GLO 2016 ACGR Annexes A C

ANNEX "A"
a Gtobe Tetecom, lnc.

ffiGtobe v
The Globe Tower
32nd Street corner 7th Avenue,
Bonifacio GLobatCity,
Taguig, PhiLippines 1 634
{71 +632.7e72ooo
@ www.qLobe.com.ph
CERTIFICATION OF FULL GOMPLIANCE WITH THE

MANUAL OF CORPORATE GOVERNANCE
The Corporation's Manual of Corporate Governance, as revised in May 2015, adopts the leading
practices and principles of good corporate governance, and to the best of my knowledge and belief, full
compliance therewith has been made since the adoption of the Manual.
This Certification is issued in accordance with the requirement of the Corporation's Manual of
Corporate Governance, Article V, Section 3, Paragraph iil; and is executed to attest to the truth of the
foregoing facts.
January 3, 2017 , Taguig City
MA crocsoN-co
,k
Compliance Officer, Assistant Corporate Secretary, and
Vice President - Law and Compliance
Countersigned by:
Preside and Chief Executive Officer
[Source: Globe 2016 Annual and Sustainability Report, p. 159; Globe company website (http://corporate-governance.globe.com.ph/reports-and-certifications.html)]
ANNEX "B"
EMPLOYEE
HANDBOOK ON
Code of
Conduct
ANNEX "B"
Introduction 2
PRIMER ON
Code of Conduct 7
Unethical Practices 25
Conflict of Interest 31
Whistleblower 37
POLICIES AND PROCEDURES ON

Code of Conduct 47
Unethical Practices 67
Conflict of Interest 77
Whistleblower 85
Form 97
ACKNOWLEDGEMENT FORM
Upon Signing this Acknowledgement form, I hereby declare
that I have received this handbook. I willingly accept my
responsibility to read and understand its content and to exert
my utmost best to comply with the mandates contained
therein.
Received by:
Name of Employee
Signature
Date/Time Received
r IMPORTANT NOTI~
This page should be signed-off and given back to HR
Group c/o Labor Relations within 24 hours after receipt of
this Employee Handbook.
For provincial areas, please send your Acknowledgement
form initially through fax at: 739-3133 and then send the
original copy to: Labor Relations, Service Delivery Center,
HR Group 3F,Tower 1,Globe Telecom Plaza, Pioneer cor.
Madison St, 1552, Mandaluyong City
Date/Time of Issue
• PRIMER
•
TABLE OF CONTENTS
•
•
• CODE OF CONDUCT
• On General Provisions
To whom does this Code of Conduct apply? 7
• How many times shall penalty be imposed? 7
• What are the responsibilities

What are the responsibilities
of Employees in relation to the Code?
of Superiors?
7
8
• What effects would disciplinary action have on
• one's career improvement?

What are the imposable penalties under the Code?
8
8
• On Offenses And Penalties
• What are considered offenses against honesty and integrity?

What are their corresponding penalties?
9
9
• What are considered offenses against good personal behavior
• and conduct and what are their corresponding penalties?

What are considered anti-customer offenses and what are
10
• their corresponding penalties? 12
• What offenses are related to job performance?

What are attendance violations?
13
14
• Willi be penalized for undertime or leaving work early? 15
•
What behaviors do not support teamwork? 15
What are my responsibilities in protecting
• my Company's name and reputation?

What are my obligations to keep a secure. safe and
16
• healthy working environment? 16
• The Rules Of A Disciplinary Proceeding
• What are the rules of a disciplinary proceeding? 18
•
•
I.
•
PRIMER •
:.•
TABLE OF CONTENTS
UNETHICAL PRACTICES
What are unbecoming and unethical practices? 25
What are corrupt practices? ......................................................•............... 25
•
What is gross negligence?
Can I solicit gifts or sponsorships from customers or suppliers?
25
25
•
Can I receive unsolicited gifts from customers or suppliers? 26
•
Can a customer or supplier sponsor my local or foreign travel?
Can I fraternize with Globe's customers and suppliers?
CONFLICT OF INTEREST
26
26
••
What are conflict-of-interest
What should I do in a conflict-of-interest
situations?
situation?
31
31
•
.!
Can a conflict-of-interest situation be considered acceptable?
What happens after my conflict-of-interest
considered unacceptable?
situation is
31
32
•
•
What happens if I fail to disclose my conflict-of-interest situation? ..32
•
WHISTLEBLOWER
•
What is whistleblower reporting? 37
•
•
What is a protected disclosure? 37
What kind of protection willi be given? 37
How do I report an improper activity?
What happens to my disclosure?
37
38 •
When does a complaint call for an investigation? 38
•
What happens to the investigation results? 38
•
••
What are the role, rights and responsibilities of a whistleblower? 39
What are the role, rights and responsibilities
of an investigation participant? 39
What are the role, rights and responsibilities
of an investigation subject? 39
•
•
Can a guilty whistleblower be granted immunity? 39
•
•
•
Primer on
Code of Conduct
•
•• Code of Conduct
• T he Company strives to do what is right and what is fair to all stakeholders. We are
••
all enjoined to do the right things always and to live out our corporate values.
The intent of our Company's Code of Conduct is to reinforce these values by
specifying the behaviors and practices that are not aligned to it. It seeks to create
awareness and thus prevents the commission of offenses punishable under the Code,
•
and not simply to administer punishment and sanctions as may be called for.
For a fuller understanding. please refer to the attached Code.
• ON GEN ERAL PROVISIONS r:::::=:;;;::;::::::;;:;;;~-=:;z::;:::~::::;:;;:;;~::m:::::;;::;~:z; .. ;0

...
• @ To whom does this @ What are the
• o
Code of Conduct apply?
The Code applies to all employees of
responsibilities of
Employees in relation to
• Globe. Innove. GXI,their subsidiaries

and affiliates. It must be enforced o
the Code?
It is the duty of every employee
• consistently and uniformly to

offenders regardless of their
to familiarize himself with all the
provisions of the Code. Ignorance of
• position within the company. It is or unfamiliarity with the provisions
•
important to stress that disciplinary will not excuse any violation
action shall be directed against the committed.
employee's wrongdoing and not
• against his person or personality.

