Environmental,
Social and Governance Report 2025
About Tencent
Executive Summary ESG Governance Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Contents
02 | Chapter 1 ESG Governance | Chapter 4 Environmental Protection | Chapter 7 Tech for Good Supporting SDGs | |||
03 | ESG Governance Structure | 05 | Environmental Strategy and Progress | 41 | Basic Sciences Research | 73 |
Board Statement | 06 | Climate Change and Carbon Neutrality | 42 | Digital Upgrade of the Philanthropic Sector | 74 | |
ESG Strategy | 07 | Biodiversity Loss and Nature Conservation | 46 | Cultural Heritage and Inclusive Access | 76 | |
Commercial Value, Social Value, and Shareholder Value | 08 | Emergency Preparedness | 77 | |||
ESG Materiality Assessment | 09 | Digital and Intelligent Upgrade of Industries | 78 | |||
Annual Review of ESG Working Group | 10 | |||||
Chapter 2 Corporate Governance | Chapter 5 Caring for Our People | |||||
Board Governance, Independence and Diversity | 13 | Our Approach and Commitments | 50 | |||
Risk Management | 14 | Development and Well-being of Our People | 51 | |||
Business Ethics | 15 | Diverse, Inclusive, and Collaborative Workplace | 59 | |||
Sustainable Supply Chain | 18 | |||||
Chapter 3 Product Governance | Chapter 6 Digital Inclusion | Appendix | ||||
Data Privacy | 21 | Development of Minors | 62 | About This Report | 80 | |
Cyber and Data Security | 26 | Empowerment of the Silver Generation | 64 | Climate- and Nature-related Information | 81 | |
Responsible Artificial Intelligence | 30 | Skill Development for People with Disabilities | 66 | Workforce-related Information | 89 | |
Trustworthy Internet Platform | 33 | Inclusive Healthcare for Women | 68 | List of Security Certifications | 90 | |
Supporting Rural Development | 69 | Assurance and Verification | 91 | |||
Inclusive Financial Products and Services | 70 | Reporting Frameworks and Content Indices | 94 |
About Tencent
Executive Summary ESG Governance Corporate Governance
Product Governance Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
About Tencent
Value for Users, Tech for Good
Creating value for our users and harnessing technology for good are at the core of Tencent's vision and mission.
This belief is deeply embedded in our product development, daily operations and corporate governance, driving the sustainable growth of our Company while guiding our engagement with broader society to create sustainable social value.
Tencent is a leading global Internet technology company dedicated to creating innovative products and services to enrich the lives of people.
Our communication and social platforms serve over one billion users worldwide, enabling them to stay connected with friends and families while enjoying easy access to life services such as entertainment, transportation and payments.
We develop and publish some of the world's most popular online games and premium digital content, delivering engaging and interactive experiences for a broad and diverse user base.
We provide enterprise services, including marketing, cloud services and computing, and FinTech services, to support the digital transformation and business expansion of our partners.
Tencent was founded in 1998 and has been listed on the Main Board of the Hong Kong Stock Exchange since 2004.
Executive Summary
About Tencent
ESG Governance Corporate Governance
Product Governance Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Executive Summary
Environment Social Governance
Tencent executes our Environmental, Social and Governance strategy through proactive risk
identification and management, while integrating sustainable social value creation into our operations and product development. In 2025, we made
significant progress in the following areas:
Driven by enhanced energy efficiency, accelerated transition to green electricity, and supply chain decarbonisation, we stay firmly on course to meet our carbon targets. Year-over-year, we enhanced the PUE performance of owned data centres from 1.257 to 1.246. The share of green electricity consumption increased from 49.8% to 82.9% in owned data centres and from 3.8% to 21.4% in leased data centres. These initiatives enabled us to maintain our decarbonisation progress despite rising AI-related power demand, with carbon intensity in 2025 reduced by 24.4% against the 2021 base year.
With the application of AI in species identification, we enabled field researchers to improve the efficiency and accuracy of data collection while facilitating public participation in urban ecological observation. These efforts were recognised as one of the 2025 Exemplary Cases for Business Biodiversity Conservation by the Centre for Environmental Education and Communications of China's Ministry of Ecology and Environment.
We are committed to advancing technological inclusivity. Beyond physical accessibility, we expanded our scope to cognitive health with our new, clinically validated training software. Within the Nearby Jobs Mini Program, we have introduced a dedicated section for people with disabilities, integrating approximately 3,000 job openings certified by China Disabled Persons' Federation Employment Service Platform.
We supported social innovation and philanthropic initiatives to advance the United Nations Sustainable Development Goals. The Xplorer Prize and the New Cornerstone Investigator Program have provided long-term and stable funding to over 430 outstanding
scientists. In 2025, our annual Giving for Good initiative generated 530 million engagements in philanthropic activities.
We formalised our commitment to Responsible AI principles, which are anchored in our Tech for Good mission and govern the ethical development and deployment of AI across our businesses and operations. Tencent Cloud obtained additional security certifications in key markets and attained ISO 42001 AI management systems certification. We further strengthened privacy governance by establishing a group-level Personal Information Protection Committee.
In business ethics, our anti-fraud and compliance management systems received international and Chinese certifications. We joined the Sustainable Value Chain Leaders Alliance initiated by the United Nations Global Compact and launched ESG training course on our supplier portal.
Building on these efforts, our ESG performance earned widespread recognition from stakeholders. Tencent was featured in the "2025 Shenzhen ESG Practice Pioneer: Exemplary Enterprise Cases", and named to Fortune Magazine's list of the "World's Most Admired Companies". Furthermore, Tencent maintains its inclusion in multiple global ESG indices, and in October 2025, our MSCI ESG Rating was upgraded from BBB to A.
