Policy on Solicitation and Acceptance of Gifts - Form

POLICY ON SOLICITATION AND ACCEPTANCE OF GIFTS

________ is committed to upholding the highest standards of honesty, integrity, and fairness. Consistent with this commitment, Directors, Employees, and Consultants should avoid situations or acting in a manner where their objective and independent judgment in performing their duties and responsibilities in the Company may be affected.

Scope

This Policy shall apply to all Directors, Employees, and Consultants of ________ (the "Company").

This Policy only covers solicitation or acceptance of gifts from Third Parties. Third Parties shall refer to any individual, entity, organization, and/or its representatives that has existing and/or future business with dealings with the Company (collectively, "Third Parties").

This Policy does not cover personal gifts such as those solicited or received from family, friends, co-employees or other persons or entities that are not Third Parties.

Guidelines

Solicitation

Directors, Employees, and Consultants are expressly prohibited from soliciting gifts, gratuity, favor, service, entertainment or other benefit from Third Parties, except for the following:

1. Gifts or donations for Corporate Social Responsibility programs provided that the following conditions are met:

________

2. Solicitations for Company use, other than Corporate Social Responsibility provided that the following conditions are met:

________

If the Company will only solicit or accept gifts or donations from selected Third Parties, the conditions for such selection shall be made known to all, including all relevant Third Parties.

Acceptance

Directors, Employees, and Consultants may not receive any business courtesy that violates the law, regulations, contracts or agreements, or reasonable customs of the marketplace.

In all appropriate instances when a Gift or Entertainment may be accepted under this Policy, it may only be accepted if all of the following conditions are met:

1. They are voluntarily offered in good faith;

2. Given for a bona fide and legitimate business purpose;

3. Reasonable and proportionate in value and frequency in comparison to the usual gift-giving practices of the industry;

4. They do not create an impression of impropriety;

5. Does not violate any law, rules and regulations, company policies, contracts or agreements, or good morals and customs;

6. Not intended to secure an improper advantage or otherwise;

7. Not intended to induce or reward for any act that may affect business decisions relating to the Company.

A Director, Employee, or Consultant must also consider the following when accepting a Gift or Entertainment:

1. The value of the gift in comparison to the usual gift-giving practices in the industry;

2. Restrictions under the law, rules and regulations, company policies, contracts or agreements, or good morals;

3. Total value of business courtesies to the recipient from the Third Party in the current year;

4. Suitability of the business courtesy in relation to the Director, Employee, or Consultant's position.

In no instance should Directors, Employees, and Consultants receive business courtesies that are extravagant, expensive, or costly or too frequent considering the customs of the industry or the business situation.

Cash, Cash Equivalents, and Free Memberships or Subscriptions

Acceptance of cash, vouchers, gift certificates, checks, or other cash equivalents of any amount, and free memberships or subscriptions from Third Parties, is prohibited and is not and cannot be subject to any exceptions.

Gifts

Gifts shall refer to any gift, gratuity, favor, benefit, discount, forebearance, other tangible or intangible item having monetary value from a Third Party for which the recipient does not pay fair market value.

Gifts shall be accepted in behalf of and surrendered to the Company, except that the following may be kept by a Director, Employee, or Consultant:

1. The Gift is valued at equal to or less than ₱________ voluntarily given by a Third Party out of courtesy or because of a celebration or occasion

2. Gifts or tokens of appreciation when a Director, Employee, or Consultant participated in an event sponsored by a Third Party provided that the same is offered to everyone who participated in the same or equivalent manner

3. Simple promotional items

4. Discounts for personal purchases of products or services of Third Parties by a Director, Employee, or Consultant provided that such discounts are made openly and are available to all Directors, Employees, and Consultants

5. Raffle tickets given to Directors, Employees, or Consultants for their attendance to events sponsored by a Third Party, provided that all other participants are likewise entitled to such raffle tickets and given an equal opportunity to win prizes. If a Director, Employee, or Consultant wins a prize from said raffle ticket, said prize may likewise be accepted and kept by the Director, Employee or Consultant, regardless of the value of said prize.

