The Group embraces a risk-aware culture and believes that an ingrained risk culture is the key to effective risk management, while training is a useful tool to promote and engage management and employees in ERM implementation. The Group promotes the risk culture with the following key themes:
The Group's ERM Framework aims to enhance the ability to achieve its vision and mission, and fulfil its five core values. In support of this, the Group has established a robust ERM framework with the following risk management objectives:
Risk appetite is defined to establish the extent and nature of risks the Group is willing to take in achieving our vision and mission. The Group’s risk appetite statement is disseminated across the Group and incorporated into our risk assessment criteria in order to align with our business objectives, core values, strategy, as well as risk management activities. The risk appetite statement is reviewed by the Board periodically to keep abreast of the ever-changing business environment and the latest development of the Group. The Group’s risk appetite is as follows:
The overall risk management process is overseen by the Board. With the emphasis on value creation and protection, the Group adopts the Three Lines Model as its risk governance structure. The model clearly defines the responsibilities for enhancing collaboration and communication among different roles, which facilitates alignment of risk management activities and provides assurance to the Board.

Risk management process starts from the establishment of context, by taking into consideration of the external environment and megatrends, as well as risk universe of the Group. Risks are then identified, analyzed, evaluated and treated with measures. With constant review, monitoring, reporting and consultation, the risk management process integrates with various business processes and activities in optimizing the risk and return.
To facilitate a comprehensive and robust risk management process, top-down and bottom-up approaches are employed to gather risk insights as well as to monitor and manage risks from the perspectives of both sides, together with “ERM Policy” and “ERM Procedure” to provide proper guidance. Also, interactive communication between the risk owners and the GRM Team is in place to enable both parties to keep abreast of risk updates.

1. Establishment of Context
The Group defines the internal and external contexts (e.g. corporate objectives, core values, organizational structure, stakeholders, business segments, operating regions, regulatory environment) as well as the parameters for risk assessment criteria.
2. Risk Identification
The Group adopts both top-down and bottom-up approaches, complemented with outside-in and spread-out mechanisms to facilitate a comprehensive risk identification process.
3. Risk Analysis
The Group adopts a two-phased methodology where business units and corporate office departments need to conduct a preliminary risk assessment to sort out key risks for undergoing comprehensive risk analysis, and a diverse spectrum of risk assessment criteria is applied throughout the process covering likelihood, impact, risk velocity, forecast risk movement, inherent risk level and residual risk level.
4. Risk Evaluation
The risk analysis results are compared with the risk appetite and tolerance level. This allows management to determine the risk response strategy for each risk and prioritize risk treatment plans.
5. Risk Treatment
Risk treatment plans for implementing risk mitigation measures are developed by respective business units and corporate office departments, based on the priority and nature of risks.
Continual tracking, review and validation of the implementation of our ERM framework have been in place to monitor various risks, change in risk exposure, their residual risk levels, as well as to ensure and increase the effectiveness and quality of ERM framework and outcomes.
| Top-Down Engagement (Annually) |
The GRM team conducts in-depth risk discussion on emerging political, economic, social, technological, legal and environmental (“PESTLE”) trends in our business context with the senior management of the Group and its business units to obtain their insights on the risk landscape faced by the Group. |
| Bottom-up Risk Register Review (Semi-annually) |
Business units and corporate office departments perform review of the risk assessment and risk treatment plans, and submit Risk Registers to the GRM team for consolidation into the aggregated risk profile of the Group. |
| Key Risk Indicator Monitoring (Quarterly reporting, with immediate notification of any exceedance upon detection) |
The Group adopts a two-tier KRI structure comprising Principle KRIs and Agile KRIs to monitor changes in risk exposure of key risks, where Principle KRIs are standardized indicators applied across business units to provide consistent oversight on potential risk appetite exceedance, while Agile KRIs are customized indicators designed to reflect the unique risk characteristics of different business units, supporting more dynamic monitoring of changing risk profiles. If there is any KRI value exceeding the pre-defined threshold, risk alerts to management will be mandated so that they can timely administer corresponding responses, and proper reporting to Executive Directors will be made. The GRM team also monitors the KRIs and corresponding follow-up actions for any exceedance. |
| Risk Treatment Validation (Annually) |
The GRM team reviews the implementation of risk treatment measures stated in the Risk Register or KRI Report. The Group Audit team also performs risk-based validation to test risk treatment measures of key risks during the internal audit process. |
| Material Control Repository and Integrated Internal Control Self-Assessment (Semi-annually) |
Business units and corporate office departments review the repository for key business processes and associated material controls and conduct Integrated Internal Control Self-Assessment to evaluate and ascertain the effectiveness of their risk management and internal control systems, with reference to the COSO framework. |
| Early Flagging Mechanism (On-going) |
An early risk flagging mechanism is applied across the Group, to proactively identify and assess emerging risks and risks with high velocity, such as quality, health and safety, disaster and media events. When a potential risk is perceived with significant impact, the risk should be flagged and reported to the relevant line manager and risk oversight parties. |
| Whistleblowing Mechanism (On-going) |
The Group has established a Whistleblowing Policy and provided reporting channels for internal and external stakeholders. Whistleblowing cases are reported to the Executive Committee and Audit Committee. |
| Independent Review of ERM System (Annually) |
Independent review of the ERM system’s processes and procedures is performed annually by an independent qualified external assessor or the Group Audit team. In FY2026, the Group has engaged SGS Hong Kong Limited (“SGS”) to assess its ERM implementation in accordance with ISO 31000:2018 Risk Management — Guidelines. |
Regular reporting, regarding identified risks and the status of risk management activities, is provided to management, the ERM Steering Group, the Executive Committee, the Audit Committee and the ESG Committee to facilitate the risk management process and decision-making. The ERM Steering Group Meeting is held every half year to discuss key risk matters and updates.
