Code of Business Conduct and Ethics

Receipt of gifts from third parties:

The fundamental principle is that no director and employee should do anything which might give rise to the impression that he or she has been or might be influenced by a gift or hospitality or other consideration to show bias for or against any person or organization while carrying out official duties.

Conflict of Interest:

In case of an actual or potential conflict of interest on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. A director who has a continuing material conflict of interest should seriously consider resigning from his position. In case of an actual or potential conflict of interest on the part of an employee, he should fully and immediately disclose it.

Compliance with Laws & Regulations:

The Board of Directors ensures that the Corporation complies with all relevant laws, regulations and codes of best business practices.

All employees are directed to comply with all relevant laws, regulations and codes of best business practices.

Respect for Trade Secrets/Use of Non-public Information: Board members are reminded not to disclose any confidential, proprietary or trade secret information without specific written approval by an authorized company representative.

During employment, no employee shall disclose any confidential, proprietary or trade secret
information without specific written approval by an authorized company representative.

Use of Company Funds, Assets and Information:

Company funds are to be used only for authorized and bona fide business purposes.

Employment & Labor Laws & Policies:

The Company assures the rights of employees to self organization, collective bargaining, security tenure and a just and humane conditions of work.

Disciplinary action:

Disciplinary action taken should be within the premise of just cause with unsatisfactory job performance and unacceptable personal conduct.

Conflict Resolution:

The Corporation shall establish and maintain an alternative dispute resolution system that can amicably settle conflicts or differences between the Corporation and its stockholders, and the Corporation and third parties, including the regulatory authorities.

The Revised Manual on Corporate Governance has been disseminated to all directors, senior management and employees.

The Corporation has complied, and will continue to comply, with the leading practices and principles on good corporate governance, as set forth in the Corporation’s Manual on Corporate Governance in compliance with SEC Memorandum Circular No. 2, Series of 2009. The Corporation monitors compliance through its Compliance Officer, Mrs. Mariza R. Santos-Tan, who submits a certificate to the SEC attesting to the Corporation’s compliance.

Please refer to the Sta. Lucia Land Inc. – Annual Corporate Governance Report 2015