James Mitchell John Lo
Co-Chairs ESG Working Group
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
ESG GovernanceESG Governance Structure 05
Board Statement 06
ESG Strategy 07
Commercial Value, Social Value, and Shareholder Value 08
ESG Materiality Assessment 09
Annual Review of ESG Working Group 10
Chapter 1
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
1.1
ESG Governance Structure
The Company's governance framework for environmental, social and governance ("ESG") matters operates at three interconnected tiers: the Company's board of directors (the "Board") provides strategic oversight, senior management drives the development of the ESG strategy and the execution of ESG priorities, and ESG Champions across various business groups ensure implementation and report regularly on the progress.
The Board Corporate Governance Committee
Authorised by the Board to oversee the Company's corporate governance and ESG matters. This includes monitoring progress on strategies, targets and metrics, reviewing and evaluating disclosure documents including ESG Reports, Corporate Governance Reports and the Shareholders Communication Policy , and making recommendations to the Board as appropriate
The committee interacts with the ESG Working Group through various means, including enquiries, progress reports, face-to-face meetings as well as committee meetings twice a year
ESG Steering Team
Leads the ESG Working Group to formulate the Company's ESG strategy and priorities
Co-chaired by the Chief Strategy Officer and the Chief Financial Officer, the ESG Steering Team is well-represented by senior executives from various business groups and functional teams, each focusing on specific ESG topics
ESG Working Group
ESG Coordination Office
Assists the ESG Steering Team in identifying ESG objectives, and coordinates various business groups and functional teams to develop action plans and monitor progress
Acts as the secretariat of the ESG Working Group and provides periodic reports on the Company's ESG-related matters to the Corporate Governance Committee
ESG Champions
Leverage their respective expertise and professional resources to collaboratively drive the Company's ESG practices while providing regular updates to the ESG Coordination Office on the latest developments
Comprise employee representatives from various business groups and functional teams involved in specific ESG topics
The ESG Working Group has established five special committees dedicated to the management of material topics:
User Privacy and Data Security
Strengthen disclosure; evaluate feasibility of joining international initiatives or industry alliances; refine internal policies and guidelines
Diversity and Inclusion
Promote a diverse and inclusive corporate culture, while monitoring the progress of related initiatives
Supply Chain Management
Guide internal departments and suppliers to adopt fundamental ESG principles, enhance management while monitoring the progress and outcomes
Culture and Communication
Develop an ESG communication strategy to broaden engagement channels, foster deeper internal resonance and strengthen external stakeholder recognition
Biodiversity Conservation
Develop initiatives in support of global action; promote environmental awareness and action among employees and in society
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
1.2
Board Statement
The Board retains overall responsibility for the Company's ESG strategy and reporting, delegating oversight to the Corporate Governance Committee.
Supported by the ESG Working Group, the committee tracks the progress and performance of ESG matters through regular updates, special reports, meetings and enquiries, covering areas including but not limited to, carbon neutrality action plan, sustainable social value innovation initiatives, progress of diversity and inclusion, and global ESG trends.
The Company has solicited views and recommendations from the Board and its key stakeholders in assessing the materiality and priority of ESG topics with potential significant influence on its sustainable development. The Company has also incorporated key ESG risks into its corporate risk assessment and management system, and formulates risk response measures by considering the possibility, impact, and trends of these risks. The Board and the Corporate Governance Committee regularly review those risks and recommend mitigation measures.
This report has obtained limited assurance from a professional third-party organisation, and was reviewed by the Corporate Governance Committee and the Audit Committee and approved by the Board.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
1.3
ESG Strategy
Rooted in our vision and mission of Value for Users, Tech for Good, our ESG strategy is closely aligned with the Company's business strategy, which prioritises users, industries, and society. Guided by leadership and embraced by employees, our commitment to ESG has become a core element of our corporate culture and serves as a driving force for the Company's sustainable development.
Business Operations Users Business Partners Industry and Society Environment
We implement ESG management through three approaches: (i) establishing an ESG governance structure that includes the Board, management, and employees;
integrating ESG principles into corporate culture and ESG practices into daily business operations; and
publishing an ESG report aligned with international reporting standards annually to enhance transparency and communicate the Company's actions and performance in ESG to our stakeholders.
With the rapid advancement of artificial intelligence alongside the convergence of digital and real economies, the Internet industry encounters new market opportunities and risks. We are committed to creating products that generate value for users and business partners, while proactively managing related risks. We put Tech for Good into practice, leveraging technologies to address environmental and social pain points, thereby advancing the United Nations Sustainable Development Goals
("SDGs"). Our ESG strategy is implemented internally through robust corporate governance, ethical business practices, and advanced human capital development. Externally, we pursue sustainable business growth that prioritises the balanced interests of our stakeholders and the environment. Our efforts can be summarised as follows:Adhere to applicable laws and regulations and uphold ethical business standards;
Provide our employees with a diverse, inclusive, and safe work environment; safeguard their rights and well-being, and support their professional growth;
Ensure the effectiveness of our corporate governance, and integrate ESG into our risk management and controls, to protect the rights of shareholders and stakeholders.
Protect the privacy of users, and the security of their data and digital properties;
Listen to feedback from users and actively respond to their needs, enquiries, and complaints, based on which we iterate our product designs and enhance our service quality;
Provide minors with a safe online environment and support underserved users with inclusive access to digital economy.
Assist industries in their digital and intelligent upgrade, provide additional support to Micro-, Small and Medium-sized Enterprises ("MSMEs");
Ensure fair and equitable treatment to our business partners, solicit and respond to their feedback, thereby honing cooperation processes and business practices;
Implement rigorous risk control measures to prevent and combat illegal and unwarranted conduct, and collaborate with value chain partners to maintain a fair and transparent business environment conducive to the long-term steady growth of the industry.
