For over 190 years, the Swire group of companies has been recognised as acting responsibly in the course of achieving its commercial success. Our reputation for fair dealing and integrity is a great asset: preserving this asset depends on maintaining our high standards. Compliance with this Code is an essential part of our doing so.

This Code applies to all Relevant Persons and is applicable wherever Swire does business. In the case of joint ventures, the Swire representatives involved/concerned are expected to act in accordance with this Code themselves and to use reasonable endeavours to influence those with whom they are working to ensure they also act to similar standards of integrity and ethical behaviour.

We take ethical behaviour and the importance of upholding the integrity of our brand and reputation seriously. This policy provides a framework to promote responsible and secure whistleblowing without fear of adverse consequences, in accordance with our Corporate Code of Conduct.

Swire Bulk aims to create long term value for our shareholders. Achieving this depends on the sustainable development of our businesses and the communities in which we operate.

To achieve sustainable development, we aim:

• To achieve net zero impact on the environment;
• To cause zero harm to our stakeholder communities and assets under our stewardship;
• To excel as corporate citizens

Swire Bulk is committed to a target of zero pollution incidents, and our ultimate goal is for our operations to have a zero net impact on the environment. The protection of the environment and the effective monitoring of a business’ impact on the environment are all criteria that every Corporate Citizen must strive to meet. Swire Bulk is committed to being an industry leader capable of innovating and improving standards in line with our reputation for best-operating practices in the industry.

Biodiversity is vital to maintaining a resilient natural environment and a resilient natural environment is vital to the sustainable development of Swire Bulk.

It is our policy that Swire Bulk will pay due regard to biodiversity considerations in our operations. Swire Bulk will identify key biodiversity risks and take steps to mitigate them.

Swire Bulk must take adequate steps to build its resilience to climate change by identifying and managing climate change risks and opportunities and by developing strategies in line with global best practices to adapt to and mitigate the impact of climate change on its operations and businesses.


It is the policy of Swire Bulk to take adequate steps to build its resilience to climate change through adequate mitigation, adaption and by building adaptive capacity. In the process of this, Swire Bulk will seek technical assistance where required from the Swire Pacific Sustainable Development Office and the Climate Resilience Working group.

Swire Bulk takes its obligations with regard to the elimination of modern slavery, wherever it may be present, very seriously. Swire Bulk will not tolerate the practice of modern slavery in any form and is committed to continue to work with all of its stakeholders and relevant regulators to combat this issue, wherever and whenever it may become aware of it.

Swire Bulk is committed to ensure that there is no modern slavery in our supply chains or in any part of our business. We have put in place a number of compliance processes to prevent, detect and eradicate any incidences of modern slavery, as laid out in:

• UK Modern Slavery Act (2015)
• Australia Modern Slavery Act (2018)
• Other relevant laws and regulations

Read more here.

As a socially and environmentally responsible company, Swire Bulk and/or its group companies and/or subsidiaries is committed to taking a more sustainable development path for ourselves and future generations. We recognise the importance of conserving, and where possible enhancing, species diversity and that we have a responsibility not to facilitate trade in any flora or fauna or their produce that may threaten the sustainability of any species.

Coal supplies about a quarter of the world’s primary energy and two-fifths of its electricity. However, the extraction and use of coal causes many premature deaths and much illness. The use of coal as fuel also damages the environment, including by climate change as it is the largest anthropogenic source of carbon dioxide. To meet the Paris Agreement target of keeping anthropogenic global warming to “well below 2°C”, usage of coal needs to halve from 2020 to 2030.


As a key player in the shipping value chain, it is incumbent on Swire Bulk to work in step and consider our support for the carriage of thermal coal cargoes, and concurrently support initiatives to accelerate the global transition towards a low carbon economy, as part of our on-going due diligence and social responsibility policy.


The business has set our own internal targets to phase out the carriage of thermal coal, in a manner that supports a just and equitable transition for individuals and communities in the markets we service.

Introduction

All companies in which Swire Bulk has a controlling interest, its affiliates and subsidiaries should commit to sustainable purchasing and give preference to sustainable products. The commitment should include identifying, selecting and purchasing products (i.e. goods and services) with significantly less adverse environmental and social impacts than alternative competing products.

Associated and Jointly Controlled companies are encouraged to follow this policy.

Procedures

The Swire Bulk  Purchasing Manager will establish administrative procedures relating to this Policy and will be designated the responsible party to communicate and implement the policy and admin procedures, including explaining to all affiliates, subsidiaries and external parties the reason for the implementation.


The following factors should be considered, where appropriate, during procurement:

• Minimal use of virgin material in the product
• Replacement of disposables with reusables or recyclables
• Minimal environmental impact from the entire product or service life cycle
• Minimal packaging or elimination of packaging
• Reduced energy /water consumption
• Toxicity reduction or elimination
• Durability and maintenance requirements (avoid single-use disposable items)
• Waste disposal considerations (high recyclability)

 Preference should be given to suppliers which have:

• A policy stating their sustainability values and commitments
• Sustainability certificates or awards
• Sustainability management systems or quality management systems that incorporate environmental and social considerations
• Full compliance with the Supplier Code of Conduct and all applicable environmental and social regulations and legislation

EXPLANATORY NOTES

As a company we strive to be good stewards of the natural resources and biodiversity under our influence. We prefer to work with suppliers and contractors including financial institutions, consultants and professional advisors who promote sustainable development through their own business activities. When procuring products and services, due consideration shall be taken into account to optimise the benefits in terms of the environment, social impact and cost, both from the point of view of the general public good and from enlightened self-interest.

