Appendix D Entertainment and Corporate Hospitality Control Guideline Relevant Persons should be particularly vigilant in offering or being offered entertainment and turn down invitations to meals or entertainment that are excessive in nature or frequency and appear to have no or minimal business purpose. Procedures on Entertainment 1. When Relevant Persons need to entertain or pay for meals for customers or business associates, they are expected to use their judgment to determine whether the kind of entertainment is appropriate and expenses incurred are reasonable. Factors such as the image of Swire Properties, local customs, etc. should always be considered. 2. If several members of staff are present at the same event, the most senior member of staff should pay and file an expense claim for approval by his/her manager followed by the relevant Head of Department. Procedures on Corporate Hospitality 1. Corporate hospitality events are arranged by the Marketing teams & Public Affairs Department from time to time to recognise the support given to Swire Properties by our tenants, business partners and journalists/media representatives and to build relationships with them. 2. Larger events are managed by and accounted for in the Swire Properties budget by the Corporate Marketing team; smaller events are paid out of each department's entertainment budget. Approval for the payment of such events should follow Swire Properties' payment approval matrix. 3. Corporate hospitality events should generally involve either gifts of low or nominal value or small items of low value from the Swire Properties merchandise catalogue.