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Code of Business Conduct and Ethics

The Code of Ethics states the principles that guide the Company’s directors, officers and employees in the performance of their duties and responsibilities, and in their transactions with investors, creditors, customers, contractors, suppliers, regulators and the general public.  It also underscores the Company’s commitment to promote and protect the welfare of its employees, customers and the communities where its businesses operate and emphasizes the need to protect, sustain and enhance the environmental, social and economic resources needed to deliver long-term growth.
 
SM Prime has developed company policies and programs in line with the principles of Code of Ethics.
 
 
Through the Policy on Accountability, Integrity and Vigilance (PAIV) the Company provides an environment where concerns and issues regarding violation of the Code of Ethics, corporate policies, law or regulation may be raised freely within the organization.
 
On an annual basis, the Human Resources Department requires all employees to take the 3-part Corporate Governance program. This program gives employees an overview of the Company’s Corporate Governance Framework, policies, and various components which are also contained in an internal portal for employees’ easy access and reference. It also covers the importance of ethics in the business, informs employees of their rights and obligations, as well as the principles and best practices in the promotion of good work ethics. This specifically includes the following:
 
  1. Confirmation – to confirm that employees have read and understood and agrees to comply with the Company’s Code of Ethics, Insider Trading Policy, Conflict of Interest Policy, and Guidelines on Acceptance of Gifts and Travel Sponsored by Business Partners (Anti-Corruption Policy), among others.
  2. Disclosure Survey - to disclose each employees’ affiliations, interests, relationships, and/or transactions which are relevant for full disclosure of all actual, apparent or possible conflicts of interest.
  3. e-Learning Courses (self-paced learning) - to be familiarized with the provisions of the Code of Ethics and other specific policies in upholding corporate governance in the workplace.