Code of Conduct - Hrd Copy

CHARTER PING AN INSURANCE CORPORATION

CODE OF CONDUCT

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Table of Contents

SECTION I. RATIONALE 4 SECTION II. COVERAGE 4 SECTION III. STANDARDS OF CONDUCT 4

ATTENDANCE AND PUNCTUALITY

PRESCRIBED WORK ATTIRE/IDENTIFICATION CARD

SECURITY AND SAFETY

CORPORATE PROPERTY AND INTERESTS

HONESTY AND INTEGRITY

RESPECT FOR SUPERIORS

PROPER WORK CONDUCT AND BEHAVIOR

RESPECT FOR CLIENTS/GUESTS/SUPPLIERS

SECTION IV. JURISDICTION 6 SECTION V. CLASSIFICATION OF OFFENSES 6

MINOR OFFENSES

LESS SERIOUS OFFENSES

SERIOUS OFFENSES

SECTION VI. KINDS OF PENALTIES 8 WRITTEN REPRIMAND

RESTITUTION SUSPENSION

DISMISSAL

SECTION VII. WITHHOLDING OF BENEFITS 9 SECTION VIII. CIRCUMSTANCES AFFECTING ADMINISTRATIVE LIABILITY 9 MITIGATING CIRCUMSTANCES

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AGGRAVATING CIRCUMSTANCES

SECTION IX. ADMINISTRATIVE PROCEDURES 10 PREVENTIVE SUSPENSION

TEMPORARY TRANSFER AND/OR RE-ASSIGNMENT OF WORK AND POSITION

REFERRAL TO LEGAL DEPARTMENT FOR FILING OF APPROPRIATE ACTION

SECTION X. ADMINISTRATIVE INVESTIGATION & PRESCRIPTION OF PENALTY 13 SECTION XI. SCHEDULE OF OFFENSES AND PENALTIES 13 ATTENDANCE AND PUNCTUALITY

PRESCRIBED WORK ATTIRE/IDENTIFICATION CARD

SECURITY AND SAFETY

CORPORATE PROPERTY AND INTERESTS

HONESTY AND INTEGRITY

RESPECT FOR SUPERIORS

PROPER WORK CONDUCT AND BEHAVIOR

RESPECT FOR CLIENTS/GUESTS/SUPPLIERS

SECTION XII. REPEALING CAUSE 21 SECTION XIII. EFFECTIVITY 21 TABLE OF APPENDICES 22 INVESTIGATION REPORT A NOTICE TO EXPLAIN B NOTICE OF HEARING C STERN WARNING D WRITTEN REPRIMAND E PREVENTIVE SUSPENSION F NOTICE OF DISMISSAL/SUSPENSION G

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CODE OF CONDUCT SECTION I. RATIONALE Charter Ping An Insurance Corp. (“CPAIC”), being a part of the Metrobank Group of Companies, is committed to the interests and welfare of its customers, business partners and shareholders and ensures responsiveness to their specific needs by providing appropriate and competitive products and delivering timely, reliable and superior services. It recognizes that this can be attained through the unwavering support of a competent, highly professionalized, well-trained and disciplined workforce. Like its parent company, CPAIC recognizes the significance of discipline among its employees to ensure efficiency and effectiveness in its business operations. The desired level of productivity can only be attained by an empowered but disciplined workforce. This Code of Conduct (“Code”) embodies the prescribed moral code for CPAIC employees. While it defines the offenses and the corresponding disciplinary sanctions that may be imposed, its overall intent is to prevent any breach thereof rather than the imposition of the disciplinary measures. Furthermore, while it states the specific disciplinary measure for a specific offense, it does not preclude Management from imposing a lesser or heavier penalty depending on the gravity of the offense committed. It is also without prejudice to existing Company policies on specific matters not covered herein and which provide for penalties in case of non-compliance therewith. In case of conflict between the provisions of this Code and existing Company policies on specific matters or procedures, the latter shall prevail. SECTION II. COVERAGE This Code applies to all CPAIC employees regardless of rank or employment status. The term “employees” refers to officers, rank and file employees including probationary and contractual employees. SECTION III. STANDARDS OF CONDUCT This Code sets forth the standards of conduct expected of all employees and enumerates the acts or omissions regarded as violative of the prescribed norms of behavior of CPAIC or prejudicial to its interest.

