Sustainability Report 2019/20

Anti-corruption The Group holds itself to the highest ethical and governance standards and adopts a zero-tolerance approach towards all forms of corruption and bribery throughout the value chain. We ensure compliance over the Prevention of Bribery Ordinance under the supervision of the Board, and clearly set forth our commitment within the Group’s anti-corruption policy and Code of Conduct, which prohibit our staff from accepting advantages, gifts or entertainment from our business partners, including suppliers and contractors. These requirements are introduced and explained to all our employees during induction training and are freely accessible on the Group’s intranet. To keep our staff vigilant against corruption risk, we offer internal refresher training such as talks and briefings on industry specific anti-corruption practices on a regular basis, and a seminar on business ethics is delivered by the Independent Commission Against Corruption (ICAC). We also extend our efforts on anti-bribery and corruption to our supply chain. Apart from Board members, our tendering companies are also required to declare any potential or apparent conflict of interest. Our anti-corruption policy covering all suppliers of construction has also been uploaded to our online vendor platform for our business partners’ reference. Vendors would be suspended from tendering or removed from the approved vendor list should they be suspected of any bribery activities. During the reporting period, the Group did not knowingly work with any suppliers or contractors who contravened our anti-bribery and corruption policy. Our robust corporate governance framework lays a solid foundation for our anti-corruption measures. For more information related to our corporate governance structure and practices, please refer to the Corporate Governance Report section of our Annual Report 2019/20 for details. Competition We embrace fair competition in pursuance of developing a prudent and just supply chain, as well as working in compliance with the Competition Ordinance to prohibit any anti-competitive behaviour. To promote awareness of respective regulations, we invite external professionals to hold training sessions on anti-competitive behaviour. In addition, we regularly update and evaluate our authorized list with qualified and pre- approved companies to prevent bid-rigging in the tendering process. Only companies that are on our list are invited for tendering, and all tender documents explicitly specify our anti-collusion requirements. We also strictly monitor the number of tenders being invited to ensure a competitive tendering process. All tenderers are required to submit an integrity and anti-collusion confirmation letter to declare that there is no anti-competitive behaviour in their operations. The Group has established a whistleblowing mechanism for our internal and external stakeholders to report any suspected cases of misconduct, malpractice, impropriety, unethical or unfair treatment. Employees may raise their concerns through suggestion boxes. The Head of Human Resources and the Head of Internal Audit are responsible for overseeing and implementing the policy. Major issues relating to the cases will also be reported to the Audit and Risk Management Committee for review. In case of violation of our anti-corruption policy, Code of Conduct or where found to be involved in any anti- competitive behaviour, we will report to the respective law enforcement authorities at once. During the reporting year, there were no material breaches of the Code of Conduct and laws relating to anti-corruption and competition. Value Created for Supply Chain Sun Hung Kai Properties Limited • Sustainability Report 2019/20 35