At Aboitiz Foods, we are committed to upholding the highest standards of ethics and integrity in all aspects of our business. Ethical conduct is a foundational principle that drives sustainable value creation and underpins our commitment to responsible corporate citizenship. Our core values—Integrity, Teamwork, Innovation, and Responsibility—define our organizational culture and guide our interactions with stakeholders.

The Aboitiz Foods Code of Ethics and Business Conduct (“Code”) is more than a policy; it is a framework that embodies our principles and expectations. It governs our decision-making, business practices, and stakeholder relationships, fostering trust with our Business Partners, communities, and team members.

Adherence to the Code is essential to achieving both our commercial objectives and our transformative purpose of “Sustainably Feeding Asia’s Growth From Mill to Meal. ” The Code also provides resources to seek guidance, raise concerns, and ensure ethical decision-making without fear of retaliation. We encourage all employees to review this Code carefully. If you require clarification or have any concerns, please consult your Team Leader or a member of the Aboitiz Foods Legal and Compliance Department.

1. Applicability

The Code applies to all Aboitiz Foods Team Members – directors, officers and employees in every country, and every Aboitiz Foods Entity. Team Members are required to read and comply with this Code, along with other applicable Aboitiz Foods policies. We expect our Business Partners with interest and dealings with Aboitiz Foods Entities including clients, suppliers, consultants, agents, business partners, and joint venture partners to comply with the principles outlined in our Statement of Business Ethics and Expectations for Business Partners.

“Aboitiz Foods Entity” means any entity that is consolidated in Aboitiz Foods financial statements or otherwise controlled by Aboitiz Foods. Aboitiz Foods General Counsel must approve any Aboitiz Foods Entity use of a code of conduct in lieu of this Aboitiz Foods Code of Ethics and Business Conduct. With respect to entities in which Aboitiz Foods has an interest but does not have control, we encourage them to adopt and follow this Aboitiz Foods Code of Ethics and Business Conduct as appropriate.

1. Purpose

While the Code may not address every conceivable scenario, the Code, together with Aboitiz Foods policies, serves as a comprehensive framework that:

a. Provides guidance to ensure Aboitiz Foods Team Members uphold the highest standards of integrity in all professional conduct;

b. Outlines resources for seeking clarification and support in addressing questions related to ethical decision-making;

c. Establishes mechanisms for reporting concerns and potential violations without fear of retaliation; and

d. Forms the foundation of Aboitiz Foods’s compliance program, which is continuously refined through regular risk assessments to  identify and mitigate the most pertinent compliance risks in our business operations.

2.Responsibilities of Aboitiz Foods Team Members

All Aboitiz Foods Team Members are required to:

a. Adhere to Aboitiz Foods’s principles and values, comply with the Aboitiz Foods Code of Ethics and Business Conduct, Aboitiz Foods policies, and all applicable laws and regulations;

b. Conduct themselves lawfully, honestly, and ethically, ensuring that their actions consistently align with the best interests of Aboitiz Foods;

c. Exercise sound judgment, proactively seek guidance when faced with ethical dilemmas, and report concerns as appropriate;

d. Complete all mandatory training to ensure a thorough understanding of their compliance obligations;

e. Promptly report any suspected or actual violations of the law, this Code, or Aboitiz Foods policies; and

f. Fully cooperate with any Aboitiz Foods-led investigation into potential violations of the Code, Aboitiz Foods policies, or applicable law, including maintaining confidentiality as required.

A. First Line Of Defence 

Aboitiz Foods Team Members serve as the first line of defense against unethical conduct, legal violations, and breaches of the Code. If you become aware of or suspect any conduct that is unethical and/or unlawful—whether committed by a fellow Team Member, Business Partner, consultant, supplier, client, or any other third party—you are required to report such concerns. Reports should be made to your Team Leader or, where appropriate, to senior management or the Aboitiz Foods Legal and Compliance Department. Failure to report potential misconduct may hinder the organization’s ability to address and mitigate risks in a timely manner, potentially exacerbating harm. 

Team Leaders have an elevated duty to take appropriate action to prevent, detect, and remediate misconduct. If a Team Leader becomes aware of any violation or suspected violation, they must take the necessary steps to stop the misconduct and prevent its recurrence. Failure to take appropriate corrective action may result in accountability for inadequate supervision.