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A. ATTENDANCE AND PUNCTUALITY All employees are expected to report for work on time and be regular in their attendance. They should perform their job responsibilities during working hours. Tardiness, absenteeism and loafing during work hours are frowned upon. B. PRESCRIBED WORK ATTIRE/IDENTIFICATION CARD When reporting for work, all employees must be in the prescribed office attire/uniform. Identification cards must be worn at all times while inside the office premises and are considered part of the prescribed office attire/uniform. C. SECURITY AND SAFETY All employees shall maintain their work areas clean, secure and safe to ensure office security as well as their health and safety and that of their co-employees as well. D. CORPORATE PROPERTY AND INTERESTS All employees shall exercise the highest degree of care in handling and using Corporate property and assets and shall protect it from loss or damage. Corporate property and assets shall be used only for official purposes. Its use for any private or personal purpose is prohibited. All employees are likewise expected to safeguard the interests of the Company in all their dealings and in the performance of their duties. They shall not expose the Company to any risk, whether financial or reputational. E. HONESTY AND INTEGRITY The importance of honesty and integrity in an employee cannot be overemphasized. All employees are expected to be honest, truthful, upright and conscientious in the discharge of their functions, in the handling of company funds and properties, and in their dealings with their superiors, subordinates, fellow employees, customers and business partners. Any form of dishonesty or fraud is unacceptable and no employee shall commit any such act nor conceal the same, facilitate or aid in the commission thereof.

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F. RESPECT FOR SUPERIORS All employees shall observe courtesy and respect in dealing not only with their co-employees but with their superiors as well. They should exert cooperation and support for their specific work units and follow their superiors’ assigned tasks to them. G. PROPER WORK CONDUCT AND BEHAVIOR All employees are expected to observe proper decorum and conduct themselves in accordance with the values of CPAIC at all times within or outside of the work premises. They should realize that they are carrying the good name of CPAIC and its mother company, Metrobank, and hence, they are obligated to protect its reputation and image to ensure and maintain the confidence and trust of its clients and the public in general. All employees shall perform their jobs with efficiency, conscientiousness and dedication and with the highest degree of professionalism, diligence, excellence and skill. H. RESPECT FOR CLIENTS/GUESTS/SUPPLIERS Pursuant to CPAIC’s commitment to deliver excellent service to its customers and acknowledging that they are the lifeblood of our business, all employees are expected to treat them with utmost importance and courtesy. SECTION IV. JURISDICTION Except for offenses on tardiness, absenteeism, failure to time in or time out, failure to file proceed forms or application for leave which shall be monitored by the Human Resources Department, the Administrative Investigation Committee (“AIC”) shall exercise jurisdiction over all violations of the provisions of this Code. It is composed of the President acting as the Chairman with the Executive Vice President, Head of Marketing, Head of Underwriting, Head of Branch Operations, Special Assistant to the Group Controller and Head of Legal/HRD as members. The latter also acts as the Secretary.

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SECTION V. CLASSIFICATION OF OFFENSES A.MINOR OFFENSES Refer to –

An act by an employee which results in the violation of any Company policy, rule or regulation without causing financial loss to CPAIC, physical injury to any CPAIC employee or third party or damage to CPAIC property or reputation.

Those which constitute an omission or oversight. Those which arise from simple negligence, not malicious intent, without

resulting in serious disadvantage to CPAIC or any of its employees or clients.

B. LESS SERIOUS OFFENSES Refer to offenses which indicate a disregard of CPAIC’s interests including repeated violations within a relatively short period of time (a period of less than one year) of policies, rules and regulations and which otherwise would have been minor offenses, or the culpable commission or omission of an act which results in serious embarrassment or inconvenience to CPAIC or any of its employees or clients. C. SERIOUS OFFENSES Refer to acts or omissions, characterized by:

Wanton, deliberate and malicious intent Gross negligence Habitual disregard of established procedures Serious undermining of authority Breach of trust relative to confidential information or CPAIC funds or

property Public scandal and consequent erosion or loss of confidence Financial loss or administrative/operational difficulty or corporate

embarrassment to CPAIC or physical harm to its stockholders, public, officers or employees.

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SECTION VI. KINDS OF PENALTIES A. WRITTEN REMINDER/WARNING This is a minor admonition for a light offense or violation committed by an employee requiring him to exercise extra care and diligence in observing established Company policies and operating procedures or generally acceptable work behavior and moral standards so as to prevent repetition of an offense or violation. This shall be included in the erring employee’s 201 files but shall not be considered as part of his derogatory records for purposes of performance evaluation. B. WRITTEN REPRIMAND

This is a strong admonition for a less serious offense requiring and forewarning an employee to be more cautious in adhering to established Company policies and operating procedures or generally acceptable work behavior and moral standards with a warning that a repetition of the same or similar offense shall warrant a more stringent disciplinary action. This shall form part of the employee’s 201 files and shall be considered a derogatory record which shall have a consequent effect on the employee’s performance evaluation. C.RESTITUTION

If the employee’s act or omission arising from his fault or negligence results to any loss or damage to CPAIC, the employee shall, in addition to the prescribed penalty, be required to restitute or restore the loss to allow full recovery of the loss or damage by CPAIC. D.SUSPENSION This is a stricter written sanction for a more serious violation involving the physical detachment from service of the erring employee for a specific period of time without pay depending on the gravity of offense or violation. This serves as an ultimate warning to the employee that any further repetition of the same or similar serious offense committed shall warrant termination of his employment for cause. This shall form part of the employee’s 201 files and shall be considered a derogatory record which shall have a consequent effect on the employee’s performance evaluation.

