Further Frequently Asked Questions on Sale and Distribution of Green and Sustainable Investment Products

55th Floor, Two International Finance Centre, 香 港 中 環 金 融 街 8 號 國 際 金 融 中 心 2 期 55 樓 8 Finance Street, Central, Hong Kong 網 址：www.hkma.gov.hk Website: www.hkma.gov.hk Our Ref: B1/15C G16/1C 29 December 2025 The Chief Executive All Registered Institutions Dear Sir / Madam, Further Frequently Asked Questions on Sale and Distribution of Green and Sustainable Investment Products Following the circular issued by the Hong Kong Monetary Authority (“HKMA”) in respect of the Sale and Distribution of Green and Sustainable Investment Products (“2023 G&S Circular”) on 29 November 2023 and the continued interest in green and sustainable investment products observed in the markets, the HKMA has conducted a round of thematic review (“Review”) on registered institutions (“RIs”) on their implementation of expected standards outlined in the 2023 G&S Circular. From the Review, the HKMA observes that RIs have generally implemented the expected standards, including putting in place the policies, procedures and controls to manage greenwashing risks. The HKMA also notes from the Review an increase in number of RIs participating in bookbuilding activities, and that these RIs have implemented the expected standards in the 2023 G&S circular for these activities. Certain areas for improvement have been identified in the Review. Some RIs have yet to establish proper policies and procedures governing the classification framework for green and sustainable investment products. As part of follow-up actions, these RIs have committed to enhance their policies and procedures to strengthen the governance and oversight of these products.

• 2 - In light of industry enquiries and to enhance customer experience while ensuring investor protection, the HKMA is providing additional guidance and further practices noted from RIs in the form of Frequently Asked Questions (“FAQs”). In particular, the further FAQs clarify the inapplicability of the expected standards (except on bookbuilding) set out in the 2023 G&S Circular to transactions where the RIs do not market or classify the investment product as green and sustainable. Separately, RIs may continue to follow existing regulatory guidance on streamlining product disclosure to meet the expected standards on “Disclosure” in the 2023 G&S Circular. The FAQs are set out in the Appendix. If there are any questions on this circular, please contact Mr Andrew Ng at 2878- 8813 or Ms Ian Au at 2878-1757. Yours faithfully, Alan Au Executive Director (Banking Conduct) Encl. c.c. Securities and Futures Commission (Attn: Dr Eric Yip, Executive Director, Intermediaries)