B. Ask Questions And Make Good Decisions 

The Code serves as a practical guide for navigating ethical and compliance-related situations. However, no single document can anticipate every possible scenario or prescribe definitive solutions for all circumstances. Accordingly, the Code is never a substitute for common sense and good judgement. In cases where a clear resolution is not readily apparent, employees must carefully evaluate their proposed course of action, exercise discretion, and seek guidance from the appropriate resources. Seeking guidance from your Team Leader, manager or engaging the Legal and Compliance Department is essential to ensuring informed and responsible decision-making. 

For any questions regarding your responsibilities or the provisions of the Aboitiz Foods Code of Ethics and Business Conduct, you are encouraged to contact the Legal and Compliance Team. 

Inquiries may be submitted via the Legal and Compliance email at aboitizfoods.legalandcompliance@aboitiz.com. If you are uncomfortable asking a question or raising a concern. You may also reach out to your local Human Resources team.

C. Aboitiz Foods Whistleblowing Policy And Hotline 

Aboitiz Foods champions a culture of openness and transparency, where Team Members are encouraged to raise concerns and engage in constructive dialogue without fear of retaliation. Open communication of issues and concerns by all Team Membesons without fear of retribution or retaliation is vital to our continued success. 

Aboitiz Foods do not and will not tolerate any form of retaliation against individuals who, in good faith, report suspected misconduct or participate in an investigation. A report is made in “good faith” when the reporting individual provides all available information and has a reasonable belief that a violation of law, ethics, or company policy may have occurred, regardless of whether the allegation is ultimately substantiated. Retaliation is a violation of the Aboitiz Foods Code of Ethics and Business Conduct and must be reported promptly through the various reporting channels available as outlined under Section D. Non-Retaliation. 

For more information, please refer to our Whistleblowing Policy. 

D. Non-Retaliation 

In Aboitiz Foods, we value giving feedback with good intentions and receiving it openly with the goal of creating a work environment where there is open, honest and constructive feedback without sacrificing human channels. As such, we do not and will not tolerate any kind of retaliation for reports or complaints regarding the misconduct of others that were made in good faith, or for participating in an investigation of possible misconduct. 

“Retaliation” refers to any unjust, adverse or negative measures, action, treatment, or behavior taken against an employee in retaliation against their act of providing feedback or expressing concerns, thereby inhibiting a healthy and inclusive work environment. 

Retaliation may take various forms, including but not limited to: 

– Imposing unwarranted disciplinary measures without due process 

– Engaging in verbal abuse, threats, isolation, or any behavior that hinders an employee’s job performance. 

– Intentionally excluding employees from meetings, projects, or other interactions as punishment. 

– Spreading false rumours, derogatory remarks, and harming professional reputation. 

Making a report in “good faith” means that you have provided all the information you have and you reasonably believe that there has been a possible violation of law, ethics, or policy. 

E. Investigations 

We take violations of the Code very seriously and investigate reports of actual or suspected misconduct, as appropriate. The investigation process will be conducted according to the local laws and regulations including Aboitiz Foods internal policies. Unless otherwise required by applicable law, we are committed to keeping your information confidential to the extent possible given our responsibility to investigate reports of misconduct. Allegations of violations are timely investigated by a person with appropriate resources and authority who is not implicated in the matter at issue. Directors, officers and Team Members are expected to co-operate in internal investigations of allegations of violations of Aboitiz Foods Code of Ethics and Business Conduct. We may also report certain activities to the applicable regulator and/or authority, which could give rise to regulatory or criminal investigations.

F. How We Deal With Violations 

We promote and consistently enforce the Code through appropriate incentives to perform in an ethical manner and appropriate disciplinary measures for violations in accordance with the law and applicable policies. The Code forms part of the terms and conditions of your employment with the Company. 

Any violation may subject you to the full range of disciplinary action, up to and including termination, where permitted by law. Disciplinary measures will depend on the circumstances of the violation and will be applied in consultation with your respective Human Resources Team. Consideration will be given to whether or not a violation was intentional, as well as whether any Team Member has acted in good faith in reporting the violation and co-operated with any resulting investigation or corrective action. 

Our Aboitiz Foods Code of Ethics and Business Conduct is organised under six (6) fundamental behaviours that apply to every one of us, every day. 

1. We respect the letter and spirit of all applicable Laws, rules and regulations. 
2. We treat each other with respect and dignity. 
3. We ensure the health and safety of our people and guests in all our workspaces. 4. We act in the best interest of clients, suppliers, Business Partners and the public. 5. We advance and protect Aboitiz Foods Interests. 
4. We act in a sustainable manner. 