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E.DISMISSAL

This is the termination of an employee’s services for cause and the maximum penalty for the commission of gross, willful or repetitive violation of established Company policies and operating procedures or generally acceptable work behavior and moral standards which include fraud, irregularities or dishonest acts committed by an employee. The erring employee shall automatically forfeit all benefits which would normally accrue to him on retirement or separation for reason/s other than for cause. SECTION VII. WITHHOLDING OF BENEFITS An employee cited in audit or under investigation or with pending administrative case may, subject to the approval of Management, be allowed to retire/resign from the service. The payment of any and all monetary benefits shall be held in abeyance until he shall have been cleared from all liability, both internally and externally (all Metrobank group subsidiaries). The total amounts of liability shall be deducted from whatever monetary benefits that may be due to the employee. SECTION VIII. CIRCUMSTANCES AFFECTING ADMINISTRATIVE LIABILITY A. MITIGATING CIRCUMSTANCES This refers to those circumstances by reason of which the penalty corresponding to the offense committed by an employee is made lighter or less severe than what is usually imposed for such offense. Among others, these include past performance, degree of participation, first time offenses or, in general, such circumstances which may support the imposition of lesser penalties than what are prescribed in the schedule of penalties. However, mitigating circumstances shall not be considered in offenses involving gross dishonesty or fraud. B. AGGRAVATING CIRCUMSTANCES This refers to those circumstances by reason of which the penalty corresponding to an offense committed by an employee is increased or made more severe than what is usually imposed for such offense. Among others, these include past record of offenses, habituality in the commission of offenses, the accompanying adverse publicity stirred by the offense which tends to erode CPAIC’s corporate image or, in general, such circumstances which may support the imposition of more severe penalties than what are usually prescribed in the schedule of penalties.

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SECTION IX. ADMINISTRATIVE PROCEDURES Administrative investigations and related proceedings shall be brief and expeditious. The technical rules of procedure or the rules on evidence shall not apply. An administrative investigation may be commenced by any of the following: 1. The Internal Audit Department in the course of its regular or special audit; 2. The Division or Department to which the employee belongs and which discovers the commission or omission of an act in the course of the employee’s discharge of his functions. Upon his discovery of such commission or omission, the Division or Department Head must immediately report the same to Management; 3. The Department of Internal Affairs (“DIA”) of Metrobank in cases where its assistance is sought by CPAIC to make initial investigations of offenses committed by employees. An initial investigation shall be conducted by any of the aforementioned group by gathering facts and evidence in the commission of the anomaly or irregularity. Regardless of the result of the investigation, i.e., whether there is a chargeable offense or not, a written report shall be submitted to AIC within ten (10) working days from the end of the initial investigation. Should the report support the finding of a violation of a minor offense which is committed for the first time, the AIC shall endorse/refer the matter to the erring employee’s Division/Department Head for the issuance of the appropriate disciplinary measure in accordance with this Code. The same shall be served on the said erring employee within three (3) days from receipt by the Division/Department Head of the endorsement from AIC, copy furnished the Human Resources Department for inclusion of the memo in the latter’s 201 files. If, on the other hand, the offense is either less serious or serious in nature, a Notice to Explain from the AIC shall be served on the respondent employee requiring him to submit his written explanation within a non-extendible period of five (5) working days. Said Notice shall state the specific charges or accusations. The written explanation must be signed by the respondent employee otherwise it shall not be admitted or considered. Other employees who have knowledge or participation on the matter sought to be investigated shall also be required to submit their written statements as well.

