Everest CODC Effective Jan 2, 2022

PROCEDURE MANUAL
THE CODE OF DISCIPLINARY CONDUCT Revision No. 1
Original Release Date : Effective Date:

SUBSECTION: HUMAN RESOURCES POLICIES
Introduction
At Everest Trading, we succeed when we all work together toward the same goals. Our culture is
based on the shared commitment to the core Everest Trading values of unparalleled client
satisfaction, teamwork, respect for the individual, developing people, diversity, shareholders’ trust,
corporate citizenship and integrity. By adhering to these values, we believe success can be
achieved both for Everest Trading as a whole, and for our employees. In furtherance of those
values and as part of the Everest Trading team, you are expected to work and behave in a
professional manner that maintains harmony within the workplace and promotes a pleasant work
environment. As part of the Everest Trading team, our expectation is that you come to work on
time, contribute to the best of your abilities and follow work rules, policies and procedures.
We recognize that issues and conflicts can arise in the workplace and when such issues arise,
Everest Trading encourages dialogue, coaching and mentoring to resolve such issues. However,
we also recognize that in some situations informal coaching and resolution may not be possible and
more significant corrective action and discipline may be required to address more serious
infractions or acts of misconduct in the workplace. The purpose of this Code is to more detail our
expectations around employee conduct and behavior and to explain the process for corrective
action and the possible disciplinary consequences should expectations not be met. The goal is not
punishment so much as it is to correct situations and ensure that certain conduct is not repeated.
Our corrective action process shall focus on rectifying the problem rather than punishing the
offender. We will fully discipline yet shall preserve the dignity and self-respect of the employee,
even as we aim to achieve positive change in the offender’s behavior and performance. Our
corrective action process shall be carried out in accordance with due process, even when the
offense is so grave that it merits outright dismissal.
It is the duty of the employee to familiarize him or herself with this Code and to understand all
applicable rules and policies associated with this Code. It is also important to note that while this
Code is specifically directed at employee discipline within the Philippines, all employees are also
bound by the Everest Trading Global Code of Business Conduct which broadly covers
professionalism, ethics and conduct globally.
EMPLOYEE DISCIPLINE AND CORRECTIVE ACTION AT EVEREST TRADING
Maintenance of discipline is primarily a function of the immediate supervisor. The immediate

supervisor is responsible in instilling a healthy and harmonious working environment that
encourages and maintains a high level of self-discipline. On any minor infraction, he or she shall
exert best effort to obtain a problem-solving approach together with the employee. However, in
certain instances, major infractions of company procedures, rules and regulations are committed
that would warrant the imposition of graver corrective action. In such situation, the following
guidelines should be followed in implementing disciplinary action:
I. Preparation and Service of the Show Cause Notice II.

Disciplinary Conference
III. Preparation and Service of the Notice of Decision
IV. Schedule of Penalties
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Definition of Terms
Code – The Everest Trading Code of Disciplinary Conduct
Company – Everest Trading
Employee – person of any rank, whether regular, casual, probationary, project, seasonal or
contractual, who receives wages/salaries and benefits from Everest Trading. An employee remains
to be one even after having submitted his/her resignation but prior to the same being effective as
provided for in the employment contract and/or existing policies.
Customer – person who buys our goods or rent our machine or services
Company Premises – Everest Trading owned and/or leased offices or grounds, including service
vehicles. It also includes venues rented for official company conferences, meetings, seminars,
outings, parties or gatherings attended by employees for the duration of the activity. Buildings that
house Everest Trading offices, for purpose of this Code, shall be considered part of company
premises.
Company Property – Everest Trading leased and/or owned equipment, furniture, supplies,
documents, intellectual property and money.
Company Time – period of time the employee is required or is deemed to be rendering work for
the company, including the period or time allocated for Company events.
Show Cause Notice – a written statement informing an employee of alleged violations he is being
charged with. This is the first notice of the twin notice rule required by law and may come in the
form of Disciplinary Action Form (DAF)
Notice of Decision – a written notice informing the employee of the result of the investigation of
the allegation/s that was/were charged against him. This may also come in the form of a
Resolution.
Prescription Period – the period in which a Disciplinary Action (DA) has been served up to the
time it is considered cleansed. Reckoning date for the prescription period begins on the date the DA
was served. Any repetition of the same before the end of the prescription period shall progress to
the next level of DA.
Summary of the Disciplinary Process- The disciplinary process includes the following steps:
I. Preparation and Service of the Show Cause Notice - If there are reasonable
grounds to believe an infraction has occurred which necessitates discipline, a
written show cause notice will be issued and the employee will be given the
opportunity to respond to the notice.
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II. Disciplinary Conference - In certain cases, a Disciplinary Conference will be

scheduled and a committee will review the notice and the relevant facts, and make
a determination as far as appropriate discipline.
III. Preparation and Service of the Notice of Decision - Upon evaluating the facts
of the case and other relevant information, a decision will be issued and the
decision will be shared with the employee. Depending on the facts and
circumstances, an appropriate level of discipline will be issued. These levels of
discipline include written warning, final written warning and dismissal. While
Everest Trading favors progressive discipline where appropriate, it also recognizes
that in some cases progressive discipline may not be appropriate and it may be
necessary to move directly to a specific level of discipline in light of the nature of
the offense and the facts and circumstances surrounding the matter. All decisions
are treated as sensitive personal information under privacy rules and shall not be
processed (i.e., shared, used, etc.) unless the processing is compliant with the
aforesaid privacy rules.
I. Preparation and Service of the Show Cause Notice
A. The Investigating Officer
The immediate supervisor of an erring employee acts as the investigating officer.
B. Procedure and Guidelines
1. When the employee commits an alleged infraction or a written complaint is filed against an
employee, the immediate supervisor must conduct a pre-investigation by gathering
pertinent documents and evidence within 48 hours after the supervisor has knowledge of
the offense.
2. If upon completion of pertinent documents, there is reasonable ground to believe that the
Employee might have committed an offense, the immediate supervisor must serve the
employee a written Show Cause Notice preferably within 48 hours from the time the
employee commits an alleged infraction or from receipt of a written complaint or date of
discovery of the infraction. The Show Cause Notice must be reviewed by HR Operations
prior to issuance to ensure correct application of the policies.
3. Show Cause Notices shall be signed off by the following:
a. Immediate Supervisor
b. Manager/Sr. Manager
c. Site HR
4. If the employee is transferred to a new immediate supervisor after the commission or the
discovery of the offense, either former or new supervisor may sign the Show Cause Notice.
5. The Show Cause Notice may be served through the use of the Disciplinary Action Form
(DAF).
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6. The Show Cause Notice should contain the specific causes or grounds for termination
against the Employee as well as a detailed narration of the facts and circumstances that
will serve as basis for the charges. The notice should also specifically mention which
company rules are violated and/or which among the grounds under Article 297* of the
Labor Code is being charged against the Employee. Finally, the notice should also require
the employee to submit a written explanation within:
• Five (5) calendar days upon receipt if allegations are terminable.

• Forty eight (48) hours if allegations are not terminable.
If at any time after the service of the Show Cause Notice and before the service of the
Notice of Decision is given to the employee, there is a need to change the ground/s for
termination, a new Show Cause Notice shall be served and the Employee shall be given all
the chances to explain as with the original Show Cause Notice.
7. The immediate supervisor is required to issue the Show Cause Notice personally. The
immediate supervisor shall ensure that the Employee acknowledges receipt of the Show
Cause Notice by signing the same. If the Employee refuses to sign, the immediate
supervisor should get two (2) witnesses to sign and confirm serving of the Show Cause
Notice to the Employee.
If the employee does not report to work and personal service is not possible, the Show
Cause Notice is sent via registered mail and/or courier service to his/her last known
address based on HR’s records. In such cases HR Operations shall retain a copy of the
registry return card and/or other proofs of service.
Copies must be furnished to HR and the next immediate level supervisor, stating the specific acts
or omissions constituting the offense as well as the date, time and place of investigation, if any.
* Just Causes under Article 297 (formerly numbered as Article 282) of the Labor Code:
 Serious Misconduct and Willful disobedience by the employee of the lawful orders of
his employer or representative in connection with his work;
 Gross and Habitual Neglect by the employee of his duties;
 Fraud or willful breach by the employee of the trust reposed in him by his employer
or duly authorized representative;
 Commission of a Crime or offense by the employee against the person of his
employer or any of immediate member of his family or his duly authorized
representative; and
 Other analogous causes to the foregoing.
II. Disciplinary Conference
A. When to Conduct a Disciplinary Conference
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1. Cases that involve offenses that are classified as grave or terminable are automatically
scheduled for disciplinary conference.
2. For offenses classified as serious and less serious, the need for a disciplinary conference
shall be decided upon by the Investigating Officer and HR Operations on a case to case
basis.
B. The Investigation Committee
In cases where a disciplinary conference is deemed necessary, the Investigating Officer shall refer
the case to site HR Operations. The latter will be responsible for convening an investigation
committee composed of the HR Manager or his representative, the program/department Manager
and the investigating officer/immediate supervisor (the “Investigation Committee”). Other officers
from different functional units, such as Network Services, Facilities and Finance, may be asked to
join the committee, if necessary. The Site Director has the option to be a part of the Investigation
Committee and/or designate a representative to act on his behalf. The Company reserves the
right to change the composition of the Investigation Committee, as it may deem fit and
necessary.
During investigation, the following guidelines shall apply:
1. The disciplinary conference is a fact-finding process intended to gather relevant case