Aboitiz Foods conducts business globally and Aboitiz Foods Team Members come from many jurisdictions and are subjected to laws and regulations of various countries. Aboitiz Foods is committed to full compliance with all applicable laws, whether local, national, or regional. Aboitiz Foods Team Members, and those acting on our behalf are responsible to know and understand the laws, rules and regulations and to comply with both the letter and the spirit of all laws, rules and regulations under which Aboitiz Foods operates, including the principles of this Code. 

Compliance extends beyond the mere avoidance of unlawful conduct (such as illegal activity, unethical business practices or violations of the Code and Aboitiz Foods policies) but also even the appearance of impropriety. Assume that any action that we personally take (or fail to take) could ultimately be publicised. Aboitiz Foods Team Members should always consider how they; their colleagues and the Company would be perceived. When in doubt, stop and reflect and seek guidance from appropriate resources (i.e. Team Leaders, Legal and Compliance Department and etc.). You should never assume that an activity is lawful and ethical merely because others in the industry engage in it.

Aboitiz Foods is dedicated to fostering an inclusive workplace where all individuals are treated with dignity and respect. Aboitiz Foods Team Members must uphold the highest standards of professional conduct, as our behavior reflects both on ourselves and the Company. 

Aboitiz Foods maintains a zero-tolerance policy for discrimination, harassment, or violence in any form. All directors, officers, and employees are responsible for ensuring a workplace that promotes equal opportunities and remains free from bias and misconduct. This standard extends to interactions with third parties, including Business Partners and service providers. 

Whether at work, travelling on business, communicating online or attending training or social events with colleagues, Business Partners or customers, we must always have the mindset that we are the “Ambassadors of Aboitiz Foods”. 

1. Human Rights 

Aboitiz Foods supports and respects internationally recognized human rights as outlined in the International Bill of Human Rights. We focus on areas most relevant to our operations and take corrective action when witnessing or becoming aware of violations. We encourage Aboitiz Foods Team Members to speak up if they experience, witness or become aware of any human rights violations. 

2. Diversity and Equal Opportunity 

Aboitiz Foods is committed to a discrimination-free workplace, making employment decisions based solely on merit, including qualifications, capabilities, and contributions to the business. We do not discriminate against any person based on these characteristics: – race, colour, ancestry, genetic information, national / regional or ethnic origin, citizenship status, religion, creed, sex, gender identity or expression, sexual orientation, pregnancy, maternity, marital or family status, age, physical or mental disability or any status protected under applicable laws. 

To maintain an ethical work environment, we conduct risk-based due diligence before hiring, transferring, or promoting individuals. This includes verifying the person’s qualifications, contacting references, taking reasonable steps to determine if an applicant has been involved in misconduct, identifying relationships with public officials and verifying that any prospective employment is not to secure improper favourable treatment for any of Aboitiz Foods Entity.

3. Labour Commitment 

Aboitiz Foods operates across multiple jurisdictions and complies with all applicable labor laws. We do not condone illegal activities such as human trafficking, slavery, servitude, forced labor, and child labor. 

4. Disrespectful Behaviours and Harassment 

Disrespectful behaviour or harassment of any kind are not tolerated by Aboitiz Foods. Disrespectful behaviour and harassment may come in many forms. These behaviours usually create an intimidating, hostile or offensive work environment, or any inappropriate behaviours that interfere with work performance. What matters when evaluating disrespectful behaviours or harassment is how the behaviour is received by the impacted individual, not whether it was intentional or not.

Any misconduct, including discrimination, harassment, retaliation or other forms of unprofessional behaviour may subject you to disciplinary action under the relevant Human Resources Policies, up to and including termination of employment. In addition, conduct that is also considered unlawful may subject you to civil and in some cases, criminal liability. 

5. We Expect More From Aboitiz Foods Executives 

Our Executives play an important role in setting the tone from the top and ensuring that we maintain a respectful, ethical and inclusive work environment. Aboitiz Foods encourages and requires its Executives to set an example and to always take action if they witness, or become aware of, inappropriate or disrespectful behaviours, harassment or retaliation and to encourage their teams to do the same.