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Within five (5) working days from its receipt of the respondent employee’s written explanation and the written statements of the other employees, the AIC shall set the formal hearing/investigation on the matter. A Notice of Formal Hearing/Investigation will be served on the respondent employee. Other employees who shall act as witnesses shall likewise be invited. A respondent employee who fails to submit his written explanation or attend the formal hearing/investigation shall be deemed to have waived his right to be heard and the AIC shall decide the matter based on the evidence available on record. Immediately after the formal hearing/investigation, should the AIC find the evidence on hand sufficient to support a decision, then it shall decide accordingly based on the appropriate provision of the Code. If, on the other hand, it needs additional information before it can make a decision, it shall adjourn the hearing/investigation and shall continue on another date not later than five (5) working days from such adjournment. It may invite other witnesses or recall other witnesses for further questioning. A decision of the AIC shall contain the following: 1. Findings of facts; 2. Offense/s committed and/or company policy violated; 3. Determination and disposition of the monetary liability of the respondent

employee; 4. Rationale of the decision The decision of the AIC shall be immediately executory. The President, as Chairman of AIC, shall issue to the respondent employee a notice informing him of the result of the investigation and stating that upon due consideration of all the circumstances and careful deliberation, grounds have been established to justify his termination from service or suspension from work or absolving him from all charges or may state a stern warning or written reprimand. The notice shall be served on the respondent employee either by personal service or via courier or via registered mail with return card at his last known address. Administrative cases involving Senior Officers shall be investigated by the AIC whose recommended action shall be submitted to the Executive Committee for its consideration. Final decision on the disciplinary measure to be taken is with the Executive Committee. Disciplinary action shall be consistently and uniformly applied to all employees regardless of rank and position taking into account the circumstances of each case.

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Human Resources Department shall be given a copy of all notices, including but not limited to Notice to Explain, Notice of Investigation, Preventive Suspension Order or Notice of Decision, served upon the respondent employee for his 201 files. A. PREVENTIVE SUSPENSION The respondent employee may be placed under preventive suspension at any time, either prior to or during the formal hearing/investigation or in case of its adjournment as provided above, if, in the determination of AIC, his continued employment poses a serious and imminent threat to the life or property of his employer or his co-workers. The Preventive Suspension Order shall be issued by the AIC and shall last not more than thirty (30) days. A decision to reinstate the respondent employee after the lapse of the preventive suspension period shall be without prejudice to the prerogative of the AIC to assign him to an office other than his former station pending the resolution of the case. The thirty (30) day preventive suspension is neither a penalty nor a disciplinary action arising from the administrative case but only a protective measure granted to the Company by the Labor Code of the Philippines. B. TEMPORARY TRANSFER AND/OR RE-ASSIGNMENT OF WORK AND POSITION In cases where no preventive suspension was imposed and so as not to impair the conduct of the investigation, preserve the records/evidence and protect the interests of CPAIC, the AIC may order the transfer and/or re-assignment of the erring employee to any office other than his original work station pending the resolution of his case. Such transfer or re-assignment shall be without diminution of rank, salary and benefits of the respondent employee but shall be without prejudice to the imposition of a preventive suspension if evidence further warrants.

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C. REFERRAL TO LEGAL DEPARTMENT FOR FILING OF APPROPRIATE LEGAL ACTION It is understood that the decision of the AIC shall be without prejudice to the filing of the appropriate legal action against the erring employee if the circumstances so warrant. Hence, the AIC may, at any time, even prior to the conduct of the formal hearing/investigation, refer the case to the Legal Department for the evaluation of the case and if it is determined that a cause of action exists, the necessary legal action shall be undertaken. The Legal Department shall submit a written report on its recommendation to the AIC as to whether or not to proceed with the filing of the legal action as may be warranted by the facts of the case. SECTION X. ADMINISTRATIVE INVESTIGATION & PRESCRIPTION OF PENALTY Administrative investigation of any offense is not barred by lapse of time. However, no penalties shall be imposed on the erring employee, except restitution for any monetary loss that CPAIC may suffer due to the act or omission of the employee, if management fails to take action against the employee within the prescribed period, as follows: a. Minor offense – one year from discovery of the offense by Management b. Less serious offense – two years from discovery of the offense by

Management c. Serious offense – three years from discovery of the offense by Management SECTION XI. SCHEDULE OF OFFENSES AND PENALTIES As a matter of policy, an employee who has been served a written reprimand and/or suspended three (3) times as a disciplinary measure for various offenses as enumerated hereunder within a 12-month period, may be dismissed from the service on the 4th offense.

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A. ATTENDANCE AND PUNCTUALITY

1ST Offense

2nd Offense

3rd Offense

4th Offense

5th Offense

A.1 Tardiness of at least three (3) times in

a month or committing undertime three (3)

times and/or more than 60 minutes within a

month.

Written Reminder/ Warning

Written Reprimand

Three (3) days

Suspension

Seven (7) days

Suspension Dismissal

A.2 Failure to return to work after availing

of a break/exceeding break time allowed

(abandonment of post).


Written Reprimand

Three (3) days

Suspension

Seven (7) days


A.3 Habitual absenteeism due to trivial

reasons or unsupported medical/health

reasons

Written Reprimand

Three (3) days

Suspension

Seven (7) days


A.4 Absence without official leave (range of

1-4 days) or failure to give notice of an

absence within the first two (2) hours of

official work schedule through any means

possible.

