7. CHARITABLE DONATIONS AND SPONSORSHIP Charitable Donations 7.1 Swire Properties only makes charitable donations that are legal and are associated with charitable causes. All charitable donations by Swire Properties should be authorised by the Chief Executive and submitted to the Finance Department for inclusion in the philanthropy report of Swire Properties. 7.2 While donations to charitable organisations are ordinarily regarded as good corporate citizenship, those made to organisations in which a political association or Government Officials possess a role (such as trustee) or have an interest may cause concerns under international Anti-Bribery Laws. Please also refer to paragraph 8 of this Policy in relation to political contributions. 7.3 Use of Swire Properties’ resources to make or solicit contributions to charitable organisations, if done in accordance with applicable laws and regulations, is appropriate. All Personnel must comply with this Policy and other relevant procedures for “Charitable Contributions and Sponsorship” applicable to their business or functional units for contributions or solicitations of contributions by Swire Properties to charitable organisations. 7.4 Personnel may make charitable donations on their own behalf, and not on behalf of Swire Properties, provided they are in accordance with applicable laws and regulations. Swire Properties will not reimburse any personal charitable donations. Sponsorships 7.5 Sponsorship enables Swire Properties to partner with third parties to create mutual benefits by an exchange of monies or in-kind benefits. Sponsorships may be of a charitable nature (such as sponsoring a charity sports event) or for commercial purposes (such as sponsorship items for a counterparty’s annual dinner or lucky draw). 7.6 In addition to cash payments, sponsorships may include items such as free flights, hotel vouchers, food and beverage or supermarket coupons. All sponsorship items 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. Specific Guidelines for Sponsorships and Charitable Donations 7.7 All sponsorships and donations must comply with applicable laws and regulations and should be made in accordance with both Swire Properties and the sponsored / recipient’s organisation’s policies and procedures. All Personnel must comply with this Policy and other relevant procedures for “Charitable Contributions and Sponsorship” applicable to their business or functional units for contributions or solicitations of contributions by Swire Properties. 7.8 Payments to individuals or private accounts are not permitted. - 8 -