Aboitiz Foods is committed to full compliance with all applicable environmental, workplace health, and safety laws. We prioritize a safe and healthy work environment for our employees while minimizing adverse impacts on the environment and communities in which we operate. Responsibility for upholding these standards rests with all directors, officers, and employees. 

1. Workspace Health and Safety And Business Continuity 

Aboitiz Foods upholds a safety-first culture, requiring all work—regardless of urgency—to be conducted safely and in accordance with established safety and emergency procedures, including incident response guidance and business continuity measures. Any incident posing a risk to life, health, or safety must be reported immediately. 

We are committed to ensuring a safe and conducive environment for all our team members and guests at our office workspace. We require all our team members to undergo the required health and safety training programs relevant to their jobs (including refresher courses). Continuous improvement of safety protocols is integral to achieving our zero-incident goal. To this end, it is everyone’s responsibility to contribute to a healthy and safe workplace. Everyone is empowered to promote safe behavior and drive interdependent safety culture. 

2. Drugs and Illegal Substances 

Aboitiz Foods maintains a total prohibition on the consumption, distribution, and sale of drugs or unauthorised controlled substances at all work locations. Team Members must report to work unimpaired, and unannounced drug testing may be conducted. Violation of this policy, including possession or being under the influence of drugs, will result in immediate termination. 

If prescribed medication impairs work performance or poses a safety risk, Team Members must inform Human Resources or your Team Leader. 

3. Alcohol 

Alcohol consumption during work hours is prohibited except at company-sanctioned events, and Team Members must remain vigilant and exercise discretion when consuming alcohol at third-party or customer events. 

4. Guidance for Team Members Travelling Abroad 

Aboitiz Foods Team Members traveling abroad must remain vigilant to avoid inadvertent involvement in illegal activities, including drug trafficking. Team Members are warned not to accept any packages for deliveries to/from third parties, unless the contents, without a doubt, have been ascertained as drug-free. 

Our drug and substance policies apply universally, including while traveling for work. Team Members must not consume illegal substances under any circumstances. 

For more information, please refer to the Safety, Health, Environmental Policy.

CONCERNS/QUESTIONS:

1. If you have any questions and/or concerns regarding health and safety, please reach out to our Health and Safety Team directly via email at 1fg.she@aboitiz.com.

2. If you have any grievances and/or conflicts related to safety concerns including matters related to emergency response plans, including evacuation procedures and contact information for emergency services please contact your local Human Resources team.

3. You may also reach out to theconducting all business transactions with integrity and ensure that we are accountable for all our actions and consequences. Legal and Compliance Team at aboitizfoods.legalandcompliance@aboitiz.com to escalate any report.

Consistent with our value of integrity, we are committed to the highest standards of ethics in relation to our dealings with clients, suppliers, business partners and the public. We value the contributions of our Team Members, customers, suppliers, shareholders, business partners and other stakeholders as we strive to achieve our corporate mission and vision. We take pride in 

1. Fair Dealings and Competition 

Aboitiz Foods is committed to fair and honest competition, striving for superior performance while complying with all applicable competition and antitrust laws that promote free and fair markets. 

While these laws vary by jurisdiction, all Aboitiz Foods Team Members—team members, officers, and directors—must prioritize the best interests of our clients and conduct business fairly with suppliers, competitors, the public, and one another. Even the appearance of a violation can pose risks. 

To ensure compliance: 

• No Unfair Competition: We do not engage in anti-competitive practices. 
• No Price Collusion: We do not coordinate pricing with competitors. 
• No Restrictive Agreements: We avoid agreements that unfairly limit competition. 
• No Unfair Advantage: We do not manipulate, misrepresent, or misuse privileged information. 
• No Abuse of Market Position: We do not engage in practices that unlawfully protect or enhance a dominant market position, such as price manipulation or exclusionary tactics. 

Violations of competition and antitrust laws can lead to severe reputational harm, criminal penalties, and substantial civil liability for both Aboitiz Foods and individuals involved. Compliance is mandatory. 

For more information, please refer to the Competition Law Policy for each applicable Aboitiz Foods countries or contact your local Human Resources team.

2. Bribery and Corruption 

We always conduct our business in an ethical manner and in compliance with the applicable laws and regulations, including laws on bribery and corruption. Aboitiz Foods Team Members must comply with all such laws at all times, and must not engage in any corrupt behaviours, including giving or accepting bribes. 