information.
2. The members of the Investigation Committee may ask any question that they deem
relevant to the case.
3. The Employee should be informed that he or she has the right to bring one representative
to act as counsel during the investigation. Counsel’s role is to advise the Employee of his or
her statutory rights and duties. The disciplinary conference is merely factual and non-
technical in character, thus rules of court shall not apply during the investigation.
Exception:
To ensure neutrality, no immediate supervisor/manager may act as investigating officer in

instances where there exists a conflict of interest for the immediate supervisor/manager,
including but not limited to, direct involvement in the case, close relation to the Employee
under investigation which shall mean, among others, being related up to the 4 th degree of
consanguinity and/or affinity, or romantic involvement with the employee, etc.. In such
circumstances, the next level supervisor shall act as investigating officer.
4. The Investigation Committee may allow the Employee to present witnesses and pertinent
reports and documents. After the testimony of each witness, the Investigation Committee
may ask further questions.
5. Failure or refusal to submit a written explanation, and/or to answer questions during
investigation and present witnesses, if any, shall be deemed a waiver of the employee’s
right to submit evidence on his behalf.
6. The Investigation Committee shall exert its best efforts to resolve the case within a period
of thirty (30) calendar days including serving the Notice of Decision, unless the attendant
circumstances or complexities of the case require a longer period to do so.
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C. Preventive Suspension
An employee whose alleged violation is the subject of an investigation may be placed under
preventive suspension the moment that his/her continued presence is determined to pose a serious
and imminent threat or danger to the life and/or property of the Company or of his co-employees.
The alleged violations which may be considered as grounds for preventive suspension include but
are not limited to the following:
1. Theft
2. Fraud or falsification
3. Insubordination
4. Sexual harassment or other forms of harassment;
5. Meaningful or real disruption in the productive or orderly operations of the company;
6. Significant or real loss and damage to company resources and property arising from gross
neglect of one’s duty;
7. Imminent threat to the life or property of the company or co-employees;
8. Other offenses determined directly by the Company or through coordination with clients/
customers and wherein an impartial and complete investigation can only be done without
the employee being in the workplace to potentially influence or alter the investigation e.g.
conceal/destroy evidence, intimidate/threaten witnesses.
Preventive suspension may only be facilitated upon consultation with and concurrence of HR
Operations.
During this time the ID, access pass and codes of the Employee will be disabled, and the Employee
cannot enter the Company premises without the consent and approval of the Operation Manager
and/or HR Operations.
The preventive suspension shall be without pay for a maximum period of thirty (30) calendar
days. However, the Investigation Committee should exert all means necessary to expedite the case
in less than thirty (30) days and come up with an appropriate decision for the benefit of all parties
concerned. If the employee is found innocent of the offense, the salary and other monetary
benefits, (i.e. allowances and bonuses, etc.) during the period of preventive suspension shall be
paid in full to the Employee. The 30-day preventive suspension may be extended provided that the
Employee’s salary and benefits are paid during such extended period. Should the employee be
found guilty of the charge/s, even though he or she is given a penalty lower than dismissal, the
unpaid days as a result of the preventive suspension shall not be reimbursed provided that the
Investigation Committee specifically states in the Notice of Decision that the preventive suspension
was justified and was with sufficient basis regardless of the final penalty meted out to the
Employee.
III. Preparation and Service of the Notice of Decision
A. Imposition of Appropriate Disciplinary Action
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The Company has the inherent right to control and manage its business effectively, including the
implementation of its rules and policies. Consequently, notwithstanding the provisions of this Code
which may be to the contrary, the Company has the prerogative to impose sanctions that it may
deem appropriate in each case, depending on the attendant circumstances.
To determine the appropriate disciplinary sanction, the supervisor/manager and/or Investigation

Committee shall, in consultation with HR Operations, do the following:
1. Evaluate facts of the case and other relevant information to establish mitigating and
aggravating circumstances.
2. Apply disciplinary action according to the table of violations and disciplinary actions. The
disciplinary actions in the table are the maximum prescribed. The application or
consideration of any mitigating and aggravating circumstances in any particular case shall
be upon consultation and coordination with HR Operations. Aggravating/ Mitigating
circumstances shall be applied on exceptional instances only.
AGGRAVATING CIRCUMSTANCES are those that tend to increase the

seriousness/gravity of the offense and merit increasing disciplinary actions depending on
the nature of the offense.
MITIGATING CIRCUMSTANCES are those that tend to lessen the seriousness/gravity of

the offense and merit decreasing disciplinary actions depending on the nature of the
offense.
3. If the disciplinary action is Dismissal, refer the case to HR Operations for evaluation prior
to implementation. Decision must also be discussed with the Program or Unit Head,
depending on employee level or position. If the decision is for Disciplinary Action other than
dismissal, discussion with the next level of management prior to implementation will
suffice.
B. Procedure and Guidelines in Implementing Disciplinary Action
1. Upon receipt of the Employee’s written explanation or the lapse of time given to the
Employee to explain, and the termination of the disciplinary conference, if any, and final
determination of the disciplinary case by the investigating officer or the Investigation
Committee, the immediate supervisor or HR Operations (in case of Dismissal) shall prepare
and issue the Notice of Decision, indicating charge against the Employee, the facts and
circumstances, disciplinary action and the basis of the decision after considering the
written explanation, disciplinary conference, records of the case and the evidence available,
if any.
2. For dismissal, after due deliberation by the investigation committee, HR Operations, shall
prepare the written Notice of Decision, indicating the penalty of dismissal, to the employee
and secure the signoff of the committee members.
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3. The immediate supervisor or HR Operations, as the case may be, is required to issue the
Notice of Decision personally to the Employee. The immediate supervisor or HR Operations
shall ensure that the Employee acknowledges receipt of the Notice of Decision by signing
the same. If the employee refuses to sign, the immediate supervisor should get two (2)
witnesses to witness the serving of the form. The copy of the signed Notice of Decision
should be retained by HR Operations and filed in the employee’s 201 File.
If the Employee does not report to work and personal service is not possible, the Notice of
Decision is sent via registered mail and/or courier service to his/her last known address
based on HR’s records. In such cases, HR Operations shall retain a copy of the registry
return card and/or other proofs of service.
For cases that involve damage or loss of company property, the decision to implement
restitution or reparation for damage caused shall be included in the decision notice.
Restitution and/or reparation cannot be implemented after the case has been closed.In
addition to the appropriate penalties and consistent with the other policies and procedures
of Everest Trading and its clients, any damage to, or penalty imposed on Everest Trading,
resulting from the acts of the offender, shall be charged to the offender.
4. The Notice of Decision shall be signed off by the following:
a. Immediate Supervisor
b. Manager/Sr. Manager
c. Site HR
5. In implementing the disciplinary action, the employee’s 201 file must at all times be
furnished with a copy of the decision as well as all documents related to the employee’s
case.
6. To ensure that the objective of the disciplinary action is met, the HR representative should
implement the disciplinary action immediately after the decision has been reached.
7. In all cases involving disciplinary action, the dignity of the employee must be upheld, and
the employee must be accorded fair and humane treatment.
C. Finality of Decision and Appeal
1. The Decision of the committee is final and immediately executory. However, in cases of
Dismissal, the employee may seek reconsideration on the decision within three (3) days
from receipt thereof, through a formal written letter addressed to the HR Director.
2. Requests to file a reconsideration or an appeal to defer the implementation of a decision or

to move its reconsideration may be filed within three (3) days from the receipt of the
decision. Appeals, reconsiderations or deferment of implementation of the decision may be
entertained based on any of the following conditions:
• to present new evidence;

• abuse of discretion in rendering the decision/ absence of due process; or,
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• questions on the interpretation of the provision of the Code of Disciplinary Conduct

or of provisions of the Labor Code
3. The review of the case will be discretionary and shall take into consideration all relevant
and pertinent documents submitted.
4. Unless otherwise suspended by the HR Director, as the case may be, the decision of the
investigation committee shall be valid and executory pending the appeal. The Director
concerned should decide the case, in writing, within three (3) days upon submission of the
written appeal.
IV. Table of Signatories
Table of Signatories
Immediate Manager/Sr. Site

