Our approach to sustainability recognises the interconnectedness of climate change, nature and biodiversity, all of which are essential for the wellbeing of both society and the environment.
People cannot thrive without healthy ecosystems and a stable climate, which is why governments and corporates need to act ambitiously on climate and nature together.
The interdependence of climate, nature and biodiversity is undeniable – changes in climate significantly affect an ecosystem’s ability to sustain biodiversity and regulate climate disturbances. Recognition of these interconnections is crucial to understanding the risks, opportunities and financial implications associated with climate- and nature-related issues. Adopting a holistic approach to managing climate- and nature-related risks and opportunities enhances our decision-making and strategic planning processes, while the transparency of this strategy will provide stakeholders along the value chain with the necessary information to make informed decisions that align with our sustainability objectives.
Climate-related Disclosures
International Financial Reporting Standards (IFRS) S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures, inaugural standards published by the International Sustainability Standards Board in 2023, align with the four main recommendations and eleven suggested disclosures put forth by the Task Force on Climate-related Financial Disclosures (“TCFD”), with additional requirements such as industry-specific metrics.
The Hong Kong Institute of Certified Public Accountants (“HKICPA”) has developed Hong Kong Sustainability Disclosure Standards that alignment basis with the ISSB Standards. The HKFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and HKFRS S2 Climate-related Disclosures were published in 12 December 2024. To align with the Hong Kong Roadmap on Sustainability Disclosure and the HKFRS Sustainability Disclosure Standards, Swire Properties now discloses our climate-related risks and opportunities outlined in HKFRS S2, making reference to the ISSB Standards. We have also begun to report on sector specific metrics as defined by the International Sustainability Standards Board (“SASB”).
Our disclosures in this chapter are also in accordance with the Part D: Climate Disclosure in Appendix C2 of the Main Board Listing Rules Environmental, Social and Governance Reporting Code (“HKEX ESG Code”).
Nature-related Disclosures
Swire Properties is one of the 40 global taskforce members of the Task Force on Nature-related Financial Disclosures (“TNFD”). We provide strategic direction to the TNFD Secretariat regarding the development, consultation and dissemination of the TNFD framework. We are also one of 320 global companies that joined the inaugural TNFD Early Adopter programme, committing to publishing our TNFD-aligned disclosures in our Sustainability Report 2024. This section discloses Swire Properties’ nature-related impacts, dependencies, risks and opportunities based on the TNFD framework, and the TNFD sector guidance for the engineering, construction and real estate industries.
Our Approach to Climate and Nature
In this report, we have prepared our climate- and nature-related financial disclosures under the four pillars of Governance, Strategy, Risk Management, and Metrics and Targets, as set out in the IFRS S2, HKEX ESG Code and TNFD recommendations.
This section has followed the general requirements set out in IFRS-S1 for disclosing material information about the climate and nature-related risks and opportunities that could reasonably be expected to affect the Company’s prospects. Materiality is defined as, if omitting, misstating or obscuring such information could reasonably be expected to influence decisions that stakeholders make on the basis of this report. All sustainability KPIs disclosed do not have material effect on the Group’s financial position, cash flows or access to capital over the short- to medium-term.
Since 2018, we have been analysing risks and opportunities to understand how climate-related risks, including both physical and transition risks, may impact our business operations and our stakeholders along the value chain. We assess and disclose potential climate-related risks and opportunities in our business development planning, facility management and enhancements and day-to-day operations. We also conduct specific physical climate risk assessment and climate resilience studies for our new projects under development. In addition to our climate scenario analyses, in 2023 we adopted the TNFD’s LEAP (“Locate, Evaluate, Assess and Prepare”) approach to analyse our nature-related risks and opportunities.
We aim to continuously deepen our understanding of the potential financial impacts that may arise from physical and transition risks and opportunities related to climate and nature. In 2024, we piloted the evaluation of nature-related dependencies, impacts, risks and opportunities for key construction materials used in our building construction, including steel and concrete. The results informed the development of our 2030 and 2035 KPIs, addressing the management of climate- and nature-related risks and opportunities of our portfolio, and the development of targeted approaches to enhance resilience and improve resource circularity. This knowledge will also support efforts to engage stakeholders effectively, communicate our sustainability initiatives and align procurement practices with industry best practices.
