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MENU PLACES PEOPLE PARTNERS PERFORMANCE PEPERFORFORRMMAANNCCEE (ENVIRONMENT) ((EECCONOONOMMIICC)) Performance (Economic) 2022 Progress Corporate Governance Risk Management and Internal Controls Green Financing Investor Relations Anti-Bribery and Corruption Policy and Practices GRI Swire Properties believes that conducting business with integrity is critical to its success as a sustainable 205 and responsible business group. We are committed to ensuring compliance with anti-bribery and HKEX corruption laws and regulations in our corporate governance. Aspect B7 KPI B7.1, B7.2, B7.3 We have procedures in place to monitor and report on related issues, preventing and actively managing possible violations against the law and related governing policies such as our Code. In 2022, we introduced the Anti-Bribery and Corruption Policy. It sets out the standard of behaviour expected from Swire Properties and the compliance procedures to be adopted. The policy applies to Swire Properties’ operations (including its subsidiaries), associated persons working for or on behalf of Swire Properties, as well as any actions taken on Swire Properties’ behalf. Our employees or associated persons are not permitted to offer or accept advantages for the purpose of influencing business decisions, which can include cash, loans, gifts, entertainment, hospitality, or travel. To prevent misconduct, all gifts (including in the form of cash), entertainment, hospitality and travel must be recorded fairly and accurately in a register maintained by the relevant business or functional unit. Any request for facilitation payment or kickbacks must be reported to the Director, Human Resources as soon as possible. No personnel or associated persons shall make or accept, directly or indirectly, facilitation payments or kickbacks of any kind. To avoid the perception of improper conduct, our employees are expected to exercise caution when making or soliciting contributions to charitable causes and when providing entertainment and corporate hospitality or reimbursing bona fide expenses for legitimate business purposes. In 2022, there were no concluded legal cases regarding corrupt practices brought against the Company or its employees. All charitable donations by Swire Properties should be authorised by the Chief Executive. While making sponsorships, our employees or associated persons must record fairly and accurately all sponsorship items in a register maintained by the relevant business or functional unit. The policy prohibits Swire Properties, including our employees or associated persons to make any direct political contributions (in cash or in kind) on behalf of Swire Properties. All our employees are required to confirm on an annual basis that they have read and have agreed to be bound by the Code, which includes our anti-bribery practices. It is compulsory for our employees in Hong Kong and the Chinese Mainland (including those who have been seconded to other offices) to receive anti-bribery refresher training on an annual basis at minimum. In 2022, approximately 8,690 hours of anti-bribery-related training was provided to employees across the Company. We provide channels for our employees and stakeholders to report on instances of actual or suspected bribery, corruption or non-compliance. In 2022, there were no convicted cases of anti-bribery and corruption. SUSTAINABLE DEVELOPMENT REPORT 2022 247

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