2.2.4. misleading or deceptive conduct (including misrepresentation), which leads to improper, misleading or breach of accounting, financial reporting and/or internal controls requirements or practices; 2.2.5. violations of any Swire Properties Group policies, including without limitation, the Corporate Code of Conduct; 2.2.6. action or inaction which could potentially endanger the health or safety of another person or any property, or cause serious harm to the environment; 2.2.7. harmful, discriminatory or retaliatory action taken against a Whistleblower for having made a report under this Policy; and 2.2.8. intentional concealment for omission of information relating to any of the above. 2.3. Improprieties including harassment, discrimination and workplace bullying can be reported under Swire Properties’ Respect in the Workplace Policy or under this Policy. 3. Protection and non-retaliation 3.1. Swire Properties is committed to the fair treatment of all persons making genuine and appropriate reports under this Policy, including the protection of Relevant Persons against unfair dismissal, victimisation or unwarranted disciplinary action. Reasonable steps will be taken by Swire Properties to protect the Whistleblower from reprisal or disadvantage as a result of making a report under this Policy. 3.2. It is a breach of this Policy for any Relevant Person to cause disadvantage to a Whistleblower who makes any report under this Policy in good faith. Swire Properties reserves the right to take appropriate action against any person who initiates or threatens to initiate retaliation against Whistleblowers who make reports under this Policy. Retaliation against or victimisation of a Whistleblower who acts in good faith will not be tolerated. Nor will a Whistleblower suffer any detriment as an employee (for example demotion or an unwanted transfer). Disciplinary action will be taken with respect to any instance of retaliation. 4. Confidentiality 4.1. Both the identity of the Whistleblower and any persons named in any report should be protected to the extent practicable from any disclosure that may prove harmful to the interests or reputation of the parties. 4.2. All information received will be treated with confidence, except where Swire Properties is required by law or regulation to disclose it (including stock exchange rules or for audit purposes) or where Swire Properties refers the matter to relevant regulators or law enforcement authorities. 4.3. Swire Properties will make every effort to keep the identity of the Whistleblower confidential. However, there may be circumstances where, due to the nature of the investigation, it will be necessary to disclose the Whistleblower’s identity. - 2 -