This section outlines our approach to identifying, assessing and managing climate- and nature-related risks and opportunities. We seek to provide integrated disclosures that include metrics and standardised qualitative disclosures to evaluate how climate- and nature-related matters and the associated risks and opportunities affect our business.
Swire Properties’ governance around climate- and nature-related risks and opportunities
HKEX ESG Code Part D Para 19 (a)
Board of Directors
HKEX ESG Code Part D Para 19 (a) (ii), 19 (b) (i) (ii)
Our Board of Directors (“the Board”) is responsible for setting and approving our sustainability strategy. The Board reviews and approves the Sustainability Report, materiality assessment results, sustainability related policies and targets. Responsibility for achieving the Company’s sustainability objectives and implementing the strategy on a day-to-day basis is delegated to the Environmental, Social and Governance Steering Committee (“ESGSC”). The ESGSC reports material SD issues and the progress made towards our 2025 and 2030 key performance indicators to the Board. The Board met [six] times in 2025. The Board discussed the Group’s progress towards meeting the decarbonisation and other ESG targets under SD 2030 Strategy, performance in key sustainability indices, regulatory developments towards sustainability, climate- and nature-related and other key ESG matters regularly at each board meeting.
The Board of Directors acknowledges its responsibility in guiding the Company’s approach to environmental, social, and governance issues. In exercising its oversight responsibilities, the Board considers these risks and opportunities when reviewing the Company’s strategy, major transactions and risk management processes, including evaluating the trade-offs associated with sustainability-related risks and opportunities.
The Board also oversees the establishment of targets linked to ESG-related risks and opportunities (including those associated with climate and nature), diligently monitoring progress towards these targets.
The Board ensures that the Company has, or will develop, the necessary skills and competencies to oversee the ESG strategy and reporting framework designed to address ESG-related risks and opportunities (including those associated with climate and nature). The Board maintains sufficient knowledge of ESG issues through the provision of training on ESG matters (including developments on sustainability and climate-related risks and opportunities), as well as ESG-related regulatory updates. The training ensure that the Board remain aware of the potential impacts of such issues on the Company's business and operations. In 2025, the Board received a dedicated training session focused on ESG regulatory updates. The session provided an overview of the evolution of sustainability reporting with a particular focus on ISSB S1 and S2, highlighting the key principles of sustainability-related and climate-related financial disclosures. It also discussed alignment with existing frameworks such as the GRI Standards and the GHG Protocol and outlined regulatory convergence with HKFRS S1 and S2 and the latest HKEX ESG Code updates, including the implementation timeline for required disclosures.
The Board of Directors has appointed the Audit Committee to oversee the Company’s financial reporting, risk management, internal control systems and ESG-related matters. On behalf of the Board, the Audit Committee annually reviews the continued effectiveness of the Group’s risk management and internal control systems dealing with risk and financial accounting and reporting, the effectiveness and efficiency of operations, compliance with laws and regulations, risk management functions and ESG-related policies, practices and matters. The Chair of the ESGSC reports relevant SD matters, including climate- and nature-related issues, to the Board four times per year.
Our corporate risk register incorporates ESG-related risks, including climate- and nature- related risks. We have also integrated SD factors into our corporate risk analysis. The Company’s Remuneration Policy differentiates pay based on performance goals, with the performance rating serving as a key factor in determining an employee’s overall compensation. Our Chief Executive, relevant strategic leaders and the general managers of our portfolios, have established corporate SD performance metrics and targets, in areas such as health and safety and decarbonisation, which are linked to variable compensation.
Environmental, Social and Governance Steering Committee
HKEX ESG Code Part D Para 38
Responsibility for achieving the Company’s sustainability objectives and implementing the strategy is delegated to the ESGSC, which is chaired by our Chief Executive. Other members are the Chief Financial Officer and six strategic leaders from the Human Resources, Portfolio Management (Office), Portfolio Management (Retail), Projects, Public Affairs and Facilities Management and Sustainable Development departments and an Independent Non-Executive Director, who is the Chair of our Audit Committee. The ESGSC meets not less than four times a year.