Written Reprimand

Three (3) days

Suspension

Seven (7) days


A.5 Absence without official leave for five

(5) consecutive working days (considered

as abandonment of work) Dismissal

A.6 Claiming absence due to illness but

later found out to be malingering Written

Reprimand

Three (3) days

suspension

Seven (7) days

suspension Dismissal

A.7 Failure to file official leave (in case of

unexpected absence) within the first twenty

four (24) hours upon return to work


Written Reprimand

A.8 Failure to report for work after availing

of a leave without acceptable reason Three (3)

days suspension

Seven (7) days

suspension Dismissal

A.9 Change of work hours without his unit

head’s written authorization Written

Reprimand

Three (3) days

Suspension

A.10 Failure to time-in or time-out in the

prescribed timekeeping machine Written

Reminder/ Warning

Written Reprimand

One (1) day suspension

Three (3) days

suspension

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B. PRESCRIBED WORK ATTIRE/IDENTIFICATION CARD B.1 Failure or refusal to wear the

prescribed uniform/office attire Written

Reminder/ Warning

Written Reprimand

Three (3) days suspension

Seven (7) days

suspension

B.2 Failure to observe cleanliness and

corporate grooming Written

Reminder/ Warning

Written Reprimand


Seven (7) days

suspension

B.3 Failure to wear identification card Written Reminder/ Warning

Written Reprimand


Seven (7) days

suspension

C. SECURITY AND SAFETY

C.1 Unauthorized carrying of firearms and/

or explosives inside Company premises. Dismissal

C.2 Reporting for work under the influence

of prohibited drugs or substance or alcohol Three (3) days

Suspension

Seven (7) days


C.3 Drunkenness/drinking liquor or any

alcoholic beverages within company

premises during or beyond office hours

except on certain occasions or social events

when tolerated by Management

Three (3) days Suspension

Seven (7) days


C.4 Refusing to submit for inspection to

Company’s authorized personnel/failure to

abide by the security regulations of general

safety practices of the Company

Written Reprimand


C.5 Allowing and/or failing to report

unauthorized persons entering restricted

areas without permission

Written Reprimand

Seven (7) days


C.6 Willful disregard of office directives on

cleanliness like littering, spitting, urinating,

etc.


Written Reprimand


Seven (7) days


C.7 Committing disorder, violence or use of

force toward co-employee within the

Company premises. Dismissal

C.8 Failure to report within 24 hours any

incident or injury/damage occurring on Written

Reprimand Three (3) days

Suspension

Seven (7) days


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incident or injury/damage occurring on

Company time or property

C.9 Unauthorized stay in Company

premises after office hours Written

Reminder/ Warning

Written Reprimand


Seven (7) days


C.10 Smoking in restricted areas Written Reminder/ Warning

Written Reprimand


Seven (7) days

Suspension

C.11 Unauthorized entry into restricted area

within the Company premises Written

Reprimand


Dismissal

C.12 Willful withholding of information from

the Company of having contagious disease

that may endanger the health of co-

employees

Written Reprimand


Dismissal

C.13 Disclosure or release of Company

records or confidential information of any

nature from Company premises without any

authorization

Seven (7) days


C.14 Entry into the Company premises

during off-hours without necessary overtime

authorization or official permit


Written Reprimand


Five (5) days Suspension

Seven (7) days

Suspension

D. CORPORATE PROPERTY AND INTERESTS

1ST Offense 2nd Offense 3rd Offense 4th Offense 5th Offense

D.1 Intentionally damaging Company properties Dismissal

D.2 Performing unauthorized work using Company time and/or doing an act in direct or indirect conflict with the interest of the Company

Seven (7) days Suspension

Dismissal


D.3 Unauthorized use of Company name and properties like vehicles, equipment, etc. This covers the use of Company building for personal, illegal or immoral purposes.


Dismissal

D.4 Unauthorized lending or usage of Company vehicle


Dismissal

D.5 Failure to shut off lights, motors, Written

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appliances and faucets when not in use.

Reprimand

D.6 Entertaining personal visitors and personal telephone calls during Company time without permission from superior which disrupts work.

Written Reprimand



D.7 Placing long distance calls not related to work or without authorization from superior

Written Reprimand



D.8 Unauthorized revelation to any company or entity confidential information such as but not limited to Company trade secrets, finances, etc.

Dismissal

D.9 Competing with the Company’s business or working for another person or Company engaged in the same business.

Dismissal

D.10 Doing work other than those relative to assigned duties or the orders of the superior.

Written Reprimand



Dismissal

D.11 Unauthorized disbursement and/or misappropriation of Company funds or disposal of Company property.

