• Working for a non-Swire Properties company or non-affiliated organisation at the same time as being employed by Swire Properties. • Becoming a member of a board of any non-affiliated commercial, financial or industrial organisation. • A Relevant Person or a Connected Person negotiating or transacting business with Swire Properties (other than employment contracts or retail purchases of Swire Properties products). • Having an interest in a company (other than as a holder of securities in a company whose securities are listed on any stock exchange) which either competes with or has business dealings with Swire Properties. Relevant Persons (except for non-executive directors of Swire Properties) who wish to take up concurrent employment, whether on a regular or consultancy basis, must seek the prior written approval of HR&A before accepting the employment. 4.3 Competition and Antitrust Swire Properties is committed to complying with all applicable competition and antitrust laws. Relevant Persons should acquaint themselves and comply with the applicable competition laws to which their businesses are subject. These are laws that aim to protect competition by prohibiting anti-competitive behaviour. Breach of competition laws is a serious offence and may expose Swire Properties to severe penalties and other sanctions, and individuals to imprisonment. Set out below is a non-exhaustive list of anti-competitive behaviour which would potentially amount to an infringement of competition laws: • Participating in price fixing, collective boycotts or market sharing arrangements. • Exchanging competitively sensitive information with competitors. • Imposing restrictions on customers or suppliers, including retail price maintenance. • Abusing a position of substantial market power or market dominance. 4.4 Bribery Swire Properties believes that conducting business with integrity is critical to continuing to develop Swire Properties as a successful, sustainable and responsible business group. Corruption hinders economic, social and political development and progress. Breach of anti-bribery laws, wherever and however this takes place, is a serious offence and may expose Swire Properties to significant fines and other penalties, and individuals to imprisonment. Even the appearance of a breach of anti-corruption laws can cause very significant damage to Swire Properties' reputation. It is Swire Properties' policy that all Relevant Persons should comply with the anti- bribery laws to which they are subject. This Code and the ABC Policy set out the standards of behaviour expected from Swire Properties and the anti-bribery compliance procedures adopted by Swire Properties. - 3 -