(e) Gifts in the form of cash equivalent, including gift cards or vouchers, provided or received, must be in accordance with any policy, guidelines or practice, including this Policy and the Code of Conduct issued by Swire Properties from time to time applicable to the relevant business unit and/or activity, subject in each case to a maximum of HK$1,000 (or its equivalent in local currency). (f) All gifts, entertainment, hospitality and travel must be recorded fairly and accurately in a register maintained by the relevant business or functional unit (as the case may be) in accordance with any practice as may be issued by Swire Properties from time to time. (g) All gifts, entertainment, hospitality and travel must have a justifiable business purpose. Such business purpose should be documented. (h) All gifts, entertainment, hospitality and travel must be reasonable and appropriate to the recipient’s position and circumstance and to the occasion as well as to local and industry standards, so that it does not create an appearance of impropriety and could not reasonably be misunderstood by the recipient or others as a bribe or placing themselves in a position of obligation to the offeror. (i) All gifts, entertainment, hospitality and travel must comply with local law and the recipient’s organisation’s policies. (j) All Personnel and Associated Persons should exercise good judgment and practice moderation in giving and/or receiving gifts. Issues to consider 5.3 It is strictly prohibited to offer or make, directly or indirectly, Anything of Value to any Government Official. The provision of festive or special occasion gifts, entertainment, hospitality or travel to Government Officials with a justifiable business purpose is permitted, but should be treated with extra care so as to avoid any appearance that they are aimed at obtaining any advantage from a person in a public position, and is subject to the prior approval of the relevant head of business or functional unit (as the case may be). Any request from a Government Official, or from another person purporting to act on behalf of any Government Official, in relation to gaining business or a business advantage for Swire Properties must be refused and promptly reported to an appropriate director or officer of Swire Properties or to Director, Human Resources. 5.4 The provision of gifts, entertainment, hospitality or travel to an individual who has (i) a position in an entity with which Swire Properties is dealing, or about to deal; or (ii) has direct or indirect decision-making responsibility over an anticipated or pending decision that will affect Swire Properties interests, is particularly sensitive and should be treated with extra care. - 6 -