Supplier Code of Conduct

1. Introduction

1.1 In line with our Sustainable Development Policy, we are committed to operating in an environmentally and socially responsible manner across all aspects of our business and in our supply chain. We must ensure that our need to purchase goods and services on competitive terms is not met at the expense of labour standards, health and safety or the environment.

1.2 We value suppliers who share the Company’s commitment to honesty and integrity, and integrate social, environmental, and sustainability policies into their business processes.

2. Scope of application

2.1 This Supplier Code of Conduct (“Code”) applies to suppliers of Swire Properties Limited and its subsidiaries in a way that is relevant to their respective businesses.

2.2 This Code outlines the minimum standards which the suppliers of Swire Properties Limited and its subsidiary should follow. Associated and joint venture companies and those with whom we do business are encouraged to comply with it. Suppliers are responsible for communicating the requirements of this Code to their employees and their own suppliers where necessary.

2.3 For details on our procurement guidelines, please refer to our Sustainable Procurement Policy.

3. Policy Statement / Principles

3.1 Legal and Regulatory Compliance

3.1.1 Suppliers shall comply with all applicable laws and regulations of the jurisdictions in which they operate.

3.2 Modern Day Slavery

3.2.1 Suppliers shall not engage in human trafficking or any other form of modern day slavery. 

3.3 Child Labour

3.3.1 The use of child labour is prohibited. Suppliers shall adhere to the minimum age provisions of International Labour Organisation (ILO), unless otherwise conflicted with applicable laws and regulations.

3.4 Forced Labour

3.4.1 Suppliers shall not employ any forms of forced labour. Physical punishment, threats of violence or other forms of physical, mental, sexual or verbal abuse shall be prohibited.

3.4.2 All work, including overtime work, should be voluntary and employees should be free to leave employment in accordance with applicable labour laws and regulations.

3.5 Health and Safety

3.5.1 Suppliers shall provide a safe working environment and identify and control hazards associated with their businesses. Suppliers shall operate in accordance with applicable health and safety laws and regulations.

3.5.2 Suppliers should have appropriate measures in place to monitor workplace health and safety performance, provide adequate health and safety training, and an effective reporting and communication protocol.

3.5.3 Suppliers should adopt and communicate health and safety policies and procedures that aim to reduce injury and illness and enhance employee health.

3.6 Compensation and Working Hours

3.6.1 Suppliers shall operate in accordance with applicable wages, work hours, overtime and benefits laws, and compensate employees with reference to applicable industry and local labour standards.

3.6.2 Suppliers should pay at least the local legal minimum wage and are encouraged to follow applicable voluntary codes relating to compensation.

3.6.3 Employees should not be required to work for more than the number of hours permitted by law and should be appropriately compensated for overtime work. All statutory (including maternity and paternity) and contractual leave entitlements should be honoured.

3.6.4 Employees should be provided with written and understandable information about their conditions of employment, in respect to wages, working hours and benefits before they enter employment.

3.6.5 Suppliers must pay their employees promptly, providing each with clear, written accounting for every pay period. Wages should be paid regularly, on time and not in more than one month in arrears. Deductions from wages as a disciplinary measure shall not be permitted.

3.7 Discrimination, Bullying and Harassment

3.7.1 Suppliers shall not tolerate any bullying or harassment (including sexual and racial harassment) of employees. The basis for recruitment, placement, training, compensation and advancement should be based on qualifications, skills, experience and performance.

3.7.2 Suppliers should not discriminate among their employees on the basis of age, gender, gender orientation, sexual orientation, relationship, family status, disability, race, ethnicity, nationality, religious or political beliefs.

3.8 Freedom of Association and Collective Bargaining

3.8.1 Suppliers shall respect their employees' right to form, join or not to join labour unions in accordance with applicable laws without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognised union, suppliers should establish a constructive dialogue and bargain with the union in good faith with such representatives.

3.10 Business Ethics

3.10.1 Suppliers should have appropriate measures in place to prevent bribery, corruption, fraud and anti-competitive behaviour. Such behaviour may include, without limitation, the offer and receipt of advantages, facilitation and other payments to government officials, charitable contributions, entertainment and corporate hospitality.

4. Enforcement, Compliance and Complaints

4.1 The Company will review this Policy from time to time as appropriate, and in any event, once every three years.

Approved by the Board on 10 March 2026.