7.9 Sponsorships or donations may sometimes create problems for Swire Properties if they are seen as being linked to seeking or obtaining an improper advantage. Care must be taken to ensure that any sponsorship activities or donations do not create, or appear to create, any improper advantage to Swire Properties or which would damage the reputation of Swire Properties. 7.10 All sponsorship activities and donations must be justified by reference to a legitimate commercial or charitable purpose and must not be made or received in conjunction with, as part of or in relation to negotiation of any bid, tender, contract renewal or prospective business relationship relevant to Swire Properties. 7.11 Sponsorship and donations must not be used to disguise a payment that is prohibited by this Policy or any Code of Conduct issued by Swire Properties from time to time. If policies prohibit the payment in another form, it must not be made under the guise of a donation or sponsorship. 8. POLITICAL CONTRIBUTIONS 8.1 Swire Properties does not itself make any direct political contributions and no Personnel or Associated Person shall make any direct political contributions (in cash or in kind, for example, by permitting Swire Properties’ premises or equipment to be used by political parties) on behalf of Swire Properties. This will not prevent paying for attendance at open social events hosted by political parties. Nor will it prevent Personnel or Associated Person from making political contributions or engaging in political activities in any case in their individual capacities. 8.2 Personnel may participate in political activities on an individual basis, with personal money and time, provided they do so in accordance with applicable laws and regulations. Swire Properties will not reimburse any personal political contributions. At Swire Properties’ discretion, Personnel may participate in political activities at times when they would normally be working. Swire Properties may, at its discretion, reimburse costs which Personnel elected to public bodies are expected to incur in performing their duties. 9. ASSOCIATED PERSONS AND THIRD PARTIES 9.1 Anti-Bribery Laws prohibit “indirect” as well as direct payments and offers. As a result, Swire Properties and our Personnel may be held liable for the conduct of Associated Persons and third parties when we know or could reasonably have known of the unlawful conduct. There is a risk that Associated Persons or third parties may mistakenly believe that as a local individual or company they enjoy more freedom and may adopt local standards, which creates potential risk for Swire Properties. 9.2 Special care must be taken when Associated Persons such as advisors, business developers and other agents and parties are engaged to provide services or where any Associated Person is expected to assist in establishing new business opportunities or where such Associated Person will be involved in obtaining any government approvals or action. Swire Properties Personnel should take steps to ensure that Associated Persons fully comply with the applicable Anti-Bribery Laws to which they are subject and to appropriately encourage them to adhere to principles set out in this Policy. - 9 -