Appendix A Acceptance of Advantages Control Guideline Relevant Persons should not solicit or accept any Advantages from any person or company having business dealings with Swire Properties {e.g. client, suppliers, contractors). However, they are allowed to accept (but not solicit) the following gifts offered voluntarily: • Advertising or promotional gifts of a nominal value; or • Gifts given on festive or special occasions subject to a maximum value as set out in the ABC Policy. Relevant Persons may accept, though not to solicit, of Chinese New Year Red Packets or “lai see” given as a token of local custom during festive season of up to HK$/RMB100 (or equivalent in other local currency). Procedures 1. All Advantages (except advertising or promotional gifts of a nominal value) to Relevant Persons should be declared by the Relevant Person and acknowledged or approved by his or her immediate Supervisor, the relevant Head of Department and HR&A. 2. In the declaration, the Relevant Person should indicate the date of receipt, name of the person offering the Advantage and how the Advantage was handled, e.g. accepted by the Relevant Person, shared with team members or donated as lucky draw items in spring/annual dinners. 3. Head of HR&A will issue a circular to all staff prior to Chinese New Year, Mid- Autumn Festival, Christmas and New Year reminding them to declare gifts received from clients or business associates irrespective of the value. Declaration should be made by completing the “Gifts Declaration Form” on Swire Properties' Intranet portal SPLinks and routing back to the Head of HR&A.