Sustainability Reports 2022/23

Sun Hung Kai Properties Limited Sustainability Report 2022/23 61 Value Created for Supply Chain Our Reporting Approach Message from the Sustainability Steering Committee Our Business Our Approach to Sustainability Value Created for People Value Created for Community Appendices Value Created for the Environment Value Created for Customers Anti-corruption We are committed to upholding the highest standards of business ethics and have zero tolerance for corruption and bribery throughout our value chain. The Board oversees our Anti-corruption Policy and manages ethics and corruption issues. The Executive Committee reviews the Anti-corruption Policy where necessary. We adhere to the Prevention of Bribery Ordinance and our Anti-corruption Policy, Code of Conduct and Supplier Code of Conduct. We review our ethical standards and relevant performance annually. As stipulated in our policies, employees are strictly prohibited from soliciting and accepting advantages, gifts or entertainment from business partners, including suppliers and contractors, and offering the same to them. This year, we updated our Code of Conduct to provide more guidance on preventing bribery and corruption. We prohibit charitable contributions that involve bribery and corruption. Contributions should be transparent and in accordance with applicable laws and regulations. Our anti-corruption policies and guidelines are available on our intranet and website, and are communicated to new employees as part of the induction process. Periodic refresher training on anti- corruption and ethical standards reinforces directors and employees’ awareness of industry-specific ethical standards and anti-corruption practices. This year, the Independent Commission Against Corruption (ICAC) was invited to deliver anti-corruption and business ethics training for all of our full-time and part-time employees, and our contractors and subcontractors. Our directors are also provided with additional training materials on anti-corruption and business ethics. Internal and external stakeholders, including customers, can use our whistleblowing mechanism to report misconduct, malpractice, impropriety, and unethical or unfair treatment. Employees may consult or report such concerns via suggestion boxes, our grievance procedure or by informing their supervisors. The Whistleblowing Policy provides examples of impropriety and guarantees the anonymity of whistleblowers during investigations. Employees should not suffer any intimidation and retaliation as a consequence of reporting a concern. The Audit and Risk Management Committee has overall responsibility for the whistleblowing policy and mechanism, while the Group Head of Internal Affairs and the Head of Internal Audit oversee its implementation. If an investigation is warranted, the investigation outcome and recommendations are reported to the Chairman and Managing Director. Major issues are reported to the Audit and Risk Management Committee for review. If corruption or criminal activity is confirmed, we report promptly to either the Chairman and Managing Director, or the Audit and Risk Management Committee, or law enforcement authorities, to determine an appropriate course of action. During the reporting year, there were no material breaches of our Code of Conduct or laws relating to anti-corruption and competition. For more details, please refer to the Corporate Governance Report section of our Annual Report 2022/23. Anti-competition Fair competition is key to building a prudent and just supply chain. We strictly prohibit anti-competitive behaviour and comply with all relevant laws and regulations such as the Competition Ordinance in Hong Kong. As stipulated in our updated Supplier Code of Conduct, all suppliers, contractors and subcontractors are strictly prohibited from engaging in anti-competitive behaviour. Anti-collusion requirements are clearly stipulated in all of our tender documents. During the procurement process, tenderers must sign an integrity and anti-collusion confirmation letter, declaring that they do not engage in anti-competitive behaviour. To prevent anti-competitive practices such as bid-rigging during tendering, we regularly update and evaluate our list of qualified and approved companies. Only companies on this list are invited for tendering. Competitive tendering is ensured by monitoring the number of tenderers. Sanfield’s e-tendering system enables suppliers and contractors to acquire and submit tender documents via a secure digital platform. All submitted documents are kept secure and confidential. Access is granted to a limited number of responsible staff. To maintain integrity, impartiality, parity and fairness, we require our people to keep tender information confidential. At our Royal brand hotels, we provide professional training for employees regarding the Competition Ordinance and our anti-competition policies. This year, we organized a seminar on Hong Kong Competition Law for our hotels’ suppliers and contractors. Some hotels conducted routine sampling and review of supplier contracts and tender documents to identify potential competition-law issues. During the reporting year We have zero tolerance for corruption, bribery, money laundering, extortion, anti-competition, fraud, false declarations and other malpractices throughout the supply chain. The Supplier Code of Conduct – available on our online vendor platform – clearly outlines our business-ethics standards for suppliers and contractors. This year, we updated and enhanced the Supplier Code of Conduct. Tendering companies must declare any potential or apparent conflict of interest. Vendors involved in actual or suspected corruption may be suspended from tendering or removed from our tender list. We did not knowingly engage with any suppliers or contractors who violated our anti-bribery and anti-corruption policy during the reporting year. Suppliers, contractors and subcontractors should establish anti-corruption policies and programmes to verify compliance. They are encouraged to report suspicious activity – corruption, anti-competition, fraud, false declarations or other malpractices – to the Group, following our whistleblowing procedure. >6,000 hours >13,000 full-time employees . of anti-corruption training was provided to