4.9 Use of Information/Company Property This Code strictly prohibits Relevant Persons from providing or making available confidential or inside information to anyone outside Swire Properties without proper authorisation. Similarly, this Code strictly prohibits Relevant Persons from making use of confidential or insider information to secure advantage personally or for another party. Directors and officers of Swire Properties are subject to more stringent requirements regarding transactions in shares of Swire Properties and these are set out in Swire Properties' Code for Securities Transactions by Directors. The unauthorised appropriation of goods and services belonging to Swire Properties for personal use or resale and the unauthorised use of Swire Properties' assets for personal benefit are strictly prohibited. Relevant Persons should not alter equipment or facilities or install software without specific authorisation or develop their own applications without management approval. Security precautions mandated by Swire Properties should be exercised when using personal computers and mobile devices, and no computer software should be installed or used on personal computers or mobile devices in breach of copyright. 4.10 Whistle-blowing All Relevant Persons are encouraged to report improprieties in accordance with Swire Properties’ Whistleblowing Policy, which can be found at https://ir.swireproperties.com/en/cg/pdf/whistleblowing.pdf. 4.11 Health and Safety and the Environment Swire Properties is committed to doing its best to safeguard the health and safety of its employees, those with whom it does business and the communities within which it operates. It aims to create long term value for its shareholders. Achieving this depends on the sustainable development of its businesses and the communities in which it operates. To this end, Swire Properties is committed to being a good steward of the natural resources and biodiversity under its influence and to ensuring that all potential adverse impacts of our operations on the environment are identified. 4.12 Diversity and Inclusion and Respect in the Workforce Swire Properties is committed to creating an inclusive and supportive working environment for all its people regardless of their age, gender, gender identity, sexual orientation, relationship, family status, disability, race, ethnicity, nationality, religious or political beliefs. We believe in creating an environment where people feel comfortable at work and able to realise their full potential. All Relevant Persons are required to comply with Swire Properties' Respect in the Workplace Policy, which can be found at https://www.swireproperties.com/en/sustainable- development/policies/respect-in-the-workplace-policy/. - 9 -