Ensuring regulatory compliance

SMG’s business ethics and compliance principles are set out in our CoC, supported by additional policies. The CoC outlines expected behaviours and principles, including prevention and management of conflicts of interest, prohibition of bribery and corruption, safeguarding of confidentiality and data protection, promotion of appropriate personal conduct and workplace safety, commitment to diversity and equal opportunities, prevention of discrimination, and upholding human rights. These business ethics risks are addressed through the implementation of our CoC and related governance mechanisms.

Approved by the BoD, the CoC applies to all employees, including those of our controlled subsidiaries, as well as all members of the BoD. It is publicly accessible at https://swissmarketplace.group/esg.

Internally, the CoC and associated policies are made available to all employees, with updates communicated through multiple channels, such as the legal news section on our intranet. We take any potential breaches of the CoC, internal directives, policies, or guidelines very seriously and implement appropriate corrective measures when necessary.

Regulatory compliance at SMG is overseen by the Group Compliance Officer (GCO), an independent function from the ELT. Additional specialised employees may be designated to ensure compliance in specific legal areas, such as data protection, information security, cybersecurity, and antitrust law. The GCO’s responsibilities include, among other things, ensuring that managers and employees adhere to regulatory requirements and assessing potential legal, reputational, or financial risks. Appointed by and accountable to the BoD, the GCO reports to the Chairman of the RAC. Regular updates on compliance, legal, data protection topics are provided to both the RAC and the ELT as part of the Compliance Update. The BoD receives ad-hoc updates on any critical issues, emerging compliance matters including cybersecurity, and other relevant developments. For more information, refer to the section Empowering sustainability: Our sustainability governance framework at a glance. During the reporting period, eight critical concerns were reported to the RAC and BoD. These related to various compliance topics and were addressed in line with internal protocols, with appropriate follow-up measures initiated. Further details on selected cases are provided in the relevant sections of this report.

SMG has implemented policies to ensure clear processes and to prevent and manage potential conflicts of interest. We actively avoid situations and circumstances that create actual or perceived conflicts between personal, private, or business interests and those of SMG, including cases involving individuals with close personal or professional ties. Potential conflicts of interest are disclosed as soon as they become known. Together with supervisors, Human Resources, Legal Services, or the GCO, we seek solutions that are in line with SMG’s internal guidelines.