Supervisor Manager HR
Show Cause Yes Yes Yes
Show Cause with Yes Yes Yes
Preventive Suspension
Written Warning Yes Yes Yes
Final Written Warning Yes Yes Yes
Dismissal Yes Yes Yes
V. SCHEDULE OF PENALTIES
A. Written Warning
A notice in writing to the employee that a violation of the Code of Disciplinary Conduct has been
established, with the admonition that a repetition of the same of offense within the prescriptive
period will lead to a higher penalty.
B. Final Written Warning
A Final Notice in writing to the employee that a violation of the Code of Disciplinary Conduct has
been established, with the admonition that a repetition of the same offense within the prescriptive
period will lead to dismissal.
C. Dismissal
A dismissal results to termination of employment for a just cause. A dismissed employee forfeits his
benefits and privileges without prejudice to any appropriate legal action the company may take
against him.
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D. Restitution or Reparation of Damage Caused
In addition to the appropriate penalty in cases involving loss of, or damage to company property,
or in any other cases resulting to a damage and/or penalty being imposed on Everest Trading, the
offender will be required to replace or pay for the property lost or damaged, pay the damage or
penalty imposed on Everest Trading, as the case maybe. The damage, loss or penalty must be
made part of the decision.
E. Civil and/or Criminal Liability
Imposition of any of the above-mentioned penalties shall be without prejudice to any civil or
criminal action that the aggrieved party or the company may take against the offender either prior
to, simultaneous with, or subsequent to the administrative investigation.
VI. CORPORATE SECURITY CASES
As a matter of Policy, Everest Trading Corporate Security shall be informed and will take
the lead in investigating cases that involve the following:
A. Internal and External Fraud

B. Internal and External Theft
C. Unethical Business Conduct
SCHEDULE OF DISCIPLINARY ACTION WITH PENALTIES
This Code of Disciplinary Conduct is not all inclusive. Offenses not included in the Code shall
be decided on a case-by-case basis. There may likewise be other acts or omissions not
explicitly contained herein but which are clearly prejudicial to the welfare or interest of
the Company. The company reserves the right to consider these punishable and to
impose appropriate sanctions as warranted by the circumstances of each case.
PENALTIES
WW - Written Warning
FWW - Final Written Warning
D - Dismissal
The company likewise reserves its right to impose stiffer sanctions than what the code
provides depending on the gravity or seriousness of the offense.
CLASSIFICATION OF OFFENSES
A. Less Serious - 1st offense would warrant a Written Warning in the schedule of disciplinary
action
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B. Serious – 1st offense would warrant Final Written Warning in the schedule of disciplinary
action
C. Grave – 1st offense would warrant Dismissal in the schedule of disciplinary action
CLEARING PERIOD OF OFFENSES
All offenses shall have a prescription period of one (1) year.
Any repetition of the same offense within the indicated prescriptive period shall merit the next level
of penalty as prescribed in the Schedule of Penalties per infraction. Offenses are considered
cleansed if there are no similar offenses committed within the indicated prescriptive period.
However, any other offense committed within the period shall give rise to a fresh clearing period.
However, the past infractions will still form part of the employee’s records and may be considered
in all other disciplinary action cases of the said employee as the Company shall be guided by the
totality of the employee’s infractions in issuing a disciplinary action.
IMPACT ON REGULARIZATION
1. Employees who have been given a final written warning shall not be eligible for
regularization for failure to meet performance standards.
IMPACT ON EMPLOYEE PROMOTION

2. Employees who have been given a Written warning shall not be eligible for promotion for
a period of six (6) months from the date the disciplinary action (DA) was served.
3. Employees who have been given a final written warning shall not be eligible for promotion
for a period twelve (12) months from the date the DA was served.
1st 2nd 3rd

Offense Offense Offense
A. TIMEKEEPING INFRACTIONS – Honest and accurate timekeeping is essential to our
business. Violations of our timekeeping and ID/Badge processes and policies will result in
appropriate disciplinary action.
It is essential that employees maintain a good attendance record and refrain from incurring
absence/tardiness that disrupts work continuity and productivity.
- The existing Attendance and Punctuality policies will apply to all employees including regular,
probationary, project and seasonal employees of all PH Everest Trading Companies. -
Employees shall refer to these policies when it comes to the implementation of their
Disciplinary Action (DA) process and the progression of Disciplinary Actions related to all
Attendance and Punctuality cases.
IN ADDITION TO THE APPROPRIATE PENALTY UNDER THIS SECTION AND CONSISTENT WITH
THE OTHER POLICIES AND PROCEDURES OF EVEREST TRADING AND ITS CLIENTS, ANY
DAMAGE TO, OR PENALTY IMPOSED ON EVEREST TRADING, RESULTING FROM THE ACTS OF
THE OFFENDER, SHALL BE CHARGED TO THE OFFENDER.
1. Failure to log-in or log-out in the official timekeeping WW FWW D

system for 3 times in a payroll period
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2. Allowing another to use his/her ID card or using another D

employee’s ID card.
3. Logging-in or logging-out for another employee or allowing D
another employee to log-in or log-out for him/her, regardless
of the time, place and circumstances.
4. Falsifying or tampering time cards or any other time D
keeping records or drawing salary/allowance by virtue of
falsified time records.
5. Loitering, leaving work station and /or company premises WW FWW D

within current shift without authorization including coming in
late after scheduled break period.
B. OFFICE PROTOCOL AND DECORUM – Respect for our co-workers, customers and clients is
essential. Everest Trading expects employees to act in a professional manner, consistent with
our core values at all times. Violations of our standards of conduct, applicable policies
concerning conduct and professionalism, and any actions which include, but are not limited to, a
lack of professionalism, inappropriate, harassing or offensive behavior, criminal behavior or
conviction, or threats or acts of violence, will result in disciplinary action up to dismissal of
employment, depending on the severity of the act or conduct and the underlying facts.
1. Violation of the dress code policy. WW FWW D
2. Engaging in or inducing disorderly conduct in the workplace WW FWW D
that may disrupt the operations of the company or create
annoyance to another employee.
3. Maligning, making discriminatory remarks, uttering obscene D

and offensive remarks, whether written or verbal, displaying
disrespectful/inappropriate behavior, fomenting distrust and
discontent, rumor mongering and/or intriguing against the
company, another employee, clients, vendors and visitors.
4. Repeated inappropriate public displays of affection FWW D
5. Lewd and lascivious acts within company premises, D

indecent exposures.
6. Restraining, coercing, with threat or intimidation, another D
employee from testifying during administrative hearings.
7. All employees are prohibited to bring into any Everest D

Trading facility and/or official functions such as Christmas
party, etc. any weapon which is defined as any item that can
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inflict any degree of physical harm to another person. The

weapons that are contemplated include but shall by no means
be limited to the following: explosives; firearms including
those that do not fire lethal projectiles which include but not
limited to the following: airguns, airsoft guns, paintball guns,
dart guns, air riffles and/or any handheld or portable weapon
that is powered by spring air; stun gun and/or any taser
device; bladed weapons or instruments which include but not
limited to daggers, knives, butterfly knives (commonly known
as “balisong”); Swiss-army knives, katanas, and/or other
similar types of bladed instrument that is capable of being
used as a weapon; blunt or cleaving instruments such as but
not limited to ice picks, dart pins, clubs, eskrima sticks, sai, bo
staff, nunchakus, fighting fan; and other similar instruments
such as brass/wood knuckles, shuriken, chains, whips, etc. In
case of doubt, all employees must declare that he/she is
bringing in a specific item that may be characterized as a
weapon so that the Security Officer can assess the same.
8. Engaging in usurious activities, including but not limited to FWW D
lending money to employees with interest.
9. Drinking of alcoholic beverages during working time OR on FWW D
company premises whether during working time or not, OR
reporting for work intoxicated and/or under the influence of
alcohol.
10. Smoking in prohibited areas. (Dismissal if violation results FWW D
in fire, damaging company property or operation.)
11. Selling merchandises or anything of value during office WW FWW D
hours inside company premises that interferes with the dayto-
day tasks of the employee and/or other employees. (Note:
Exchange of merchandise may only be done outside company
premises)
12. Using fictitious name or using another employee’s name D

for the purpose of concealing an offense or evading
responsibility.
13. Unauthorized possession of and/or use of master key FWW D
which can open lockers, drawers, disks, cabinets, rooms or
offices.
14. Commission of acts which constitute a crime as defined in D

the Revised Penal Code and other laws, within the company
premises. This shall be subject to disciplinary action without
prejudice to any criminal prosecution and/or civil liability. If
employee is convicted, disciplinary action will be applied even if
it was not committed within company premises.
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15. Commission of any act, whether inside the company D

premises or not, that tends to cause damage or prejudice to
the company.
16. Gambling, betting, and conducting lotteries or other similar D

acts inside company premises.
17. Soliciting and collecting monetary contribution during WW FWW D
working hours and inside company premises.
18. Refusal to submit to reasonable inspection conducted WW FWW D
within the company premises by authorized security
personnel. The inspection includes but is not limited to
employee’s locker, drawer, computer and all other company
property and equipment assigned to the employee concerned,
and shall likewise include inspection of recordable devices that
are subject of the violation under I.21. of this Code. If the
refusal pertains to the inspection of recordable devices
brought in the production and/or training rooms, the penalty
shall be dismissal.
19. Performing any act pertaining to any person in authority in D
the company or any of its departments thereof, without being
officially entitled to.
20. Cheating customers or clients including but not limited to D
charging of excessive fees.
21. Fighting or quarreling during official company time or on D
company premises. Any other threats of violence or acts of
violence within the workplace and/or directed at other
employees, clients, customers or vendors.
22. Violation of the Policy on Gifts and Gratuities, including but D
not limited to the unauthorized solicitation of any items of
value from company suppliers, clients, customers, visitors for
any purpose; (refer to Policy)
23. Violation of the Procurement Policy and Procurement Up to Dismissal depending on
Process. the severity of the offense
24. Partiality in favor of a certain supplier, regardless of D