Sustainable procurement helps achieving actual environmental and social benefits, promoting public awareness on sustainability issues and encourages manufacturers to introduce environmentally and socially responsible products.

Swire Bulk has a Policy that all ships at the end of their economic lives will be recycled in a sustainable, safe, responsible and environmentally sound manner. This Policy details how this will be assured by Swire Bulk.

This Policy applies to all Swire Bulk group vessels at the end of their economic life that are not sold for onward trading and are thus sent for recycling.

Find out more about our sustainable shipping initiatives.

Our Sustainable Development Policy commits Swire Bulk to high standards on environmental, health & safety, human rights & labour policies, business ethics and community issues. It also commits us to working with suppliers who share the same standards and promote sustainable development.


This Code of Conduct has been explicitly named to closely reflect the goal that we share with all of our suppliers – to make our businesses sustainable.

We actively seek to select and work with suppliers who not only comply with laws and regulations but go beyond by setting standards that are expected of an industry leader.

We also have a strong preference to work with suppliers who share our commitment to honesty and integrity and who seek to integrate principles of sustainable development into all areas of their business.

We are committed to selecting and retaining qualified suppliers that meet this Supplier Code of Conduct.

Swire Bulk shall ensure that they do not support or encourage the production or supply or consumption of unsustainably produced food items. Swire Bulk will ensure that all food purchased for consumption at a Swire Bulk worksite and/or by Swire Bulk employees at a Swire Bulk group or 3^rd party worksite is sustainably produced.

• The Swire Pacific Green Guidelines provide a reference point for operating companies under the Swire group to set standards in areas which impact the environment. They cover:
• Running offices: For example, reducing air-conditioning load by setting indoor temperatures at the highest comfortable level when outside weather is hot and having a dress code which makes this comfortable.
• Consumption of foods from non-sustainable sources at company functions.
• Organising company events, meeting and conferences.

Purpose

Social networking through the use of Internet-based and other electronic social media tools is now part of our everyday lives. The lines between work and personal life have become increasingly blurred.

You have participated in social media if you have:

• Posted a comment on a blog
• Posted a status update on Facebook
• Tweeted anything
• Created a LinkedIn profile
• Posted a review or rated a product

Swire group companies which are using social media for marketing activities will already have developed relevant policies or guidelines. This set of guidelines addresses areas of concern in your personal social networking conduct and covers all (and emerging) social media platforms including but not limited to:

• Social networking sites (Facebook, Myspace, Foursquare, LinkedIn)
• Micro-blogging sites (Twitter, Weibo)
• Blogs (including company and personal blogs as well as comments)
• Video and photo sharing websites (Flickr, YouTube)
• Forums and discussion boards (Google Groups, Yahoo! Groups)
• Online encyclopedias (Wikipedia)
• Personal use of social media

In your personal use of social media, you should assume that you will be identified as a Swire employee. You should always keep the following in mind:

• Refrain from posting items that could reflect negatively on the Swire group, or otherwise embarrass the group and its companies.
• Never disclose information that is confidential or proprietary to the company, or to any third party that has provided information to us (e.g. a supplier). Get permission from the content owner prior to sharing or publishing their intellectual property, and get permission before publishing or reporting on meetings and conversations that were meant to be internal.
• Please obtain permission from your supervisor or management before publishing any conversations or information that were meant to be internal.
• Do not make implicit or explicit reference to your colleagues, business partners, or suppliers without their approval.
• Respect the privacy of your colleagues, business partners, and suppliers. Do not post photos of them without their approval.
• Keep in mind that posts are visible to all with online access. Think of what you write in the same way as things that you might say to a journalist, or to people you don’t know. If you would not say it in those situations, do not say it online.
• Do not use the Swire logo, unless specifically authorised to do so.
• Ensure that your social networking conduct is consistent with all policies contained in the Swire Code of Conduct.
• Respect the law, including those laws governing defamation, discrimination, harassment, data privacy, copyright and fair use.
• Show proper respect for people’s privacy and for topics that may possibly be considered objectionable or inflammatory, such as politics and religion.
• Make sure that your online activities do not interfere with your job performance.
• If you explicitly identify yourself as a Swire employee when you publish something on social media, or if you publish content that is related to your work, you should make it clear that the views you express are yours alone. You may want to use the following disclaimer: The postings on this site are my own and do not necessarily represent the views and positions of my employer”.
• Do not download or install software that you find through social networks on your work computer as it may breach IT security rules.
• Please let your colleagues know (offline) if you see anything they post which could be interpreted as inappropriate and consider suggesting they remove it.

In general, respecting differences, appreciating the diversity of opinions and speaking or conducting yourself in a professional manner is expected at all times. If you are not completely confident about what you intend to share online, you should seek your supervisor’s or management’s advice before you post anything online.