7.8. If, having considered the facts available, Swire Properties is of the opinion that a criminal offence may have been committed, we will seek legal advice to determine if it is necessary to, and if so, we will, refer the matter to the appropriate authorities for their further action. 7.9. Relevant Persons who are found to have perpetrated or participated in an impropriety will be subject to disciplinary action, which may include termination of employment. In the case of any suspected corruption or other criminal offences, a report will be made to the appropriate authorities in the relevant countries, as we may consider appropriate. 7.10. All allegations are recorded in a Claims Register maintained by GIAD. The register contains the following information:- 7.10.1. source of the allegation; 7.10.2. brief description of the allegation; 7.10.3. dates when the allegation was received, reviewed and closed; and 7.10.4. investigation result. 8. False reports 8.1. All reports must be made in good faith. If a Whistleblower makes a false report maliciously or for personal gain, Swire Properties reserves the right to take appropriate action against that person, including reporting the matter to law enforcement authorities and to recover any loss or damage suffered as a result of the false report. In particular, Relevant Persons will face disciplinary action, including termination of employment where appropriate. 9. Retention 9.1. All records of reports or complaints made, including results of any investigation, shall be retained for a period of not more than seven years following completion of the investigation (if any) or closure of the matter. 10. Policy governance and review 10.1. This Policy has been approved by the Board of Directors of Swire Properties. The Executive Committee has overall responsibility for the implementation of this Policy, and has delegated the day-to-day responsibility for the administration of this Policy to GIAD. 10.2. The Swire Properties Audit Committee is responsible for reviewing this Policy, recommending changes, and addressing issues of concern. 10.3. Changes to this Policy may be made from time to time. This Policy is posted on the website of Swire Properties. The version stored on the website shall be retained as the most current and authoritative version of this Policy. - 5 -