All employees are duty-bound
to report to management any
• The identity of an employee,

who is the subject of a Code of
information they may have about
any offense which has been. is
• Conduct process, and information

on any Code proceedings should
being, or is about to be committed.
Failure to do so will subject the
• be maintained in confidence to the

extent possible given the legitimate
employee to the appropriate
disciplinary action under ART.54
• needs of law and the fact-finding

process.
Concealing or Withholding
Information of the Code of Conduct.
• @ How many times shall The protection of the reporting

party's identity will be maintained
• o
penalty be imposed?
Only one penalty shall be imposed
to the extent possible. within
the legitimate needs of law and
• for each offense. If an offense

violates two or more rules in the
the fact-finding process. Where
appropriate, the protected
• Code. the penalty for the most

serious offense shall be applied.
disclosure protocols will be followed
as specified in our Whistleblower
• policy.
•
•
•
PRIMER
@ What are the
responsibilities of
O~~RNA~C
<:> ~
••
"
Superiors?
Superiors are held accountable for
We recognize the
importance of good
•
•
governance in realizing
maintaining discipline and order our vision, carrying our
within their areas. They are given mission and living our
sufficient authority and power to
act upon all reports of violations
values for increased
satisfaction of our
customers. •
immediately. Otherwise, they are
held responsible for failure on the •
job of management, as provided
under ART. 36 Failure to Provide
3. Suspension
The temporary separation of
•
Guidance/ Failure of Management
the Code the Conduct.
@ What effects would

of an employee from service, in
number of working days without
pay and other corresponding
benefits.
•
••
• I
disciplinary action
have on one's career 4. Demotion
improvement? The transfer of an employee
to a lower rank with or without
••
" An employee's record of
offenses shall diminish or, as the the corresponding reduction in
circumstances may warrant, remove salary.
their eligibility for merit increases,
5. Dismissal
•
promotion, incentives or similar
improvement in his job situation. The permanent separation of an
employee from service.
@ What are the imposable
penalties under the The Company may consider any •
"
Code?
In order of severity:
1. Verbal Warning
attendant aggravating or mitigating
circumstances when imposing such
penalties. It must be stressed that
these penalties shall be imposed
••
Cautions the offender to without prejudice to any civil,
criminal or other actions that the •
•
refrain from repeating the same
offense in the future, lest they Company may decide to take
receive a more severe penalty. against the offender.
This is documented as a recall Any violation that does not fall
•
••
mechanism. under the offenses specified in the
Code but are clearly damaging to
2. Written Reprimand the interest ofthe Company shall
More severe than a warning in still receive the appropriate penalty
•
the sense that it is accompanied to enforce the Company's inherent
by censure, rebuke or sharp right to discipline its employees and
•
scolding. protect its interest.
•
• CODEOF CONDUCT
•• The Code shall not prevent the

Company from applying the just
causes for dismissal under the Labor _,~ 'IALll
• Code and other laws. OV ~
•
The Code shall be a living document. We are fair.
as such. may be changed from time ethical
and honest.
•
to time. as may be required by any
change in laws. rules and regulations
•
that may pertain to the behavior
of employees. Code updates shall
•
follow our HRpolicy change.
approval and cascade process.
• ON OFFENSES AND PENALTIES lIi
• @ What are considered

2.3. makes a false or fraudulent
•
offenses against honesty
claim against the company;
and integrity? What
are their corresponding 2.4. initiates or participates
• penalties? in any action intended to

defraud the Company;
• 0 1. Corruption. Extortion. and/or

Bribery 2.5. obtains payment. benefit. or
• Any employee who directly or

indirectly demands. requests.
gain from the Company to
which he is not entitled;
• solicits. receives or accepts

any commission. share or
2.6. knowingly honors a forged
signature for his own
• consideration. monetary or
otherwise. for himself. or for
benefit or that of another
person; or
•• another person. in connection

with any contract or transaction
entered into by the Company.
or in connection with the
2.7. gives due course or approval
to a document knowing it to
be false or erroneous
• performance of his duties. or

because of his position. shall
3. Theft. Pilferage or
Misappropriation
• suffer the penalty of Dismissal.

Stealing. misappropriating.
• 2. Fraud Against the Company or attempting to steal or

misappropriate funds or
Committing any of the following
properties belonging to the
• shall be penalized with

Dismissal:
Company or co-employee. shall
suffer the penalty of Dismissal.
• 2.1. makes a false

representation of facts; 4. Perjury or FalseTestimony
• 2.2. employs any kind of Giving false testimony on a
• deception; matter that is the subject of
•
•
PRIMER
official inquiry or investigation
by the Company, shall suffer the
penalty of Dismissal.
@ What are considered
offenses against good
••
5. Falsification
personal behavior and
conduct and what are
•
Committing any of the following
o
their corresponding
penalties?
•
•
shall be penalized with Dismissal:
1. Sexual Harassment
5.1. falsifies any company
In a work-related environment,
document or record;
5.2. enters false information on
sexual harassment is committed:
•
•
1.1. when sexual favor is solicited
any company document or
as a condition for hiring, re-
record
5.3. makes untruthful
statements in a narration of
facts; or
employment, or continued
employment of an employee;
1.2. when sexual favor is solicited
as a condition for granting
••
5.4. uses a falsified document or
certificate
6. Conflict of Interest
favorable terms or conditions
of employment, promotions,
compensation, privileges or
other considerations;
••
All employees are required to
state in writing his involvement
1.3. when refusal to grant
sexual favor results in the •
in any conflict of interest with
the Company. Failure to do so
discrimination or deprivation
•
•
of the employee of his
shall result in the Dismissal of
employment opportunities
the employee. and other adverse effects;
Conflict of interest generally 1.4. when sexual advances impair
•
••
exists when financial or other the employee's rights under
personal considerations, existing labor laws; or
relations or interest may
compromise an employee's 1.5. when sexual advances result
ability to fulfill his duties in an intimidating, hostile, or
properly. offensive environment for
the employee.
•
•
Personal interest may also arise
from the employee's family", or Any employee who commits
any of the aforementioned acts,
•
close personal relationship' or
employment with any entity that regardless of whether the sexual
demand, request or requirement
•
does business with the Company.
is accepted, shall suffer the
I Family relationship includes the spouse or relatives by consanguinity or affinity to the fourth ~egree . .
Close personal relationship includes close friendship or professional employment by the emp oyee giVing
•
•
rise to or assuring free access to such employee •
•
•
••
CODE OF CONDUCT
2. Immoral or Indecent Conduct 6. Drunkenness
Engaging in immoral. indecent Reporting for work under the
• or lascivious behavior. including influence of liquor. or drinking

