6. Anonymous reports 6.1. Whistleblowers are strongly encouraged to provide their names and contact details, so that clarification of the reports made or further appropriate information can be obtained directly from them, where required. However, it is recognised that in some cases Whistleblowers may not feel comfortable identifying themselves. In these cases, anonymous reports may be submitted, although in such instances our ability to investigate the allegations and/or follow up with the Whistleblower may be seriously restricted. 7. Investigations 7.1. All reports will be referred to GIAD and/or HR&A. 7.2. Depending on the nature of the report received, GIAD and/or HR&A will carry out a preliminary review to understand the circumstances surrounding the allegation based on any information provided by the Whistleblower. All preliminary assessment will be reported to the Head of GIAD and/or Director, Human Resources (as the case may be) prior to the commencement of any investigative work. Head of GIAD will report all claims reviewed by GIAD to the Swire Properties Audit Committee. Director, Human Resources will report all claims reviewed by HR&A to the Executive Committee. 7.3. Subsequent to the preliminary review, the Head of GIAD or Director, Human Resources (as the case may be) will discuss the case (together with the proposed detailed investigative work to be conducted or other proposed action (e.g. report to law enforcement authorities where necessary)) with senior management of the relevant Swire Properties Group Company, including the Finance Director. The Finance Director will also ensure that the Executive Committee is informed of the matter. 7.4. If the Head of GIAD or Director, Human Resources determines that detailed investigation for the case should be carried out, GIAD or HR&A (as the case may be) will carry out a detailed review which may include, but is not limited to, inspection of relevant documents and interviewing of relevant parties. 7.5. Relevant advice from in-house or external legal counsel and/or HR&A will be obtained where appropriate. 7.6. The result of GIAD’s investigation, together with corrective action plans, will be documented and provided to the Audit Committee and where appropriate, senior management. Where the matter is investigated by HR&A, the result of the investigation, together with corrective action plans, will be documented and provided to the Executive Committee and where appropriate, senior management. For complaints investigated by HR&A, any matters of significance will also be reported to the Audit Committee. 7.7. The result of any investigation may be communicated to the Whistleblower, where it is deemed appropriate by Swire Properties. - 4 -