absence of damage to the company.
25. Failure to exercise fairness and ethical business D
relationships with clients, customers and suppliers.
All other acts of misconduct that cause or tend to cause damage or prejudice to the Company
shall be subject to disciplinary action depending upon the gravity of the offense committed.
*Due to the differences in the severity that each act may present based on evidence and merit,
the investigative committee shall exercise due diligence and discretion in assigning the nature of
sanction that would be proportionate to the acts that were committed.
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THE
OTHER POLICIES AND PROCEDURES OF EVEREST TRADING AND ITS CLIENTS, ANY DAMAGE TO,
OR PENALTY IMPOSED ON EVEREST TRADING, RESULTING FROM THE ACTS OF THE OFFENDER,
SHALL BE CHARGED TO THE OFFENDER.
C. NEGLECT OF DUTY - Employees are expected to perform their job functions and to follow
the work instructions of their management. Acts of Negligence and/or Gross Neglect of Duty
shall include but not limited to the following:
1. Omission to carry out or perform the duties, functions or assignment inherent to his position
or specifically given to the employee including any conduct of the employee not conforming to
the applicable standards of care committed during working time or on company premises tending
to cause or resulting in personal injury, or damage to property belonging to the Company or
third parties or otherwise causing expenses to be incurred by the Company. If warranted, the
offender may be meted with either disciplinary action or restitution of damage caused or both.
a. Simple neglect of duty which means the failure to give WW FWW D

proper attention to a task expected from an employee
resulting from either carelessness or indifference.
b. Neglect of duty which means the failure to observe FWW D

the degree of diligence demanded by the situation taking
into consideration the time, place, environment, among
others thereby exposing the company to unnecessary risk
or expenses.
c. Gross and habitual neglect of duty, or the repeated D

failure to exercise the standard of care that a reasonably
prudent person would have exercised in a similar situation
or acting or omitting to act in a situation where there is a
duty to act, not inadvertently but willfully and intentionally
with a conscious indifference to consequences insofar as
other persons may be affected thereby, causing or tending
to cause loss or damage to the Company or injury to
others. In the event of considerable resultant damage to
the company or to others, the gross neglect need not be
habitual to be accordingly sanctioned.
For employees who are measured against specific

performance targets and/or metrics, this provision includes
but not limited to habitual failure to meet the monthly
scorecards and/or any critical metric provided these are
discussed and documented in accordance with the
Performance Management Plan policy.
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d. Habitual failure in training standards in cases wherein D

an employee has been transferred in multiple programs
within a 1 year period (for regular employees)
2. Failure of a salaried employee to report for work on WW FWW D
designated time.
3. Sleeping during working hours. WW FWW D
4. Furnishing false, misleading or inaccurate data or D

information to persons duly authorized to receive the same,
arising out of the employee’s negligence or failure to discharge
his duty to make personal research, investigation or
verification, which acts causes prejudice to the Company.
5. Hiding, losing or misplacing records, instruments, papers, D
and documents of the company, which causes prejudice to the
Company.
6. Failure to liquidate cash advances within the required WW FWW D
period from the fulfillment of the activity or event for which
the cash advance was made. The penalty shall depend, among
others, on the amount involved.
7. Failure to observe prescribed standards of work, or to WW FWW D
fulfill reasonable work assignments due to inefficiency or pass
training while on regular employee status or failure to attain
work goals or standards, either by failing to complete the
same within the allotted reasonable period, or by producing
unsatisfactory results. This shall be without prejudice to
provisions of the policy on Performance Management Plan.
8. Failure to submit on time necessary documents and WW FWW D

update information pertaining to the employee, i.e. address,
telephone number, civil status as well as failure to complete
within specified time, pre-employment requirements, such as
submission of clearances, undergoing pre-employment medical
and drug tests, and other related requirements
9. Failure to file appropriate leave together with necessary WW FWW D
supporting documents within prescribed period.
10. Failure to undergo/complete/comply with the required FWW D

Security, Education, Training and Awareness (SETA) module,
including all mandatory trainings.
The penalty of dismissal shall be imposed depending on the gravity and severity of the offense
committed. All other acts of negligence that cause or tend to cause damage or prejudice to the
Company shall be subject to disciplinary action depending upon the gravity of the offense.
IN ADDITION TO THE APPROPRIATE PENALTY UNDER THIS SECTION AND OTHER POLICIES AND
PROCEDURES OF EVEREST TRADING AND ITS CLIENTS, ANY DAMAGE TO, OR PENALTY IMPOSED
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ON
EVEREST TRADING, RESULTING FROM THE ACTS OF OFFENDER SHALL BE THE CHARGED TO THE
OFFENDER.
D. FRAUD, DISHONESTY AND SIMILAR ACTS PREJUDICIAL TO COMPANY INTEREST -

Everest Trading places trust and confidence in its employees to act honestly and with integrity in
all their work and interactions with co-workers, clients and customers, in full compliance with its
Global Code of Conduct, applicable policies and its core company values.
1. Improper / non-accomplishment of reports documents WW FWW D
relative to the employee’s duties and responsibilities.
Provided that FALSIFICATION on the contents of the reports
and any form of FORGERY shall be penalized with DISMISSAL.
2. Manipulating any system, data and/or report to improve D

metrics, performance ratings, earn incentives and/or to avoid
work assignments.
3. Rendering services for another employer or personal WW FWW D
client, without the approval of the Manager.
4. Failure or refusal to cooperate or testify in Company D

investigations unless the employee himself is under
investigation and his testimony will infringe or violate his
constitutional right against self-incrimination for a criminal
offense.
5. Misappropriating, withholding funds or failure to account D
for or turn over to the company, immediately upon receipt
thereof, any goods or money, and/or property belonging to the
company, whether for personal gain or not.
6. Receiving bribes, “kickbacks” or clandestine profits in the D
course of a transaction in which he represents the company.
7. Concealing defective work, whether resulting in prejudice D

to the company or not.
8. Making and submitting false claims for reimbursements, D
false statements in employment records or other documents,
false testimony in Company investigations and/or any form of
forgery or falsification.
9. Using another employee’s login to access any system. D
10. Inappropriately using any customer data or account D
information including but not limited to billing information,
password, email information, or account history.
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11. Obtaining through fraudulent means materials, goods or D

services from the Company or any of its other assigned work
places.
12. Knowingly giving false or misleading information or D

documents to seek or qualify for any employment preference
or benefit from the Company.
13. Conniving with or inducing employees, supervisors, D
customers, competitors or third person to defraud or
otherwise prejudice the Company or to commit an offense
under the Company rules and regulations.
14. Attempted, frustrated or consummated theft or robbery of D
company property or property belonging to another person or
employee within company premises or, having found lost
property, shall fail to deliver the same immediately to the
guard on duty or immediate supervisor.
15. Obtaining loan/s using another employee’s identity without D
his consent.
16. Engaging in the same business activities that are of the D
same nature as the operations or business of the Company.
17. Borrowing money or merchandise from the D
customer/client.
18. Violation of any of the provisions of the Everest Trading D
Anti- Corruption Policy
19. Other forms of deceit, fraud, swindling and D
misrepresentation committed by an employee against the
company, its employees or representatives or its clients or
customers.
20. Failure to disclose any real or potential conflict of interest D
to appropriate management.
21. Cheating customers or clients including but not limited to D
charging of excessive fees.
22. Carrying out any fraudulent transaction using company D
computer or systems data whether in or outside of the
Company’s network
All other acts of dishonesty that are analogous to the foregoing and that cause or tend to cause
damage or prejudice to the Company shall be subject to disciplinary action depending upon the
gravity of the offense committed.
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E. HEALTH AND SANITATION - Everest Trading takes the health and safety of its employees
seriously. Everest Trading expects its employees to abide by all health and safety related
policies to ensure a safe and healthy working environment for all of its employees.
1. Failure and/or Refusal to submit to an annual physical WW FWW D

examination or treatment that may be prescribed by the RU
physician as follow-up to the results of the annual medical
check-up or secure medical clearance (if mandated by the
Manager)
If after failure to submit to an annual physical examination or
treatment required on a specific schedule , the employee is
given a new period to comply , the failure of such employee to
follow such directives within the prescribed new period shall
merit the next level penalty.
2. Refuses to receive treatment/medication prescribed by the FWW D
company physician for an illness or disease that is contagious
and which treatment/medication is to the best interest of the
employee or operations of the company.
The employee will be asked to go on sick leave for the