the use of profane or obscene alcoholic beverages during
•
language in addressing another working hours (except on official
person. within the company functions) shall be penalized as
••
premises during working hours follows:
shall be penalized as follows:
1st Offense - Seven (7) days
- Three (3) days Suspension
1st Offense
Suspension 2nd Offense - Fifteen (1S)days
•
Suspension
2nd Offense - Seven (7) days
Suspension 3rd Offense - Dismissal
•
3rd Offense - Fifteen (1S)days
Suspension 7. Use or Possession of Prohibited
4th Offense - Dismissal Drugs
• 3. Fighting Within Company

Any employee caught using
or in possession of prohibited
• Premises
Quarrelling. physically assaulting
or regulated drugs shall
be dismissed and/or dealt
• or engaging in a fight with a co-

employee or any person within
with in accordance with the
Comprehensive Dangerous Drug
• company premises shall suffer

the penalty of Dismissal.
Act (RA no. 9765).
• 4. Threats or Coercion
8. Smoking in Prohibited Places
•
Smoking in designated smoke-
Threatening. intimidating or free zones in the employment
coercing a co-employee or a premises is strictly prohibited.
• third party within the company

premises shall be penalized as
Offenders shall be dealt with as
••
follows:
follows:
1st Offense - Verbal Warning
1st Offense - Seven (7) days 2nd Offense - Written Reprimand
Suspension 3rd Offense - One (1) day
2nd Offense - Fifteen (1S)days Suspension
• Suspension
3rd Offense - Dismissal
4th Offense - Seven (7) days
Suspension
• S. Discourtesy
Co-employees
or Disrespect to
Sth & Subsequent Offense
- Fifteen (15) days
Suspension
• Shall be penalized as follows: Where smoking threatens
• 1st Offense - Seven (7) days

Suspension
the safety and security of the
Company, the penalty shall be as
• 2nd Offense - Fifteen (lS) days follows:

Suspension
3rd Offense - Dismissal 1st Offense - Fifteen (15) days
• Suspension
2nd Offense - Dismissal
•
•
.-1
PRIMER
9. Gambling 2. Unauthorized Disclosure of •
Any employee caught gambling Information
•
in any form at any time within
company premises shall be
Divulging confidential
such as a customer's personal
matters
•
penalized as follows: information. call details, billing
statement, account and history
•
••
1st Offense - Written Reprimand
without appropriate authorization,
2nd Offense -. Fifteen (15) days
Suspension shall be penalized as follows:
1st Offense - Fifteen (15) days
Suspension
10. Failure to Report Loss Incident
Occurrence
•
••
Failure to report a loss, such as a 3. Misinformation
motor vehicle accident involving Employee who is in a position
a service vehicle of the Company, to obtain information but gives
property damage, etc. by an inaccurate, misleading, delayed,
employee entrusted therewith
or in physical possession thereof,

or no information to customers,
and his act results in the
dissatisfaction
the customer,
of or disservice to
shall be dealt with
••
Suspension
2nd Offense - Fifteen (15) days
as follows:
1st Offense - Verbal Warning • I
•
Suspension
3rd Offense - Dismissal 2nd Offense - Written Reprimand
3rd Offense - Three (3) days
@ What are considered
anti-customer offenses
Suspension
Suspension •
and what are their
corresponding penalties?
5th Offense - Fifteen (15) days
Suspension
•
e 1. Discourtesy Against Customers
Discourtesy in any form,

such as rudeness, arrogance,
6th Offense - Dismissal
4. Neglect of Customer
Failure, refusal or neglect to
••
insolence, impoliteness,
disdain, contentiousness,
respond and attend to the
concerns of a customer or failure
•
ungraciousness, incivility or
inconsiderateness in word or
or refusal to provide prompt,
efficient and courteous service
•
action against any customer,
shall be dealt with as follows:
1st Offense - Verbal Warning •
1st Offense - Three (3) days
Suspension
2nd Offense - Written Reprimand
•
•
2nd Offense - Seven (7) days Suspension
Suspension 4th Offense - Seven (7) days
Suspension
••
3rd Offense - Fifteen (15) days
Suspension 5th Offen se - Fifteen (15) days
4th Offense - Dismissal Suspension
•
• CODE OF CONDUCT
• Incompetence in responding and
• attending to the concerns of

the customer shall be dealt with
_,~ \/ALu.
0'" ~
• similarly. . We take
ownership of
•• 5.. Mishandling a Customer

Deliberate actions that result
in the failure of attending to a
our actions
•
customer's call shall be dealt with procedures for direct or indirect
as follows: personal gain shall be meted a
• 1st Offense - Verbal Warning

penalty ranging from suspension
to dismissal depending upon the
•• 3rd Offense - Three (3) days gravity of the offense.

