Information extracted from the section "Corporate Governance" of 2019 Annual Report:

Directors' Securities Transactions

The Company has established and implemented the “Code for Securities Transactions by Directors” (the “Company’s Code”) to govern the Directors’ dealings in securities transactions of the Company. Terms of the Company’s Code are more stringent than the mandatory standards set out in the “Model Code for Securities Transactions by Directors of Listed Issuers” as contained in Appendix 10 of the Listing Rules. Apart from the Directors’ dealings in the securities of the Company, the Company’s Code has also been applied to the Directors’ dealings in the securities of BOC and BOC Aviation Limited (BOC’s subsidiary) since their share listing on the Stock Exchange of Hong Kong in June 2006 and June 2016 respectively as well as BOC International (China) Co, Ltd (BOC’s associate) since its share listing on the Shanghai Stock Exchange in February 2020.

Upon specific enquiry by the Company, all Directors confirmed that they had strictly complied with the provisions as set out in both the Company’s Code and the said Model Code throughout the year 2019.