2.5 Prohibited payments or offers as set out in this Policy are always impermissible, whether or not they are given to a Government Official or to an employee of a non- governmental business or entity, and regardless of whether they are given by another person or entity on behalf of Swire Properties. 2.6 Swire Properties and its Personnel will conduct business in compliance with this Policy and will not violate any Anti-Bribery Laws. All Personnel must be familiar with the rules described in this Policy and regularly refresh their understanding of this Policy. Those who are in supervisory roles must ensure that the Personnel who report to them are familiar with and understand the contents of this Policy. 3. SCOPE 3.1 This Policy applies directly to: (a) the operations of Swire Properties and its subsidiaries and its and their respective Personnel and Associated Persons; if a subsidiary already has its own anti-corruption and bribery policy, such policy shall be aligned and consistent with this Policy; (b) Personnel shall mean Swire Properties’ directors, officers, employees (including secondees), temporary agency workers and interns working for Swire Properties; and (c) actions taken on Swire Properties’ behalf by its Associated Persons and other third parties. 3.2 For the purposes of this Policy, Associated Persons includes all of Swire Properties’ agents, contractors, intermediaries, business developers, service providers, joint ventures over which it does not exert control, outside consultants and other parties acting on behalf, or under the control, of Swire Properties. 4. ANTI-BRIBERY LAWS 4.1 Bribery and corruption are prohibited in all countries in which Swire Properties operates. 4.2 Under applicable Anti-Bribery Laws, Swire Properties and Personnel may be subject to criminal liability if any Personnel or Associated Person directly or indirectly, offers or pays, receives or solicits, Anything of Value in exchange for an improper advantage or the influence of the performance of a function or activity. 4.3 It is important to note that: (a) even an attempt to bribe a person is unacceptable. It is still illegal even if the offer is not accepted or the payment does not achieve the desired outcome; and (b) the perception of impropriety can cause irreparable damage to Swire Properties’ brand and reputation and may require us to pay significant litigation fees in our defence. - 4 -