Business Ethics

Code of Conduct

At CITIC, we are committed to upholding “The CITIC Spirit 中信風格” which is the cornerstone of our corporate culture, and also the fundamental code of the Company for guiding the business practice and conduct of our people:

Under the CITIC Spirit, we consider an ethical corporate culture and employees’ honesty and integrity to be important assets. We endeavour to comply with the laws and regulations of the countries in which we operate, and all directors and employees are required to act responsibly to ensure that the reputation of the Company is not tarnished. To uphold a high standard of integrity in all aspects of everyday activities, the Company has adopted a code of conduct which provides employees with a set of defined ethical standards for adherence. To ensure all new and existing employees fully understand the code of conduct and major applicable laws and regulations, training and briefing sessions were conducted in 2014. As part of the initiative to further enhance the internal control of the Company and to protect the reputation and interest of the Company, we are now in the process of revising the code of conduct which all the employees are required to strictly abide by, whilst adhering to all applicable laws and regulations.

Whistle-blowing policy

CITIC considers the whistle-blowing channel a useful means of identifying possible misconduct or fraud risks of the operation or function by encouraging employees to raise concerns in good faith. The audit and risk management committee is responsible for ensuring that proper arrangements are in place to facilitate employees reporting on whistle-blowing matters, and that proper follow-up actions are taken. Meanwhile, the Company is in the process of revising the whistle-blowing policy in order to further enhance the governance processes of the Company and its business units, and to prevent inappropriate conduct from harming the interest of the Company and its shareholders.

Inside information/price sensitive information disclosure policy

The Company has adopted an inside information/price sensitive information disclosure policy setting out the practices and procedures for monitoring business and corporate developments and events so that any potential inside information/price sensitive information is promptly identified and relayed to the board to enable it to make timely decisions on disclosure, if necessary, and for taking appropriate measures to preserve confidentiality of inside information/price sensitive information until proper dissemination of the inside information/price sensitive information via the electronic publication system operated by the Stock Exchange.

Good employment practices

In Hong Kong, the Company has broadly followed the guide to good employment practices issued by the Employers’ Federation of Hong Kong to ensure legally compliant, non-discriminatory and professional employment practices are implemented.

Directors’ and relevant employees’ securities transactions

The Company has adopted the model code for securities transactions by directors of listed companies (‘model code’) contained in Appendix 10 to the Listing Rules. All directors confirmed that they have complied with the required standard set out in the model code throughout 2014. The interests held by individual directors in the Company’s securities as at 31 December 2014 are set out in the Report of the Directors on pages 124 to 125.

In addition to the requirements set out in the Company’s code of conduct, the joint company secretaries regularly write to executive management and other relevant employees who are privy to unpublished price sensitive information, as reminders of their responsibility to comply with the provisions of the model code and keep the matter confidential until announced. They are also specifically reminded not to engage in any insider dealings as stipulated under Section 270 of the Securities and Futures Ordinance.