Sustainability Report 2023/24

• If corruption or criminal behaviour is confirmed, prompt reports are made to the Chairman and Managing Director, the Audit and Risk Management Committee, or law enforcement authorities, as appropriate, to determine appropriate action Resolution The Audit and Risk Management Committee holds ultimate responsibility for the whistleblowing policy and mechanism. Implementation of the policy is overseen by the Group Head of Internal Affairs and the Head of Internal Audit. During the reporting period, there were no significant violations of our code of conduct or laws pertaining to anti-corruption and competition. For more details, please refer to the Corporate Governance Report section of our Annual Report 2023/24. Anti-competition SHKP believes fair competition is key to an equitable supply chain. Our Supplier Code of Conduct strictly prohibits suppliers, contractors and subcontractors from engaging in any form of anti-competitive behaviour. We comply with applicable laws and regulations, including Hong Kong’s Competition Ordinance. Strict measures clearly communicated in all our tender documents prevent collusion. As part of the procurement process, vendors submitting tenders must sign a letter of integrity and anti-collusion to confirm that they do not engage in anti-competitive behaviour. We regularly review and update our list of eligible companies to eliminate practices such as bid-rigging. Only qualified and approved companies on the list are invited to participate in tendering, and we monitor the number of applicants to ensure a competitive bidding environment. Sanfield’s e-tendering provides suppliers and contractors with a secure digital platform to access and submit documents. All tender information is confidential and accessible only to authorized staff. To raise awareness of competition laws and regulations, Hong Yip encourages its approved vendors to participate in the Webinar on Competition Ordinance. Our Royal brand hotel employees receive regular training on the Competition Ordinance and its policies. During the reporting year, we hosted seminars on Hong Kong Competition Law for our hotels’ suppliers and contractors. Some of our hotels performed routine sampling and review of supplier contracts and tender documents to detect any issues related to competition law. Quarterly meetings with management are also held to discuss any concerns and ensure compliance with competition law policies. • Employees may raise or report concerns through suggestion boxes or our grievance procedure, or by informing their supervisors • Whistleblowers’ anonymity is guaranteed during investigations Reporting • All reports are treated seriously and investigated thoroughly • Whistleblowers are protected from any form of intimidation and retaliation • If an investigation is deemed necessary, the findings and recommendations are communicated to the Chairman and Managing Director • The Audit and Risk Management Committee assesses significant issues reported in the investigation Investigation Our Whistleblowing Procedures Sun Hung Kai Properties Limited | Sustainability Report 2023/24 < 82 > Our Reporting Approach Message from the Sustainability Steering Committee Our Business Our Approach to Sustainability Value Created for the Environment Value Created for People Value Created for Customers Value Created for Supply Chain Value Created for Community Appendices