The Group operates and invests in a diversified portfolio of businesses predominantly in Hong Kong and the Chinese Mainland, including financial services, toll roads, logistics, construction, and facilities management.
Through the comprehensive risk management process described in the previous section, the Group has identified major risks which may affect the achievement of its business objectives. However, risks evolve through interactions among various dynamic forces and factors in the business environment. Certain risks that are not currently significant may emerge as key risks in the future, while other risks may not yet have been identified. Accordingly, our risk portfolio is regularly reviewed and updated to react and respond to the changing risk landscape.
Overall Risk Trend and Emerging Risk Drivers
The Group’s risk environment in FY2026 continues to be influenced by the pace of economic recovery in Hong Kong and the Chinese Mainland, geopolitical tensions, trade policy uncertainty and an increasingly demanding regulatory landscape. Although interest rate volatility has moderated and inflation remains relatively contained, economic growth across the region remains uneven. Hong Kong’s GDP growth is forecast at 2.5%–3.5% in 2026, while the Chinese Mainland is expected to maintain moderate growth amid ongoing economic restructuring.
While these developments may affect consumer spending, investment decisions and financing conditions, the Group remains resilient, supported by a strong balance sheet, healthy liquidity position and prudent financial management practices. Existing liquidity resources and funding capacity are considered adequate to support business operations and strategic initiatives under both normal and stressed conditions. Notwithstanding the external uncertainties, the Group’s overall risk profile remains within its risk appetite.
Technology transformation remains a strategic priority for enhancing the Group’s competitive position. Advances in artificial intelligence, automation and digital solutions present significant opportunities to improve operational efficiency, customer engagement and decision-making capabilities. Across the Group, various business units are accelerating the adoption of emerging technologies, with investments subject to pilot implementation and ongoing evaluation to ensure they are supported by demonstrable business value, appropriate use cases and prudent cost-benefit considerations prior to wider deployment. For example, the insurance business utilizes digital platforms, data analytics and AI-enabled solutions to enhance customer experience, streamline operational processes and strengthen distribution effectiveness. Meanwhile, the construction business is expanding the use of smart site technologies and construction robotics to improve quality, productivity, safety and cost control, while fostering a more modern and technology-enabled working environment that supports attraction and retention of next-generation talents.
As reliance on technology grows, the Group faces heightened risks relating to cybersecurity threats, data privacy and AI governance. The Group will reinforce technology risk management, cybersecurity capabilities and governance frameworks to ensure these transformation initiatives are implemented in a secure, resilient and responsible manner. In parallel, certain business units have developed dedicated AI governance frameworks to support the responsible adoption of AI, with a focus on accountability, risk assessment, human oversight, continuous validation and ongoing training. The Group also promotes employee awareness and capability building through training programmes designed to encourage the effective use of emerging technologies, such as generative AI, while reinforcing the importance of cybersecurity, data protection, and ethical and compliance considerations. In addition, the Group’s expansion into digital infrastructure may introduce new technology, operational and regulatory considerations, which will continue to be incorporated into the Group’s risk assessment and monitoring processes.
Climate-related risks continue to grow in significance. The increasing frequency and severity of extreme weather events, evolving transition requirements associated with decarbonization initiatives and expanding ESG disclosure expectations may impact business operations, asset values, project delivery and stakeholder expectations. The Group continues to enhance its climate risk management capabilities through climate scenario analysis, business continuity planning, infrastructure resilience measures and sustainability initiatives under its ESG strategic priorities.
Looking ahead, the Group will maintain a vigilant and forward-looking approach towards emerging risks and opportunities. By strengthening risk awareness, enhancing resilience and promoting innovation, the Group remains well positioned to navigate uncertainties and support sustainable value creation for its stakeholders. Please refer to the following table for the major risks identified by the Group and the corresponding response measures. This is neither intended to be exhaustive nor comprehensive.
