Appendix B Offer of Advantages Control Guideline Under no circumstances may a Relevant Person offer an Advantage to any person, including government officials, or company having business dealings with Swire Properties for the purpose of influencing such person or company in any business dealings. Relevant Persons should exercise good judgment and practise moderation in giving gifts. Excessive gifts in terms of value or frequency should not be offered to potential or existing customers. Gifts bearing a Swire Properties logo are preferred. The provision of advertising or promotional gifts of a nominal value or gifts given on festive or special occasions (including Swire branded vouchers or coupons) is permitted subject to a maximum value as set out in the ABC Policy. Procedures 1. For Advantages offered to speakers or facilitators of training programmes or luncheon talks which are given on a complimentary basis, the Training & Development Team of HR&A will request corporate items from the Corporate Marketing team. The request must be submitted with the purpose of the request and the name of the receiver and his/her company clearly stated. 2. Subject to 3 below, for offer of Advantages, Relevant Persons should obtain the proper approval from the relevant Heads of Department. Gifts offered to tenants for use at tenants' official functions, including cash vouchers, should be at the discretion of Director, Retail or Director, Office. Gifts bearing the Company's logo and cash vouchers for use within Swire Properties portfolio are encouraged. 3. Prior approval of the Chief Executive should be obtained for any offer of Advantages with a value exceeding HK$2,000 or equivalent. 4. The Relevant Person should submit the claim with sufficient supporting details, including date, purpose, name of recipient, description and value of the Advantage, etc. 5. The Finance Department should produce a quarterly report on “Offer of Advantages” with value exceeding HK$500 or equivalent for review by the Chief Executive.