We believe that strong governance and responsible operational management lie at the heart of a resilient business. Therefore, we are committed to enhancing the resilience and reliability of our operating systems and we promote the highest standards of integrity and professionalism in everything we do. This commitment not only ensures compliance with laws and regulations in where the Group operates but also fosters stakeholders’ confidence and trust in our markets and services.

We continuously invest in technology and infrastructure, ensuring a resilient operating model for a fair and orderly market. Complementing a robust governance framework, we embrace a culture of responsibility, transparency and accountability across our operations through our business ethics and risk management policies, training and tools. Our Code of Conduct, together with other internal policies, outlines the ethical and behavioural standards we expect of our employees. Throughout the year, we organise mandatory refresher training and targeted sessions on business ethics and risk management topics, reinforcing the importance of upholding public interest, our corporate values and responsibilities.

Prevention of Financial Crimes

The Group Prevention of Financial Crime Policy outlines our approach to properly identifying and appropriately managing money laundering, terrorist financing and the proliferation financing risks. It sets out our roles and responsibilities, and control measures in different scenarios when dealing with market participants, members or persons who have applied to become market participants or members, or any person/entity which has a business relationship with the Group.

Anti-competitive Behaviour

We comply with applicable anti-competition laws and regulations in where we operate. As HKEX and its exchanges and clearing houses are subject to Section 76 of the Hong Kong Securities and Futures Ordinance, any introduction of new fees and amendment to fees are subject to the approval of the Securities and Futures Commission of Hong Kong (SFC). In 2001, HKEX signed a regulatory MOU with SFC which requires that any fee proposal submitted to the SFC must be supported by a comparison of the fees charged by exchanges and clearing houses in other jurisdictions where appropriate. The MOU specifically states that the primary objective of the fee mechanism is to ensure that HKEX does not abuse a monopoly position by charging excess or predatory fees or by discriminating against a particular participant.

Employment and Labour Practices

The Group has not identified any operations that constitute a risk to the right to exercise freedom of association or collective bargaining. Employees’ freedom of speech and association are respected as long as they are exercised in accordance with all applicable laws and regulations. All employment with HKEX is voluntary and HKEX strictly complies with the applicable employment laws and does not employ any child labour. 

Third-party Sustainability

At HKEX, we believe that maintaining a responsible and ethical supply chain is crucial for long-term business success, as it not only reduces our environmental impact but also enhances operational resilience and promotes sustainability throughout the business community. Alongside the Procurement Policy, suppliers are required to comply with the HKEX Supplier CSR Code of Conduct, which mandates our expectations relating to our supplier’s approach to business ethics, occupational health and safety, human rights, labour practices, and environmental protection.