A. Accepting Advantages Relevant Persons should not solicit or accept any Advantages from any person or company having business dealings with Swire Properties (e.g. clients, suppliers, contractors). However, they are allowed to accept (but not solicit) the following gifts offered voluntarily: • Advertising or promotional gifts of a nominal value; or • Gifts given on festive or special occasions subject to a maximum limit set out in the ABC Policy. Any Advantage or gift accepted by a Relevant Person should be in accordance with Swire Properties' procedures for “Acceptance of Gifts or Advantages” described in Appendix A. Relevant Persons should decline an offer of a gift if acceptance of it could affect the Relevant Person's objectivity, or induce the Relevant Person to act against Swire Properties' interests, or lead to questions of bias or impropriety. B. Offering Advantages Under no circumstances may a Relevant Person offer an Advantage to any person or company having business dealings with Swire Properties for the purpose of influencing such person or company in any business dealings. Any Advantage given in the conduct of Swire Properties' business should be in accordance with Swire Properties' procedures for “Offer of Gifts or Advantages” (Appendix B). Relevant Persons should also exercise good judgment and practise moderation in giving gifts. These should not be given in cash, cash equivalents or loans. Excessive gifts in terms of value or frequency should not be offered to potential or existing customers. Gifts bearing a Swire Properties logo are preferred. C. Observing local laws when working in another jurisdiction Sections A and B above apply whether the solicitation, acceptance and offering of Advantages are within or outside Hong Kong. Any Relevant Person who conducts business on behalf of Swire Properties in another jurisdiction must also abide by the laws of that jurisdiction, including laws and regulations on anti-bribery and corruption, and all other laws and regulations pertaining to ethical business conduct. D. Payments to Government Officials It is strictly prohibited to offer an Advantage to any Government Official. Prohibited Advantages should not be made directly, through a Relevant Person's own personal involvement, or indirectly, for example by authorising or allowing a third party to provide a prohibited Advantage on behalf of Swire - 4 -