Suspension
4th Offense - Seven (7) days 3. Sleeping While on Duty
Suspension
5th Offense - Fifteen (lS) days Sleeping while on duty shall be
• Suspension
disciplined as follows:
• @ What offenses are related

to job performance?
2nd Offense - Written Warning
3rd Offense - Seven (7) days
•
Suspension
01. Failure on the Job 4th Offense - Fifteen (15) days
Suspension
• Refusal or inability to perform

duties and responsibilities
• without justifiable cause;

disregard for performance and
4. Failure to Provide Guidance/
Failure of Management
• productivity standards; and

neglect for operating procedures
A leader is expected to provide
••
his team the basic orientation,
have corresponding penalties
training or guidance in the
depending on the frequency as
performance of their duties
well as the extent of the offense:
and responsibilities. He is held
•
1st Offense - Verbal Warning accountable for any violation
2nd Offense - Written Reprimand of company policies or existing
3rd Offense - Three (3) days laws that his staff may commit
• Suspension
4th Offense - Seven (7) days because of neglect for this
•
Suspension responsibility. The penalty for
5th Offense - Fifteen (15) days such violation ranges from
Suspension suspension to dismissal based on
• 6th Offense - Dismissal

the gravity of the offense.
•
2. Non-Observance of Standard
5. Culpable Delay in Disposing
Operating Procedures -
Disciplinary Cases
• Willful or unintentional non-

observance of standard operating
Any official who unreasonably
•
delays the resolution of
I•
I
•
•
PRIMER
disciplinary cases is penalized as 3. Tardiness
follows:
At the very least, employees
•
•
Ist Offense - Seven (7) days are expected to report for work
Suspension on time. Any employee who
••
2nd Offense - Fifteen (15) days reports for work late for two (2)
Suspension
times, or accumulates one (1)
3rd Offense - Thirty (30) days
Suspension hour tardiness within a 7-day
4th Offense - Dismissal attendance monitoring cycle, shall
•
be disciplined as follows:
6. Limiting Work Output
•
Extending beyond the necessary
time to finish a job or task, and 3rd Offense - Three (3) days
••
inciting others to do the same Suspension
shall be meted a penalty ranging 4th Offense - Seven (7) days
Suspension
from suspension to dismissal
depending upon the gravity of Suspension
•
the offense. 6th Offense - Dismissal
•
For the above 6th offense to merit
® What are attendance dismissal, the 1st up to the 6th
violations?
••
offense must be committed within
01. Absence Without Leave (AWOL) one calendar year, l.e., January to
December of the same year.
If an employee would not be
able to report to work, he should 4. Improper Use of Sick Leave
inform his immediate superior
prior to his absence. Failure to
comply means:
An employee who: (a) avails of
his sick leave without informing
his superior about the nature
••
•
1st Offense - Two (2) days of his illness; (b) extends his
Suspension
approved sick leave without prior
2nd Offense - Three (3) days
•
Suspension notification; or (c) refuses to
3rd Offense - Seven (7) days be examined by the company-
•
Suspension designated physician while on
4th Offense - Fifteen (15) days sick leave, shall be penalized as
Suspension
•
follows:
5th Offense - Thirty (30) days
Suspension
Absence without leave for
fifteen (15) days or more shall be
2nd Offense - Seven (7) days
Suspension
•
•
3rd Offense - Fifteen (15) days
considered as gross and habitual Suspension
neglect of duty. The penalty is 4th Offense - Dismissal
Dismissal.
5. Malingering
•
Pretending to be sick or claiming
disability to avoid work, duty or
•
•
•
•
••
CODEOF CONDUCT
service. or for other personal 2. Abuse of Authority

reason. shall be penalized as Abuse of authority to gain undue
follows: favors or personal advantage to
• 1st Offense - Fifteen (15) days

Suspension
oppress. harass.and otherwise
•
prejudice another shall be
penalized either by suspension or
•• The penalty of Dismissal shall be by outright dismissal depending

imposed if the employee submits upon the gravity of the offense.
a falsified medical certificate
to justify his feigned illness or 3 Sowing Intrigues
• disability. Spreading false. inaccurate, and

misleading information about
••
@ Willi be penalized for another employee or superior to
undertime or leaving damage or slander reputation. or
work early? undermine his authority. shall be
o 1. Unauthorized Under-time; penalized as follows:
•
Loitering and Abandonment of 1st Offense - Fifteen (15) days
Post Suspension
•
Any employee who leaves his
workplace during or before his 4. Withholding of Cooperation
• work time ends. or leaves his

workplace for more than one (1) Refusal to cooperate where
• hour without the approval of his the Company's operations and

superior. shall be disciplined as interests are at stake will be
penalized as follows:
• follows:

Suspension
• 2nd Offense
3rd Offense
- Written Reprimand
- Seven (7) days
• 4th Offense
Suspension
- Fifteen (15) days
5. Withholding of Information
Refusing or failing without
•
Suspension
5th Offense - Dismissal justifiable reason. to
communicate information
• @ What behaviors do not

support teamwork?
that is needed to ensure the
performance or completion of
• o 1 Insubordination
Any direct order given by
any company operation. or for
sound decision. or to protect the
• a superior relating to work Company's interests- shall be

•
assignment must be promptly
obeyed. Penalty for refusal shall 1st Offense - Fifteen (15) days
be either suspension or outright
•
Suspension
dismissal depending upon the 2nd Offense - Dismissal
gravity of the offense.
•
•
•
PRIMER _ •
6. Giving False Information
•
Any employee-
responsibility
with the
of giving correct
o
~~ VAI..u.
~ •
information- who deliberately We take
•
•
or through negligence, gives responsibility for
inaccurate, misleading, or our decisions and
their results.
••
delayed information that leads to
damage to product and service
quality; customer dissatisfaction;
higher costs; lost revenues; 3. Concealing or Withholding
inefficiencies; and similar
•
Information
disruptions in operations shall be
Refusing to report information
••
on any wrongdoing or threat/
1st Offense - Seven (7) days danger to the safety of
Suspension employees, customers, property,
2nd Offense - Fifteen (15) days
interests, or to the profitability
Suspension
3rd Offense - Dismissal of the company's operations, will
be penalized according to the
•
@ What are my
responsibilities in
•
o
protecting my Company's
name and reputation?
4. Damage to Company
Causing damage to company
Property
•
1 Injuring Company Reputation property shall suffer the
following penalty: •
•
Every employee is expected
to help build and protect the 1st Offense - Fifteen (15) days
•
good name of the Company. Suspension
Anyone who spreads false 2nd Offense - Dismissal
rumor, embarrassing, ridiculing,

or mocking, or criticizing the
If the damage is deliberate
caused by disregard for standard
or
•
•
Company in public, shall suffer
operating procedures, the
the following penalty:
penalty shall be Dismissal.
Suspension @ What are my obligations
•
to keep a secure, safe
•
and healthy working
2. Revelation of Confidential
Information
environment?
Refusal to Cooperate With
•
•
Revealing or releasing " 1. Security Personnel
confidential information
Refusing to cooperate with
•
pertaining to the Company or
security personnel in the
assisting any person to access
performance of their duties shall
•
such confidential information,
be dealt with as follows:
shall suffer the penalty of
.1•
Dismissal.
•
••
CODE OF CONDUCT
---
1st Offense - Verbal Warning 5. Improper Wearing
2nd Offense - Written Reprimand of Company ID
3rd Offense - Seven (7) days
Penalty for failing to wear the
•
Suspension
4th Offense - Fifteen (15) days Identification Card on the chest
•
Suspension area for immediate security
5th Offense - Dismissal identification within Company
••
premises is as follows:
2. Unauthorized Use of Company
Property 1st Offense - Verbal Warning
Misusing company property for 2nd Offense - Written Reprimand
personal purposes or removing Suspension
• it from the usual area without

proper approval shall be
Suspension
• disciplined as follows: 5th Offense - Fifteen (15) days

