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Appendix C Charitable Contributions and Sponsorship Control Guideline Use of Swire Properties' resources to make or solicit contributions to charitable organisations or other organisations, if done in accordance with applicable laws and regulations, is appropriate. Care must be taken to ensure that such activities do not create, or appear to create, an improper Advantage to Swire Properties. Procedures for Charitable Contributions 1. Charitable contributions are only given to recognised charitable bodies with a strong track record of delivering value to the community or the environment. 2. All such contributions by Swire Properties to the charitable body should be authorised by the Chief Executive. When seeking approval, the initiators should provide supporting details including date, purpose and amount, etc. 3. Such contributions and sponsorships are managed by and accounted for in the Swire Properties budget by the Public Affairs Department. Procedures for Sponsorships 1. Sponsorship may be of a charitable nature (such as sponsoring a charity sports event) or for commercial purposes (such as sponsorship items for a counterparty’s annual dinner or lucky draw). 2. Sponsorships are only given to recognised legal entities which have a strong track record of providing the appropriate level and type of exposure for corporate sponsors in return for the sponsorship. 3. In addition to cash payments, sponsorships may include items such as free flights, hotel vouchers, food and beverage or supermarket coupons. All sponsorship items must be recorded fairly and accurately in a register maintained by the relevant business or functional unit (as the case may be) in accordance with any practice as may be issued by Swire Properties from time to time. 4. Such contributions and sponsorships are managed by and accounted for in the Swire Properties budget by the Corporate Marketing team.

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