Whistleblowing

Whistleblowing Policy 1. Purpose 1.1. Swire Properties Limited (“Swire Properties”) is committed to maintaining high standards of business ethics and corporate governance. We believe in dealing appropriately with our employees, those with whom we do business and the communities in which we operate. 1.2. We therefore require our employees and encourage third parties to report suspected or actual improprieties involving Swire Properties and its subsidiaries (the “Swire Properties Group”, and each a “Swire Properties Group Company”) and their respective directors, officers, employees and any of its suppliers, contractors, agents, and other third parties who are acting for or on behalf of a Swire Properties Group Company. 1.3. This whistleblowing policy (“Policy”) sets out Swire Properties’ policy on, and commitment to, whistleblowing and the protection of whistleblowers, and how reports of suspected or actual improprieties can be made and how they are reviewed and investigated. 1.4. This Policy applies to all employees (including secondees), officers and directors of the Swire Properties Group (together, the “Relevant Persons”) and to suppliers, contractors, agents and other third parties who deal with the Swire Properties Group (“Third Parties”). Associated and joint venture companies are encouraged to establish whistleblowing policies comparable to this Policy. 2. Whistleblowing and improprieties 2.1. “Whistleblowing” refers to a situation where a Relevant Person or a Third Party (each, a “Whistleblower”) who, in good faith, has reasonable cause to believe that anyone acting for or on behalf of a Swire Properties Group Company anywhere in the world has acted, or is now or may be intending to act illegally, improperly or in a manner which is contrary to applicable laws or regulations, including policies and practices the Swire Properties Group may issue from time to time, raises those concerns to the relevant Swire Properties Group Company. 2.2. Improprieties include misconduct, malpractice and unethical behaviour. It is not possible to give an exhaustive list. Examples of improprieties include but are not limited to the following:- 2.2.1. conduct or practices which are illegal or breach any applicable law, regulation or code of conduct; 2.2.2. fraudulent or corrupt conduct; 2.2.3. misappropriation of company property; - 1 -