Policies and Management

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The Company adopts the SMC Group-wide Whistle Blowing Policy in the pursuit of ensuring that its business is conducted in the highest standards of fairness, transparency, accountability and ethics, Ginebra San Miguel Inc. (“GSMI”) has adopted procedures for directors, officers, employees and other interested parties to communicate concerns regarding GSMI’s and its subsidiaries’ (collectively, the “GSMI Group”) accounting, internal accounting controls, or auditing matters to the GSMI Audit Committee, and other matters to the appropriate investigating officers or body in accordance with the conventional reporting channels implemented by the GSMI Group.

Employees may communicate concerns regarding questionable accounting or auditing matters to the Compliance Officer on an anonymous basis.

The GSMI Audit Committee will determine whether any action or response is necessary or appropriate in respect of a communication, and it will take or direct such action as it deems appropriate.

All communications received will be placed on confidential files and will be retained for seven years or for such longer time as may be deemed necessary by the GSMI Audit Committee. These files will be under the direct control of the GSMI Audit Committee.

Misdirected communications as determined by the Audit Committee or concerns not relating to accounting, internal accounting control, auditing or financial reporting matters shall be addressed to and be acted upon by the appropriate responsible supervisor or officer of the business units affected in accordance with the GSMI’s Group’s conventional reporting channels.

The GSMI Group shall not tolerate retaliation in any form against a director, officer or employee who, in good faith, raises a concern or reports a possible legal or ethical violation under this policy. This policy, however, shall not be used for addressing or taking up personal grievances.

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The Company’s policy on Conflict of Interest embodies the principle that officers and employees have a duty to act in the best interest of the Company. As such, in the event that any personal interest of an officer or employee may conflict with the interest of the Company, proper disclosure through the accomplishment of the Full Business Interest Disclosure Form should be made, and a review by higher Management shall resolve the conflict.

This policy specifically requires offices and employees to:

Conduct business affairs with fairness;
Avoid granting undue personal favors;
Engage only in private activities or business consistent with responsibilities as officers and employees and not detrimental to the interest of the Company;
Refuse gifts that might connote bribery in any way;
Utilize Company property, funds, equipment and time solely for Company purposes, and recognize that all intellectual property and rights so created are owned by the Company; and
Seek prior Management clearance before engaging in outside work.

The Company adopts the SMC Group-wide Whistle Blowing Policy in the pursuit of ensuring that its business is conducted in the highest standards of fairness, transparency, accountability and ethics, Ginebra San Miguel Inc. (“GSMI”) has adopted procedures for directors, officers, employees and other interested parties to communicate concerns regarding GSMI’s and its subsidiaries’ (collectively, the “GSMI Group”) accounting, internal accounting controls, or auditing matters to the GSMI Audit Committee, and other matters to the appropriate investigating officers or body in accordance with the conventional reporting channels implemented by the GSMI Group.

Employees may communicate concerns regarding questionable accounting or auditing matters to the Compliance Officer on an anonymous basis.

The GSMI Audit Committee will determine whether any action or response is necessary or appropriate in respect of a communication, and it will take or direct such action as it deems appropriate.

All communications received will be placed on confidential files and will be retained for seven years or for such longer time as may be deemed necessary by the GSMI Audit Committee. These files will be under the direct control of the GSMI Audit Committee.

Misdirected communications as determined by the Audit Committee or concerns not relating to accounting, internal accounting control, auditing or financial reporting matters shall be addressed to and be acted upon by the appropriate responsible supervisor or officer of the business units affected in accordance with the GSMI’s Group’s conventional reporting channels.

The GSMI Group shall not tolerate retaliation in any form against a director, officer or employee who, in good faith, raises a concern or reports a possible legal or ethical violation under this policy. This policy, however, shall not be used for addressing or taking up personal grievances.

DOWNLOAD CONFLICT OF INTEREST POLICY

This policy mandates the directors, officers and employees of the Company and its subsidiaries (“GSMI Group”) to exercise extreme caution when dealing in the Company’s securities and ensure that such dealings comply with this policy, as well as the requirements of the Securities Regulation Code. It sets out the conditions and rules under which the directors, officers and employees of the GSMI Group shall deal in securities of the Company.

Under this policy, directors, officers and certain employees are considered to have access to “insider information” i.e. knowledge or possession of material non-public information about the Company by virtue of their functions and responsibilities. Therefore, such directors, officers and key employees with access to inside information are prohibited from trading in the Company’s shares at any time when they have knowledge or possession of material non-public information about the Company, and during a specified time frame, or a “blackout period”. The same prohibition applies even if the material non-public information refers to another company, so long as the same was obtained in the course of performing the duties as directors, officers or employee of the GSMI Group.

The Company recognizes the importance of its people as shown in its corporate value of “Respect for our People”. This value is summed up in the statement “We are committed to maintain a work environment that encourages trust, openness and mutual respect, regardless of rank or title. We promote a healthy work and life balance and provide opportunities for professional and personal growth. Our people are our strength.”

The Company ensures compliance with general labor standards, inclusive of occupational health and safety standards in the workplace. To ensure the employees’ good health, Annual Physical Examinations of employees are conducted, as well as other health-related activities throughout the year.

It is also the Company’s policy to promote career advancement and development through the numerous training programs and seminars implemented by and/or facilitated by the Company’s Human Resources Department. In this connection, the Company launched an Employee Education Program (EDPRO) which supports employee efforts on continuous learning and self-improvement. Subject to certain conditions, the Company through the EDPRO may subsidize the educational expenses of qualified employees who are pursuing undergraduate, post-graduate or technical-vocational courses.

The Company declares all forms of sexual harassment in the workplace as unlawful through its Policy on Anti-Sexual Harassment. The Company values the dignity of every individual, enhances the development of its human resources, guarantees full respect for human rights and upholds the dignity of its employees and applicants for employment. Thus, it is committed to create a work environment that is characterized by professionalism, fairness, openness, trust and respect.

The Company promotes a workplace that is free from drug abuse as it is detrimental to the safety, health and work performance of its employees through its Policy and Guidelines on Drug Abuse. Consistent with this policy, the Company shall provide opportunities to rehabilitate employees who are engaged in drug abuse and discipline employees who persistently refuse to give up drug abuse.