ETHICS

I. STATEMENT ON ETHICAL STANDARDS
Mabuhay Vinyl Corporation adheres to the highest ideals of ethics in conducting its business. To this end, the company and its employees shall ensure commitment through words and deeds, to conform to the basic tenets of service, integrity, teamwork, excellence and social responsibility consistent with the value of Godcenteredness.

II. INTRODUCTION
Mabuhay ´s long years of operations is grounded in maintaining high ethical standards in the conduct of its business. It has published a Code of Business Conduct that summarizes its Ethical Principles and Core Values. This Code describes acceptable behaviors and how it treats its customers, its employees, and all the company's stakeholders (suppliers, government, etc.) The company expects its employees to support a work environment that fosters respect, fairness and integrity, the ultimate objective of which is to preserve is untarnished reputation as a reliable and ethical company. Every MVC employee is expected to faithfully comply with and perform his jobs and tasks. He/she shall not allow himself/herself to be placed in a situation that will cast doubt upon his/her company loyalty or invite any opportunity to compromise his/her fidelity. Utmost dedication and zeal in work performance and execution are highly expected.

III. ETHICAL STANDARDS FOR SPECIFIC RELATIONAL DOMAINS (PARTIAL LIST)

A. CUSTOMERS
MVC shall at all times, seek to attain customer satisfaction and loyalty by delivering only quality products and services, stressing value and safety to the user while affirming the company's reliability. To enhance and maintain customer confidence, an MVC employee is expected to attend to customers, in ethical behavior and with utmost competency knowing that the customers are the reason for the company's existence.

B. SHAREHOLDERS

• C. CODE OF ETHICSINTRODUCTIONAs a good corporate citizen. shareholders. rather. employees.permanent or temporary and receiving compensation regardless of amount. negative publicity and similar unfair practices aimed at securing undue advantage over its competitors.COVERAGEThese Rules shall cover all Executives.The following statement of business principles has been prepared to guide the futureconduct of company activities in an ethical and legal manner. MVC shall never resort to fraud or machinations in order to overvalue or undervalue the company's worth. It shall not resort to blackmail. Staff and employees of FilEstate.employed. it is an effort to reiterate the continuingpolicies of the corporation on ethical business behavior. and the communities in which its branches andprojects are located. which must be observed by allFil-Estate employees and representatives throughout the world. The company'sreputation for unquestionable integrity is its most valuable asset in its relationships withits customers.VISIONFil-Estate shall be recognized as:The leader in the real estate industry for . Officers. COMPETITORS MVC undertakes to promote and market its products by abiding by the rules of free competition and fair play. It is not intended to supplyanswers for every business activity. shareholders deserve no less than fair and full disclosure of information on the company's operations and finances. Fil-Estate (the Company) has always endeavored to conductits business in a manner conforming to the highest ethical standards. Transparency shall forever be espoused. It is essential that allemployees and representative conform to these principles as they perform their activitieson behalf of Fil-Estate.Being the very source of MVC´s lifeblood.

Providing our customers the best value for their money. Customer satisfactions shall be the rule at all times. innovation and superiorcustomer satisfaction. Affording our employees with opportunity for career advancement and personalgrowth. excellent performance.Be Customer Focused — placing premium value in knowing the needs andrequirements of our customers and doing what is necessary to meet and exceedtheir expectations. we— the Executive Committee. Every member ofFil-estae shall be involved in the continuous improvement of processes.Recognized.An active partner in nation building. In active pursuit of this commitment.product quality. Officers. Ourcustomers shall equate Fil-etate with quality.Ensuring that our investors and shareholders get a reasonable return for theirinvestments. reliabilityand service. Innovation and Customer Satisfaction. Managers and Staff of Fil-Estate shall at all times:Be Quality Driven — ensuring that every Fil-Estate product and service thatreaches our customers will bear our distinct mark of Excellence.Creating and marketing real estate products and services of superior quality anddesign. andA committed citizen for world ecological balanceMISSIONFilEstate provide high quality products and services for the total delight and satisfactionof customers by:Conducting our business with the highest standards of professionalism andintegrity. . leading to the improvement of their quality of life.Providing our salesmen unlimited opportunity for career advancement andpersonal growth.Supporting an optimum environment for planet Earth.QUALITY POLICYFil-Estate is committed to be the recognized leader in real estate industry for ProductQuality. and responsiveness to every related need and expectation. improvement in theirquality of life. systemand procedures for the satisfaction of our customers.