Our stance on corruption and bribery is very simple. Bribery and corruption is always wrong, against the law and we do not give or accept bribes. Generally a “Bribe” is broadly defined as: 

• Anything of value; 
• Offered, promised, or given, directly or indirectly; or 
• To improperly influence the actions of a third party in order to obtain or retain business or gain a business advantage. 

All Aboitiz Foods Team Members, directors, and agents must act with integrity in all business dealings. We have zero tolerance for corruption, extortion, or embezzlement, whether involving public or private entities, whether offered, paid, accepted, or solicited directly by Aboitiz Foods Team Members or indirectly through third parties. 

For more information, please refer to our Anti-Corruption Guidelines or contact your local Human Resources team. 

3. Gifts, Meals And Entertainment 

While gifts, meals, and entertainment can foster business relationships, they must never create undue influence or conflicts of interest. Care must be exercised when giving gifts or extending hospitality to avoid being perceived as trying to influence a decision or outcome. Team Members must ensure compliance with the Code, policies, and applicable laws when offering or accepting any form of hospitality from customers, suppliers, business partners, or government officials. 

For more information, please refer to our Gifts, Meals and Entertainment Guidelines or contact your local Human Resources team. 

4. Trade Compliance & Third-Party Due Diligence 

Our international reach demands that we exercise appropriate due diligence as to the third parties which we do business with and that we comply with all applicable legal requirements with respect to trade, import and export. 

We may be held responsible for bribes given by third party business partners on our behalf even in cases where we did not approve or do not know of such actions. Therefore, we must always be vigilant in reviewing our business partners before entering into transactions with them. To ensure that we only work with ethical individuals and companies, we conduct due diligence on all business partners prior to engaging them. We conduct ongoing monitoring as necessary to ensure that such third-party business partner risks are appropriately mitigated throughout the business relationship. 

For more information, please refer to our Business Partner Due Diligence Guidelines or contact your local Human Resources team.

5. Anti-Money Laundering 

We do not engage in any money laundering or terrorist financing activities or assist any third party in doing so. Money laundering is the process by which individuals or entities move criminal funds through the financial system in order to hide traces of their criminal origin or otherwise try to make these funds look legitimate. Team Members are responsible for escalating any potential red flags in relation to money laundering and/or terrorist financing activities to us.

As an organisation under the Aboitiz Group of Companies, Aboitiz Foods works to uphold the wider Aboitiz Group’s interest and values. We work towards building a better, stronger and more durable company, advancing businesses and communities through protecting our brand, assets, information and intellectual property. We take ownership in protecting and developing our Team Members. 

1. Advancing and Protecting Aboitiz Foods Interest 

Everyone within Aboitiz Foods has a responsibility and duty when it comes to advancing and protecting Aboitiz Foods interest. No director, officer or Team Member may use their position or corporate property or information for personal gain. No director, officer or employee may also take for themselves company opportunities for sales or purchases of products, services or interests, unless the opportunity is expressly waived in writing. Business opportunities that arise as a result of your position in any Aboitiz Foods Entity or through the use of corporate property or information belongs to Aboitiz Foods. 

2. Proprietary And Confidential Information 

Proprietary and confidential information generated and gathered in our business are valuable assets to us. The protection of such information is critical to our reputation, integrity and relationships with customers, and in doing so, ensures compliance with the complex regulations governing our industry across the different Aboitiz Foods jurisdictions in which we have presence and business activities. 

Accordingly, all Team Members must protect and maintain all proprietary and confidential information in strict confidence, except when its disclosure is authorised by us or required by law. For this purpose, each Team Member shall undertake to sign a non-disclosure agreement as part of their commitment to the Company.

The unauthorised use or distribution of proprietary or confidential information violates our policy and could be illegal. Such use or distribution could result in negative consequences for both the Company as well as the individuals involved and could merit potential legal and disciplinary actions. Your obligation to protect our Proprietary and Confidential Information continues even after you leave us. You must return all such information in your possession (wherever located) upon your departure or termination of employment in accordance with our Integrated Information Security Management (ISMS) Policy and applicable guidelines. 

Report any suspected information security incidents to our Information Technology Team at servicedeskgroup@aboitiz.com immediately or contact your local Human Resources team.

3. Data Privacy 

We only collect, use and maintain personal information that is required for business or legal reasons, and maintain appropriate access controls and use limitations. You are required to follow all applicable privacy, information security and data privacy and protection laws that govern the handling and use of personal data, which means any information that stands alone or in connection with other data, could be used to identify the individual to whom the information relates. 

