corruption policies consistent with the general principles of this Code and the ABC Policy. All such individuals or companies over which Swire Properties does not have direct control should be required contractually (and where not legally possible be appropriately encouraged) to adhere to the general principles set out in this Code and the ABC Policy. J. Loans Relevant Persons should not grant or guarantee a loan to, or accept a loan from or through the assistance of, any individual or organisation having business dealings with Swire Properties. For instance, a conflict of interest arises when a supplier acts as a guarantor on a bank loan for an employee. There is, however no restriction on normal bank lending made on normal commercial terms by banks which provide banking services to Swire Properties. K. Training All Relevant Persons should receive anti-bribery training. All employees should attend anti-bribery training organised by HR&A at least once every two years (except that those who need to handle cash or are involved in the decision making process of any business transactions should attend such training on an annual basis). In addition, all employees should sign an annual declaration on their compliance with Swire Properties Code of Conduct which includes Swire Properties' anti-bribery policies and procedures. 4.5 Political Activities and Contributions Like any other citizens, Relevant Persons may participate in political activities on an individual basis, including by being members of political parties and standing for election to public bodies. At Swire Properties' discretion, Relevant Persons may participate in political activities at times when they would normally be working. Swire Properties may also, at its discretion, reimburse costs which Relevant Persons elected to public bodies are expected to incur in performing their duties, if those costs are not reimbursed by the bodies to which they are elected. In participating in political activities, Relevant Persons must at all time comply with applicable laws and regulations. Swire Properties, as a normal business activity, will lobby Government Entities either directly or through trade associations to promote policies that encourage business and achieve workable legislation. However, Swire Properties does not itself make direct political contributions and Relevant Persons should not make direct political contributions (in cash or in kind, for example by permitting Swire Properties' premises or equipment to be used by political parties) on behalf of Swire Properties. This will not prevent paying for attendance at open social events hosted by political parties. Nor will it prevent Relevant Persons from making political contributions in their individual capacities or engaging in political activities as contemplated by the previous paragraph. - 7 -