Code of Business Conduct and Ethics

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Rules and Regulations on Conduct

All employees must observe proper conduct and courtesy. Any employee who commits any offenses in the Rules of Conduct may be disciplined in accordance with the penalties stipulated in the Disciplinary Action Policy.

Employee Welfare and Health

The Management of OPMC is after the welfare of its employees. Therefore, all regular employees of OPMC are entitled to the following benefits:

Company HealthCard for medical/dental and confinement package.
Retirement Plan, upon retirement of an employee with at least ten (10) years of continuous service or depending upon his length of service with the Company he is entitled to a gratuity plan embodied in the Retirement Package.

Conflict of Interest Policy

OPMC Employees are bound to respect and obey the Rules and Regulations of the Company. Employees in all levels, shall not use their positions or power for personal benefit or convenience. Anyone found violating these rules will be subject to disciplinary action.

Disciplinary Action

An employee found violating the Company Rules and Regulations will be disciplined in accordance with the Code of Business Conduct.

Whistle Blowing Policy

The Company is committed to conduct business according to the highest ethical and legal standards.  In line with this commitment, we encourage employees and business partners to raise concerns about any aspect of the business partners to raise concerns about any aspect of the business operation.

The objectives of this policy are the following:

1. To encourage employees, business partners and other stakeholders to report concerns involving actual or suspected violations of Company policies, its code of conduct, criminal or unlawful acts or omissions, and instances when an act or omission endangers the health and safety of the employees.
2. To provide clear procedures for reporting any actual or suspected violation of Company policies, misconduct, malpractice, irregularities or risks against the Company.
3. To protect the Whistleblower against any form of retaliation.

The policy shall apply to all employees of the Company, employees of third party service providers, on the job trainees, business partners and other stakeholders of the Company, its subsidiaries and affiliates.

Whistleblowing refers to the act of filing a written complaint/report, by an employee, a business partner of the Company or other stakeholder who, in good faith, reasonably believes that an employee or business partner or stakeholder violated Company policies, or committed any unlawful act or omission or one that is similar to or in the nature of a corrupt practice, unethical behavior, malpractice, misconduct, irregularity or any risk affecting the Company or is aware of any irregularity or circumstances that may have an adverse effect on the Company.

The Whistleblowing Policy (WBP) shall include, but is not limited to complaints, reports or disclosure of information for acts involving actual or suspected violations of Company code of conduct (i.e. Offenses Subject to Disciplinary Actions – OSDA), Company policies, criminal or unlawful acts or omissions, and instances when an act or omission endangers the health and safety of the employees.

This policy shall apply to serious concerns already brought to the attention of the immediate superior, but not acted upon in accordance with the Company’s standard reporting procedures.

Any employee, business partner and other stakeholders may discuss or disclose in writing any concern on potential violation of the Code of Business Conduct with the Conflicts of Interest Committee (CICOM).

1. Reports can be made in writing or by email using the following contact details:
   • Email: CICOM@jgsummit.com.ph
   • Fax: +632 395 3888
   • Mailing Address:
     CICOM
     JG Summit Holdings, Inc.
     44/F Robinsons Equitable Tower
     ADB Avenue cor P Poveda St.,
     Ortigas Center, Pasig City
     Metro Manila, Philippines
2. Reports must be sent in a sealed envelope clearly marked Strictly Private and Confidential: To Be Opened by Addressee Only
3. Reports shall be filed using the Complaint Disclosure Form (CDF).
4. All information received in connection with the reports or disclosures shall be strictly confidential and shall not be disclosed to any person without prior consent of CICOM.

Download Policy: Whistleblowing Policy
Complaint Disclosure Form
Appendix 1 Responsibilities
Appendix 2 Reporting Channels Contact Details