Strengthen our technical foundation through proprietary innovation and industry collaboration, and participate in the development of an open, win-win ecosystem;
Increase community investment and leverage our products, platforms and technologies to implement Tech for Good, bringing the benefits of technological advancements to wider communities;
Leverage our digitalisation capabilities to assist philanthropic organisations to broaden reach to potential donors, enhance operational efficiency, and increase transparency and public trust.
Advance our own carbon neutrality goals, and assist the transition to low-carbon society through investments in low-carbon technology startups;
Minimise our operational dependence and impact on natural resources while applying digital technologies to advance biodiversity conservation;
Utilise digital tools and products to raise public environmental awareness and encourage behavioural change.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
1.4
Commercial Value, Social Value, and Shareholder Value
Tencent places user value at the core of our mission and culture, and at the forefront of commercial design for our products and services. Our investment in social value innovations, which was funded by investment gains and may take time to produce
scalable outcomes, was separate from the resources we allocated to research and development for our products, technologies and platforms that are crucial for user
value creation, and ultimately shareholder return. We proactively manage the balance between commercial value, social value
and shareholder value, ensuring the Company can steadfastly attain sustainable development in the long run.
In designing commercial value, we focus on user value.
We invest heavily in technologies and products, strengthening the protection of user privacy and data security to deliver
superior and innovative product experiences to our users. By assisting industries in their digital upgrade, we create social value together for the benefit of
society. This, in turn, enables us to share commercial benefits brought by the convergence of digital
and real economies. We position ourselves as a trusted digital assistant facilitating innovation, entrepreneurship and upgrade of industries.
Regarding social value innovation, we focus on deploying our
products and technologies to find innovative pathways to solve social pain points. We encourage our business teams to
Social valuediscover and enhance the social value of our products by,
for instance, enhancing digital accessibility for communities with disabilities, protecting biodiversity, and more. Led by
our Sustainable Social Value Organisation, we provide funding support for researchers in basic sciences
and, in certain core areas, partner with recognised
philanthropic organisations to incubate projects that can bring scalable benefits to society.
Commercial value Shareholder valueOn shareholder value, our continuous focus on creating user value and the organic integration of social and commercial values strengthens our foundation in sustainability, thus safeguarding the long-term value of the Company. We are committed to maintaining a high standard of
corporate governance and have integrated environmental and social factors into our corporate strategies and risk management.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
1.5
ESG Materiality Assessment
High
2025 ESG Materiality Matrix
We incorporate stakeholder perspectives and suggestions into our evaluation of ESG risks and opportunities. We regularly engage with stakeholders through various channels to understand their expectations, concerns, and information needs.
We commissioned third-party professional firms to conduct a comprehensive ESG materiality assessment. The assessment followed a structured process to identify and prioritise the topics most significant to our business and our stakeholders.
The key steps are as follows:
1
Identify the universe of ESG topics relevant to the Company, based on:
Tencent's corporate strategy and core businesses.
The Environmental, Social and Governance Reporting Code set out in Appendix C2 of the Main Board Listing Rules of The Stock Exchange of Hong Kong Limited ("HKEX ESG Reporting Code") and major
Users
User satisfaction surveys, online customer service, official website, and social media platforms
Media and the Public
Press conferences, official website, and social media platforms
Government and Regulators
Information disclosure, policy consultation and feedback, special meetings or reports,
official visits, and official website
Employees
Employee engagement and satisfaction survey, annual all-hands meetings,
Key Stakeholder Engagement Channels
internal bulletin boards, employee channels for appeals, official website, and social media platforms
Communities and NGOs
Online charity platforms, workshops,
official website, and social media platforms
Investors
Investor meetings, company announcements, annual general meeting, official website, and
social media platforms
Business Partners
Industry conferences, supplier conferences, supplier evaluation, site visits, and
official website
international ESG reporting standards and frameworks, including International Financial Reporting Standards ("IFRS") S1 and S2, the Task Force on Climate-related Financial Disclosures ("TCFD"), the Taskforce on Nature-related Financial Disclosures ("TNFD"), the Global Reporting Initiative ("GRI") Standards, and the Sustainability Accounting Standards Board ("SASB") Standards, Ten Principles of the UN Global Compact ("UNGC"), as well as the SDGs.
Sustainable development trends and stakeholder expectations.
2
Collect stakeholder views on the materiality of ESG topics through interviews and online surveys. Interviews were conducted with directors, senior management and investors to gain in-depth understanding of their prioritisation of ESG topics, as well as their perspectives and recommendations on our ESG strategy. Online surveys covered employees, users, business and supply chain partners, regulatory bodies,
academia, media and communities, with more than 3,200 valid
Low
High
Environmental and Social Impact
Environment Society Governance
21
20
12 11
8
10
23 26
25 22
7
17
14
24
30
15
19
13
6
16
2
29
9
27
28 18
3
4
5
1
Business Impact
responses received. The data collection process took into consideration stakeholder coverage and sample size to ensure the reliability and representativeness of the assessment results. Following the publication of the ESG report, we gathered feedback on our ESG disclosures and materiality assessment through online channels and face-to-face engagement, including meetings with stewardship teams.
3
Develop a materiality matrix to illustrate the business impact, as well as the social and environmental impact of ESG topics. Consistent methodologies have been
applied throughout the assessment process to ensure the comparability and reliability of data and conclusions across reporting periods.
