasing, management, maintenance, and demolition of properties.
Supplies obtained directly from TCCC include juices, concentrates and other ingredients, fountain packaging, and advertising materials. Goods which TCCC authorises third parties to supply include packaging, speciality merchandise, sales and marketing equipment, sweeteners, and carbon dioxide.
HAECO's principal suppliers are manufacturers of aircraft and engine components, and suppliers of fuel and engineering services.
Sustainable Supply Chain Management
Sustainable supply chain management enables effective management of environmental and social risks in our supply chains, encourages innovation and strengthens relationships with our key suppliers. In addition to the Sustainable Procurement Policy, we are developing an internal, Group-level framework to enhance our supplier ESG programme. This framework will offer additional guidance to our operating companies on strengthening supplier due diligence and systematically identifying and managing supply chain ESG risks.
We have conducted a high-level assessment to evaluate the ESG risk exposure of high-spend suppliers across our operating companies, focusing on key areas such as environmental considerations, labour conditions, human rights, and ethics. Using a credible third-party platform, the assessment considered suppliers’ geographical locations, sectors and commodities. The results will inform the further enhancement of our supplier ESG programme. In 2025, webinars were conducted with procurement teams across our businesses to strengthen understanding of sustainable procurement practices in support of our supplier ESG programme.
Swire Properties requires service providers to perform well in the areas of health and safety, the environment, procurement, management, and quality. It is standard practice to require that all suppliers in Hong Kong, the Chinese Mainland, and Miami, U.S.A. comply with its SCoC. It has an e-Contractor List Management System in place which is integrated with its vendor requisition process in Hong Kong and the Chinese Mainland. Sustainability considerations are integrated into supplier selection and retention. For new suppliers to be included on the list of approved contractors, they must complete a self-assessment questionnaire to confirm that they have appropriate policies and systems in place to comply with the SCoC, which covers its expectations on health and safety, environmental practices, labour standards and ethics. Suppliers that fail to comply fully with its SCoC risk termination of their contracts, subject to the contractual terms therein, and removal from its approved contractors list. Compliance status of suppliers on its approved contractors list is monitored on an ongoing basis.
Swire Properties' Business Partner Sustainability Programme is a key initiative designed to allow effective implementation of its SCoC and improve supply chain data transparency, accuracy and reliability. The programme involves supplier screening and ESG assessment focused on environmental considerations, labour and human rights, ethics and sustainable procurement practices, as well as support for continuous improvement. A high-level ESG screening was conducted for all active suppliers in 2025. High risk suppliers identified under the screening will be invited to fill in a self-assessment questionnaire using a credible third-party platform. Suppliers’ ESG risk exposure levels will be adjusted based on the response to this questionnaire. If they are identified as high risk, the supplier will be invited to conduct a detailed ESG assessment when necessary. The assessed suppliers will gain in-depth insights into their strengths and areas for improvement, along with access to information on ESG best practices and valuable resources through an online e-learning platform.
As part of its Business Partner Sustainability Programme, Swire Properties hosted webinars in July and October 2025 for its Hong Kong and Chinese Mainland suppliers to share its sustainability vision and highlight evolving ESG trends. Featuring presentations and sharing sessions by EcoVadis, SGS, and HSBC, the event aimed to empower suppliers to implement effective ESG practices and drive continuous improvement. The webinars engaged over 100 participants from more than 65 companies.
Swire Coca-Cola aims to partner with those who share its commitment to ethical conduct, fairness and environmental protection. The Coca-Cola Company (TCCC) works with Swire Coca-Cola on human rights through its Supplier Guiding Principles (SGP) and Principles for Sustainable Agriculture (PSA). All suppliers of Swire Coca-Cola’s critical materials and ingredients for beverages, packaging and any items with TCCC’s logo must comply with the SGP and PSA. The SGP is a set of standards for suppliers covering human rights, labour practices, health and safety and environmental protection. Supplier compliance is verified by independent third-party audits arranged by TCCC. Approximately 240 suppliers were reviewed in 2025. The PSA provides detailed guidance on human and workplace rights, environmental and ecosystem management, animal welfare, farm management systems and transparency. By 2030, the farms that supply Swire Coca-Cola's key agricultural ingredients (sugar and corn) will meet the requirements of the PSA, as verified by third-party audits.
