• Conflict of Interest

It is the policy of the Company that employees should make a conscious effort to avoid conflict of interest in situations that his judgment and discretion is not in influenced by considerations or personal gain or benefit.

Directors must never allow themselves to be placed in a position where their personal interests are in conflict (or could be in conflict) with the interests or business of the Company. They must avoid any situation or activity that compromises, or may compromise, their judgment or ability to act in the best interest of the Company.

a. It is the duty of a Director to report to the Board any conflict of interest or presumption thereof involving a Director which could materially impair the latter’s judgment, exercise of duties and responsibilities and loyalty to the Company.

c.  The Director, who is in conflict of interest, should not be counted in determining the existence of a quorum at the Board of Directors’ meeting at which the matter is voted upon.

d.  If the conflict of interest is significant, ongoing and competing with the Company’s interest and if it impedes the ability of the Director to carry out his/her duties, the Company has the right to remove the Director from his/her position.

Any transaction with conflict of interest requires prior approval of the members of the Board.

• Conduct of Business and Fair Dealings

Employees of the company who are involved or in charge with the approval of procurement or sale of goods and services should make a conscious effort to avoid any conflict of interest in transactions in which they are involved.

• Receipt of Gifts from Third Parties

Employees are discouraged from accepting gifts. However tokens of appreciation or those that are small in value are allowed.

• Compliance with Laws & Regulations

The Company sees to it that all its transactions comply with relevant laws and regulation.

• 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.

• 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

Company’ funds, asset and information shall be used with honesty and shall not be diverted or applied to any other use not intended for its planned purpose.

• Employment & Labor Laws & Policies

The Human Resources Department ensures compliance with labor laws and policies.

• Disciplinary Action

Violation of any provisions of company policies or code of business conduct may result to a disciplinary action such suspension, dismissal and reimbursement for any loss. A legal action may also be instituted.

• Conflict Resolution

Directors must never allow themselves to be placed in a position where their personal interests are in conflict (or could be in conflict) with the interests or business of the Company. They must avoid any situation or activity that compromises, or may compromise, their judgment or ability to act in the best interest of the Company.

a. It is the duty of a Director to fully disclose to the Board any conflict of interest or presumption thereof involving him/her which could materially impair his/her judgment, exercise of duties and responsibilities and loyalty to the Company.

b. It is the duty of a Director to report to the Board any conflict of interest or presumption thereof involving a Director which could materially impair the latter’s judgment, exercise of duties and responsibilities and loyalty to the Company.

c. The Director, who is in conflict of interest, should not be counted in determining the existence of a quorum at the Board of Directors’ meeting at which the matter is voted upon.

d. If the conflict of interest is significant, ongoing and competing with the Company’s interest and if it impedes the ability of the Director to carry out his/her duties, the Company has the right to remove the Director from his/her position.

Any transaction with conflict of interest requires prior approval of the members of the Board.