Climate Change and Carbon Neutrality Energy Management
1
2
3
Water Management
4
Waste Management and Circular Economy
5
Biodiversity Loss and Nature Conservation
6
Digital Solutions to Support Environmental Education and Protection
7
8
9
10
Talent Attraction, Development and Retention Employee Compensation and Well-being Diversity and Inclusion
Labour Rights
Responsible Content and Platforms
11
12
Build a Safe and Healthy Online Environment for Minors
13
Provide Digital Solutions for the Silver Generation
14
Provide Accessible and Assistive Digital Products for People with Disabilities
15
Support the Digital Upgrade of the Real Economy
16
Digital Technologies Promoting Financial Inclusion
17
Service Quality and Customer Feedback
18
Executing Tech for Good to Support the Advancement of the SDGs
19
Corporate Governance (Effectiveness, Independence, Diversity)
20
Protection of Data Privacy
Protection of Data and Cyber Security Responsible AI
23
24
25
21
22
Anti-corruption Anti-monopoly
Anti-money Laundering
26
Protection of Intellectual Property Rights
27
Integrate ESG Factors into Corporate Strategies and Balanced Scorecard Review
28
29
30
Incorporate ESG Value into Corporate Culture Sustainable Supply Chain Management Stakeholder Dialogue and Engagement
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
1.6
Annual Review of ESG Working Group
The ESG Working Group is dedicated to enhancing the Company's ESG performance and fostering a robust ESG culture. Corporate culture is fundamental to the implementation of our ESG strategy, inspiring employees to embody ESG principles in their daily work. To this end, we hold monthly ESG quiz competitions to reinforce employees' understanding of material topics. We also host an annual ESG Culture Week, featuring seminars
with internal and external experts to share industry insights and global ESG trends. In 2025, our thematic initiatives included:
Business Ethics
We held nine outreach activities focused on business ethics, strengthening employees' compliance awareness and commitment to business integrity through in-person activities.
AI Safety and Governance
We collaborated with academic institutions on research initiatives to explore the opportunities and challenges that AI presents across various ESG domains. We also hosted online seminars to share insights on ESG theories and governance best practices, enhancing employee awareness of AI safety.
Diversity and Inclusion
We hosted an inaugural global forum covering five core themes: cross-cultural communication, women's career development, age-friendly product development, care for children with autism, and employment for people with
disabilities. These sessions aimed to foster mutual respect and a deeper understanding of diversity and inclusion.
Privacy Protection and Data Security
We reinforced privacy protection principles by sharing compliance requirements and best practices. We conducted 38 specialised privacy training sessions to ensure compliance standards are understood at all levels of the organisation.
Environmental Protection
During Earth Day and World Environment Day, we organised educational campaigns and encouraged employees to log green actions, such as carbon reduction, energy and water conservation, waste reduction, and ecological preservation, via our Nature Positive Mini Program.
Philanthropy
Through the Act for Good Mini Program, employees can apply their personal skills and knowledge to participate in or initiate philanthropic projects. Over 41,600 volunteers had participated in 2,969 projects by the end of 2025.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
ESG Governance Structure Board Statement ESG Strategy Commercial Value, Social Value, and Shareholder Value ESG Materiality Assessment Annual Review of ESG Working Group
Users
Our ESG materiality assessment results indicated that the five topics most recognised by users are talent attraction, development and retention; digital solutions to support environmental education and protection; employee compensation and well-being; protection of data and cyber security; and protection of data privacyGovernments and Regulators
Listed in 2025 Enterprise ESG Cases by the Centre for Environmental Education and Communications of the Ministry of Ecology and Environment
Listed in 2025 Shenzhen ESG Practice Pioneer Enterprise Cases by the Development and Reform Commission of Shenzhen MunicipalityRecognition from Key Stakeholders
Privacy-Friendly Awards 2025, including the Gold Award and the Best Data Breach Response Plan Award, from the Office of the Privacy Commissioner for Personal Data, Hong KongInvestors
Extel (formerly Institutional Investor) ranked Tencent No. 1 for Best ESGin the Internet sector (Asia ex-Japan) for five consecutive years, from 2021 to 2025. The ranking is based on a survey of more than 6,000 investment professionals from over 1,300 financial services institutions globally.
In 2025, Tencent was also named the Most Honoured Company by Extel
Employees
Our ESG materiality assessment results indicated that the five topics most recognised by employees are build a safe and healthy online environment for minors; talent attraction, development and retention; protection of data privacy; digital solutions to support environmental education and protection; and support the digital upgrade of the real economyESG Rating
S&P Global raised Tencent's ESG score to 611
MSCI upgraded Tencent's ESG rating from BBB to A2Media
TIME - 2025 World's Most Sustainable Companies
Forbes China - 2025 China ESG Top 50
Forbes - 2025 World's Best Employers
China Media Group - 2025 China ESG Listed Company Pioneer 100
Sina Finance - 2025 China ESG Top 100
Fortune - 2026 Most Admired CompaniesNon-profit and Professional Organisations
Listed among the 25 Sustainable Value Chain Leaders Alliance Corporate Practice Case Collection by the UNGC
Hong Kong Institute of Certified Public Accountants, Special Mention in the Large Market Capitalisation Category of the Best Corporate Governance and ESG Awards 2025
The Hong Kong Management Association, Best Annual Reports Awards-Best Environmental, Social and Governance Reporting Award 2025 (Technology & Information)ESG Indices
MSCI Emerging Markets ESG Leaders Index and MSCI China ESG Leaders Index since 2013
S&P Global Dow Jones Sustainability World Index and Sustainability Emerging Markets Index since 2023
Hang Seng ESG 50 Index and Hang Seng Corporate Sustainability Benchmark Index since 2024According to the S&P Global ESG Score released on 13 November 2025.
According to the MSCI ESG Rating Report released on 21 October 2025.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
Corporate GovernanceBoard Governance, Independence and Diversity 13
Risk Management 14
Business Ethics 15
Sustainable Supply Chain 18
Chapter 2
UNGC Anti-Corruption Principles
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
2.1
Board Governance, Independence and Diversity
Tencent has a unitary board. As of 31 December 2025, the Board consisted of eight directors,
including an executive director, two non-executive directors ("NEDs") and five independent
non-executive directors ("INEDs").