Swire Coca-Cola engages its Chinese Mainland suppliers to decarbonise their own value chains
Swire Coca-Cola also aims to drive social responsibility within its supply chain in the Chinese Mainland and other markets. The China Bottlers Procurement Consortium (CBPC) has incorporated an explicit clause into supplier contracts committing Swire Coca-Cola and suppliers to fostering an equitable, diverse and inclusive environment that has a positive effect on employees. This non-binding clause is intended to raise awareness of gender equality and other types of diversity among our suppliers. This approach was also adopted in agreements with direct material suppliers in Vietnam.
Swire Coca-Cola shares knowledge with other Coca-Cola bottlers in the Chinese Mainland to manage procurement better. This facilitates the identification and selection of suppliers who follow appropriate procurement principles. As part of the CBPC, Swire Coca-Cola works with its suppliers in the Chinese Mainland to strive for a green and low-carbon end-to-end supply chain. CBPC has hosted quarterly webinars to share expertise and impactful case studies for its supplier network. These sessions covered topics like decarbonisation management and energy conservation, engaging around 360 suppliers and procurement team members. Through a six-step engagement strategy, Swire Coca-Cola partners with its suppliers in the Chinese Mainland to enhance alignment on decarbonisation goals. A supplier-specific emission factor platform was employed to enable its key suppliers to calculate and report their product carbon footprints, supported by expert guidance.
In Thailand, ThaiNamthip Coca-Cola has signed a Memorandum of Understanding (MoU) with 11 critical suppliers, marking a significant step toward advancing shared sustainability goals across the supply chain. The MoU sets a common framework for action that aligns strategic priorities and sustainability goals between ThaiNamthip Coca-Cola and its key suppliers covering five key dimensions: business ethics, labour standards, safety and health, environmental management, and management guidelines. This partnership aims to extend sustainable practices to all relevant stakeholders, as well as create a platform for knowledge sharing and best-practice exchange in sustainability.
HAECO identifies its critical suppliers based on volume and asks them to complete self-assessment surveys. It assesses their compliance with its requirements and engages with them based on their responses. This is done every two years. Critical supplier audits are conducted periodically when necessary.
Sustainable Procurement in Practice
Swire Properties tracks consumption of office supplies, building services equipment and building materials that meet specific environmental criteria, as well as sustainability-related products and services that promote safety, health and wellbeing in its properties and new developments. The data is used to evaluate its sustainable procurement performance and to identify opportunities for sourcing more sustainable products and services. In 2025, more than HK$1.7 billion of sustainable products and services were procured in Hong Kong and the Chinese Mainland.
Swire Properties procured more than
HK$1.7billion
of sustainable products and services in 2025
Swire Properties specifies low-carbon concrete, reinforcement bar (rebar) and structural steel in its contract for new developments in Hong Kong and the Chinese Mainland, as appropriate. Pre-qualification checks are conducted to ensure that those tendering fulfil all sustainability requirements in their tender specifications. It also tracks the consumption and environmental impacts of specific construction materials such as timber, concrete, and rebar, which enables benchmarking across its new developments.
It aims to promote greater innovation and availability of low-carbon building materials by sharing its experience with primary contractors and building material suppliers through publications, presentations at conferences and other methods. In 2024, Swire Properties endorsed the “Collaboration Statement on Low Carbon Emissions Steel for Real Estate in China” to accelerate the adoption of low carbon emissions steel in the real estate industry.
Swire Coca-Cola integrates sustainability into its procurement decisions and actively works with suppliers to identify opportunities to reduce the environmental footprint of its products. Its procurement teams work with suppliers to identify or develop recycled packaging and CDE options that help the company meet its sustainability targets. To monitor supplier progress, a digital tracking system collects information on carbon emissions and recycled content of packaging sourced in the Chinese Mainland.
HAECO is developing sourcing policies for key materials such as plastic, fuel and gas to provide procurement and buying teams with guidance to make more responsible choices.
For more information on our operating companies’ approaches to sustainable procurement, please refer to each company’s 2025 sustainability report.
