Introduction Our business SwireTHRIVE About our report Other ESG disclosures Appendices Overview GGoveoverrnnaannccee Supply chain Talent management Customers Biodiversity OTHER ESG DISCLOSURES Governance We conduct our a昀昀airs in accordance Our representatives in joint venture and All new employees take part in induction with high ethical standards and our associated companies and contractors programmes that include anti-corruption values of integrity, endeavour, excellence, who are hired to conduct business on our training. Additionally, 100% of our humility, teamwork and continuity. We behalf are expected to act in accordance directors completed anti-bribery and must act with probity, transparency and with the Code of Conduct, and in昀氀uence anti-corruption training over the past accountability to achieve our long-term those with whom they are working with to two years. Our operating companies also objectives. Doing this will maximise follow similar standards of integrity and implement their own anti-corruption long-term shareholder value and bene昀椀t ethical behaviour. training programmes for employees employees, those with whom we do The Code of Conduct and anti-bribery and directors. Their approaches to business, and the communities in which training is included in the induction implementing anti-corruption practices we operate. Our core principles include a programme of all employees. Our and training are outlined in their commitment to sustainable development. conditions of employment require respective sustainability reports. compliance with the Code of Conduct. In 2022, there were 29 cases of Our approach whistleblowing and three reports of breaches of the Code of Conduct. Our approach to corporate governance Anti-corruption can be found in our Corporate Governance All cases have been investigated. As at Code, our Memorandum and Articles of The Group complies with the anti- 31 December 2022, two cases have been Association, our Board Diversity Policy, corruption laws of the countries in which resolved and the investigation of one we do business. Our Corporate Code of case remains in progress. None of the and the Swire Paci昀椀c Annual Report 2022. Conduct sets out the Group policy on three breaches of the Code of Conduct We are subject to the Corporate con昀氀icts of interest, competition and in 2022 were material to the Group’s Governance Code in Appendix 14 to The anti-trust, and bribery. Business units 昀椀nancial statements or overall operations. within Swire are required to establish Rules Governing the Listing of Securities The number of breaches to speci昀椀c on The Stock Exchange of Hong Kong their own Code of Conduct which include principles within the Code of Conduct is procedures designed to put these general Limited (Hong Kong Listing Rules). shown below. During 2022, Swire Paci昀椀c For details of our governance of principles into practice. did not have any breaches related to sustainability matters, see Our Approach Our Whistleblowing Policy applies Bribery, Business ethics, Competition and to Sustainable Development. to all employees and others who antitrust, Con昀氀icts of Interest, Gambling, deal with us to raise concerns about Health and safety and the environment, suspected improprieties, or report Political activities and contributions, Business ethics actual improprieties, including potential or Privacy. Our Corporate Code of Conduct requires misconduct, malpractice, or unethical employees to maintain the highest behaviour. Con昀椀dential reports can standards of business ethics and to deal be made to the Group Internal Audit appropriately with each other, those Department via a designated third-party with whom we do business, and the service provider, or to relevant line communities in which we operate. The management or Human Resources with no Code of Conduct includes operating fear of retaliation. principles covering business ethics, con昀氀icts of interest, bribery, procurement, record keeping, whistleblowing, health and safety, the environment, equal opportunities, diversity and respect in the workplace, and privacy. SWIRE PACIFIC — SUSTAINABLE DEVELOPMENT REPORT 2022 — 77