APPENDIX I – GLOSSARY Glossary of defined terms used in this Policy “Anti-Bribery Laws” Includes, without limitation, the FCPA, the UK Bribery Act, the POBO, the PRC Criminal Law (中華人民共和國 刑法),the PRC Anti-unfair Competition Law (中華人民 共和國反不正當競爭法), the United Nations Convention Against Corruption and all laws enacted and implemented pursuant to the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions issued by the Organisation for Economic Cooperation and Development (“OECD”). “Anything of Value” Means a financial advantage, or any other benefit, whether in cash or in kind, tangible or intangible. Examples include, money, gifts, loan (including the forgiving of a loan), fee, reward, commission, payment, release discharge, contract, service, promise, meals, entertainment, airline tickets or discounts, travel or other types of vouchers, offers of employment, charitable contributions and any other favour. “Associated Persons” Means all of Swire Properties’ agents, contractors, intermediaries, business developers, service providers, joint ventures over which it does not exert control, outside consultants and other parties acting on behalf, or under the control, of Swire Properties. “Code of Conduct” Means (i) the Swire Properties Corporate Code of Conduct Policy; (ii) Swire Properties Supplier Code of Conduct Policy; and (iii) such other code of conduct as may be issued by Swire Properties from time to time. “FCPA” Means the United States Foreign Corrupt Practices Act. “GIAD” Means Swire Pacific Limited’s Group Internal Audit Department. “Government Entity” Includes any national, regional or local government and any department, agency or instrumentality of the foregoing and any entity or enterprise owned or controlled by another Government Entity, including sovereign wealth funds, government-controlled businesses, government-controlled non-profit organisations, and government-affiliated investment vehicles. - 14 -