All Gifts that are valued over ₱________ ("Expensive Gift") will be received on behalf of the Company and should be turned over to the following: ________ for the following actions:

1. If the Gift is non-perishable: to be raffled off for the benefit of all Directors, Employees, and Consultants of the Company.

2. If the Gift is perishable: to be shared and consumed by all Employees in the business unit to which the recipient belongs.

The recipient of an Expensive Gift should inform the giver that the Expensive Gift will be received on behalf of the Company and that the same will be handled according to the foregoing.

Entertainment

Entertainment shall refer to all types of hospitality extended to Directors, Employees, and Consultants including but not limited to meals and activities, whether the Director, Employee, or Consultant is a spectator or participant, such as concerts, sports, and other similar activities.

Customary invitations to meals and activities that are paid for by Third Parties may be accepted provided that such meal or activity does not impair the objectivity of the recipient in the performance of their duties and responsibilities to the Company.

Locations of business meetings that do not conform to accepted standards of propriety and are not conducive to business purposes should be avoided.

Reasonable judgment must always be exercised in accepting any form of Entertainment.

Acceptance of any such invitations must be cleared and approved by the recipient's immediate supervisor or, if prior approval is not reasonably possible, the same must be reported to the recipient's immediate supervisor as soon as is reasonably possible.

Property Belonging To Third Parties

Directors, Employees, and Consultants are prohibited from accepting any invitation to use property belonging to Third Parties, their directors, officers, employees, consultants, agents, and/or representatives. This includes, but is not limited to, vehicles, resorts, beach houses, vacation houses, regardless of whether the same will be used for their personal benefit or for Company purpose.

Sponsored Travel

Sponsored Travel shall refer to any travel, accommodation, and/or expenses for attending conferences, conventions, seminars, whether international or domestic, or for business or personal purposes, that are fully or partially paid for by Third Parties.

Directors, Employees, and Consultants are prohibited from Sponsored Travel unless it is part of an approved/existing contract between the Company and a Third Party.

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Travel sponsored by organizations other than the Company may likewise be accepted if the sponsor is not associated with any Third Party.

All travels, whether sponsored by Third Parties or not, must be for business purposes and are deemed to have a direct benefit to the Company. The same must also have the prior approval of the following: ________.

Conflict of Interest Directors, Employees, and Consultants must avoid any situation that creates or may create a conflict of interest between their personal interests and the interests of the Company. Any actual, potential, or perceived conflict of interest arising from the solicitation or acceptance of Gifts, Entertainment, Sponsored Travel, or the use of property belonging to Third Parties must be immediately disclosed in writing in accordance with this Policy.

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Responsibility It is the responsibility of every Director, Employee, and Consultant to read, understand, and comply with this Policy. When in doubt as to whether a particular solicitation, offer, or acceptance is permitted under this Policy, the Director, Employee, or Consultant must seek guidance from their immediate supervisor or the appropriate authority within the Company before acting.

Reporting

All solicitations, offers, receipt, and/or acceptance of the foregoing must be immediately reported in writing as follows:

________

Any attempt by a Third Party to undermine or impede the transparency, honesty, integrity, and fairness of a Director, Employee, or Consultant must also be reported.

Relatives

Relatives shall refer to all relatives up to the fourth degree, by consanguinity or affinity.

If a relative of a Director, Employee or Consultant solicits and/or accepts Gifts, Entertainment, or Sponsored Travel from a Third Party or uses property belonging to a Third Party in violation of this Policy, said Director, Employee, or Consultant must immediately, upon discovery of the fact, report the same in writing in the manner provided in the foregoing.

Violations

Any Director or Employee who violates this Policy will be subject to sanctions under the Company Code of Conduct and/or the labor code.

Any Consultant who violates this Policy will be subject to penalties under their contract with the Company, which may include the termination of the contract.

Information Dissemination

All new Directors, Employees, and Consultants shall receive a copy of this Policy upon the start of the performance of their duties.

If this Policy is amended or modified, all Directors, Employees, and Consultants will be informed of the amended or modified policy.

Effective Date

This Policy shall become effective on ________.

Signed and approved:

________
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