5.5 The frequency of prior gifts, entertainment, hospitality or travel provided to the same recipient can create an appearance of impropriety. Excessive gifts, entertainment, hospitality or travel in terms of value or frequency should not be offered to potential or existing customers. Gifts bearing a Swire logo are preferred. 5.6 Any travel provided by Swire Properties must be for a justifiable business purpose and should be documented. Swire Properties may reimburse any reasonable and bona fide expenditures directly related to such justifiable business purpose, such as reasonable travel, meal or lodging expenses. In any event, no unreasonable side trips or per diem cash of any amount may be provided. It should be noted that any free trips or travelling expense are considered as Anything of Value; without the prior consent of your supervisor or manager, the provision or acceptance of such items is strictly prohibited. 5.7 Government Entities and commercial customers and other business partners may have their own restrictions based on policies or law, regarding their ability to receive any gifts, which may prohibit even modest or token gifts. Before you offer a gift to a customer or business partner, it is advisable to find out if it is permissible for such customer or business partner to accept such a gift under their own policies. 5.8 Swire Properties Personnel should be present at any entertainment or hospitality paid for by Swire Properties and should exercise judgement to ensure that the activity does not jeopardize Swire Properties’ reputation or interests. Swire Properties should only pay for entertainment, hospitality or travel for those whose involvement is for justifiable business purposes. 5.9 If you have any questions or concerns about whether any gift, entertainment, hospitality or travel is appropriate, you should consult your supervisor before incurring any expense or accepting any offer. 6. FACILITATION PAYMENTS AND KICKBACKS 6.1 No Personnel or Associated Persons shall make or accept, directly or indirectly, “facilitation” payments or “kickbacks” of any kind. 6.2 A “facilitation” (or “facilitating”) payment is typically a small, unofficial payment to a Government Official over and above any official fee or charge made to secure or expedite a routine government action by a Government Official. “Kickbacks” are bribes to obtain an undue advantage, where a portion of the undue advantage is “kicked back” to the person who gave, or is supposed to give, the undue advantage. Swire Properties prohibits facilitation payments or kickbacks of any kind. 6.3 Any request for facilitation payment or kickbacks must be reported to Director, Human Resources as soon as possible. - 7 -