The Board plays a pivotal role in steering Tencent's strategic direction, overseeing corporate governance, and ensuring the Company's long-term sustainable growth. It operates through a well-defined governance structure, and delegates matters requiring dedicated time, attention, and expertise to its various committees. The Board has established
five committees, each with its own terms of reference outlining the duties and responsibilities of the committee members. In 2025, Professor Ke Yang was appointed to the Nomination Committee, bringing the total number
of members to six. Her appointment introduces a more diversified perspective into the committee's talent selection and evaluation processes. For more details on our corporate governance efforts, please refer to the Corporate Governance Report in Tencent 2025 Annual Report.
The diverse experience and background of Board members are highly valued, and the advice and oversight provided by the NEDs and INEDs are fully recognised. In 2025, INEDs accounted for 62.5% of the Board, with NEDs accounting for 25.0%.
The NEDs are senior management from the Naspers Group, a long-term shareholder investing in Tencent through its subsidiary, Prosus. Naspers is a global consumer Internet group and one of the largest technology investors in the world. The NEDs bring global perspectives and expertise in business, finance and management, performing their supervisory duties in reflection of shareholders' long-term interests.
The INEDs are professionals from a wide range of backgrounds, possessing diverse expertise and broad management experience. They provide checks and balances that safeguard the interests of the shareholders, the Company, and other stakeholders. The Nomination Committee regularly assesses the independence of
the INEDs and determines them to be independent. The Company, in undertaking this assessment, has considered the independence guidelines set out under the Rules Governing the Listing of Securities on The Stock Exchange of Hong Kong Limited (the "Hong Kong Listing Rules"), along with the tenure of service of each INED and the unique perspective, skill and experience each contributes to the Board. The Company has received the annual independence confirmation from all INEDs, including three who have served for more than nine years, and the Board has affirmed their independence. The Nomination Committee and the Board, after careful assessment,
are of the view that they possess the independence necessary to fulfil their roles as INEDs effectively and will continue to bring valuable experience, knowledge and professionalism to the Board.
The Board collectively brings profound professional expertise across a wide range of sectors, including computer and information technology, telecommunications, business administration, financial management, accounting, law, medicine, and social sciences. For more details on our directors' prior experiences, please refer to the Directors' Report in Tencent 2025 Annual Report. The Board maintains a good mix of director tenure lengths to embrace various perspectives and experience from seasoned directors and those appointed in recent years, while ensuring the effectiveness and efficiency in fulfilling their fiduciary duties.
In the process of nominating and selecting directors, the Board adheres to the Board Diversity Policy and the Board Nomination Policy, comprehensively evaluating candidates against a set of diverse factors, including knowledge, professional background, experience, gender, and cultural and educational background, having due regard to the benefits of Board diversity, while ensuring adherence to the relevant requirements of the Hong Kong Listing Rules. In terms of gender diversity, a target was set in 2022 to raise the female representation on the Board to 30.0% by
2030. By the end of 2025, the female representation on the Board was 25.0%.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
2.2
Risk Management
Appropriate and effective risk management and internal control systems are fundamental to safeguarding our strategic objectives. The Board retains ultimate responsibility for these systems and delegates oversight responsibility to the Audit Committee. The committee members oversee the
Risk Identification
Risk Management Process
implementation of the risk management and internal control systems quarterly, and conduct an annual review of their effectiveness. The Audit Committee also ensures that ESG-related factors, including but not limited to climate change, are integrated into the Company's risk assessment and internal control management process, and material risks are identified and managed. The Audit Committee members have extensive experience and knowledge in financial management and risk management. Through regular updates and training, they remain well-informed on the latest requirements and industry best practices for risk management and internal control, which are discussed as needed during the committee meetings.
We provide regular training to employees through various channels, such as on-site training, online courses, and in-person interactive activities, covering risk management systems, key risk analysis, and internal controls. The training enhances their awareness of, and capabilities in, risk management, thereby strengthening our internal control environment. We also embed risk management and internal control performance into appraisals to ensure accountability.
Please refer to the Corporate Governance Report in Tencent 2025 Annual Report for a detailed discussion on our significant risks and response measures.
Business and functional departments of each business group identify, assess, and respond to risks in the course of business operation, including those arising during product and service development, in a bottom-up manner.
Risk Evaluation and Management
The risk management and internal control department (the "Internal Control Department") systematically collects, consolidates, and analyses business information to identify and compile a list of significant risks at both the corporate and business levels annually. It ensures appropriate response strategies and control measures are developed and implemented to address these risks. The identified risks, along with the corresponding response and control measures, undergo review by management and the Audit Committee before being reported to the Board.
Risk Monitoring
The Internal Control Department analyses and evaluates responses to significant risks regularly. To ensure the effectiveness of risk management and internal controls, the Internal Audit Department conducts annual risk-prioritised audits across critical business units on a rotational basis, identifying control gaps in a timely manner and providing actionable recommendations. Both departments report findings to the Audit Committee quarterly. The Company also engages external auditors annually to conduct independent assessment and validate the effectiveness of these practices.