Suspension
• 1st Offense - Verbal Warning 6th Offense - Dismissal

••
3rd Offense - Seven (7) days 6. Unauthorized Use of Another
Suspension Employee's 10
Suspension Using the Identification Card of
5th Offense - Dismissal another employee for gaining
•
access to Company premises;
3. Carrying Deadly Weapons and consequently allowing
•
Unless authorized by the another to use his ID will be dealt
Company, employees who carry with the following penalties:
• within company premises-

including company sponsored
Suspension
•
events- deadly weapons will be 2nd Offense - Fifteen (15) days
suspended or dismissed outright, Suspension
•
depending on the gravity of the
offense.
Z Climbing Tower Without
• 4. Failure to Wear Prescribed

Authorization to Climb
Climbing a tower without an
•
Uniform
Authorization to Climb shall be
Not wearing the prescribed
•
penalized by either suspension or
uniform while on duty shall be
by outright dismissal depending
dealt with as follows:
•
upon the gravity of the offense.
8. Tampering Safety Systems
2nd Offense - Three (3) days
• Suspension
3rd Offense - Six (6) days
Tampering Fire Protection
Appliances and Life Safety
•
Suspension
Systems, such as fire alarms and
extinguishers, smoke detectors,
• etc., shall be penalized by either

suspension or outright dismissal,
•
•
•
PRIMER
depending upon the gravity of •
the offense. N~R~
(:)0 ¥ •
9. Commission of Unsafe Acts
Unsafe acts and hazards caused We commit ourselves
•
•
to the principles and
by employees shall be penalized
best practices of
by either suspension or outright governance.
dismissal, depending upon the
10. Failure to Act on a Preventive/
Corrective Action Request
1st Offense - Written Warning
2nd Offense - Ten (10) days
••
(PCAR)
Suspension
•
All operating units involved in
operations and maintenance,
11. Poor Housekeeping and
Sanitation •
projects and site management,
are obliged to strictly comply All employees are obliged to be
•
••
with the Company Safety, Health safety conscious and concerned
& Environmental Management with the preservation of health
policies and procedures. and good housekeeping.
Penalties for violation are:
Failure to act on a non-
compliance matter those results
in business interruption, loss of
service or fatal accident shall be
penalized with Dismissal. Under
Suspension
••
•
other circumstances, the penalty Suspension
shall be as follows: 5th Offense - Fifteen (15) days
Suspension
•
THE RULES OF A DISCIPLINARY PROCEEDING
•
® What are the rules of a
Disciplinary Proceeding?
assisted by HR, Internal Audit.
Legal and Security when needed.
•
" 1. Responsibility of Line
Management3
2. Nature of Disciplinary
•
Line managers are responsible
Proceedings
Administrative investigations
•
for maintaining order and
discipline, including the
shall be summary in nature and
in the interest of due process; •
enforcement of rules and
the conduct of disciplinary
the Company shall use all
reasonable means to consider
•
proceedings, They shall be all facts in each case with speed
and objectivity.
•
, Line Management refers to all the officers of the Section, Department, Division or Group where the
•
employee con~erned is assigned.
•
•
•
•• 3. Fact-finding Inquiry: Gathering
0' Evidence
CODEOF CONDUCT
6. Period of Preventive Suspension

Preventive suspension lasts for
• Upon receipt of a report on

a violation. the Immediate/
thirty (30) days only and the
disciplinary proceedings are
• Next Level Superior should

immediately cause a fact-finding
terminated within this period.
If the employee concerned
•• inquiry with the purpose of

determining the accuracy of the
report and gathering evidence.
He or she shall be assisted by the
causes delay in the procedures.
this delay is not considered in
reckoning the 30-day period.
• Security. Internal Audit. HRor 7. Non-Accrual of Salaries and

Legal Divisions. Benefits During Preventive
• 4. NotIce 0' Administrative Charge

Suspension
During preventive suspension.
• If evidence shows violation of

rules. the Immediate Superior. in
the employee is not entitled to
salaries and benefits. unless he is
• coordination with the Division

Head/Group Head. issues a
later cleared of the charge.
During preventive suspension.
• Notice of Administrative Charge

against the employee.
the Immediate Superior is tasked
to notify:
• 5. Contents of the Notice of 7.l. Payroll and Timekeeping to
• Administrative Charge
The Immediate Superior and the
withhold salaries & benefits.
as well as
• Division Head/Group Head sign

on the Notice of Administrative
7.2. Security Division
for retrieval of the
• Charge. that specifies: Identification Card and

other company-issued
••
5.1. the particular acts or
properties.
omissions committed by the
employee; and 8. Answer/Explanation
5.2. directs the employee to
Within twenty-four (24) hours
• explain within twenty-four

(24) hours from receipt why
from receipt of the Notice of
Administrative Charge. the
• no disciplinary action should

be taken against him.
employee should submit his
written answer. Twenty Four
• The notice also states