With this in mind.Fil-Estate and the CommunityThe corporation shall conduct its business in a manner that is socially responsible. Quality shall be important criterion forindividual and team performance measurement. it is the intent of Fil-Estate to:Choose its employees on the basis of their ability to perform the work for whichthey are hired without regard to race. sex. and it is a Fil-Estate policy to treat themfairly in all matters and to pay them competitively. age. sex. experience. or otherfactors requiring affirmative actionOffer employees a safe. national. or other factorsrequiring affirmative action. The corporation requires continuous management attentionat all corporate levels to assure compliance with the spirit and letter of this policy.Fil-Estate and its EmployeesEmployees are the corporation's greatest asset. age. Management shall ensure an environment where the pursuit ofquality is a fulfilling as well as a never-ending process. national origin.Support and Reward team and individual efforts that are contributoryto the fulfillment of the Corporate Vision and Mission. and the attainment of TotalQuality Management objectives.within the boundaries of current standards. Inaddition to developing .Pursue Quality as a mean to Corporate Viability and Profitability —knowing very well that only Quality will differentiate the Corporation from therest and guarantee it's competitive edge and leadership in the real estate industry. andtraining without regard to race. promotion and career movement. origin. and clean work environmentOffer work that challenges the employees and gives them a feeling of satisfactionPay employees fairly in relation to their contributions to the company's efforts.Towards this end. religion. religion. healthy. Fil-Estate and its subsidiaries areengaged in a program of full compliance with all national and local laws applicable tohiring and promoting people on the basis of demonstrated ability.

expect that employeeswith significant responsibilities will have a general knowledge of prohibited activitiesinvolved in their work and will seek guidance on any . social. character . and culture.There is an obligation. The company does.and selling real estate products.FilEstate and the LawIt is the policy of Fil-Estate to comply with all valid laws and regulations that govern itsoperations in the various cities and municipalities in which it operates and conduct itsaffairs in keeping with the highest moral. however. and to participate in its activities as a concerned andresponsible citizen. or volunteerorganizations can be public service of a higher order. education.FilEstate and its CustomersThe corporation shall endeavor to provide its customers with quality real estate productsand services and sold at a fair price. both corporate and individual. and ethical standards. it benefits from such activities as health. Like individual citizens. It is not expected that every employee will have full knowledge of the lawsaffecting his or her responsibilities. and all Fil-Estate employees areencourage to participate in public activities of their individual choice. it has theresponsibility to support and develop these social and civic activities. Fil-Estate real estate products will be developed tothe company's superior quality standards and design providing our customers the bestvalue for their money. to fulfill the intent of the abovestatement.Each of the corporation's offices is expected to make every effort to be an integral part ofthe community in which it operates.welfare.building. it shall protect the quality of theenvironment and endeavor to conserve energy and other valuable resources.The company recognizes that employee participation in cultural. And like individuals. improvement in their quality of life and responsiveness to everyrelated need and expectation. legal.

matter on which there is a question.Employees must not engage in sexual harassment. gifts.Gifts. fighting. or appear to influence.Relationship with Clients and SuppliersEmployees should avoid investing in or acquiring a financial interest for their ownaccounts in any business organization that has a contractual relationship with theCompany. in any wayinfluence. by using inappropriate language. or that provides goods or services or both to the Company.Conflict of InterestFil-Estate expects that employees will perform their duties conscientiously. gambling. honestly. Entertainment and FavorsEmployees must not accept entertainment. Employees must not use theirposition or the knowledge gained as a result of their position for private or personaladvantage. General Employee ConductFil-Estate expects its employees to conduct themselves in a businesslike manner. andin accordance with the best interests of the company. for example. are presently pursuing. swearing. or conduct themselves in a way thatcould be construed as such. or are contemplating pursuing may involvethem in a conflict of interest with their employers. Regardless of the circumstances. they should immediately communicateall the fact to their superior. if employees sense that a course of actionthey have pursued. keeping orposting inappropriate materials in their work area. if such investmentor interest could influence or create the impression of influencing their decisions in theperformance of their duties on behalf of the Company. and similar unprofessional activities are strictlyprohibited while on the job. or .either directly from the corporation's legal department or through their supervisors. or personal favors that could. or accessing inappropriate materials ontheir computer. business decisions in favor of any person ororganization with whom or with which the Company has.Drinking.

