12.3 All Personnel must ensure that all expense claims relating to gifts, entertainment, hospitality, travel or expenses incurred in relation to Associated Persons or other third parties are submitted in accordance with the relevant Swire Properties policy and specifically record the reason for the expenditure. 12.4 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. This includes any commissions, service or consulting fees, expenditures for gifts, meals, travel and entertainment, and expenses for promotional activities. Proper reporting should include clear notation regarding the nature of each expense, identification of all recipients and/or participants, the necessary approvals received for the expense and the accounts payable voucher. 12.5 No accounts shall be kept “off-book” to facilitate or conceal improper payments. No artificial, inaccurate, incomplete, false or misleading entries in the books, records, or accounts are permitted. 12.6 All records must be maintained for a minimum of seven years, or a longer period if required pursuant to applicable Swire Properties records retention policy or local laws and regulations. 12.7 Personal funds must not be used to accomplish what is otherwise prohibited by this Policy. 12.8 To ensure that this Policy is followed correctly, GIAD may conduct audits to review transaction files and financial records, agreements with third parties, and interview with any Personnel. Full cooperation is required of all Personnel. 13. ABOUT THIS POLICY 13.1 This Policy is subject to regular review by Swire Properties. This Policy and any changes will be posted on the website of Swire Properties Limited. The version stored on the website of Swire Properties Limited shall be retained as the most current and authoritative version of this Policy. Personnel should periodically refresh their understanding to ensure that they are familiar with current policies and procedures. This Policy should be read in conjunction with the Code of Conduct. In the event of any inconsistency between this Policy and other policies of Swire Properties (including the Code of Conduct), this Policy shall prevail. 13.2 This Policy defines the minimum standards that all Personnel worldwide must observe when dealing with Associated Persons, Government Officials, business partners and other parties on behalf of Swire Properties. If any Personnel have questions regarding this Policy or the Anti-Bribery Laws, are in a situation that may raise anti-bribery concerns or are uncertain about how to proceed, they must consult Director, Human Resources. 13.3 All Personnel should receive anti-bribery and corruption training. - 13 -