"preventive suspension" for
(24) hours extension may be
requested by an employee as
• employees who may pose

serious and imminent threat
provided by law.
• to Company property or to
life.
9. Administrative Hearing
Whether the employee
• responds or not to the notice

of administrative charge. the
•
•
•
PRIMER
Immediate or Next Level Superior
with HR determines whether to
CODE OF CONDUCT
render a decision immediately

after the hearing to either
••
•
proceed with an administrative impose appropriate disciplinary
hearing. action or clear the employee of
•
In case of a hearing. the any charges.
Immediate Superior sends the The decision is signed by the
employee a written notice
stating the date. time and place
of hearing. He or she shall be
assisted by Security. Internal
Immediate Superior and noted
by the Division/Group Head.
In sexual harassment cases.
the decision is signed by the
••
Audit. HR. and/or Legal.
•
.'•
Committee on Decorum.
10. What happens in a sexual 12. Implementation of the Decision

harassment case?
The Immediate Superior serves
Cases involving sexual the Notice of Disciplinary Action
harassment shall be heard to the employee and provides
by a Committee
composed of:
on Decorum copies to:
12.1. Payroll and Timekeeping •
10.1. HR; who shall immediately
cut-off or adjust the •
•
10.2. Legal;
salaries and benefits of the
10.3. Security; and
employee for penalties of
10.4. Union. if a union
member is involved.
suspension.
dismissal;
demotion or
•
The administrative hearing is 12.2. Security Division who shall
•
•
summary in nature and limited to retrieve the Identification
factual issues not clear from the Card and other properties
•
evidence at hand. issued to the employee for
The accused employee will be penalties of suspension or
heard and may be assisted by
his lawyer or representative. The 12.3.
dismissal; and
Human Resources Group
•
participation or presence of such
lawyer or representative shall
shall file in the 201 of the
concerned employee any
•
not be allowed to delay or in any
way detract from the summary
decision rendered in a
disciplinary proceeding.
•
nature of the proceedings. whether for or against
employee
•
11. Decision
Based on substantial evidence.
12.4. Union; if a union member
is involved •
the Immediate Superior or the
Committee on Decorum. shall
•
•
•
•
•
• NOTES -------
•
•
•
••
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Primer on
Unethical Practices
•
•
• Unethical, Corrupt & Other
• Prohibited Practices
• A Globe employee maintains the highest standards of honesty and professional
••
conduct. Seeking undue financial and material advantage from transactions for
Globe is a breach of trust between him and the Company.
@ What are unbecoming

•
4. Divulging valuable, confidential
and unethical practices? information acquired in
o These are practices that do not
•
your official capacity to
conform to approved standards of unauthorized persons
• social or professional behavior.

@ What is gross
•
These are behaviors that are not negligence?
aligned with the organization's
codes of conduct that stress
o It is behavior that would naturally
• honesty, responsibility,
accountability and reliability.
and reasonably result in injury,
clearly disregarding the welfare
• @ What are corrupt

of the Company or consciously
ignoring adverse consequences,
• o
p-a-tices7 which were evident at the time
the contract was entered into. It is
•
1. Requesting or receiving violating the conflict-of-interest
financial or material benefit policy.
• for yourself or another from

anyone you have helped {or will @ Can I solicit gifts or
••
help} secure any contract or sponsorships from
purchase from Globe customers or suppliers?
2. You or any relative accepting
employment in an organization
o You cannot solicit personal gifts or
events sponsorship from potential
• that you are in business with-

or within one year after such
or current customers, suppliers,
contractors and sub-contractors.
• business had been terminated
•
3. Giving anyone unwarranted
benefits or advantages-
•
through partiality, bad faith
or gross negligence-in
performing your official
• functions
•
•
•
•
PRIMER
® Can I receive unsolicited
gifts from customers or O~~\lA~(/~
••
"
suppliers?
Within 48 hours of receipt, submit
We faithfully
•
•
adhere to the
the gift and a filled-out gift highest ethical
standards.
••
disclosure form to the Group Head.
He decides whether the gift will be
1) returned, 2) surrendered to the
Human Resources Group (HRG),or 3)
kept by the staff or Group.
® Can I fraternize with
Globe's customers and
If Globe is evaluating the giver as a suppliers?
•
•
contender for any kind of project or
" These have to be interactions
product accreditation, you will have that benefit the Company, which
•
to return the gift. may include supplier-hosted
You may, however. keep corporate sports activities. social events or
giveaways that do not exceed
Php3,OOOin cumulative value
workshops for Globe employees.
However, these have to be •
{within three months}. unsolicited and declared in advance.
The Group Head has to approve •
® Can a customer or
supplier sponsor my local
employee attendance, and the
Human Resources Group (HRG)has •
or foreign travel?
e Official business trips that benefit
to determine that the activity meets
Globe's standards of modesty. •
Globe require the Group Head's
endorsement and the President's
Unless they are work-related.
•
approval.
supplier-hosted activities should be
held outside of office hours.
•
•
A formally documented offer of
travel sponsorship has to layout
the itinerary and terms. In the case
of having to deliver a speech or
•
presentation, for example, you will
have to decline anything (other than
•
tokens of appreciation) that can be
considered as compensation.
•
Sponsored expenses also need to be
listed for the Company's reference •
in processing cash advances and
reimbursements. •
But a customer or supplier cannot
sponsor your trip if it is connected •
to their pending business with the
Company. •
•
•
•
• NOTES ------~
•
•
•
••
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• •
••
•
• Primer on
• Conflict of Interest
•
•
•
•
• A
GIObe employee is above board and, at all times, exercises discretion, prudence
•
and mature judgment when entering transactions for the Company.
This policy instructs employees. project hires. consultants and secondees on handling
• conflict-of-interest situations.
• @ What are conflict-of-

interest situations?
@ What should I do in a
conflict-of-interest
• o Your having a personal or financial
o
situation?
• interest or consideration that is

divergent or in conflict with your
Disclose this within 24 hours, in a
memo and disclosure form. to your
• professional obligations. that may

compromise or have the appearance
immediate supervisor and Group
Head.
• of compromising your judgment in

the administration. management.
Potential employees. project hires or
consultants must similarly disclose
• decision-making and discharge of

duties, including. but not limited to
in writing preexisting conflict-of-
interest situations before Globe can
• the following:
1. You-or your middleman-doing
possibly engage their services.
• business for Globe with your

spouse, relative (up to the
You are also expected to accomplish
the Related Party Disclosure Form
• fourth degree of consanguinity

annually, every January.
@ Can a conflict-of-
•
or affinity) or former employer
(within two years before this interest situation be
considered acceptable?
•
transaction);
2. Having a financial interest in a o If your immediate supervisor and
• business transaction where you

can officially intervene;
Group Head determine that your
work duties and responsibilities will
• 3. Accepting employment or
directorships outside of Globe.
not be compromised. they would
next seek the approval of the HRG
• except if your Group Head

had approved this upon your
Head and the President. Only upon
their clearance can you continue
• disclosure;
4. Access to sensitive information
in your current function (with
appropriate safeguards from your
• that is of value to your spouse.