Dismissal

D.12 Driving Company vehicle under the influence of liquor or prohibited drugs.


Dismissal

D.13 Writing on walls or posting unauthorized written materials, notices, signs, or other printed materials on the wall or the bulletin board.

Written Reprimand



D.14 Removing or defacing any official notice or announcement on Company bulletin boards and other areas without prior authorization.

Written Reprimand



D.15 Soliciting donations, selling merchandise or tickets, peddling any type of goods or service to employees during work hours.


Written Reprimand



D.16 Circulating petitions or similar literature during work hours without specific approval of Management.


Written Reprimand

One (1) day Suspension


D.17 Carelessness which caused wastage, spoilage or damage of Company properties.

Written Reprimand

One (1) day Suspension



D.18 Substituting Company property, materials, or equipment for another with inferior quality or lesser value.



Dismissal

D.19 Causing, inciting others to disturbance, disorder or plot which results in the disruption of operation of the Company.

Written Reprimand


Dismissal

D.20 Deliberate slowing down or restricting production output.

Written Reprimand



Dismissal

D.21 Engaging in corporate sabotage Dismissal

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or any similar activity detrimental to the good name of the Company.

Written Reprimand



D.22 Lending of Company funds to a co-employee or non-employees Dismissal

D.23 Personal borrowing of Company funds

Dismissal


D.24 Installation and/or use of unlicensed software including but not limited to installation of games in the Company’s computers

Written Reprimand



Dismissal

E. HONESTY AND INTEGRITY

1ST Offense

2nd Offense

3rd Offense

4th Offense

5th Offense

E.1 Gambling within Company premises Written Reprimand


Dismissal

E.2 Stealing/unauthorized possession of Company property.

Dismissal

E.3 Falsifying or tampering Company records/documents.

Dismissal

E.4 Giving false pre-employment information that would have been a critical consideration to hiring.

Dismissal

E.5 Delegating the swiping of one’s ID card to a co-employee or swiping the ID card of another employee or preparing fraudulent attendance sheet or altering attendance records

Dismissal

E.6 Fraud or willful breach by the employee of the trust reposed on him by the Company.

Dismissal

E.7 Permitting another to use one’s ID or using another ID for personal gain or for unlawful purposes.


Dismissal

E.8 Extending favors to clients that will compromise the Company.


Dismissal

1ST Offense

2nd Offense

3rd Offense

4th Offense

5th Offense

E.9 Commission of a crime or offense by the employee against the person of his employer or any immediate member of his family or his duly authorized representatives.

Dismissal

E.10 Deliberate, careless, or negligent submission of any item of fraudulent expense for Company account.

Dismissal

E.11 Issuing policies without corresponding invoices. Written Reprimand


Dismissal

E.12 Causing the Company to lose time and/or money through fault or negligence.


Dismissal

E.13 Tampering with or mishandling the timekeeping machine causing it to malfunction and/or changing the

Seven (7) days

Dismissal

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time/information. Suspension E.14 Accepting or soliciting, directly or indirectly, any sum of money, unauthorized commission either from suppliers or reinsurers, offer or promise in consideration of any act, contract, decision or service involving the Company and the other party, which tend to compromise the discharge of the employee’s official duties towards his/her employer.

Dismissal

E.15 Giving false testimony during Company investigation.

Dismissal

E.16 Embezzlement, malversation and/or misappropriation of Company funds or assets

Dismissal

E.17 Theft (whether Company property or property of a co-employee, clients)

Dismissal

1ST Offense

2nd Offense

3rd Offense

4th Offense

5th Offense

E.18 Concealment of one’s knowledge of the commission of fraud, deceit or other forms of dishonesty.

Dismissal

E.19 Failure to report or to take action on the commission of offenses of subordinates


Seven (7) days suspension

Dismissal

F. RESPECT FOR SUPERIORS 1ST

Offense 2nd Offense

3rd Offense

4th Offense

5th Offense

F.1 Refusing to perform assigned work. Written Reprimand



Dismissal

F.2 Refusal to render overtime or holiday work despite advance notice.

Written Reprimand



Dismissal

F.3 Insubordination/refusal to obey orders on work matter.


Dismissal

F.4 Disrespect towards superior. Seven (7) days Suspension

Dismissal

F.5 Serious misconduct or willful disobedience by the employee of the lawful orders of his employer or its representative in connection with his work.

Dismissal

F.6 Insult or willful disrespect by the employee on the honor or person of his superior or any Company officer.

Dismissal

G. PROPER WORK CONDUCT AND BEHAVIOR 1ST 2nd 3rd 4th 5th

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Offense Offense Offense Offense Offense G.1 Any act of indecency or immorality committed with or against a co-employee or a client within Company premises or in carrying one’s tasks.