The ESGSC oversees six dedicated SD 2030 working groups – Places, People, Partners, Performance (Environment), Performance (Economic) and SD Communication and Engagement – which are chaired by the respective members of the ESGSC. The working groups are tasked with the day-to-day execution of sustainability-related policies and initiatives as well as the attainment of specific targets within their areas of focus. Please refer to the respective Pillar sections for more details.
The ESGSC meets at least quarterly. In accordance with its Terms of Reference, which were updated in March 2025, the ESGSC is responsible for:
- Reviewing, and suggesting any changes to, the Company’s SD Strategy with respect to ESG matters, including reviewing targets or key initiatives recommended by the working groups.
- Ensuring that the Company’s operations and practices are carried out in line with the ESG Strategy.
- Reviewing on an annual basis the performance of the Company in achieving targets approved by the Board or key initiatives recommended by the working groups.
- Reviewing any significant risks, opportunities or investments that exist in connection with the implementation of the ESG Strategy.
- Keeping abreast of ESG-related market developments and regulatory updates.
- Overseeing the internal carbon pricing mechanism and project approval, and reviewing the performance of approved projects.
- Reviewing the Sustainability Report, materiality assessment results, sustainability-related policies and targets with relevant materiality for further submission for the Board of Directors’ approval.
- Through its Chair, reporting relevant matters of significance relating to sustainable development and ESG to the Board.
The ESGSC’s climate- and nature-related responsibilities include the formulation and review of climate and nature policies and strategies. This involves evaluating targets and key initiatives focused on climate change mitigation and adaptation, as well as building resilience against climate and nature transitions. The committee assesses significant risks, opportunities and investments related to climate change, energy and carbon management, low-carbon transitions and nature. It also conducts an annual review of the Company’s performance in achieving energy intensity reduction and decarbonisation targets, monitoring progress toward science-based targets and other climate- and nature-related KPIs.
The Company’s Remuneration Policy is designed to align employee compensation with our strategic priorities and performance outcomes. We integrate specific SD performance metrics and targets directly with the variable compensation of our Chief Executive, EXCOM members, relevant strategic leaders, and the general managers of our portfolios. This includes members of the ESGSC.
This performance-based approach ensures that the variable compensation for our Chief Executive, EXCOM members, relevant strategic leaders and general managers is meaningfully linked to the achievement of climate-related targets, such as decarbonisation and health and safety. By embedding these objectives into individual performance appraisals, we ensure that our sustainability ambitions are reflected in their variable compensation outcomes and integrated into our corporate accountability structures.
Our decarbonisation goals are tied to annual improvements in the energy use intensity performance of our existing portfolio and new developments, in order to lead the Company’s efforts to accelerate progress towards achieving our SBTs, driving measurable energy and carbon reduction and contributing to the achievement of the Company’s Net Zero 2050 Vision. For example, our general managers have a balanced scorecard to monitor their performance around energy and water management, staff turnover rate and training hours and performance targets related to energy management in their respective portfolios.
The ESGSC maintains sufficient knowledge of ESG issues through the provision of training on ESG matters (including developments on sustainability or climate-related risks and opportunities), as well as ESG-related regulatory updates. The training ensures that the ESGSC remains aware of the potential impacts of such issues on the Company's business and operations. In 2025, the ESGSC was informed about such topics as the latest global trends in ESG, the evolution of sustainability indices, ESG standards and regulatory updates (e.g. IFRS S1 and S2) and updates to the Company’s climate risk register.
In late 2024, the ESGSC held a comprehensive refresh of Swire Properties’ Sustainable Development vision and strategy to ensure our continued ambition and alignment with global trends. This multi-phase process included benchmarking and ideation workshops, organisation-wide engagement to refine strategic priorities, external and internal validation of proposed goals and final approval of the updated strategy framework and KPIs by the ESGSC, Audit Committee and Board. Please refer to the “SD 2050 Strategy” section for more details.
SD Working Groups
Each Pillar is supported by a working group. In 2025, there were six SD working groups that continued to work on the KPIs and future targets set for each Pillar for 2030 and 2035. These are:
- The Places Working Group, chaired by the Director, Office.
- The People Working Group, chaired by the Director, Human Resources.
- The Partners Working Group, chaired by the Deputy Director, Projects (HK & SE Asia).
- The Performance (Environment) Working Group, chaired by the General Manager, FMSD.
