1. INTRODUCTION 1.1 Swire Properties believes that conducting business with integrity is critical to its success as a sustainable and responsible business group. Bribery and corruption hinder economic and social development and progress by confounding market principles. As such, Swire Properties is committed to ensuring compliance with anti-bribery and corruption (“Anti-Bribery Laws”) laws and regulations that governs its global businesses. 1.2 Swire Properties is subject to laws that prohibit bribery and corruption and that requires us to take certain steps to prevent bribery and corruption within Swire Properties and by Associated Persons. The consequences of any violation of these laws can be severe, including unlimited fines for Swire Properties and imprisonment of the individuals involved. Moreover, failure to follow applicable laws can result in irreparable damage to Swire Properties’ brand and reputation. 1.3 This Anti-Bribery and Corruption Policy (“Policy”) sets out the standards of behaviour expected from Swire Properties and the compliance procedures adopted by Swire Properties and reaffirms Swire Properties’ commitment to provide guidance to all relevant parties about compliance with global Anti-Bribery Laws. 1.4 Compliance with this Policy is essential to maintaining Swire Properties’ reputation and good standing in the global business community. Should you, at any time, have any questions or concerns related to this Policy, Anti-Bribery Laws or acts/conduct that are not permissible, please contact the Director, Human Resources. 1.5 A glossary of defined terms is included in Appendix I to the Policy. 2. POLICY STATEMENT 2.1 It is our policy to conduct all of our business honestly and in accordance with the laws by which we are bound. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. 2.2 Swire Properties’ Personnel must comply with the applicable Anti-Bribery Laws of all countries in which Swire Properties does business. 2.3 Swire Properties expects its Associated Persons to comply with the values contained in this Policy. 2.4 Swire Properties will not, and nor will our Personnel or Associated Persons, either directly or indirectly (i) offer, (ii) promise, (iii) agree to pay, (iv) authorise payment of (v) pay, (vi) give, (vii) receive, (viii) accept or (ix) solicit Anything of Value to or from another Associated Person or any third party in order to secure or reward the improper influence of the performance of a function or activity. - 3 -