Properties. The provision of festive or special occasion gifts, entertainment, hospitality or travel to Government Officials with a justifiable business purpose is permitted, but should be treated with extra care so as to avoid any appearance that they are aimed at obtaining any advantage from a person in a public position, and is subject to the prior approval of the relevant head of business or functional unit (as the case may be). Any request for an Advantage by any Government Official in relation to gaining business or a business advantage for Swire Properties must be refused and promptly reported to an appropriate director or officer of Swire Properties or to Director, Human Resources. E. Charitable contributions and sponsorship Use of Swire Properties' resources to make or solicit contributions to charitable or other organisations, if done in accordance with applicable laws and regulations, is appropriate. Nevertheless, care must be taken to ensure that such activities do not create, or appear to create, an improper Advantage covered by this Code. Relevant Persons must comply with procedures for “Charitable Contributions and Sponsorship” (Appendix C) for contributions or solicitations of contributions by Swire Properties to charities or other organisations. F. Entertainment and Corporate Hospitality Although entertainment is an acceptable form of business and social behaviour, Relevant Persons should not accept excessive gifts or entertainment in terms of value or frequency from persons with whom Swire Properties has business dealings if, by doing so, it might be perceived that they are placing themselves in a position of obligation to the offeror. When giving entertainment, company functions are normally preferable to entertaining individuals, though this does not preclude meals and similar entertainment of moderate expense for individuals with whom Swire Properties has dealings. The business purpose of entertainment and corporate hospitality should be documented. Relevant Persons should be particularly vigilant concerning entertainment offered to them outside Hong Kong and turn down invitations to meals or entertainment that are excessive in terms of value or frequency and appear to have no or minimal business purpose. It should be noted that any free trips or travelling expenses are considered as Advantages. Without the prior consent of Swire Properties, acceptance of these advantages is strictly prohibited. Relevant Persons should follow the procedures for “Entertainment and Corporate Hospitality” (Appendix D). G. Travel Expenses Travel expenses incurred on behalf of a person or company (including a Government Official or a Government Entity) that are directly related to promoting, demonstrating, explaining, or certifying Swire Properties' - 5 -