“Government Official” For the purposes of this Policy, “Government Officials” means all individuals, who, regardless of rank, are: • Government officials or employees; • Members of political parties, party officials and candidates for public office; • Directors and employees of any Government Entity; • Officials and employees of public international organisations (for example, the United Nations, International Olympic Committee, International Red Cross, World Bank, etc.); • People who are considered to be Government Officials under Anti-Bribery Laws or other applicable local laws; • People acting on behalf of any of the foregoing, even though they may not be employees of the government or any of the organisations referred to above; or • Close relatives (for example parent, sibling, spouse or child) or close business associates of any of the above. “Personnel” Means Swire Properties’ directors, officers, employees (including secondees), temporary agency workers and interns working for Swire Properties. “POBO” Means the Hong Kong Prevention of Bribery Ordinance Cap. 201. “Policy” Means this Policy as defined at paragraph 1.3 above. “Red Flags” Means the non-exhaustive list of unusual transaction and requests as set out in Appendix II. “Swire Properties” or Means Swire Properties Limited and/or, as the context may “Company” require, its subsidiaries or any of them. “UK Bribery Act” Means the United Kingdom Bribery Act 2010. - 15 -