relative or a former employer;
Group Head).
• S. Having a spouse. relative or close
• friend employed by competing

companies.
••
•
PRIMER _
•
o
~~\JALU~
•
Wetake
responsibility
~
•
•
for our decisions
and their results.
•
@ What happens after my
conflict-of-interest •
situation is considered
unacceptable? •
o You will be given one month to
•
•
resolve this by
1. seeking reassignment or
2. removing your relative from the
situation. In either case. you may •
continue your employment with
the appropriate safeguards. •
@ What happens if I fail to •
disclose my conflict-of-
interest situation? •
o This subjects you to reprimand,
•
•
suspension or termination at the
discretion of your immediate
•
supervisor. Furthermore, violation of
this policy may be construed as an
•
unethical or corrupt practice having
the consequences specified under
•
the Unethical, Corrupt and Other
Prohibited Practices Policy.
•
•
•
•
•
•
•
•
• NOTES -------
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
I.!.
•
•
•
Primer on
Whistleblower
•
•
• Whistleblower Reporting
• T his policy provides a mechanism for employees. suppliers and third parties. and
business partners to report activities that violate Company policies and
• regulations.
• @ What is whistleblower @ What kind of protection
•
reporting? willi be given?
o Mechanism for any person. o If you are not involved in the
• whether employed by Globe
or not. to submit information
reported improper activity. you
will not be subject to dismissal.
• on suspected: violations of the

Company policy on unethical and
demotion. harassment or
discrimination. The Disclosure
• corrupt practices. misappropriation

of Company assets. fraudulent
Committee will desiqnate a
Human Resources Group (HRG)
• reporting practices violations of

the Company's Stock Transaction
representative as a Whistle blower
Protection Officer to ensure this.
• Policy. violations of the Securities

Regulation Code. or violations of
However. if you withdraw your
disclosure. you lose the protection
• the Code of Corporate Governance.

of this policy.
• @ What is a protected
o
disclosure?
@ How do I report an
improper activity?
• A good faith communication

on improper activities (as listed
o 1. Call the Whistleblower Hotline
•
0917-8189934.
above) that we protect and hold in
confidence. 2. Submit a report through the
• As a whistleblower. protection Whistleblower Portal.
• of your identity and that of your 3. Send a letter to the e-mail

sources will be maintained to address gt_ whistleblower@
•
the extent possible within the globetel.com.ph for disclosures.
legitimate needs of law and the 4. Submit a letter to Employee
•
investigation. Relations (ER).HR-Service
However. a disclosure is not deemed Delivery Center at 3rd Floor. GT
• as a protected disclosure if it is:

false. simulated and malicious
Tower 1. Mandaluyong.
• intended to harass or slur the

character or service record of
• a person. or disrupt company

operations without any basis a
• mockery of this policy.
•
•
•
PRIMER
•
@ VYhat happens to my
o
disclosure? ~~RN~~
(.:)0 ~ •
You will be notified that your
complaint has been received. The We are driven
•
•
by a culture of
ERor the Complaint Administrator
excellence.
will relay this to the Disclosure
Committee for investigation and
action. •
If the Disclosure Committee is
involved in the report, this will be @ Y"hat happens to the •
endorsed to the Board of Directors. investigation results?
o The Disclosure Committee submits •
On the other hand, if a member
either of the Board of Directors its findings to the HRGfor the
•
or Employee Relations or the
Complaint Administrator is involved,
appropriate disciplinary action.
If the report finds that the improper •
this will be sent to the Corporate
Secretary.
activity risks damaging Globe's
reputation or financial standing, this •
@ When does a complaint will be forward to the Office of the
President and the Audit Committee •
o
call for an investigation?
If the Disclosure Comrnittee-
within 10 days of HRG'sreceipt.
•
•
The Audit Committee will
composed of the Company's
recommend if the report needs to
Corporate Secretary and one
•
be further relayed to the Board of
representative each from HRG,
Directors.
Internal Audit, Enterprise Risk
Management (ERM)and Legal
Services Division-determines that:
1)this policy covers the complaint,
and 2) sufficient and valid evidence
If the report determines that the
investigation subject is civilly and
criminally liable, a copy will be
forwarded to the Legal Division for
••
supports it. the appropriate legal action.
•
•
The committee either conducts the The Disclosure Committee will
investigation or assigns a handler state in its report whether the
•
to present his findings. This policy investigation results will be included
protects committee members in in the employee's 201file or vendor
•
the reasonable exercise of their accreditation file.
functions.
•
•
•
•
•
•
•
WHISTLEBLOWER
to conduct an investigation is not
• @ What are the role, rights

and responsibilities of a
an accusation; it is a neutral fact-
finding process.
• "
whistleblower?
Unless asked to participate, you
He has the right to consult with
• must refrain from investigating or

obtaining evidence on your own.
persons of his choice, including
legal representation. Unless there
• Be candid and thorough with Globe-

are compelling reasons against it,
he has the chance to respond to the
•
authorized investigators. investigation's evidences against
Unless the Committee on Protected him.
• Disclosures overrules it, you have to

be informed on the status of your
He may not withhold, fabricate or
alter evidence and testimony. These
• disclosure. Until you choose to

reveal yourself, your identity will be
obstruct the investigation and call
for disciplinary action.
• protected.
He will be informed of the
• @ What are the role, rights investigation results. Any

and responsibilities disciplinary action against him will
• of a~ i.nvestigation
participant?
follow personnel procedures.
@ Can a guilty
• " If asked to participate in an
investigation, you have a duty
whistleblower
Immunity?
be granted
• to cooperate. A request for

