Code of Conduct
We are committed to upholding “The CITIC-Style 中信風格” which is the fundamental code of the Company for guiding the business practice and conduct of our people:
| Compliance | 遵紀守法 |
| Integrity | 作風正派 |
| Veracity | 實事求是 |
| Innovation | 開拓創新 |
| Modesty | 謙虛謹慎 |
| Cooperation | 團結互助 |
| Diligence | 勤勉奮發 |
| Efficiency | 雷厲風行 |
We think highly of employees’ integrity, morality and professional integrity. The company’s Code of Conducts requires employees to strictly obey the laws, regulations and disciplines in their operational activities. It is a code that the employees must abide by and a standard for assessing professional conducts of employees. In 2024, we organised trainings in terms of professional integrity, anti-fraud and anti-corruption based on the types of industries and levels of posts. Various publicizing platforms including the internal network, official accounts of Wechat and APP were utilised to educate and guide employees to establish and maintain their excellent conducts and behaviors. The heads of every branches were required to conduct education, supervision and assessment regarding employees’ conducts. The company developed the system of regular self-criticism to detect the risks to honesty and justice, to investigate and punish all sorts of illegal behaviors, to analyse and evaluate the effective implementation of this system, to propose advices for further improvement and correction, and to stably improve the levels of internal control management.
Code of Anti-Corruption
CITIC Limited upgraded the code of anti-corruption (“Anti-corruption Code”) in December 2022. CITIC Limited believes that honesty, integrity and fair play are important assets. CITIC Limited will respect and adhere to the laws of the countries in which it operates and all directors and employees of the Group must ensure that the Group’s reputation is not tarnished by dishonesty, lack of integrity or corruption. The Group fully supports the global campaign against corruption and has zero tolerance for corruption and any fraudulent practices. The Anti-corruption Code and the code of conduct for employees of CITIC Limited stipulate the Company’s policy on matters of personal conduct of all employees (including directors, employees and anyone working on the business or affairs of the Company). The Anti-corruption Code applies to the Company and to its subsidiaries and all businesses the Company manages or controls wherever they are located.
The audit and risk management committee, with delegated authority from the board, shall review the Anti-corruption Code from time to time, recommend changes and evaluate its effectiveness.
Whistle-blowing policy
CITIC Limited is committed to achieving and maintaining high standards of integrity and ethical business practices. The whistle-blowing mechanism is an important part of the Company’s internal control and risk management system, and an effective way to detect misconducts or significant risks within the Company.
The whistle-blowing policy aims to safeguard the interests and reputation of the Company, to strengthen the corporate governance and internal control, and to prevent acts that harm the interests of the Company and its shareholders. The whistle-blowing policy was updated in December 2022.
The internal whistle-blowing mechanism sets out a series of principles and procedures to (i) encourage the reporting of actual or suspected inappropriate behavior, misconducts or violations occurring within the Company or involving the Company itself or its employees; (ii) guide the Company’s senior management and employees in handling reports in a fair and appropriate manner; and (iii) prevent malicious allegations and protect whistleblowers from retaliation.
The audit and risk management committee, with delegated authority from the board, shall review the whistle-blowing mechanism periodically to improve its effectiveness.
Inside information/price sensitive information disclosure policy
CITIC Limited 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 Hong Kong Stock Exchange.
Good employment practices
In Hong Kong, CITIC Limited has 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
CITIC Limited has adopted the Model Code for Securities Transactions by Directors of Listed Issuers contained in Appendix C3 to the Listing Rules as the code for dealing in securities of CITIC Limited by the directors (“Model Code”). Having made specific enquiry by CITIC Limited, all directors and senior management confirmed that they complied with the required standard set out in the Model Code throughout the year ended 31 December 2024. The interests of directors in the securities of CITIC Limited as at 31 December 2024 are set out in the Report of the Directors.
In addition to the requirements set out in CITIC Limited’s code of conduct, the joint company secretaries regularly write to executive management and other relevant employees who are privy to unpublished inside information/ 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.