Risk Appetite and Response Strategy
The Board is responsible for evaluating and determining the nature and extent of the significant risks the Company is willing to assume in pursuing its strategic objectives. On behalf of the Board, the Audit Committee assesses the nature of risks, determines the Company's risk tolerance to achieve its business objectives, and establishes risk ratings to prioritise mitigation efforts. Based on the assessment outcomes, the Audit Committee formulates appropriate response strategies, assigns ownership of significant risks, and guides the Company's management in implementing an effective risk management system, with support from the Internal Control Department. The Audit Committee considers that management has taken appropriate measures to address and manage the significant risks within acceptable levels.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
2.3
Business Ethics
Business ethics underpins all our decisions and actions, essential to maintaining the trust of our customers. Guided by integrity, fairness, and transparency, we engage responsibly with our business partners to foster a fair and transparent business environment. To translate these principles into practice, Tencent employees are required to adhere to the Tencent Sunshine Code of Conduct ("Sunshine Code of Conduct") and participate in training designed to raise their ethical awareness and capabilities to make sound and responsible judgements in their daily work.
Tax Policy Adherence to Integrity Practice
Tencent's tax policy is grounded in the principles of integrity and transparency. We implement a robust tax strategy, supported by effective internal risk management and control systems, and ensure compliance with applicable tax laws and regulations in the jurisdictions where we operate. For more detailed tax information, please refer to the financial statements in Tencent 2025 Annual Report and our Group Tax Strategy
.We foster a corporate culture of integrity with
zero tolerance for corruption and other fraudulent
behaviours, while cultivating a high level of employee awareness through continuous training. By providing case studies and examples of acceptable behaviours, our training is designed to enhance employees'
understanding of business ethics and fraud risks. Our workforce, from permanent employees to interns and workers of contractors, is mandated to complete the annual training on the Sunshine Code of Conduct and acknowledge their understanding and acceptance of the Sunshine Code of Conduct upon completion. In
addition, we organise additional trainings on anti-fraud for managers, employees holding sensitive positions
In-person event to communicate the requirements of the Sunshine Code of Conduct to employees, reinforcing the corporate culture of integrity
and new hires.
The Board delegates its oversight of business ethics to the Audit Committee. The Chief Executive Officer and relevant senior management executives contribute to this oversight through company-level Internal Audit Committee meetings. During the Audit Committee and Internal Audit Committee meetings, the directors and senior management executives are briefed on the latest anti-fraud regulatory requirements and trends, review policies related to anti-fraud and conduct business ethics risk assessments.
We have established the Sunshine Code of Conduct and other policies, supplemented by operational guidelines, to prevent and address violations, including fraud, corruption, commercial bribery, facilitation payments, conflicts of interest, and insider dealings. The code of conduct applies globally to all permanent employees, consultants, interns and workers of contractors and specifies the following:
Definition of violations and prohibited behaviours;Classification and handling of violations, detailing the impact of violations on performance assessments, and disciplinary actions for responsible managers, including demotion, dismissal, or termination of labour contract;
Investigations and procedures for handling reported violations.
For sensitive positions such as procurement, marketing, and sales, our Sensitive Position Management Policy outlines additional internal control measures, for example, regular job rotation and audit.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
Our anti-fraud policies are reviewed annually and revisions are made in response to changes in applicable laws, regulations, ISO standards and industry practices. We abide by applicable anti-fraud laws and regulations in the jurisdictions where we operate, including but not limited to the Criminal Law of the People's Republic of China, the
Anti-Unfair Competition Law of the People's Republic of China, and Hong Kong's Prevention of Bribery Ordinance. In 2025, we obtained certifications for GB/T 35770-2022 Compliance management systems - Requirements with guidance for use, ISO 37001 Anti-bribery management systems, and ISO 37301 Compliance management systems, marking authoritative recognition of our anti-fraud management capabilities to global standards.
We identify fraud clues through proactive screenings and whistleblowing reports from both internal and external sources. These leads are independently investigated by the highly autonomous Anti-Fraud Investigation Department which reports directly to the Audit Committee of the Board and the Internal Audit Committee of the Company on a quarterly basis. The Internal Audit Committee reviews and approves all disciplinary actions and related decisions. We also leverage AI and big data analytics to develop a dynamic risk model that spans across business partner onboarding, project bidding, contract delivery, and reimbursements. This model enables us to detect potential risks at an earlier stage and strengthen our internal controls.
Our Anti-Fraud Whistleblowing System provides multiple 24/7 reporting channels, including a dedicated email address, postal box, hotline, and Tencent Sunshine Official Account, available to all employees, suppliers, business partners, and other stakeholders. We accept anonymous reports and handle all whistleblower information with strict confidentiality under a non-retaliation policy that prohibits any form of retaliation.
Employees may seek clarifications on our anti-fraud policies through dedicated channels, including WeCom Official Account, an internal hotline, and a dedicated email address. In 2025, we received approximately 1,800 enquiries.
We publish the Tencent Anti-Fraud Announcement annually to disclose the outcome of our anti-fraud efforts. In 2025, the Anti-Fraud Investigation Department investigated over 70 cases of Tencent's Red Line violations, resulting in the dismissal of more than 90 individuals. Furthermore, during the reporting period, we received litigation outcomes for eight corruption-related cases where employees had been handed over to the relevant government authorities in accordance with the law (including employees handed over in previous years).
We have joined the Business Sector Integrity Charter, initiated by the Independent Commission Against Corruption of Hong Kong ("Hong Kong ICAC"), demonstrating our commitment to ethical conduct.
We also participated in the Coding4Integrity Asian Youth Anti-Corruption Hackathon 2025, co-hosted by the United Nations Office on Drugs and Crime, the Hong Kong ICAC, and the International Association of Anti-Corruption Authorities. During the event, our representatives shared insights into how we leveraged AI in auditing to strengthen risk management and fraud detection capabilities, and also served as mentors and judges, offering professional guidance to participants as they developed innovative solutions for integrity challenges.
