Sustainability Report 2020/21

Anti-corruption Committed to upholding the highest standards of governance and integrity, the Group has zero tolerance for all forms of corruption and bribery along the value chain. While ensuring compliance over the Prevention of Bribery Ordinance under the supervision of the Board, we clearly stipulate anti-corruption standards within the Group’s Anti-corruption policy, Code of Conduct and Supplier Code of Conduct. For example, our staff are prohibited from soliciting, accepting or offering advantages, gifts or entertainment from any business partners, including suppliers and contractors. These requirements are communicated to all our staff during induction training and are freely accessible on the Group’s intranet and website. In addition, to promote ethical business practices and awareness of all directors and employees, internal refresher training on industry-specific ethical standards and anti-corruption practices are held on a regular basis. We have also invited the Independent Commission Against Corruption (ICAC) to deliver integrity training workshops during the year. Directors are provided with additional training materials on anti-corruption and business ethics. More than 7,500 of our employees have attended the above trainings during this reporting year alone. We have also made continuous efforts to prohibit any corruption, money laundering, extortion, anti-competition, fraud, false declaration or other malpractices across the supply chain. To ensure all suppliers and contractors understand and follow our anti-corruption policy, the policy is available on our online vendor platform. Our tendering companies are also required to declare any potential or apparent conflict of interest. Vendors would be suspended from tendering or removed from the approved vendor list should there be actual or suspected corruption activities. During the reporting period, the Group did not knowingly work with any suppliers or contractors who contravened our anti-bribery and corruption policy. The Group has a whistleblowing mechanism for 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 Audit and Risk Management Committee has an overall responsibility for the mechansim, whereas the Group Head of Internal Affairs and the Head of Internal Audit are responsible for overseeing and implementing the mechanism. Major issues in the case will be reported to the Audit and Risk Management Committee for review. In case of suspected corruption or other criminal offences, a report will be made to either the Chairman and Managing Director or Audit and Risk Committee or relevant law enforcement authorities to decide the best course of action. During the reporting year, there were no material breaches of the Code of Conduct and laws relating to anti-corruption and competition. Our robust corporate governance framework is fundamental to our anti-corruption efforts. For more information related to our corporate governance structure and practices, please refer to the Corporate Governance Report section of our Annual Report 2020/21 for details. Competition Fair competition serves as a foundation for creating a prudent and just supply chain. We strive to prohibit any anti-competitive behaviour in compliance with the Competition Ordinance. To prevent bid-rigging during tendering processes, we regularly update and evaluate our authorized list with qualified and pre- approved companies. Only companies that are on our list are invited for tendering, and all tender documents clearly stipulate our anti-collusion requirements. The number of tenders being invited are also strictly monitored to ensure a competitive tendering process. Signing of integrity and anti-collusion confirmation letters is required for all tenderers to declare that there is no anti-competitive behaviour in their operations. In addition, we invited external professionals to organize online seminars to raise the awareness on anti-competitive behaviour. Value Created for Supply Chain Sun Hung Kai Properties Limited • Sustainability Report 2020/21 39