Code of Business Conduct and Ethics

Conflict of Interest

The Conflict of Interest Policy requires directors, officers, and employees to make a conscious effort to avoid conflict of interest situations; so that his judgment and discretion is not influenced by considerations of personal gain or benefit.

Related Party Transactions

Related party transactions shall be conducted on an arm’s length basis, in such terms that are at least comparable to normal commercial practices to safeguard the best interest of the Corporation, its stockholders, creditors, policyholders and claimants.

Overlapping interests by directors, officers, or employees in the company and other parties shall be sufficiently disclosed to the Board of Directors and any material transaction involving such interests shall be similarly disclosed.

Any related party transactions that the Company will undertake shall be disclosed fully to the Board of Directors and the Related Party Transaction Committee for appropriate action.

Any member of the Board of Directors who has an interest in the transaction under discussion shall not participate in the deliberations and voting on the approval of the Related Party Transaction either at level of the Board of Directors or the Related Party Transaction Committee.

Conduct of Business and Fair Dealings

Officers and employees who 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.

In the event such officer or employee has a conflict of interest in a particular transaction, it must be sufficiently disclosed to the Board of Directors and the Related Party Transaction Committee for appropriate action.

Receipt of gifts from third parties

The Company allows the acceptance of gifts only during the Christmas Season. There is no restriction in the value of the gift accepted. However, accepted gifts with estimated value of over Php2,000 must be disclosed to the Corporate Governance Committee.

Respect for Trade Secrets/Use of Non-public Information

Officers and employees who have access to classified or confidential information including but not limited to corporate plans, objectives, personnel, resources, organizational structures, customer data, and other similar records and data, are restricted from sharing such information without prior approval of the President of the Company or his/her authorized representative.

Any public statements to be made on behalf of the Company also require prior approval of the President of the Company or his/her authorized representative. Furthermore, disclosures to the public can only be done after disclosure to the SEC and PSE by the Company’s authorized officers.

Any officer or employee who leaves the Company is prohibited
from procuring any form of classified or confidential data for personal or commercial gain.

Use of Company Funds, Assets and Information

Employees are required to safeguard Company resources and assets with honesty and integrity.

Officers and employees are responsible for the proper use of all Company property. These include, but are not limited to, information, facilities, equipment, software, vehicles and supplies owned or leased by the Company.

Plans, manuals, strategies, systems, developments, and other relevant documents prepared by officers and employees of the Company in the course of their work become the intellectual property of the Company.

Employment and Labor Laws and Policies

The Company 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 Corporate Governance
Committee.

Insider Trading Policy

The Company strictly prohibits insider trading and abusive dealing in securities of the Company.

Reports related to any change in personal shareholdings in the Company of its Directors and key officers resulting from open market transactions or from shares acquired from incentive-based schemes implemented by the Company are sent in a timely manner to the SEC, PSE and PDEx.

Compliance to the policy on insider trading is strictly enforced and monitored by the Company. This includes buying and selling of Company securities during prescribed periods by covered persons who are identified as members of the Board of Directors, all officers and employees, consultants, and advisers who have been made aware of undisclosed material information with respect to the Company and its operations.

Pursuant to the PSE Black-out rule, the Company shall also strictly adhere to a Trading Black-out Policy which covers trading before the date of disclosure of any material and non-public information and two (2) trading days thereafter.

Policy and Data Relating to Health, Safety and Welfare of Employees, Including company sponsored trainings

All employee benefits as required by law are provided to all
employees.

The company’s policy for its employee’s safety, health and welfare are made known to all employees by clearly outlining it in their employment contracts.

New employees are given orientation on the Corporation’s policies and procedures and officers and employees are sent to specialized training course as may be necessary.