Procedures for handling anti-fraud investigations
1
2
3
4
5
6
7
8
9
Receive/record reports
Preliminary review of reports
Filter out reports that meet filing criteria
Initiate a formal inquiry
Carry out investigation
Issue investigation report
Close out investigation and file reports for approval
Process and execute approval decisions
Formulate and implement rectification plan
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
Anti-Money Laundering Management Adherence to the Principle of Fair Competition
Tencent adopts a risk-based management approach to
anti-money laundering, continuously refining our anti-money laundering governance framework to address evolving risks and environments.
We dynamically benchmark against global anti-money laundering regulatory requirements, and regularly update and refine relevant policies and management processes, to ensure compliance with applicable laws and regulations in the jurisdictions where we operate, including but not limited to the Anti-Money Laundering Law of the People's Republic of China. We implement the Tencent Group Anti-Money Laundering and Sanctions Compliance Minimum Standard, and have published the Tencent Anti-Money Laundering Policy Statement
and the Tencent Sanctions Policy Statement , available on our website. Additionally, each of Tencent's licenced financial institutions independently revises its relevant policies in response to business developments and regulatory requirements.Our money laundering and sanctions management structure comprises:
The Anti-Money Laundering and Sanctions Committee: provides guidance and oversight on anti-money laundering and sanctions compliance efforts, including the review and approval of the formulation of relevant strategies, policies, processes, as well as other significant compliance matters.
The Anti-Money Laundering and Sanctions Compliance Department: coordinates the management of risks across different regions and business groups, such as ensuring existing mechanisms comply with applicable laws and regulations and overseeing the implementation of various measures.
Licenced financial institutions: promote, implement, and oversee anti-money laundering and sanctions compliance action plans within their respective institutions, ensuring effective control of relevant risks across business operations.
We monitor trends in money laundering risks and regulatory developments in anti-money laundering and conduct gap analyses, based on which we provide employee training, and enhance anti-money laundering management tools and methodologies, to improve the efficiency and effectiveness of compliance management. In 2025, we enhanced our risk management capabilities and compliance awareness and skills through the following initiatives:
Adjusted our overall assessment system based on different risk categories, such as money laundering, terrorist financing, and proliferation financing, in line with the latest regulatory requirements. We also built a risk monitoring model and leveraged technologies, such as AI and big data, to enhance our capability to identify, monitor, analyse, and respond to risks. For non-financial sectors such as virtual assets, online games, and live-streaming, we examine sector-specific money laundering patterns and conduct targeted risk assessments to address emerging money laundering risks arising from these business models.Conducted 54 training sessions and awareness campaigns, covering regulation interpretation, internal control policies, developments in anti-money laundering compliance, global trends, case studies on sanctions, and emerging risk management approaches.
Tencent continuously enhances its compliance management and collaborates with market participants to maintain a fair and competitive business environment.
We foster an anti-monopoly culture and embed it into our corporate culture. In 2025, we conducted 10 training sessions for key personnel, including managers, sales, and staff from marketing, product operations, and legal departments, strengthening their compliance capabilities. We also incorporated online courses into new hires' onboarding, enabling them to acquire an early awareness and understanding of the relevant policies and management requirements.
In the course of business development, we comply with applicable laws and regulations related to anti-monopoly and fair competition in the jurisdictions where we operate, including but not limited to the Anti-Monopoly Law of the People's Republic of China, and prevent and control any prohibited conduct that undermines fair competition. We developed the Tencent Group Anti-Monopoly Compliance Process Management Policy and established mechanisms and processes for compliance management. We continue to enhance the anti-monopoly compliance system, covering the various business units and product lifecycles, through the implementation of key policies and operating guidelines, such as the Tencent Group Anti-Trust Compliance Guidelines, the Tencent Group Overseas Anti-Monopoly Compliance Guidelines, the Guidelines on the Filing Assessment Process for Tencent Investment and Mergers & Acquisitions in China, and the Guidelines on the Prevention of Gun-jumping Behaviours in Merger Control Filings in China for Tencent Investment and Mergers & Acquisitions Transactions.
Our Anti-Monopoly Compliance Department is dedicated to providing advice on anti-monopoly compliance and training for various business units. In daily operations, the department ensures effective management of our compliance efforts through conducting ex-ante risk assessments, ongoing monitoring of policy implementation, and ex-post reviews which enhance management workflows. Our anti-monopoly compliance database aggregates a rich collection of case studies, policies, and research reports. In 2025, we further strengthened our anti-monopoly compliance capabilities using AI, enabling timely updates to our database, and staying abreast of the development of regulatory policies and compliance requirements.
Tencent Music Entertainment Group maintains a robust competition compliance system, which includes
non-exclusive collaborations with upstream copyright owners, to ensure its commercial practices adhere to anti-monopoly regulatory requirements.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
2.4
Sustainable Supply Chain
Tencent incorporates the ESG Code of Conduct for Tencent's Suppliers
into contracts or the onboarding process, specifying behavioural requirements for all suppliers on labour rights protection, occupational health and safety, environmental protection, and business ethics. We encourage our suppliers toGuided by the Tencent Supplier Management Policy, we leverage our supplier management system to exercise robust governance throughout the supplier lifecycle, from onboarding and selection to engagement and performance evaluation. This ensures continuous oversight and the mitigation of potential supply chain risks.
Supplier Management Process
adopt internationally and industry-recognised best practices. With reference to the Responsible Business Alliance Code of Conduct and the Ten Principles of the UNGC, we support them in strengthening their ESG management and disclosures, working together to build a sustainable supply chain.
Onboarding
We regularly update our supplier database, based on which we assess the validity of supplier qualifications, alongside the requisite service capabilities and experience, to support subsequent performance and risk assessment.
Our engagement with suppliers is built on a shared commitment to the ESG Code of Conduct for Tencent's Suppliers and the Anti-Commercial Bribery Declaration. We maintain a policy where any breach of these standards leads to the termination of our business relationship.
