Code of Business Conduct and Ethics










Business Conduct and Ethics  Directors  Senior Management  Employees 
 (a) Conflict of Interest Directors, Senior management, officers and employees shall avoid any activity and interest that could significantly affect the objective or effective performance of duties and responsibilities in the company including existing business interests, activities outside of their employment with the Company, and all other situations that may give rise to potential conflict of interests.

(b) Conduct of Business and

        Fair Dealings

The Company should maintain a reputation for fairness and integrity in dealings with legitimate and reliable firms and promote sound relationships with such firms. Hence, Directors, Senior management, officers and employees involved in the purchasing function shall:

* maximize competition among reputable firms;
* conduct impartial selection of qualified sources of goods and services, and maintain high ethical standards;
* Deal fairly by not divulging information obtained from suppliers and contractors, in recognition of the competitive environment among them.

(c) Receipt of gifts from third parties

The policy of the Company is to avoid the receipt of gifts, in cash or in kind, commissions, share in profits, loans or advances, materials and services at reasonably low prices, excessive or extravagant entertainment, paid travel from
any firm doing or seeking to do business with the Company; except those which are customarily accepted in usual course of business and allowed by Management.

If Employee is uncertain about what constitutes nominal or reasonable gift or “lunch”, the employee should discuss the matter with his/her immediate superior.

(d) Compliance with Laws &
One of the Board’s functions is to ensure that the Company complies with all relevant laws, regulations and best business practices. The should have working knowledge of the statutory and regulatory requirements affecting the Company, including the contents of its Articles of Incorporation and By-Laws, the requirements of SEC, and where applicable, the requirements of other regulatory agencies. The policy of the Company is to comply with all governmental laws, environmental laws, rules and regulations applicable to the business.

 (e) Respect for Trade Secrets/Use of

Non-public Information

Directors, Senior Management/Officers and Employees shall maintain and safeguard the confidentiality of information entrusted by the Company, customers, business partners or other parties with whom the Company relates, except when disclosure is authorized or legally mandated.

Officers and employees are enjoined to avoid using, divulging or releasing to anyone, any data or information which could adversely affect the Company in any way right then and there, or in the future; or whether or not it is for personal gain or any gratification, material or otherwise (e.g. to do a favor to another).

The Company also enters into confidentiality agreements with third parties.

(f) Use of Company Funds, Assets

and Information

Use of company funds

The Company thru its Corporate Finance and Treasury Dept (CFTSD) shall ensure at all times that all its business activities are in conformity with the provisions of the Company’s Anti- Money Laundering Operating Manual.

Use of company assets

To be in step with the rest of the local business community as well as for survival in this global economy - the Company has invested heavily in communications and computer systems & facilities.

* These facilities are made available to specific officers and employees primarily for official business use i.e. to enhance their effectiveness and efficiency in the performance of their respective functions in this age of
* Our major and primary concern therefore is that these systems and facilities be used – first and foremost - to the greatest business advantage of the Company.

Use of information

The Company policy requires that all employees should protect the integrity of the company’s proprietary and confidential information as well as the proprietary and confidential information of others.

* Officers and employees must exercise a greater degree of caution in transmitting company trade secrets or other confidential information on the electronic media and related communications facilities because of the
reduced effort required to redistribute such information.
* Electronic transmission of confidential information should be avoided or minimized.

(g) Employment & Labor Laws &


The Company has a Personnel Policies and Procedure Manual, a compilation of all current practices concerning personnel matters, which are consistent with and in accordance with relevant provisions of the Labor Code.
(h) Disciplinary action Any officer or employee who commits a violation of the Code of Conduct, Organizational Discipline and Ethics (CCODE) shall be subject to disciplinary action. In the implementation of its disciplinary policy, the Company shall be fair, consistent and reasonable.