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.
Employee Wellness and Development Programs
Environment and Sustainability Programs
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.
The Human Resources Department (HRD) orientation program gives new employees an overview of the various components of SM Prime’s Corporate Governance Framework, the Code of Ethics and related policies 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. Relative to this, the HRD, on an annual basis, requires all employees to take the 3-part Annual Code of Ethics Course. This specifically includes the following:
- Confirmation – to confirm that employees have read and understood and agrees to comply with the Company’s Code of Ethics, Code of Conduct and Matrix of Violations (including Anti-Money Laundering-specific violations Insider Trading Policy), Conflict of Interest (COI) Policy, Guidelines on Acceptance of Gifts and Travel Sponsored by Business Partners (Anti-Corruption Policy), and Information Security Guidelines, among others.
- Handling COI Situations (E-Learning Course) – to be familiarized with the proper disposition of actual or perceived COI situations.
- 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.