10. CONFIDENTIAL REPORTING 10.1 Any Personnel who is asked to provide or is offered Anything of Value in a manner that is prohibited by this Policy or suspects that any other Personnel or Associated Person is engaging in conduct which this Policy prohibits, including any actual or suspected impropriety, must report such conduct without delay under the Whistleblowing Policy which can be found at https://ir.swireproperties.com/en/cg/pdf/whistleblowing.pdf. 10.2 All Personnel are responsible for preventing, detecting and reporting instances of actual or suspected bribery, corruption or non-compliance with this Policy via the above channels. In all circumstances immediate reporting is essential. Prompt reporting and resolution of bribery and corruption issues can help to ensure that Swire Properties acts in accordance with this Policy and all applicable laws. 10.3 Any report of actual or suspicious conduct will be treated as confidential. No Personnel acting in good faith will suffer any adverse consequences for reporting or refusing to engage in prohibited conduct (even if such a refusal results in a loss of business to the Company). Swire Properties will not tolerate any retribution or retaliation against anyone who in good faith reports a concern or cooperates with any investigation, even when allegations are found to be unsubstantiated. 10.4 Any Personnel who retaliate against any other Personnel or Associated Person in violation of this Policy will be subject to disciplinary action, up to and including termination of employment or engagement (as the case may be). Any suspicion of retaliation must be immediately reported to GIAD. 10.5 When contacted by GIAD or the Legal Team, Personnel have an obligation to cooperate with investigations into alleged misconduct. Failure to cooperate and provide honest, truthful and complete information may result in disciplinary action. 11. CONSEQUENCE OF NON-COMPLIANCE AND DISCIPLINARY ACTION 11.1 Failure to comply with any provision of this Policy will result in disciplinary action, up to and including termination of employment or engagement (as the case may be), as well as civil or criminal charges being brought. In case of actual or suspected breach of Anti-Bribery Laws or other applicable laws, a report will be made to the relevant authorities in Hong Kong and elsewhere in the world as may be relevant. 12. RECORD KEEPING AND MONITORING 12.1 Swire Properties and its Personnel must maintain all financial records or such other records, according to relevant financial and internal controls standards, requirements and generally acceptable practice, which evidence the business reason for making payments (including, but not limited to, gifts, entertainment, hospitality and travel, whether in cash or cash equivalent) to third parties. 12.2 Personnel must declare and keep a written record of all hospitality or gifts accepted or offered in departmental registers, which will be subject to managerial review. - 12 -