CODE of CONDUCT & BUSINESS ETHICS

Chairman’s Message

Mr. Vincent H. S. LO

Shui On encourages staff members to live our corporate culture, embodying the ideas of community, ownership, learning and enjoyment of work. However, the most important part and the foundation of our culture is our integrity.

This Code of Conduct and Business Ethics gives meaning to our concept of integrity. All staff members now have a clear set of principles and guidelines of how we should act in situations where our integrity may be challenged. These principles will be important to our growth, as they will establish our values and beliefs in the daily behavior of all Shui On people.

I encourage each and everyone of you to embrace this Code of Conduct and Business Ethics to make Shui On a socially responsible company and a good corporate citizen.

December 19, 2007

CODE OF CONDUCT & BUSINESS ETHICS

Shui On Land Limited strives to conduct all business affairs in accordance with the highest business ethics standards, acting as a socially responsible company and a good corporate citizen. This Code of Conduct & Business Ethics sets out basic principles and practices to guide all directors and employees of the Company (including Shui On Land Limited and all its subsidiaries). This Code will also be provided to and should be followed by the Company’s agents and representative

Download Document Ethics Charter

IRREGULARITY REPORTING SYSTEM (IRS)

Any reporting on violation of the Shui On Land Ltd’s Code of Conduct and Business Ethics, and complaints on integrity related matters from staff, vendors, customers, and business partners can be sent directly to the Company’s top management through the following channels. Any such reporting will be treated seriously and confidentially by the Company provided that it is made in good faith and properly documented. The Company will not take any retaliating action against such reporting.
Reporting are classified as follows:

Tier 1

Reporting related to members of the Executive Committee of the Company, executive directors or above of the Company, executive directors of Shui On Development Ltd, and members of the Company’s Ethics Committee.

Tier 2

Reporting related to those other than in Tier 1
The members of the Shui On Land Ethics Committee are listed as below:

Name
SOL Title
Email Address

Willie Uy
Chairman of SOL Ethics Committee appointed by SOL EXCOM
willie.uy@shuion.com.cn

Stephanie Lo
Executive Director
stephanie.lo@xintiandi.com

Jessica Wang
Executive Director, Chief Executive Officer
jessica.wang@shuion.com.cn

Allan Zhang
Managing Director
allan.zhang@shuion.com.cn

Douglas Sung
Executive Director, Chief Financial Officer, Chief Investment Officer
douglas.sung@shuion.com.cn

Secretary of SOL Ethics Committee:

Helen Chen
Director of Human Resources
helen.chen@shuion.com.cn

Reporting Channels:

1. Email Hotline

For Tier 1 Reporting
Email Address: irsx@shuion.com.cn
For Tier 2 Reporting
Email Address: irs@shuion.com.cn

2. Telephone Hotline Telephone Number: 86-21-53829390

Irregularity Reporting Policy (RAR)

TRAINING AND ANNUAL DECLARATION

Ethics Training

New staff have to go through an introduction to ethics in their orientation, and have to join an ethics training session conducted by a member of the Ethics Committee or from senior management upon completion of their probation. In early 2011, more than 40 designated staff were appointed as Ethics Experts of the Company, and underwent appropriate training by the ICAC of Hong Kong. Their mission is to further enhance the ethical awareness and standard of the Company through providing coaching and training to other staff.

Annual Declaration

Starting from 2011, before the end of each year, all managers and above, together with some selected staff, must complete an ethical e-course. Upon completion they have to make an on-line declaration of their commitment to abide by the Company’s Code of Conduct and Business Ethics in all their business dealings on an annual basis.