Dismissal

1ST Offense

2nd Offense

3rd Offense

4th Offense

5th Offense

G.2 Using abusive language in addressing any person on Company time or premises. Three (3) days

Suspension


Dismissal

G.3 Causing ill-will and/or defiance among co-employees or toward superior.


Dismissal

G.4 Creating malicious statements/fomenting intrigues concerning any employee/rumor mongering. Three (3) days

Suspension


Dismissal

G.5 Gross or habitual negligence in the performance of duty. Dismissal

G.6 Loafing, loitering or leaving work post premises during office hours without permission of superior.

Written Reprimand


G.7 Being convicted of a crime. Dismissal G.8 Threatening, coercing, harassing, or quarreling with physical contact against/with fellow workers within Company premises.


Dismissal

G.9 Abuse of position in the Company for personal benefit or to take advantage of the employee/s under his supervision.


Dismissal

G.10 Sleeping while on duty. Written Reprimand



G.11 Undue failure to perform an act within the scope of an assigned task.


Dismissal

G.12 Irresponsible conduct or act apt to show job disinterest. Written

Reprimand Three (3) days Suspension


G.13 Making noise or disturbance that may distract other employees in the performance of their duties. Written

Reprimand Three (3) days Suspension


G. 14 Abuse of position to gain profit or to take advantage of the employee/s under his supervision. Dismissal

G.15 Conduct of grossly indecent nature. Dismissal G.16 Disorderly conduct, which includes engaging in horseplay or use of disrespectful, insulting or profane language within Company premises

Written Reprimand



Dismissal

G.17 Sexual harassment as defined under RA 7877 Three (3) days Suspension


Dismissal

G.18 Showing or exhibiting obscene materials, pictures, etc. within the Company premises not for the sake of art or in the interest of art

Written Reprimand



Dismissal

G.19 Simple negligence or dereliction of duty without resulting to serious disadvantage to the Company

Written Reprimand



Dismissal

G.20 Failure to observe prescribed standards of work or to fulfill reasonable work assignments due to inefficiency (includes failure to attain work goals or

Written Reprimand



Dismissal

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work quotas, either by failing to complete within the allotted period or by producing unsatisfactory results which may be reflected in the employee’s performance appraisal for a period of one year) G.21 Failure to comply with the provisions of the Manual on Signing Authority


Fifteen (15) days Suspension

Dismissal

H. REGARD TO CLIENT/GUESTS/SUPPLIERS 1ST

Offense 2nd Offense

3rd Offense

4th Offense

5th Offense

H. 1 Any form of disrespect or discourtesy toward customers, suppliers, guests.

Written Reprimand


H. 2 Quarreling with customers, suppliers, guests Seven (7) days Suspension

Dismissal

H. 3 Using offensive language, behavior or signs towards anyone in the presence of the customers, suppliers, guests


Dismissal

SECTION XII. REPEALING CLAUSE All other rules and regulations on the conduct of employee or parts thereof which are inconsistent with this Code are hereby repealed, amended or modified accordingly. SECTION XIII. EFFECTIVITY This Code shall take effect upon its dissemination to all employees. Done this 31st day of March 2010 at Makati, Philippines.

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ANNEX “A” MEMORANDUM FOR : ADMINISTRATIVE INVESTIGATION COMMITTEE FROM : Name & Rank of Reporting Officer DATE : SUBJECT : NATURE OF IRREGULARITY/ANOMALY The undersigned submits this report on our investigation/audit of the subject irregularity/anomaly conducted on (state date). BASIS OF THE REPORT (if applicable) This investigation was conducted based on the (specify) SCOPE OF INVESTIGATION/VERIFICATION (mention the extent of review/verification made. Also, indicate or describe the nature of the loss) PERSONNEL PRIMARILY INVOLVED (state the name and position/unit/department and other pertinent employment information/history of the employee and whether he had been charged or involved in the past for any infraction. Also state the specific act or omission that was committed) OTHER CITED PERSONNEL (these are employees who by reason of their violation of policies and procedures have facilitated the commission of the irregularity or anomaly of the personnel primarily involved. State the pertinent employment information/history of these employees and their commission in the past of any violation of policies and procedures) BACKGROUND INFORMATION (any antecedent information that led to the discovery of the anomaly/irregularity)

