4.4 Certain Anti-Bribery Laws, including without limitation the Prevention of Bribery Ordinance, 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), FCPA, the UK Bribery Act and the United Nations Convention Against Corruption have potential application wherever in the world an act of bribery or corruption takes place. Accordingly, regardless of your citizenship or the country in which you work, all Personnel in all of our offices must comply with this Policy. 5. GIFTS, ENTERTAINMENT, HOSPITALITY AND TRAVEL 5.1 Swire Properties recognizes that the exchange of business courtesies (whether given or received), such as modest gifts, entertainment, hospitality and travel, is common practice for various legitimate reasons, including to create goodwill, establish trust in relationships, or improve the image of a commercial organisation. Such courtesies have a justifiable business purpose and are allowed, provided that they are given in accordance with this Policy and that the value of the gift, entertainment, hospitality or travel is reasonable in the light of accepted business practices and is not intended to influence any decision of the person involved. 5.2 The provision or receipt of gifts, entertainment, hospitality and travel are only permissible where they are given or received, as the case may be, in accordance with the following rules: (a) All gifts, entertainment, hospitality and travel must comply with any policy or practice, including any Code of Conduct issued by Swire Properties from time to time. (b) The acceptance, though not the solicitation, of advertising or promotional gifts of a nominal value or gifts given on festive or special occasions subject to a maximum limit of HK$1,000 (or its equivalent in local currency) given by a business partner for a justifiable business purpose or consistent with local customary practice and not with the intention of influencing any decision is acceptable and requires no pre-approval. Prior approval of the relevant head of business or functional unit (as the case may be) should be obtained for the acceptance of any item exceeding this limit. This does not prevent the acceptance, though not the solicitation, of Chinese New Year Red Packets or “lai see” given as a token of local custom during festive season of up to HK$/RMB100 (or equivalent in other local currency). (c) The provision of advertising or promotional gifts of a nominal value or gifts given on festive or special occasions (including Swire branded vouchers or coupons) is permitted subject to a maximum value of HK$1,000 (or its equivalent in local currency). Prior approval of the relevant head of business or functional unit (as the case may be) should be obtained for any offer or provision of any item exceeding this limit. (d) The giving or receiving of cash gifts or loans is strictly prohibited. This does not prevent (i) the acceptance of “lai see” contemplated under paragraph 5.2(b) or (ii) the giving of “lai see” to another Personnel. - 5 -