treatment needed. If the disease will need prolonged
treatment, the provision of the law will apply. Should the
employee refuse to comply with the instructions, the penalty
provided in this code will be applied.
3. Non-disclosure and/or concealment of disease/illness, D
which endangers the health, and/or safety of other
employees.
4. Refusal to submit and undergo drug-tests. FWW D
5. Failure to visit or call the clinic or attending physician while WW FWW D

under the attendance monitoring plan.
All other acts that cause or tend to cause damage or prejudice to the Company shall be subject
to disciplinary action depending upon the gravity of the offense committed.
THE
F. COMPANY FACILITIES AND PROPERTY – Use of company property, workstations, systems,

and company email and internet should be for official business use only. Employees must abide
by all applicable policies concerning company property, facilities, workstations and email and
internet use.
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1. Failure to prevent and/or report loss of company WW FWW D

property, spoilage, wastage of resources within 24 hours
resulting in loss to the Company. Either first and/or second
degree of penalty may be ignored depending on the gravity of
the offense.
2. Improper use and care of company property including WW FWW D
company facilities.
3. Use of company premises, equipment for illegal and D

unlawful transactions.
4. Unauthorized possession use or lending of company D

property or equipment or materials.
5. Violation of Facilities Guidelines, Safety Rules and WW FWW D
Regulation and/or general security practices posted by the
company, in the performance of work , during company
initiated activities and/or in the use of company facilities for
any purpose, unless the violation involves a more specific
offense.
6. Unauthorized removal of company property. FWW D
7. Contributing to causing poor sanitary conditions/poor WW FWW D

housekeeping/littering within Company Premises
8. Possessing unnecessary personal belongings (e.g. WW FWW D
handbags, grooming kits ) in prohibited/restricted areas
9. Failure of host employee to escort visitors or special services WW FWW D
personnel (where applicable) or failure to sign in
guests/visitors before entering company premises.
10. Failure to observe CLEAN DESK POLICY WW FWW D
11. Intentionally obstructing pathways and hallways, fire exits D
or fire cabinets, thus posing hazard to employees.
12. Bringing or using in and/or storing E-Cigarettes inside the D
store, production area, training rooms or other unauthorized
areas.
All other acts amounting to unauthorized, illegal, improper, and negligent use of company
property that cause or tend to cause damage or prejudice to the Company shall be subject to
disciplinary action depending upon the gravity of the offense committed.
THE
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G. INSUBORDINATION - All company rules and regulations should be followed by employees.

Any direct and lawful order given by a supervisor relating to work assignment must be promptly
obeyed. The following acts, though not exclusive, are deemed to be acts of insubordination:
1. Serious misconduct or the willful transgression of some D

established and definite rule of conduct, a forbidden act, a
dereliction of duty, which is willful in character.
2. Willful disobedience without justifiable reason by the D
employee of the lawful order/s of the supervisor or by the
Management in connection with the employee's roles and
responsibilities of the supervisor.
3. Utterance of invectives, obscene, offensive and insulting D

words, or willful disrespect, or any other acts of disrespectful
and/or inappropriate behavior (including, but not limited to,
comments, gestures delivered in a sarcastic or disrespectful
manner), by the employee towards his/her supervisor or any
company executives.
4. Gross Insubordination and/or assault by the employee D
against his supervisor or any company executive.
5. Willful holding back, slowing down, hindering or limiting D
work output.
6. Encouraging, coercing, inciting, bribing or otherwise D
inducing any employee to engage in any practice in violation
of the Company’s work rules.
All other acts of insubordination that cause or tend to cause damage or prejudice to the
Company shall be subject to disciplinary action depending upon the gravity of the offense
committed.
H. CONFIDENTIALITY OF WORK AND INFORMATION – Everest Trading requires strict

adherence to its policies and practices around confidentiality, data privacy, information security
and protection of company, client and customer confidential information. Additionally, Everest
Trading requires its employees to agree to and abide by non-disclosure agreements.
Confidential and proprietary information includes, but is not limited to: information related to our
clients, potential clients, customers, information not accessible to by the general public, financial
information, contractual information, software code, client documents, employment records,
business strategies, pricing, internal processes or business practices, personal or private
information about customers and employees, etc.
Restricted Information – information for which disclosure is prohibited except to specifically
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named individuals or groups within Everest Trading. Restricted information is a subset of

Confidential and Proprietary Information and can be any form of information/data, including but
not limited to: compensation information, passwords, personnel files, software source codes, etc.
These
types of information are classified as restricted because these are strictly limited to certain
persons within Everest Trading.
1. Mishandling/Inappropriate or Malicious use of D
Company/Client documents by employees entrusted with the
care and custody of said documents.
2. Spying or maliciously obtaining information from D
company/client confidential records, or inducing, pressuring,
influencing or bribing others to spy or obtain information, for
the purpose of discrediting the Company and/or its clients,
and/or transmitting the same to others to the prejudice of the
company and/or its clients.
3. Making false or malicious statements concerning the good D

name of the company and/or its clients and its products and
services.
4. Revealing or issuing without authority, confidential D
information, data reports or similar documentation, or trade
secrets of the company and/or its clients and the latter’s
customers, and/or suppliers and vendors of the company to
persons not authorized to receive the same.
5. Posting or uploading, including of photos, videos, and the D
like, of confidential information in any social networking/online
site, including but not limited to production facilities, client
names, company tools.
6. Revealing or issuing without authority, confidential D
information, data reports or similar documentation, or trade
secrets of the company and/or its clients to persons not
authorized to receive the same.
7. Revealing of procurement bids, offers and data of D

suppliers to other suppliers or persons not authorized to
receive the same, regardless of the intention and the absence
of damage to the company.
8. Unauthorized use of the Company/Client name and/or FWW D
logo during events, exercises, activities not sanctioned by the
company.
9. Utilizing the company system to review/access confidential D

information of customers, clients without a valid business
reason or in violation of data privacy laws or rules.
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10. Unauthorized opening/reading/reproducing of company FWW D

proprietary and confidential documents
11. Any violation of confidentiality agreements or data security Up to Dismissal depending on
agreements, to which the Company is a party. the severity of the offense
For violation of the confidentiality of any personal information,

regardless of any damage to the Company, the penalty for 1st
offense should be dismissal.
11. Any violation of the provisions and rules under the Data D
Privacy Act of the Philippines as well as any privacy
obligations, policies, requirement, notices, etc. that have been
communicated in relation to the handling of personal
information and sensitive personal information as the same is
defined under the law.
All other acts that violate the confidential nature of his employment and which cause or tend to
cause damage or prejudice to the Company shall be subject to disciplinary action depending
upon the gravity of the offense committed.
*Due to the differences in the severity that each act may present based on evidence and merit,
the investigative committee shall exercise due diligence and discretion in assigning the nature of
sanction that would be proportionate to the acts that were committed.
I. USE OF WORKSTATIONS, COMPUTER PROGRAMS, E-MAIL, INTERNET and other

DEVICES - Use of company property, work stations, systems, and company email and internet
should be for official business use only. Employees must abide by all applicable policies
concerning company property, facilities, work stations and email and internet use.
1. Uploading and/or transmitting materials that contain D

viruses, Trojan horses, worms, or any other harmful programs
2. Hacking or cracking which refers to unauthorized access D

into or interference in, or attempt to access, a computer
system/server or information and communication system or
security system; or any access to corrupt, alter, steal, or
destroy using a computer or other similar
information/communication devices, including the introduction
of computer viruses and the like, resulting in the corruption,
destruction, alteration, theft or loss of electronic data
messages or electronic document.
3. Piracy or unauthorized copying, reproduction, D
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dissemination, distribution, importation, use, removal,

alteration, substitution, modification, storage, uploading,
downloading, communication or making available to the public,
of the Company's protected material, electronic signature or
copyrighted works.
4. Producing, using, possessing, or trafficking one or more D
counterfeit access devices with the use of Company
computers, electronic devices, equipment, or tools.
5. Trafficking inside Company premises one or more D
unauthorized access devices or access devices that were
fraudulently applied for.
6. Inducing, enticing, permitting, or in any manner allowing D
another employee, for a consideration or otherwise, to
produce, use, or traffic any counterfeit or unauthorized access
devices, or access devices fraudulently applied.
7. Using, possessing, or trafficking any access codes or D

numbers given by or obtained from the client/customer,
whether or not for personal benefit or gain, including but not
limited to any kind of possession, retention, or use of Credit
Card Information, may the retention, possession, or use be in
print or electronic media and regardless of any reason given
for the possession, retention, or use thereof.
8. Obtaining money or anything of value from the Company D
or its clients and customers through the use of an access
device obtained in the course of employment, with intent to
defraud or with intent to gain with or without the intention of
fleeing thereafter.
9. Making any alteration, without the access device holder's D
authority, of any amount or other information stated in the
customer’s account data.
10. Effecting transaction, with one or more access devices D
issued to another person or persons, to receive payment or
any other item of value.
11. Unauthorized duplication and/or possession of corporate D
confidential files or data.
12. Tampering with server/network configurations, changing D
server/network rights of users, creating unauthorized user
accounts on the server/network, or any related acts of breach
of confidentiality.
13. Conspiracy to commit any of the foregoing offenses D
(offenses #1-14).
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14. Posting, or transmitting sexually explicit and other D