- The Performance (Economic) Working Group, chaired by the Chief Financial Officer.
- The Sustainable Development Communication and Engagement Committee, chaired by the Deputy Director – Public Affairs.
The members of each working group are carefully selected to ensure the inclusion of employees with diverse backgrounds, types of expertise and varying levels of seniority. The Performance (Environment) Working Group met four times in 2025 to discuss climate- and nature-related matters.
The SD Communication and Engagement Committee
Our SD Communication and Engagement Committee identifies, prioritises and oversees the implementation of communication and engagement plans for initiatives that support our SD 2030 Strategy. This Committee also includes representatives from distinct functions within the Company.
We regularly engage with our stakeholders to understand their priorities, expectations and perceptions regarding SD issues, including climate and nature-related matters. In 2023, we conducted a double materiality assessment review to gather feedback from over 600 internal and external stakeholders through qualitative interviews and a quantitative survey. The topics of green building construction and renovation, energy efficiency, decarbonisation and climate adaptation and resilience were identified as material issues to our business continuity and development. A significant shift was observed in stakeholders’ perceptions towards biodiversity, highlighting its increasing impacts on the environment, society and our business. These issues are consistent and have been incorporated into our SD Strategy.
Our Stakeholder Engagement Strategy focuses on reputation management, engaging key stakeholders including government entities, media outlets and community organisations. This strategy is built around four key pillars:
- Government relations: Strengthening partnerships and communication with government bodies to advocate for sustainable practices and policies.
- Media relations: Enhancing our presence and narrative in the media to effectively communicate our sustainability efforts and achievements.
- Internal communications: Fostering a culture of transparency and engagement within the Company to ensure all employees are informed of and involved in our sustainability goals.
- Community engagement: Building strong relationships with local communities to support and promote our sustainability initiatives and gather valuable feedback.
Sustainability Policies
We recognise the risks and opportunities presented by climate change and nature degradation to our business. We have a suite of sustainability-related policies in place that allow the Company to respond to the effects of climate change and protect nature and local communities.
Sustainable Development Policy
Swire Properties aims to be a leader in sustainable development in the real estate sector by 2030. Our focus is on reducing carbon emissions, minimising waste, using water responsibly and protecting natural resources.
Environmental Policy
The policy outlines principles for managing and minimising the environmental impacts of operations, using a comprehensive building lifecycle approach to assess environmental risks. It promotes environmentally responsible actions among stakeholders, suppliers and partners, indicating preferences based on the environmental performance of suppliers and contractors during procurement.
Climate Change Policy
We are committed to communicating our management approaches and strategies for climate mitigation, adaptation and resilience to our stakeholders. Our Climate Change Policy details our strategy to mitigate climate risks and enhance resilience.
Energy Policy
Our Energy Policy aligns with ISO 50001 requirements and focuses on a new energy management approach that prioritises demand reduction through an energy management hierarchy. It commits to increasing renewable energy use by promoting on-site generation, purchasing off-site renewable energy and other methods. The policy also emphasises influencing energy-related behaviour by engaging with tenants, employees, and collaborators.
Biodiversity Policy
Swire Properties recognises that there are biodiversity risks to our business and integrates nature and biodiversity considerations into our developments and operations. Most projects are in urban areas, and assessments of our direction operation show no significant impacts on global or national sites of high biodiversity importance.
Water Policy
Our Water Policy cites our commitments around the responsible use of water. These include understanding the water risks in places where our developments are located; reducing water consumption intensity through improved design; implementing efficient water management measures during operations; ensuring that water is discharged into the environment safely; and engaging our stakeholders to encourage the responsible consumption of water.
Resource and Circularity Policy
This policy guides our approaches to reducing waste, from the design and construction phases of our projects to the daily operation and management of our buildings.
Human Rights Policy
We uphold human rights in our operations and supply chains, and encourage our partners to do the same. Our policy aligns with international human rights standards, including the UN Guiding Principles and the International Labor Organization’s Declaration.
Supplier Code of Conduct
This policy sets out the minimum standards and practices for our suppliers relating to legal and regulatory compliance, environmental protection, health and safety, labour practices and other areas.
All policies are reviewed from time to time as appropriate, and at least once every three years.