We implement the Guidelines for Supplier Blacklist Management. Suppliers who breach requirements such as anti-commercial bribery or confidentiality, or engage in fraudulent practices during our cooperation, will be placed on our blacklist, resulting in permanent cessation of business relations.
In 2025, the number of suppliers in China was 25,219, and the number in other countries and regions was 4,954.
Selection and Engagement
We establish open and transparent decision-making processes to provide qualified suppliers with equal opportunities for business cooperation. The screening and selection of suitable business partners are based on our comprehensive evaluation of their operational capabilities, commercial terms offered and risk profile.
We require suppliers to disclose all interests involving current or former Tencent employees, with the scope of potential cooperation defined in accordance with the Sunshine Code of Conduct. Any identified fraudulent practices will result in immediate termination of the business relationship.
We require suppliers to provide all necessary qualifications and analyse public information regarding their labour practices, operations, financial standing, and other relevant aspects. We utilise AI-driven analytics to verify quotation integrity; when potential risks are detected, our management system triggers automated alerts to guide procurement decisions.
During the engagement process, our digital deliverable review platform leverages AI to flag and intercept risks such as duplicate or low-quality deliverables. It provides reviewers with risk alerts and handling guidance.
Performance Evaluation
We require each department to conduct semi-annual performance evaluations for its suppliers, setting qualitative and quantitative indicators to objectively assess delivery capabilities and potential risks. Supplier performance ratings are adjusted based on evaluation results.
We have established coaching and exit mechanisms to handle under-performing suppliers subject to compliance with relevant contracts.
If evidence suggests a potential violation of the Guidelines for Supplier Blacklist Management, we will conduct an investigation and if verified, add the supplier to the blacklist.
In 2025, 15 contracting entities were placed on Tencent's supplier blacklist, permanently barred from future partnerships.
About Tencent
Executive Summary
ESG Governance
Corporate Governance
Product Governance
Environmental Protection
Caring for Our People
Digital Inclusion
Tech for Good Supporting SDGs
Appendix
Board Governance, Independence and Diversity
Risk Management
Business Ethics
Sustainable Supply Chain
Supply Chain ESG Management Practices
Tencent incorporates ESG principles into supply chain management. Requirements of the ESG Code of Conduct for Tencent's Suppliers
are available to all suppliers via our official website, while onboarded suppliers can access an ESG training course and the latest updates to the Code through the supplier portal at any time. In 2025, we joined the 25 Sustainable Value Chain Leaders Alliance initiated by the UNGC and recommended select suppliers for advanced sustainability training. Our practices in building a sustainable value chain were included in the Corporate Practice Case Collection of the UNGC 25 Sustainable Value Chain Leaders Alliance.Environmental Protection
The Tencent Environmental Management Policy
guides our green procurement by prioritising environmental friendliness as an additional evaluation criterion, including energy-saving, low-carbon products, and waste recycling services. In cases where two or more suppliers have the same or similar scores, the green supplier will be given priority.We define green or low-carbon certifications as one of the mandatory onboarding requirements for server suppliers and data centre service providers, and incorporate their compliance status and environmental practices into the annual
evaluation process. Furthermore, we assisted leased data centres in accelerating their green electricity transition, building on our procurement experience. In 2025, the share of green electricity used in our leased data centres increased from 3.8% in 2024 to 21.4%.
Responsible Content
Suppliers are required to ensure that the content and services they provide comply with all applicable laws and regulations. Deliverables must not contain text, images, audio, or video involving gambling, violence, pornography, abuse, exploitation, fraud, harm to children's welfare, threats to health or safety, or any content that infringes the lawful rights of third parties, including intellectual property, reputation, or portrait rights. Deliverables are subject to review to prevent the release of illegal, non-compliant, or harmful content.
Ethical Employment
We require suppliers to protect the rights and interests of their employees, prohibiting the use of child labour, any form of forced labour, or human trafficking. All human resources service suppliers must adhere to relevant requirements for
protecting labour rights and ensuring occupational health and safety. We regularly evaluate service providers' performance, and the results serve as the basis for improving supplier management.
Data Privacy
We require third-party data processing activities to comply with Tencent's privacy protection standards and applicable laws and regulations of the jurisdictions where they operate, and manage suppliers throughout their entire lifecycle through our privacy management system. Firstly, we conduct due diligence on suppliers via questionnaires, qualification reviews, and other assessment procedures, and evaluate the effectiveness of their data protection measures. Secondly, we enter into Data Processing Agreements with suppliers, clearly stipulating their data protection obligations, including the implementation of technical measures such as encryption, de-identification, and anonymisation, and requiring their consent to Tencent's audit rights over their data processing activities. Thirdly, we require suppliers to ensure that data collection, processing, storage, and transmission comply with the security and compliance requirements of applicable privacy and data security laws and regulations in the jurisdictions where we operate, including but not limited to the Personal Information Protection Law of the People's Republic of China ("PIPL") and the EU's General Data Protection Regulation ("GDPR").
In 2025, we provided privacy protection training for suppliers, covering key data protection regulations and emphasising the essential requirements of Tencent's privacy policies and Data Processing Agreements. We also collaborated with value chain partners to sign a Personal Information Protection Initiative, jointly promoting the rights and interests of Internet users.
Business Ethics
We require all suppliers to uphold business ethics, prohibiting conflicts of interest, bribery, fraud, and falsification. The Sunshine Tencent Introduction Brochure requirements are communicated to suppliers through our website, supplier portal, Weixin official account, online courses, and in-person training. Since 2023, we have conducted mandatory training for suppliers of our domestic game business covering topics such as intellectual property, confidentiality, compliance, and integrity. By the end of 2025, over 16,000 suppliers had completed the training.