offensive, bigoted, hateful or racially offensive images using
company owned computers, email systems, computer
programs and other company owned devices.
15. Online posting of libelous, false, malicious, slanderous D
statements against the company or any of its employees using
company owned computers, email systems, computer
programs and other company owned devices.
16. Online discussion of non-business related topics, using D

obscene topics, offensive, libelous, bigoted, hateful or racially
offensive statements using company owned computers, email
systems, computer programs and other company owned
devices.
17. Violation of the Company’s Social Medial Policy, including D
but not limited to, mentioning client’s name in social media
posts, making your personal opinion to be that of the
Company, and disclosing confidential and proprietary
information. This violation shall include other similar
infractions which clearly show employees failure to use his
best judgment when deciding whether the content is
appropriate to publish and was clearly not mindful that the
published/posted statements can be a reflection of the
Company as a whole.
18. Bringing cellular phones, e-Cigarettes, diskettes, flash or D
thumb drives, storage discs, MP3 and its varieties, IPOD and
its varieties, Bluetooth, infrared devices, and other
wireless/storage/communication devices, writing instruments,
camera, writing pad, or any similar storage devices inside the
production floor, training rooms or other unauthorized areas at
any time. Please refer to the policy on recordable and mobile
devices.
19. Negligence or the careless act of leaving the computer FWW D
unattended and/or unlocked thereby risking the network to a
possible security violation.
20. Failure to erase or delete immediately before logging off D

any notes, data, numbers, records or other information that
were placed, pasted, or stored in Windows Notepad. Google
notebook, or other similar systems on-line links or otherwise,
excluding offenses related to Credit Card Information which is
covered by item 7 in this same subsection.
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21. Storing non-business related files such as MP3, video files, D

pictures and program installers in network drives and/or
unauthorized installation and/or use of external hardware,
paraphernalia, computer accessories, and the likes.
Any other acts of improper, unauthorized use of workstations, computer programs, e-mail,
internet and other devices, which may cause or tend to cause prejudice to the Company shall be
subject to disciplinary action depending upon the gravity and severity of the offense committed.
Access Device is any card (including but not limited to credit cards), plate, code, account
number, electronic serial number, personal identification number or other telecommunications

service, equipment, or instrumental identifier, or other means of account access that can be
used to obtain money, goods, services or other things or value or to initiate a transfer funds
(other than a transfer originated solely by paper instrument).
Unauthorized Access Devices is any access device that is stolen, lost, expired, revoked, canceled,
suspended, or obtained with intent to defraud.
THE
J. PEOPLE MANAGEMENT –Managers must exemplify company’s desired values, behaviors and
ethics. Managers are expected to be role models and stewards of their team at all times and
must carry themselves in a respectable manner whether inside or outside the office premises.
1. Utterance of invectives, obscene, offensive and insulting D

words or willful disrespect by the supervisor on his
subordinate.
2. Maligning and/or intriguing by any employee against any D
other employee, or performing or attempting to perform an
act by any employee to a co-employee (including but not
limited to any form of physical attack), which tends to cast
dishonor, discredit or contempt, upon the latter.
3. Giving illicit, unlawful and immoral orders by a supervisor to D
his/her subordinate or coercing or compelling a subordinate to
do illicit, unlawful and immoral acts that may cause or tend to
cause damage to the company.
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4. Failure to disclose a romantic/intimate/family relationship WW FWW D

with any employee reporting under the supervisor’s hierarchy
particularly those wherein one party may be able to influence
the performance, performance appraisal and/or salary
increase of the other party and those relationships that may
potentially put the company at a serious business risk.
5. Failure to disclose a romantic/intimate/family relationship WW FWW D

with any employee of the company’s clients.
6. Requesting for a date and/or personal relationship with any WW FWW D
employee of the company’s clients.
All other analogous acts, which may cause or tend to cause prejudice to the Company shall be
subject to disciplinary action depending upon the gravity and severity of the offense committed.
K. SEXUAL HARASSMENT and ACTS of LASCIVIOUSNESS - The Company values the dignity
of its employees and demands full respect for the individual, whether employees, trainees, or
applicants.
1. Displaying, distributing, saving, viewing nudity or any D

sexually offensive pictures or publications or any other
pornographic material (any obscene film, drawing, cut-out,
writing, pictures downloaded from a computer software or the
Internet, DVD’s, VCD’s, VHS tapes, mobile phones, magazines
and the like) within company premises, be it in print or
electronic format.
2. Any act or conduct which tends to sexually harass any D
coemployee including but not limited to persistently telling
smutty jokes; taunting a co-employee with constant talk of sex
or sexual innuendoes; asking a co-employee intimate
questions on his/her sexual activities; making offensive hand
or body gestures, staring or leering at a co-employee; making
obscene phone calls, text/online chat messages, emails to a
co-employee; requesting for dates or favors in exchange for a
job, favorable working conditions or assignments etc.;
unnecessary body contact in any sensitive part of the body;
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and other analogous acts.

3. All acts violating the Anti-Sexual Harassment Act of 1995 D
(RA 7877).
4. All other acts of Lasciviousness based on the Revised Penal D

Code.
L. PROHIBITED DRUGS AND PARAPHERNALIAS - Possession, sale, use and/or being under
the influence of dangerous drugs, and use of regulated drugs beyond medically prescribed limits
are prohibited in the workplace. It is detrimental to the health, safety and work-performance of
the employee and is harmful to the welfare of families, the company and surrounding
community.
1. Possession or causing to be brought into the company D

premises or company events dangerous drugs, whether during
working time or not, except when such are medicines duly
prescribed to the employee by a physician. Company premises
extend to all company vehicles, rooms, hotel rooms and sites
used by the employee while on an out-of-base duty.
2. Possession or custody of equipment, instrument, apparatus D

and other paraphernalia used in the administration of
dangerous drugs.
3. Possessing, selling, trading, transferring, using, or D
administering dangerous drugs within Company premises.
4. Willfully inserting, placing, adding, or attaching directly or D

indirectly, through any overt or covert act, whatever quantity
or quality of any dangerous drugs in the person, office, effects
or in the immediate vicinity of an individual for the purpose of
implicating, incriminating or imputing him to a crime.
5. Knowingly and willfully consenting to the unlawful acts D
provided for in this policy and uses his/her influence, power or
position in shielding, harboring, screening or facilitating the
escape of any employee who has violated the provisions of
this policy in order to prevent the arrest, prosecution and
conviction.
6. Repeated drug use and/or yielding positive results for drug D
use even after ample opportunity for treatment and
rehabilitation.
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7. Addiction on dangerous drugs that will require rehabilitation D

or confinement of more than 6 months, as certified by the
Rehabilitation Center.
8. Refusal to undergo drug rehabilitation and treatment. D
9. Other acts analogous to the foregoing. D
10. All other acts in violation of the Comprehensive Dangerous D
Drugs Act of 2002.
M. POLICY ON TRANSACTION HANDLING for VOICE, EMAIL, CHAT and all other
CUSTOMER TRANSACTION METHODOLOGIES - In representing the company, excellent
customer service is our business and should be everyone’s priority.
1. Shouting at the customer or utterance of invectives, D

obscene, offensive, rude, sarcastic remarks, disrespectful,
abrasive comments or consistently interrupting the customer
in a rude manner or uttering any abusive, offensive language
and/or any profanity while handling a customer transaction
but not directed at anyone including the customer.
2. Utterances of obscene, offensive and insulting words or D

discriminatory languages in reference to race, religion, gender,
ethnicity, sexual preference/ orientation or lifestyle.
3. Placing inappropriate/sarcastic/offensive notations in the D

account of the customer.
4. Incorrect Tagging/Documentation of a transaction. D
5. Failure to review the customer’s account notes resulting to FWW D

a fraudulent transaction.
6. Misrepresenting the Company or oneself to the customer D

and/or using fictitious name or using another employee’s
name or access for the purpose of concealing an offense or
evading responsibility therefore.
7. Failing to verify/obtain any security information prior to WW FWW D
discussing account specific/critical account information with a
customer.
8. Utilizing the system to look at an employee or customer D

account or celebrity/famous name account, with or without
using it, where he/she has no acceptable business
reason/purpose as part of job responsibilities/procedures for
viewing the account.
9. Burning of leads D
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10. Utilizing the system to process any transactions (financial D

or non-financial) on an employee’s own account, a customer’s
account or another account.
11. Being the subject of an Executive, customer or Client D
Complaint of an act which likewise constitutes a violation of
this Code.
* Program Zero Tolerance Offenses are grave offenses that stem from behavioral issues that
have a serious effect on the relationship with between a client of the company and any of its
members. Commission of these offenses may result to penalties imposed on the company by its
clients and/or client pullout. These offenses include but are not limited to:
- Rude, offensive, vulgar behavior
- Violations of security procedures
- Gross and Habitual negligence of transaction related processes
THE
FINAL PROVISIONS
The company reserves the right to make modifications, amendments, additions or

