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Code of Business Conduct and Ethics

Conflict of Interest The Company’s Code of Business Conduct and Conflicts of Interest Policy require employees to make a conscious effort to avoid conflict of interest situations; that his judgment and discretion is not influenced by considerations of personal gain or benefit.
Conduct of Business and Fair Dealings The Company’s employees that recommend, endorse, or approve the procurement or / sale of goods and services should make a conscious effort to avoid any conflict of interest situation in transactions that they are involved in.
Receipt of gifts from third parties The Company allows the acceptance of gift only during the Christmas Season. There is no restriction in the value of the gift accepted. However, accepted gift with estimated value over Php2,000 must be disclosed to the Conflicts of Interest Committee.
Respect for Trade Secrets/Use of Non-public Information The Company has policies that ensure proper and authorized disclosure of confidential information. Disclosures to the public can only be done after disclosure to the SEC and PSE by the Company’s authorized officers.
Use of Company Funds, Assets and Information Employees are required to safeguard Company resources and assets with honesty and integrity.
Employment & Labor Laws & Policies The Company’s Human Resources Unit ensures compliance with employment and labor laws and policies.
Disciplinary action Violation of any provision of the Code of Business Conduct may result to disciplinary action, including dismissal and reimbursement for any loss to the Company that results from the employee’s action. If appropriate, a violation may result in legal action against the employee or referral to the appropriate government authorities.
Whistle Blowing Any employee may discuss any concern on potential violation of the Code of Business Conduct with the Conflicts of Interest Committee.
Conflict Resolution The Conflicts of Interest Committee submits recommendations to the Chairman on courses of action to be taken on conflicts of interest situations.