9.3 Personnel must not authorise an Associated Person or third party to do something that violates this Policy. Personnel may not circumvent this Policy or any other relevant Swire Properties policies, including the Code of Conduct by using an Associated Person or third party to do something that Swire Properties or the relevant Personnel could not do itself. 9.4 Turning a “blind eye” or ignoring “red flags” that something may be wrong does not protect Swire Properties or its Personnel from criminal liability. It is therefore vital that Personnel pay close attention to Swire Properties’ relationship with Associated Persons and third parties. It is the responsibility of all Personnel to understand the services that Associated Persons and third parties perform for Swire Properties. Where Associated Persons or third parties perform services in a jurisdiction or market where there is a reputation for bribery and corruption, particular attention should be paid. A non-exhaustive list of unusual transactions and requests (“Red Flags”) which may indicate heightened risk is included in Appendix II. If you have any concerns about the behaviour of an Associated Person or third party, you should report the concern in accordance with the Whistleblowing Policy. Due Diligence & Associated Person Compliance 9.5 Before entering into any contract or arrangement with an Associated Person or prospective recipient of any charitable donations or sponsorships, you must first conduct a reasonable investigation into his, her or its background, reputation, business credentials and capabilities, charitable status (where relevant), including compliance with the Know-Your-Partner Policy. The purpose of the due diligence process is to obtain comfort that an Associated Person does not pose an unacceptable risk of violating Anti-Bribery Laws. The due diligence process may be different for each scenario as it must be proportionate and risk-based in order to mitigate Swire Properties’ bribery risks. Due diligence may be conducted by Swire Properties Personnel if it is considered appropriate. 9.6 All relationships with Associated Persons must be documented in signed, written contracts, which include appropriate contractual provisions. No oral agreements or arrangements may be entered into with Associated Persons and written contracts must reflect the substance of the agreement and include full details of all compensation. 9.7 All contracts between Swire Properties and Associated Person or third parties acting for or on its behalf must contain appropriate provisions protecting Swire Properties from bribery and corruption risks. The circumstances surrounding the relationship with an Associated Person or third party will help determine the appropriate contract provisions relevant to Anti-Bribery Laws to be included in the contract. These are likely to include provisions preventing third parties from sub-contracting their obligations under the contract, subject to the express written agreement of Swire Properties. The Legal Team should be consulted when incorporating the appropriate provisions in the contracts. GIAD may also mandate anti-corruption and bribery training for Associated Persons operating in higher-risk jurisdictions or markets. - 10 -