deletions in this Code of Disciplinary Conduct as business exigencies require.
All policies, operating procedures, penalties provided, and rules inconsistent with this
Code of Disciplinary Conduct are hereby replaced and modified accordingly.
The provisions of this Code of Disciplinary Conduct shall be without prejudice to any
liability for violations of the provisions of the labor, penal and civil laws. Should any part
of this Code, be declared unconstitutional or otherwise illegal, the remaining portions
shall remain valid and effective.
The provisions of the Labor Code, the Revised Penal Code, The E-Commerce Act, The
Access Device Regulation Act of 1998, the Data Privacy Act, the Anti - Sexual Harassment
Law and Dangerous Drugs Act shall supplement the provisions of this Code of Conduct.
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ANNEX “A”
DISCIPLINARY RULES ON SEXUAL HARASSMENT CASES
DECLARATION OF POLICY
The company values the dignity of its human resources and guarantees full respect for the
individual, whether employees, trainees, or applicants for employment;
The company likewise commits to maintain a work environment free from sexual harassment and
all forms of sexual intimidation and exploitation, and it will not tolerate harassment of its
employees by anyone, including any of its officers, managers, supervisors, vendors, clients or
customers;
Towards this end, the company renounces all forms of sexual harassment and hereby adopts this
policy defining the offense of sexual harassment and prescribing penalty thereto.
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Sexual Harassment may be committed by any of the following:
1. Employer or his agent

2. Manager, supervisor or employee
3. Trainer, teacher, instructor or facilitator
4. Persons with authority, influence or moral ascendancy over another in a work, training
or education environment
5. Person directing or inducing another to commit any act of sexual harassment
6. Person cooperating in the commission of any act of sexual harassment by another
without which it would not have been committed
Coverage
This covers all complaints that fall under RA 7877 (Anti-Sexual Harassment Act of 1995).
Types of Sexual Harassment
Sexual harassment comes in two (2) types, as follows:
1. Work or employment-related
2. Training or education-related
Specific Acts of Sexual Harassment
A. Work or employment-related
1. Sexual favor is made as a condition in:
a) Hiring
b) Employment
c) Re-employment
d) Continued employment
e) Granting favorable compensation, terms/conditions, promotions/privileges
2. Refusal to grant sexual favor results in limiting, segregating or classifying the employee which
in any way would discriminate, deprive or diminish employment opportunities or otherwise
adversely affect said employee
3. The above acts would:
a) Impair the employee’s rights or privileges under existing labor laws; or

b) Result in an intimidating, hostile or offensive environment for the employee
B. Training or education-related
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1. Sexual favor is made a condition in:
a) Giving of a passing grade

b) Granting of honors and scholarships
c) Payment of a stipend, allowance or other benefits, privileges or considerations
2. Sexual advances result in an intimidating, hostile or offensive environment for the trainee,
apprentice or student
This type of sexual harassment is committed against one:
a) who is under the care, custody or supervision of the offender

b) whose training, apprenticeship, tutorship or education is entrusted to the
offender
IV. THE COMMITTEE ON DISCIPLINE
There shall be a Committee on decorum and investigation of cases of sexual harassment

which shall:
• conduct meetings, as the case may be, with officers and employees, instructors,
coaches, trainers, and students or trainees to increase understanding and prevent
incidents of sexual harassment;
• conduct the investigation of alleged cases constituting sexual harassment; and
• be composed of at least one (1) representative each from management, the
supervisory rank and from the rank and file employees.
When a member of the Committee is the complainant or the person complained of in a

sexual harassment case, he/she shall be disqualified from being a member of the committee.
When a complaint is filed with the Chairman of the Committee and finds probable cause,
he/she shall convene the committee on Discipline and refer the matter thereto for investigation.
V. PROCEDURE FOR FILING
A. Complaint
Any complaint for sexual harassment should be filed, as follows:
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• in writing, signed and sworn to by the complainant before a notary public

• within three (3) years after the incident
Requirements
1. The Complaint must be in writing, signed and sworn to by the complainant
If the complaint is not under oath, the complainant shall be summoned by a Committee to
swear to the truth of the allegations in the complaint.
2. It must contain the following information:
• full name, position and department of the complainant

• full name, position and department of the respondent
• specification of the charge or charges
• brief statement of the relevant and material facts
• evidence complainant has, including affidavits of witnesses, if any.
If the complaint is vague or too general, a Committee may require the complainant
to specify the acts complained of as sexual harassment in writing within five (5) days from
receipt of the notice, otherwise, the complaint shall be dismissed.
3. A withdrawal of the complaint made or filed at any stage of the proceedings shall not
preclude the Committee from proceeding with the investigation of the case.
B. Answer
Requirements
1. The accused employee or officer must file an answer within ten (10) days from
receipt of the complaint.
2. The Answer shall be in writing, signed and sworn to by the respondent, copy
furnished the complainant
No particular form is required but it is sufficient if the answer contains a specific

admission or denial of the charge or charges and a statement of the relevant facts
constituting the respondent’s defense.
3. Must indicate whether or not respondent elects a formal investigation

4. Must be supported by any evidence respondent has including affidavits of
witnesses, if any
5. Filed through personal service or by registered mail. If this mode is followed, the
date of mailing shall be considered as the date of filing.
Unless otherwise directed by the Committee, failure of the respondent to file an answer or
to appear in the investigation shall be construed as a waiver to present evidence in his/her behalf.
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January 1, 2022
C. Reply
Must be filed within ten (10) days from receipt of the answer
D. Preventive Suspension
Requirements
1. Must be exercised by the Committee on Discipline

2. Must be for a maximum of thirty (30) days pending an investigation
3. Must have strong reasons to believe that the respondent is guilty of charges which
would warrant his/her removal from the service.
When the case is not finally decided within a period of thirty (30) days after the date of
preventive suspension of the respondent, he/she shall be automatically reinstated in the service.
However, if the delay in the disposition of the case is due to his fault or negligence or upon his
petition, the period of delay shall not be counted in computing the period of suspension.
E. Hearing
Requirements:
1. Discretionary upon the Committee

2. Must be conducted after all pleadings have been submitted
3. Must be conducted not earlier that five (5) days nor later than ten (10) days from the
date of receipt of the respondent’s answer or complainant’s reply if any
4. Must be resolved within thirty (30) days from the filing of the charges
5. May be extended by the Committee if it deems necessary
The parties and their respective witnesses shall be notified of the scheduled hearing at
least five (5) days before the date thereof, specifying the time, date and place of hearing.
No postponement shall be granted except in meritorious cases.
All documentary evidence shall be admitted for whatever value they may have and shall be
attached to the record of the case.
The parties may be required to submit their respective memoranda within ten (10) days
after the hearing of their case.
Nothing in this Procedure shall preclude the victim of sexual harassment from instituting a
separate action in the proper courts.
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VI. RETALIATION FOR SEXUAL HARASSMENT COMPLAINTS
Any person against whom a complaint for sexual harassment is filed is deemed to commit
retaliatory acts, amounting to serious or grave offense, when he carries out any of the
following:
1. Disciplining, changing work assignments of, providing inaccurate work information to,
or refusing to cooperate or discuss work-related matters with any employee because
that employee has complained about or resisted harassment, discrimination or
retaliation;
2. Intentionally pressuring, falsely denying, lying about or otherwise covering up or

attempting to cover up acts of sexual harassment;
3. Threatening the promotional opportunities, job securities and other service-related
benefits and privileges;
4. Other acts analogous to the foregoing.
ANNEX “B”
POLICY ON DRUG- FREE WORKPLACE AND MANDATORY RANDOM DRUG

