Code of Conduct

Corporate Code of Conduct 1. Background 1.1 For over a century, the Swire group of companies has been recognised as acting responsibly in the course of achieving its commercial success. Our reputation for fair dealing and integrity is a great asset: preserving this asset depends on maintaining our high standards. Compliance with this Code is an essential part of our doing so. 1.2 This Code applies to all Relevant Persons and is applicable wherever Swire Properties does business. In the case of joint ventures and associated companies, the Swire Properties representatives concerned are expected to act in accordance with this Code themselves and to use reasonable endeavours to influence those with whom they are working to ensure they also act to similar standards of integrity and ethical behaviour. 1.3 This Code establishes general principles. Certain areas covered by this Code may be the subject of more detailed provisions and requirements established by other documents. 2. Interpretation 2.1 In this Code: “Advantage” includes any money, gift, loan, fee, reward, commission, employment, payment, release, discharge, contract, service, promise and any other favour. “ABC Policy” means the Anti-Bribery and Corruption Policy of the Company. “Connected Person” includes any close relative of a Relevant Person and any company controlled by a Relevant Person or by a close relative of a Relevant Person. “Government Official” includes any officer or employee of any Government Entity, any candidate for political office, any close relative of any such officer, employee or candidate and any company controlled by any such officer, employee or candidate or by any such close relative. - 1 -