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MODUS OPERANDI (briefly state the scheme used in committing the anomaly/irregularity) FINDINGS/OBSERVATIONS (present the details of the anomaly/irregularity and the supporting documents) VIOLATION OF POLICIES, PROCEDURES, INTERNAL CONTROLS (include in this section the lapses committed by the other cited personnel which facilitated the commission of the anomaly/irregularity) WRITTEN EXPLANATION OF THE ERRING EMPLOYEE AND THE OTHER CITED EMPLOYEES ACTIONS TAKEN BY THE UNIT/DEPARTMENT/DIVISION TO WHICH THE ERRING EMPLOYEE AND THE OTHER CITED EMPLOYEES BELONG RECOMMENDATIONS Signature over printed name of the reporting officer

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ANNEX “B” MEMORANDUM FOR : Name of Employee FROM : ADMINISTRATIVE INVESTIGATION COMMITTEE DATE : SUBJECT : NOTICE TO EXPLAIN This refers to the attached Investigation Report/Audit Report dated ______ alleging acts you committed which constitute (specify the offense and the specific provision of the Code of Conduct violated) and which, if proven to be true, may result to (state the penalty as provided by the Code of Conduct). In this regard, please explain in writing within five (5) working days from your receipt hereof why no such disciplinary action should be imposed upon you. Your failure to submit your written explanation shall be taken as a waiver of your right to be heard and this matter shall be submitted for resolution and/or hearing based on the records and available evidence. For your strict compliance. Signed Chairman – AIC Cc: 201 Files

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ANNEX “C” MEMORANDUM FOR : Name of Employee FROM : ADMINISTRATIVE INVESTIGATION COMMITTEE DATE : SUBJECT : NOTICE OF HEARING Please be informed that a formal hearing on your reported violation of our Code of Conduct will be held on (date of hearing) at (time of hearing) at (venue of hearing). You are therefore required to appear at the hearing and present your side on the matter. We wish to reiterate that the hearing is intended to afford you the opportunity to present your side on the charges against you. Your failure to appear shall mean a waiver of your right to be heard and the Committee will proceed with the deliberation on the issues raised against you and make the appropriate decision based on the available evidence. For your information. Signed Chairman – AIC cc: 201 Files

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ANNEX “D” MEMORANDUM FOR : Name of Employee FROM : ADMINISTRATIVE INVESTIGATIONCOMMITTEE/ DEPARTMENT/DIVISION HEAD DATE : SUBJECT : STERN WARNING After due investigation and hearing, it has been established that you have violated (state provision of the Code of Conduct) which is punishable by (state penalty). Pursuant thereto, you should have been meted the appropriate penalty. However, by reason of (state the circumstance justifying the issuance of a stern warning rather than the penalty provided by the Code of Conduct, i.e., length of service, degree of participation, first time offender, etc.), Management is instead issuing this stern and final warning that your repetition of the same offense or any violation of our Code of Conduct shall be dealt with more severely. Signed Chairman – AIC/Division/Department Head cc: 201 files

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ANNEX “E” MEMORANDUM FOR : Name of Employee FROM : ADMINISTRATIVE INVESTIGATIONCOMMITTEE/ DEPARTMENT/DIVISION HEAD DATE : SUBJECT : WRITTEN REPRIMAND After due investigation and hearing, it has been established that you have violated (state provision of the Code of Conduct) which is punishable by (state penalty). Pursuant thereto, you are hereby issued a Written Reprimand. We wish to stress that your failure to comply with Company policies and/or a repetition of the same offense shall be dealt with more severely in accordance with our Code of Conduct. Signed Chairman – AIC/Division/Department Head cc: 201 files

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ANNEX “F” MEMORANDUM FOR : Name of Employee FROM : ADMINISTRATIVE INVESTIGATION COMMITTEE DATE : SUBJECT : PREVENTIVE SUSPENSION This refers to the ongoing investigation/audit of your reported violation of (state specific act or omission being investigated). Pending completion of the investigation/audit, please be informed that pursuant to the provisions of Department Order No. 9, Series of 1997 Amending the Rules Implementing Book V of the Labor Code, As Amended, you are hereby placed under preventive suspension effective ___________ until _________. Please understand that such suspension shall be without pay. Should your presence be further required in the investigation, you shall be so informed. For your information. Signed Chairman – AIC cc: 201 Files

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ANNEX “G” MEMORANDUM FOR : Name of Employee FROM : ADMINISTRATIVE INVESTIGATION COMMITTEE DATE : SUBJECT : NOTICE OF DISMISSAL/SUSPENSION Please be informed that after investigation and hearing and consideration and evaluation of your testimony and your written explanation and the testimony of the witnesses, the Administrative Investigating Committee has found you guilty of violating (specify provision of the Code of Conduct) which carries a penalty of (specify the penalty of either dismissal or suspension). Accordingly, you are hereby dismissed for cause from the services of the Company effective (state the date)/suspended without pay for a period of (state the period of suspension). Signed Chairman - AIC cc: 201 Files

Code of Conduct - Hrd Copy

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