Many countries have laws and regulations that restrict the dissemination and use of personal data outside their borders. We comply with the local legal requirements applicable to personal data. 

Report any suspected data privacy incidents to our Data Privacy Team at goldcoin.dpo@aboitiz.com immediately or contact your local Human Resources team. 

For more information, please refer to Pilmico Data Privacy Policy & Gold Coin Data Privacy Policy. 

4. Company Systems And Assets 

Aboitiz Foods has adopted policies that regulate the use of its telecommunication and mixed media communication systems, including telephones, computer networks, electronic mail and remote access capabilities. These systems and properties should generally be used only for legitimate company business and activities. Under no conditions may you use these systems to view, store and/or send unlawful, offensive or other inappropriate materials, or to improperly disclose or misuse our proprietary and confidential information. 

For more information, please refer to Integrated Information Security Management (ISMS) Policy and Bring Your Own Device (BYOD) Guidelines. 

You may obtain copies of our policies from the Information Technology Team at servicedeskgroup@aboitiz.com or contact your local Human Resources team. 

5. Prevent The Misuse of Inside Information 

Using inside information to trade securities, or to “tip off” a family member, friend or any other person, is illegal. 

As an employee, you may never, under any circumstances, trade, encourage others to trade, or recommend the trade of securities or other financial instruments based on (and in some circumstances, while in the possession of) inside information. 

The misuse of inside information may result in disciplinary action by the Company, up to and including termination of your employment. Misusing inside information may also end any career in the securities industry and result in civil and criminal penalties, including imprisonment. 

6. Insider Trading 

To protect against insider trading or even the appearance of insider trading, we have adopted Aboitiz Equity Ventures, Inc.’s strict policies governing directors, officers, and employee trading, which vary depending on your position and where you work within the Aboitiz Group of Companies. You are required to familiarise yourself and comply with these policies. 

If you have any questions about your ability to buy or sell securities, you should contact the Aboitiz Equity Ventures Legal and Compliance Team at AEV_BoardSecretariat@aboitiz.com. 

For more information, please refer to the General Trading Policy or contact your local Human Resources team. 

7. Conflict of Interest 

All employees have an obligation to act in the best interests of the Company. You should avoid, where possible, any activity, interest, or association outside the Company that could 

impair your ability to perform your work objectively and effectively (including spending Company time or other business endeavours) or that could give the appearance of interfering with your responsibilities on behalf of the Company or its customers. 

Examples of Conflict-of-Interest Situations: 

• Serving as a Board Member, advisor, consultant or contractor for yourself or any other third party while employed by the Company. 
• Accepting special favours as a result of your position with the Company from any person or organisation with which the Company has a current or potential business relationship 
• Competing with the Company for a purchase or sale of property, services or any dealings or transactions where the Company has an interest or other interests. 
• Acquiring an interest in a transaction involving the Company, its customers, or supplier (excluding routine investments in publicly traded companies). 
• Receiving a personal loan or guarantee of an obligation as a result of your position with the Company (other than company loans enjoyed as an employee benefit). 
• Having an outside business, employment or other interest (including in competition with the Company) that would impair your ability to perform your duties. 
• Directing business to a supplier owned or managed by, or which employs, a relative or other person with whom you have a close personal relationship. 

NOTE: It is not possible to describe every situation in which a conflict of interest may arise. The above however, are examples of situations that may give rise to a conflict of interest (unless permitted by law and Aboitiz Foods policies). 

Involvement in certain outside activities may require the prior approval of the Company (particularly if you are a licensed person or if you have secondary employment). Directors should disclose any actual or potential conflicts of interest to the Chairman of the Board and the Compliance Officer who shall determine the appropriate resolution. All directors must recuse themselves from any board discussion or decision affecting their personal, business or professional transactions and interests. 

Team Members are expected to complete a Declaration of Conflict of Interest on a real time basis. We also subject all new hires to providing a Declaration of Conflict of Interest. If you have any questions about whether any potential conflict of interest may arise, you should contact your respective Human Resources Department or if such queries are not resolved, please refer them to the Legal and Compliance Department at aboitizfoods.legalandcompliance@aboitiz.com.

For more information, please refer to Conflict of Interest Policy & Declaration Form or contact your local Human Resources team. 

