4.6 Gambling Relevant Persons should not engage in frequent or excessive gambling of any kind with other Relevant Persons or with persons having business dealings with Swire Properties. In social games of chance with clients, suppliers or business associates, they must exercise judgment and withdraw from any high stake games. 4.7 Procurement In procurement, Swire Properties requires Relevant Persons to support the following principles: • The Swire Properties group should develop policies as to the size of the purchase above which tendering should be carried out. For purchases exceeding this limit, suppliers should be selected on the basis of competitive tendering including the impartial selection of appropriately qualified suppliers. • Whenever competitive tendering above the size thresholds is not carried out a file note explaining why such tendering was not done should be produced and kept on the supplier file. • Re-tendering should in general take place at least every three years. • Monitoring systems should be put in place to ensure the proper fulfilment of contractual obligations and to provide reasonable assurance that fraudulent or corrupt activities are prevented. • Suppliers should be encouraged to make an annual statement that no personal benefit accrues to Swire Properties personnel or supplier personnel from this business arrangement and that they have complied with all legal requirements. • Construction contract procurement should adhere to Section 10 “Contract Procurement Process” of the Swire Properties Project Manual. Contracts for the procurement of minor works and for property maintenance should adhere to Swire Properties Management Limited Tendering Procedures and General Guidelines. Exceptions should be approved by the Chief Executive. • Suppliers are assessed to ensure they comply with Swire Properties supplier corporate social responsibility code of conduct as well as the Swire sustainable procurement policy. 4.8 Keeping of Records Swire Properties is committed to keeping proper records and following sound accounting policies. All company books, records, accounts, invoices and other documents must be created and maintained so as to reflect fairly and accurately and in reasonable detail the underlying transactions and the disposition of company business. All relevant expenses should be properly approved and recorded in the financial records. This Code prohibits all Relevant Persons from making any false or misleading statements or other entries in financial records. This Code also prohibits Relevant Persons from creating, maintaining and using any off-the-record accounts with banks or any other third parties and from destroying company records before the normal destruction date. - 8 -