REPUBLIC OF THE PHILIPPINES)

SECRETARY’S CERTIFICATE

I, _____________, of legal age, Filipino with office address at

Mamplasan, Biñan, Laguna, being the duly elected and qualified Corporate
Secretary of LEMCON (PHILIPPINES) INC. (the “Corporation”), a
corporation duly organized and existing under the laws of the Philippines,
hereby certify, under oath, that during the meeting of the Board of Directors
of the Corporation held on _______________________, 2021, the following
resolutions were approved:

“RESOLVED THAT, the Corporation be authorized to

file and prosecute the appropriate legal remedies/action(s)
against the Commissioner of Internal revenue and/or the Bureau
of Internal Revenue in relation to its deficiency assessment, for
the taxable year 2017, with the following courts: (i) Court of
Tax Appeals in Division; (ii) in case of an adverse decision, to
the Court of Tax Appeals En Banc, and (iii) in case of any
unfavorable decision and/or resolution, to the Supreme Court.”

“RESOLVED, FURTHER, that the Corporation

designates Mr. Harsyl R. Tan, as the Corporation’s _______,
as the authorized representative of the Corporation, with full
power and authority to do and perform any of the following
acts:

1. To cause the preparation and filing of any

petitions, complaints, pleadings, papers or
documents necessary therefor;
2. To verify, sign, execute such petitions or
initiatory pleading, and issue the certification
against forum-shopping therefor;
3. To prosecute and terminate the proceedings in
connection therewith;
4. To appear before the court and to represent the
Corporation in all the proceedings;
5. To appoint another representative to appear on
his behalf.

“RESOLVED, FURTHER, that MR. HARSYL R. TAN and/or

ATTY. GINA. V. ILAO and/or RC Menzon Law Office, or any
of its lawyers, (the “Representative/s”) be authorized, upon
filing of a case with the proper court and during pre-trial:

a. To discuss and explore the possibility of an

amicable settlement, negotiate, enter into
conclude, execute, sign and deliver a
compromise agreement, and/or plea bargaining
as they may deem just and equitable;
 b. To submit to alternatives modes of dispute
resolution;
c. To enter into stipulations or admissions of facts
and documents and agree on a simplification of
the issues;
d. To amend and/or agree to the amendment of the
pleadings;
e. To limit the number of witnesses;
f. To agree on such matters and do such things as
may aid in the prompt disposition of the above-
captioned case; and
g. To do and perform such other acts and things as
may be necessary to promote a fair and
expeditious trial of the case;

“RESOLVED FURTHER, that the Corporation hereby

grants unto said authorized representative/s full power and
authority to sign, execute and deliver any and all documents
and papers and to do and perform every act necessary to be
done in and above the premises for the accomplishment of the
above purposes.”

“RESOLVED FURTHER, that the Corporation hereby

ratifies and confirms all that the said authorized
representative/s, may do or cause to be done by virtue hereof;

“RESOLVED FINALLY, that the Corporate Secretary be

authorized, as he/she is hereby authorized, to issue the
necessary certification to attest to the foregoing resolutions.”

In witness whereof, this Certificate was signed this ____day of

November 2021 at ___________________

SIGNATURE
NAME
Corporate Secretary

SUBSCRIBED AND SWORN to before me this ______ day of

November 2021 at Pasig City, Metro Manila, affiant having exhibited to me
as his/her competent evidence of identity, his/her ___________ issued at
_______ and valid until _________.

Doc. No. _______;

Page No. _______;
Book No. _______;
Series of 2021.