TESTING
I. Statement of Policy
EVEREST TRADING envisions a drug free community and it renounces all forms of illegal drug?
trafficking, abuse, addiction and dependency on a working environment.
The company commits to safeguard the well-being of the employees from the ill effects of
dangerous drugs by pursuing an intensive and unrelenting campaign against the use of dangerous
drugs and other similar substances.
Towards this end, all employees are required to attend anti-drug abuse programs and undergo
random drug tests, in accordance with this Policy.
II. Implementing Guidelines
A. Definition of Terms
Administer – Any act of introducing any dangerous drug into the body of
another person, with or without his/her knowledge, by injection, inhalation,
ingestion or other means, or of committing any act of indispensable
assistance to a person in administering a dangerous drug to himself/herself
unless administered by a duly licensed practitioner for purposes of
medication.
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Confirmatory Test – An analytical test using a device, tool or equipment

with a different chemical or physical principle that is more specific which
will validate and confirm the result of the screening test.
Dangerous Drugs. –as enumerated and defined under Republic Act 9165
otherwise known as the Dangerous Drugs Act
Drug Dependence. – As based on the World Health Organization definition, it is a

cluster of physiological, behavioral and cognitive phenomena of variable intensity,
in which the use of psychoactive drug takes on a high priority thereby involving,
among others, a strong desire or a sense of compulsion to take the substance and
the difficulties in controlling substance-taking behavior in terms of its onset,
termination, or levels of use.
Trafficking. – The illegal cultivation, culture, delivery, administration,

dispensation, manufacture, sale, trading, transportation, distribution, importation,
exportation and possession of any dangerous drug and/or controlled precursor and
essential chemical.
Instrument. – Any thing that is used in or intended to be used in any manner in the
commission of illegal drug trafficking or related offenses.
Manufacture. – The production, preparation, compounding or processing of any

dangerous drug and/or controlled precursor and essential chemical, either directly or
indirectly or by extraction from substances of natural origin, or independently by means of
chemical synthesis or by a combination of extraction and chemical synthesis, and shall
include any packaging or repackaging of such substances, design or configuration of its
form, or labeling or relabeling of its container; except that such terms do not include the
preparation, compounding, packaging or labeling of a drug or other substances by a duly
authorized practitioner as an incident to his/her administration or dispensation of such drug
or substance in the course of his/her professional practice including research, teaching and
chemical analysis of dangerous drugs or such substances that are not intended for sale or
for any other purpose.
Screening Test. – A rapid test performed to establish potential/presumptive positive

result.
Sell. – Any act of giving away any dangerous drug and/or controlled precursor and
essential chemical whether for money or any other consideration.
Trading – Transactions involving the illegal trafficking of dangerous drugs and/or

controlled precursors and essential chemicals using electronic devices such as, but
not limited to, text messages, email, mobile or landlines, two-way radios, internet,
instant messengers and chat rooms or acting as a broker in any of such
transactions whether for money or any other consideration in violation of this
policy.
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Use – Any act of injecting, intravenously or intramuscularly, of consuming, either by

chewing, smoking, sniffing, eating, swallowing, drinking or otherwise introducing into the
physiological system of the body, and of the dangerous drugs.
B. Prohibited Acts - (see table of offenses and penalties)
C. THE ASSESSMENT COMMITTEE
There shall be an Assessment Committee attached to the Human Resources, composed of the Site
HR Manager, who shall be the ipso facto Chairman of the Committee, the Medical Team and the
Manager of Business Unit where the employee belongs. The immediate supervisor of the concerned
employee shall be the fourth member of the committee.
When a member of the Committee is the complainant or the person subject of investigation, he
shall be disqualified from being a member of the committee.
D. PROCEDURE IN HANDLING CASES
The provisions of the Code of Disciplinary Conduct on due process in administrative investigations
shall be applied in all cases involving violations of the provisions of this policy.
E. RANDOM DRUG TESTING FOR OFFICERS AND EMPLOYEES
1. All employees are required to undergo a random drug test for purposes of reducing the
risk in the workplace.
The Assessment Committee shall, with strict confidentiality prepare the list of
employees who shall undergo drug testing and the specific date of the tests in a DOH
accredited testing centers and in conformity with the procedures prescribed by the
Department of Health.
2. Drug testing shall consist of both the screening test and the confirmatory test, the
latter to be carried should the screening test turn positive. The employee concerned
must be informed of the test results whether positive or negative.
3. Where the confirmatory test turns positive, the Assessment Committee shall evaluate
the results and determine the level of care and administrative interventions that can be
extended to the concerned employee.
4. A drug test is valid for one year, however, additional drug testing may be required for
just causes.
5. All cost of drug testing shall be borne by the company.
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F. TREATMENT, REHABILITATION AND REFERRAL
1. The Assessment Committee shall prepare drug prevention and control programs, which
shall include treatment, rehabilitation and referral procedure. It shall also include
employee assistance and counseling programs for emotionally stressed employees.
2. The Assessment Committee shall determine whether or not an officer or employee

found positive for drugs would need referral for treatment and/or rehabilitation in a
DOH accredited center for a period not to exceed 6 months.
All expenses for the rehabilitation of the employee shall be for his account.
This option is given only to officers and employees who are diagnosed with drug
dependence for the first time, or who turn to Assessment Committee for assistance, or
who would benefit from the treatment and rehabilitation.
3. Following rehabilitation, the Assessment Committee, in consultation with the head of

the rehabilitation center, shall evaluate the status of the drug dependent employee and
recommend the resumption of the employee’s job if he poses no serious danger to his
co-employees and the workplace or terminate his employment his employment with the
company.
Confinement or rehabilitation of an employee exceeding 6 months, as certified by the

head of the rehabilitation center, is a valid ground to terminate his employment with
the company.
4. During his confinement and/or rehabilitation, the employee shall be considered on

leave without pay and shall not receive any salary and/or bonuses from the company.
5. Repeated drug use during and after rehabilitation and treatment shall be a valid ground
to terminate the employment of the employee from the company, in accordance to the
provisions of the Code on Employee Discipline and this policy.
6. The Company shall maintain the confidentiality of all information relating to drug test
or to the identification of the drug users in the workplace, except when
a. Required by law;
b. Overriding public health and safety concerns; and
c. Authorized by the employee in writing.
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III. The Assessment Committee shall periodically evaluate the implementation of the policy to
ensure a drug-free Community.
ACKNOWLEDGEMENT RECEIPT WITH UNDERTAKING
I acknowledge the receipt of this Everest Trading Code of Disciplinary Conduct, which I have had
the opportunity to review and which was thoroughly and extensively discussed with me.
I undertake to abide by the rules, policies and standards of work set forth in this Policy at all times
and to cooperate in any company investigations of cases involving violations of the Code and other
related policies. Any violation of its provisions may result in civil, criminal and/or administrative
liabilities.
I am fully aware that Everest Trading, can modify, rescind and/or amend this Code or any part
thereof, as business exigencies may require.
___________________________________
Signature of Employee above printed name
Date _______________________________
This Code of Disciplinary Conduct is the property of Everest Trading Philippines Services
Corporation. No portion of this Code may be used for any purpose without the prior written consent
of the Legal Department of Everest Trading. This copy must be returned together with other
company property and facilities upon separation from the company.
39

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PROCEDURE MANUAL

THE CODE OF DISCIPLINARY CONDUCT Revision No. 1

Original Release Date : Effective Date:

EMPLOYEE DISCIPLINE AND CORRECTIVE ACTION AT EVEREST TRADING

Maintenance of discipline is primarily a function of the immediate supervisor. The immediate

I. Preparation and Service of the Show Cause Notice II.

Original Release Date : Effective Date:

Code – The Everest Trading Code of Disciplinary Conduct

Company – Everest Trading

Original Release Date : Effective Date:

II. Disciplinary Conference - In certain cases, a Disciplinary Conference will be

I. Preparation and Service of the Show Cause Notice

A. The Investigating Officer

The immediate supervisor of an erring employee acts as the investigating officer.

B. Procedure and Guidelines

3. Show Cause Notices shall be signed off by the following:

Original Release Date : Effective Date:

• Five (5) calendar days upon receipt if allegations are terminable.

II. Disciplinary Conference

A. When to Conduct a Disciplinary Conference

Original Release Date : Effective Date:

B. The Investigation Committee

During investigation, the following guidelines shall apply:

1. The disciplinary conference is a fact-finding process intended to gather relevant case

To ensure neutrality, no immediate supervisor/manager may act as investigating officer in

Original Release Date : Effective Date:

III. Preparation and Service of the Notice of Decision

A. Imposition of Appropriate Disciplinary Action

Original Release Date : Effective Date:

To determine the appropriate disciplinary sanction, the supervisor/manager and/or Investigation

AGGRAVATING CIRCUMSTANCES are those that tend to increase the

MITIGATING CIRCUMSTANCES are those that tend to lessen the seriousness/gravity of

B. Procedure and Guidelines in Implementing Disciplinary Action

Original Release Date : Effective Date:

4. The Notice of Decision shall be signed off by the following:

C. Finality of Decision and Appeal

2. Requests to file a reconsideration or an appeal to defer the implementation of a decision or

• to present new evidence;

Original Release Date : Effective Date:

• questions on the interpretation of the provision of the Code of Disciplinary Conduct

IV. Table of Signatories

Immediate Manager/Sr. Site

B. Final Written Warning

Original Release Date : Effective Date:

D. Restitution or Reparation of Damage Caused

E. Civil and/or Criminal Liability

VI. CORPORATE SECURITY CASES

A. Internal and External Fraud

SCHEDULE OF DISCIPLINARY ACTION WITH PENALTIES

Original Release Date : Effective Date:

CLEARING PERIOD OF OFFENSES

All offenses shall have a prescription period of one (1) year.

IMPACT ON EMPLOYEE PROMOTION

1st 2nd 3rd

1. Failure to log-in or log-out in the official timekeeping WW FWW D

Original Release Date : Effective Date:

2. Allowing another to use his/her ID card or using another D

5. Loitering, leaving work station and /or company premises WW FWW D

3. Maligning, making discriminatory remarks, uttering obscene D

4. Repeated inappropriate public displays of affection FWW D

5. Lewd and lascivious acts within company premises, D

7. All employees are prohibited to bring into any Everest D

Original Release Date : Effective Date: