The Code of Ethics sets the standards that guide SM Prime’s directors, officers and employees in carrying out their duties and engaging with investors, creditors, customers, contractors, suppliers, regulators and the public.

It also reflects the Company’s commitment to employee welfare, customer well-being, community development and the sustainable use of environmental, social and economic resources to support long-term growth.

SM Prime advances these principles through policies and programs focused on:

• Community Welfare
• Employee Wellness and Development
• Environment and Sustainability

Through the Whistleblowing Policy, employees may raise concerns involving potential violations of the Code of Ethics, Company policies, laws or regulations in a safe and responsible manner.

New employees are introduced to SM Prime’s Corporate Governance Framework, Code of Ethics and related policies through the Human Resources Department’s orientation program. These materials are also available through the Company’s internal employee portal.

On an annual basis, all employees are required to complete the Annual Code of Ethics Course to refresh on the Company’s standards and expectations on its governance, ethics, and compliance policies and procedures. The course covers the following:

Confirmation

Employees confirm that they have read, understood and agree to comply with the Company’s key policies on governance, ethics, employee conduct, conflict-of-interest, anti-corruption, insider trading, and information security, among others.

Handling Conflicts of Interest

An e-learning course guides employees on the proper management of actual, apparent or potential conflicts of interest and is required to pass an online assessment at the end of course.

Disclosure Survey

Employees disclose relevant affiliations, interests, relationships and transactions that may give rise to actual, apparent or potential conflicts of interest as espoused in the Company’s Conflict of Interest Policy.