Human Rights Policy

We recognise that respecting human rights and dignity is essential to safeguarding the wellbeing of our employees, those in our supply chains and the communities in which we operate. We conduct our business in a manner that seeks to respect and promote internationally recognised human rights across all our activities.

This Policy applies to Swire Properties Limited and its subsidiaries in a way that is relevant to their respective businesses. Associated and joint venture companies and those with whom we do business are encouraged to comply with it. Implementation of this Policy is the responsibility of the Management team of each group of operating companies.

In this Policy, we aim to:

• comply with applicable human rights laws and regulations in the jurisdictions where we operate;

• respect internationally recognised human rights standards, including those outlined under the Ten Principles of The United Nations Global Compact and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, unless otherwise conflicted with applicable local laws and regulations;

• foster inclusive, respectful and supportive working environment, free from discrimination, harassment, violence or intimidation;

• base employment decisions on merit and eliminate bias in all its forms;

• prohibit child labour, forced labour and human trafficking in our operations;

• ensure that all employment is voluntary and conducted under safe, healthy and dignified conditions;

• continuously improve our health and safety management systems with the aim of achieving zero harm;

• respect the rights of employees to freedom of association and collective bargaining in accordance with local laws and regulations; and

• encourage our suppliers, contractors and other business partners to adhere to the principles set out in this Policy. Our Supplier Code of Conduct sets out the minimum standards we expect of all our suppliers. For details, please refer to our Supplier Code of Conduct.

• comply with relevant principles described in Appendix 1.

PUBLIC DISCLOSURE

Appropriate disclosure on matters relating to this Policy will be included in our sustainability reports.

REPORTING

Concerns about suspected or actual improprieties relating to this Policy may be raised in accordance with our Whistleblowing Policy. Confidential reports can be submitted to the following channels:

• GIAD: group.audit@jsshk.com

• EthicsPoint: http://whistleblowing.swireproperties.com/

REVIEW

We will review this Policy as appropriate and, in any event, once every three years.

Approved by the Board on 10 March 2026.

Appendix 1

1. Diversity and inclusion

We aim to create an inclusive and supportive working environment for all our people regardless of their age, gender, gender identity, sexual orientation, relationships, family status, disability, race, ethnicity, nationality or religious or political beliefs. We do not tolerate discrimination or harassment based on the foregoing matters. We believe in creating an environment where people feel comfortable at work and able to realise their full potential. Assessments are conducted from time to time to ensure that our premises are accessible to people with disabilities. In addition, these assessments make certain we are complying with all applicable laws and regulations.

We base employment decisions on merit, considering qualifications, skills and achievement, and work to eliminate discriminatory bias in all its forms. We have established targets to maintain pay ratio balance and gender balance in senior management.

Swire Properties has a Diversity & Inclusion Committee and Diversity and Inclusion Policy to guide and deliver our strategies.

2. Suppliers and contractors

We seek to include in our agreements with suppliers and other contractors provisions which encourage them to adhere to the principles in this policy. Our supplier code of conduct can be viewed here.

We expect third parties who deal on our behalf to adhere to the principles in this policy.

3. Labour practices

We prohibit the use of child labour in our businesses and supply chains. All our employees are above the legal age of employment in the countries in which they are employed. Interns and those gaining work experience who are under the legal age of employment are only engaged where it is legal and safe to do so.

We do not employ forced labour, including prison, indentured, bonded, military or slave labour. Nor do we engage in human trafficking. We do not tolerate physical punishment, threats of violence or other forms of physical, sexual, psychological or verbal abuse as a means of enforcing discipline or control in the workplace.

4. Health and safety

Protecting the health and safety of our workforce is fundamental to our businesses achieving long-term success. We aim to conduct our operations in a manner that safeguards the health and safety of our employees, contractors, suppliers, customers, and visitors to our business premises and the communities in which we operate.

We aim to improve our health and safety management systems continuously with a view to achieving zero harm. Our health and safety policy can be viewed here.

5. Employment

We place significant emphasis on our people. Our success depends critically on our employees. We aim to recruit the best people, to offer competitive remuneration and benefits and to provide training to enable staff to realise their potential.

We do not tolerate discrimination, harassment, violence, intimidation, threats or other breaches of applicable employment law.

We comply with applicable laws relating to working hours. We permit flexible working in appropriate circumstances.

We respect our employees’ right to join, form or not join labour unions in accordance with local law without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognised union, we negotiate with the union in good faith and expect the union to do the same with us. We comply with applicable laws and regulations relating to freedom of association and collective bargaining (ILO Convention No. 154).

6. Stakeholder Engagement

We place significant emphasis on our community. We aim to promote equitable outcomes, reinforcing our commitment to creating sustainable and inclusive places through our placemaking and placekeeping efforts.

We are dedicated to actively engaging with local and affected communities and indigenous peoples, where applicable, in our assessments of, and responses to, sustainability-related (including climate and nature) risks and opportunities, ensuring that their knowledge, rights, and perspectives are protected, empowered and considered in our decision-making processes.

Sustainability Reports

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