8. Maintaining Accurate Books And Records 

We maintain accurate and complete books and records which are critical to our decision-making process and compliance with external reporting, legal requirements and existing accounting standards. 

Every business transaction undertaken must be recorded correctly and in a timely manner in its corporate books and records, including gifts and hospitality extended to any Business Partners. We therefore expect Team Members to be candid and accurate when providing information for these documents. 

You are specifically prohibited from making false or misleading entries in the corporate books and records. In particular, senior financial officers must endeavour to ensure that financial information included in the corporate books and records is correct and complete in all material aspects. No payment on the Company’s behalf is to be made without adequate and legitimate supporting documentation or made for any purpose other than as described in the supporting documents. 

9. Records Management 

We are committed to compliance with all applicable laws and regulations relating to the preservation of documents and other records. Our policy is to identify, maintain, safeguard and destroy or retain, as applicable, all records in our possession on a systematic and regular basis. 

You need to know what policies apply to how long you should retain these documents and records, and when and how you should dispose of them. All records that relate to your work are the property of the Company, including those that you may have authored or helped to prepare. 

Records can include forms of communications such as emails, text messages, voicemails, and social media postings. If you are notified that documents in your possession are relevant to any pending litigation or an investigation or audit, do not alter, delete or destroy the documents and follow the guidelines set forth in the notification.

10. Use of Digital and Social Media 

We have adopted social media policies and guidelines that are founded on the belief that Team Members embody the core values of integrity, teamwork, innovation and responsibility in daily life. We encourage Team Members to use social media in a responsible manner as inappropriate usage can have damaging consequences and negative impact to the business. We value the digital conversations related to our business and brands, and adopt policies to empower us to engage ourselves online – The Aboitiz Way. 

The guiding principles of disclosure and transparency, privacy, confidentiality and security, respectfulness, and diplomacy as outlined in our existing social media policies and guidelines will help you know when and how to use these social media channels to become our brand ambassadors. We expect all Team Members to know, understand and follow these policies and to always ask questions when in doubt. 

For more information, please refer to Social Media Policy and Social Media Guidelines or contact your local Human Resources team.

In growing Aboitiz Foods business, we make sure to do our best to minimize an environmental impact that may result from our decisions and actions. We manage our operations well and utilise resources prudently to achieve sustainable financial growth and profitability. 

We strive to find more innovative and strategic ways to create long-term value for all our stakeholders, including the communities in which we operate. We contribute to local communities through appropriate social and economic development programs, including through our wider Aboitiz Foundation activities. These projects must comply with applicable laws, this Aboitiz Foods Code of Ethics and Business Conduct and other applicable company policies, including a location, timing and selection of community projects, due diligence and procurement processes, deed of donation provisions and signatories, and monitoring of projects.

A. Continuous Training And Education 

Aboitiz Foods Human Resources Department is responsible for disseminating a copy of this Code to existing and new directors, officers and employees of Aboitiz Foods through the new hires’ orientation (NHO) and other training, and by making this Code and other policies available in the Company portal for easy access. Upon completion of the NHO, attendees are required to sign the personal commitment form of this Code which serves as an acknowledgment that such attendee understood and agrees to abide with the principles of this Code. 

The Legal and Compliance Department provides periodic training to all Team Members on how to comply with our Aboitiz Foods Code of Ethics and Business Conduct as appropriate depending on their roles and the risks to which they are exposed, which can change over time as Team Members move into different roles. In addition, the Legal and Compliance Department also annually requires all directors, officers and employees to declare that they have complied with this Code. 

B. Team Member’s Assurance 

Team Members must confirm annually that they understand and will comply with our Aboitiz Foods Code of Ethics and Business Conduct and shall certify their compliance with this Aboitiz Foods Code of Ethics and Business Conduct by signing the Briefing and Compliance Acknowledgement and Certification contained at Appendix 1 and Annual Employee Certification at Appendix 2. 

C. Continuous Efforts In Making This Code A Living Document 

We take reasonable steps to ensure compliance with our Aboitiz Foods Code of Ethics and Business Conduct and other related policies, including monitoring the effectiveness of the compliance programs and auditing to detect any violations. As such, we will continue to develop and annually review this Code which could include amendments to the Code and/or other policies and procedures to ensure their continued adequacy and relevance to the evolving business, legal and regulatory environment.

Employees with any questions about this Code should contact Aboitiz Foods Legal & Compliance Team or contact your local Human Resources team.