Macroeconomic Risk
Risk Description
Global economic uncertainties and slow recovery affecting business growth and financial performance
Risk Trend
Mitigation Measures
Competition Risk ![]()
Risk Description
Intense competition arising from existing competitors and/or new entrants to the market regarding the industries the Group is operating
Associated ESG Issue:
Innovation and Digitalization
Risk Trend
Mitigation Measures
Government Policy and Intervention Risk
Risk Description
Imposition of government policies, intervention, laws or regulations, exposing the Group to legal or regulatory liabilities, business disruption, reputational damage and/or financial loss
Risk Trend
Mitigation Measures
Geopolitical risk
Risk Description
Conflicts between nations, political issues towards individual business, political instability and etc., impacting the Group’s ability to sustain its profitability
Risk Trend
Mitigation Measures
Cybersecurity Risk ![]()
Risk Description
Cybersecurity issues compromising data integrity, confidentiality and system availability, which may lead to adverse impacts on reputation, financial conditions, and operational performance
Associated ESG Issue:
Cybersecurity and Information Security
Risk Trend
Mitigation Measures
Project Management Risk
Risk Description
The risk of improper planning, execution, monitoring or control of a major project, impacting the Group’s achievement of strategic goals and financial performance
Risk Trend
Mitigation Measures
Quality, Health and Safety Risk ![]()
Risk Description
Sub-standard or unsafe product, service or business activities impacting the achievement of the Group’s quality, health and safety goals
Associated ESG Issue:
Responsible Product and Services, Health and Safety
Risk Trend
Mitigation Measures
Talent Attraction and Retention Risk ![]()
Risk Description
Failure to attract and/or retain qualified staff to support operations impacting the achievement of business objectives
Associated ESG Issue:
Talent Attraction, Retention and Development
Risk Trend
Mitigation Measures
Credit/ Default Risk
Risk Description
Default or any other failure to fulfil their current or future obligation by an obligor (e.g. debtor, client, tenant) with which the company conducts business
Risk Trend
Mitigation Measures
Climate Risk ![]()
Risk Description
The risk of adverse impacts arising from climate change, including physical risks from natural disasters and extreme weather events, and transition risks associated with the shift to a low-carbon economy
Associated ESG Issue:
Climate Change
Risk Trend
Mitigation Measures
| Risk Identification | Material ESG issues, together with climate-related physical and transition risks, are integrated into the CTFS Risk Bank to support the systematic identification, assessment and management of ESG-related risks, in alignment with the strategic focus of the Group’s ESG priorities. The GRM team works closely with the Group ESG team to incorporate ESG insights into the risk identification process and engages with risk owners to assess and discuss relevant ESG risk factors. |
| Risk Assessment | The Group is committed to minimizing its negative impacts on the environment and society. It has integrated ESG considerations into its risk assessment process:
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| Risk Treatment & Monitoring | Consistent with the Group’s ERM approach, KRIs and risk mitigation measures are developed for ESG-related risks by respective business units and corporate office departments, based on the nature and priorities of the identified risks and their associated ESG issues. To further strengthen climate risk oversight, the Group leverages climate scenario analyses to identify meaningful indicators that support the monitoring of key climate risk drivers and enable timely mitigation actions. The GRM team works closely with the Group ESG team, sharing ESG risk insights to support the effective management of ESG-related risks and the development of ESG initiatives. |
| Risk Awareness Building | Periodic training sessions are conducted to share our approach to managing ESG-related risks, as well as information and knowledge about emerging trends and popular ESG and climate-related topics to our management, risk owners and relevant individuals. ESG and climate considerations have also been incorporated in our regular risk induction training and deep-dive workshop on risk assessment. We also actively engage the Group ESG team and external experts to share their insights and best practices on management of ESG-related risks. All relevant training materials, together with the Group’s policies, procedures and guidance materials related to risk management and internal control, are centralized within the “ERM Library” module under ERMApps, the Group’s policies unified digital ERM platform, to enhance the accessibility, consistent understanding and sharing of risk management knowledge, requirements and practices across the Group. |
| BCM Governance | Establishes a governance framework, together with clear roles, responsibilities and oversight mechanisms, to support effective BCM implementation across the Group |
| Group BCM Framework | Defines the principles, standards and requirements governing the development, implementation and ongoing maintenance of BCM capabilities and planning across the Group |
| Crisis Communication Plan | Provides a structured mechanism across the Group for timely crisis reporting, activation of the crisis management team, and appropriate communication with key stakeholders during crisis and disruption events |
| BCM Approach and Methodology | Incorporates Business Impact Analysis and Disruption Risk Assessment methodologies to identify critical business activities, assess disruption risks and evaluate business continuity preparedness, with a strong emphasis on regular training, testing, drills and reviews |
| Group Audit Reports |
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| Whistleblowing Reports (if any) |
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| Group Risk Management Reports |
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| Review of Risk Management and Internal Control Systems |
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| Management Confirmation through Integrated Internal Control Self-Assessment |
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| External Auditor Reports |
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