Similarly. Any breach of this rule will result inimmediate termination and prosecution to the fullest extent of the law. The . that individual must use good judgment on theCompany's behalf to ensure that good value is received for every expenditure.Company funds and all other assets of Fil-Estate are for the Company's purposes onlyand not for personal benefit. and protecting money as detailed in the Company'sinstructional manuals or other explanatory materials. or both. the Company strictly prohibits the acceptance of kickbacks andsecret commissions from suppliers or others. This includes the personal use of organizational assets suchas computers. they should immediately advise their superior or theInternal Audit department so that the Company can promptly investigate further.Organizational Records and CommunicationsAccurate and reliable records of any kinds are necessary to meet the Company's legal andfinancial obligations and to manage the affairs of the Company. handling.Kickbacks and Secret CommissionRegarding the Company's business activities. Organization funds and Other AssetsEmployees who have access to Company funds in any form must follow the prescribedprocedures for recording. except as authorized under the Company's remunerationpolicies. If employees become aware of anyevidence 'of fraud and dishonesty.is likely to have. or beperceived to. employees may not receive payment orcompensation of any kind. The Company imposesstrict standards to prevent fraud and dishonesty. employees must not accept any other preferential treatment under thesecircumstances because their position with the Company might be inclined to. place them under obligation. In particular. businessdealings.When an employee's position requires spending Company funds or incurring anyreimbursable personal expenses.

or government body. and equipment forpersonal or political matters. attendance. or any outside individual. production.Company's booksand records must reflect in an accurate and timely manner all business transactions.Privacy and ConfidentialityWhen handling . and timely communications — responding promptly and courteously to allproper requests for information and to all complaints.When communicating publicly on matters that involve Organization business. suppliers. employeesmust not presume to speak for the Organization on any topic.Employees must not make or engage in any false record or communication of any kind. liabilities. Theemployees responsible for accounting and record keeping must fully disclose and recordall assets. or similar reports and statementsFalse advertising.Prompt CommunicationsIn all matters relevant to customers. and it is the Company's desire thatsuch views be publicly disseminated. all employees must make every effort to achieve complete. employeesmust take care not to compromise the integrity or damage the reputation of either theCompany. government authorities. unless they are certain thatthe views they express are those of the Company. including public officials. including but not limited to:False expense. or both.accurate. supplies. or other misleadingrepresentationsDealing with Outside People and OrganizationsEmployees must take care to separate their personal roles from their Organizationpositions when communicating on matters not involving Company business. deceptive marketing practices. business.whether internal or external. and must exercise diligence in enforcing these requirements. the public andothers in the Company. Employeesmust not use organization's identification. financial. stationery. When dealing with anyone outside the Company.

unless legalprocess or contractual obligation provides otherwise. and retain only the personal information necessary for theCompany's business. Retain information only for as long as necessary or as required by law. Collect. 2003 Code of Ethics . obtain any relevant information directlyfrom the person's concerned. Protect thephysical security of this information.2. Whenever possible. use.3. AMENDMENTThe Management of Fil-Estate may amend or modify these rules as may be necessary._______________________________Chief Executive Officer_______________________________Chairman of the BoardJuly 07. observe the following principles:1.EFFECTIVITYThese Rules shall take effect effective days following the completion of the publicationin the Company's official newsletter or as may be announced by the management of FilEstate. Obtain the consent of the personconcerned before externally disclosing any personal information. Use only personal information for thepurposes for which it was originally obtained. Use only reputable and reliable sources tosupplement this information.financial and personal information about customers or others with whomthe Company has dealings. Limit internal access to personal information to those with a legitimate businessreason for seeking that information.

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