confidentiality will be honored. " The Disclosure Committee may,
• You cannot discuss evidence or

testimony to the investigation
under exceptional circumstances,
with the endorsement of the
• subject or with anyone else not

connected to the case.
President and approval of the Board
of Directors, grant immunity to a
• Do not withhold, fabricate or alter

whistleblower who participated in
improper activity.
• evidence and testimony. These

obstruct the investigation and call
However, there are conditions:
• for disciplinary action. 1. he must not be the guiltiest of

the investigation subjects;
•
@ What are the role, rights 2. his testimony is indispensable;
and responsibilltles of an and
•
investigation subject?
3. he extends his full cooperation.
" Once the Disclosure Committee
• informs the subject of the

allegation, he has the duty to
• participate in the investigation. His

identity will be protected and he
• will be informed of his right against

self-incrimination. The decision
•
•
•
NOTES •
,
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
• TABLE OF CONTENTS POLICIES &: PROCEDURES
• CODE OF CONDUCT
• Title I
Title II
Philosophy on Discipline
General Provisions
47
• ART. 1. Coverage 47
•
ART. 2. Uniformity of Penalties 47
ART. 3. Impersonal Imposition of Discipline 47
• ART. 4.
ART. 5.
Single Penalty
Responsibility of Superiors
47
47
• ART. 6.
ART. 7.
Responsibility of Employees
Obligation to Report Wrongdoing
47
48
• ART. 8.
ART. 9.
Duty of Superior to Act on the Report
Effect of Disciplinary Action on
48
• Career Improvement
ART. 10. Imposable Penalties
48
48
• ART.11. Separate Civil or Criminal Action 48
•
ART. 12. Non-Exclusivity 49
Title III Offenses And Penalties
• Chapter I Offenses Against Corporate Values Involving
• Honesty And Integrity

ART. 13. Corruption/Extortion/Bribery 49
• ART. 14. Fraud Against the Company

ART. 15. Theft. Pilferage or Misappropriation
49
49
• ART. 16. Perjury or False Testimony 49
•
ART. 17. Falsification 49
ART. 18. Conflict of Interest 50
• Chapter II Offenses Against Corporate Values Involving

Good Personal Behavior And Conduct
• ART. 19. Sexual Harassment .5'1
•
ART. 20. Immoral or Indecent Conduct 52
ART. 21. Fighting Within Company Premises 52
• ART. 22. Threats or Coercion

ART. 23. Discourtesy or Disrespect to co-employees
52
52
• ART. 24. Drunkenness

ART. 25. Use or Possession of Prohibited Drugs
52
52
• ART. 26. Smoking in Prohibited Places

ART. 27. Gambling
52
53
• ART. 28. Failure to Report Loss Incident Occurrence 53
•
•
« PROCEDURES TABLE OF CONTENTS •
POLICIES
•
Chapter III Anti-Customer Offenses
ART. 29. Discourtesy Against Customers S3
•
ART. 30. Unauthorized Disclosure of Information
ART. 31. Misinformation
53
53 •
ART. 32. Neglect of Customer
ART. 33. Mishandling a Customer
53
54 •
Chapter IV Offenses Against Job Performance
•
ART. 34. Failure on the Job
ART. 35. Non-Observance of Standard Operating
54
•
Procedures
ART. 36. Failure to Provide GUidance/
54
•
Failure of Management
ART. 37. Sleeping While on Duty
54
54
•
ART. 38. Absence Without Leave be
ART. 39. Tardiness
S4
55 •
ART. 40. Unauthorized Undertime
ART. 41. Limiting Work Output
5S
55 •
ART. 42. Loitering and Abandonment of Post 55
•
•
ART. 43. Malingering 55
ART. 44. Improper Use of Sick Leave 55
ART. 45. Culpable Delay in Disposing Disciplinary Cases
Chapter V Offenses Against Teamwork
56
•
ART. 46. Insubordination 56
•
•
ART. 47. Abuse of Authority 56
ART. 48. Sowing Intrigues 56
ART. 49. Withholding of Cooperation
ART. 50. Withholding of Information
56
57
•
ART. 51. Giving False Information
Chapter VI Offenses Against The Good Name
57
•
And Security Of The Company
•
ART. 52.
ART. 53.
Injuring Company Reputation
Revelation of Confidential Information
57
57
•
ART. 54.
ART. 55.
Concealing or Withholding Information
Damage to Company Property
57
57
•
Chapter VII Offenses Against Security, Safety, Health
•
•
And Environment
ART. 56. Refusal to Cooperate With Security Personnel. 58
ART. 57.
ART. 58.
Unauthorized Use of Company Property
Carrying Deadly Weapons
58
58
•
ART. 59. Failure to Wear Prescribed Uniform 58
•
•
• « PROCEDURES
• ART. 60.
TABLE OF CONTENTS POLICIES
Improper Wearing of Company 10 58
• ART. 61. Unauthorized Use of Another Employee's 10 •.••......59
• ART. 62.
ART. 63.
Allowing Another Employee to Use His 10
Climbing Tower Without Authorization to Climb
59
59
• ART. 64.
ART. 65.
Tampering Safety Systems
Commission of Unsafe Acts
S9
S9
• ART. 66. Failure to Act on a Preventive/Corrective Action

Request (PCAR) 59
• ART. 67. Poor Housekeeping and Sanitation S9
• Title IV Rules Of Disciplinary Proceedings

Rule I Preliminary Provisions
• SEC 1. Responsibility of Line Management 60
•
SEC 2. Nature of Disciplinary Proceedings 60
Rule II Fact-Finding Inquiry
• SEC 1. Gathering of Evidence

Rule III Administrative Proceedings
60
• SEC 1. Notice of Administrative Charge 60
,.
•
SEC 2. Contents of the Notice of Administrative
SEC 3. Period of Preventive Suspension
SEC 4. Non-Accrual of Salaries and Benefits
During Preventive Suspension
Charge 60
61
61
• SEC 5. Answer/Explanation
SEC 6. Administrative Hearing
61
61
• SEC 7. Decision
SEC 8. Implementation of the Decision
62
62
• SEC 9. Role of Payroll and Timekeeping

SEC '0. Role of Security Division
62
62
• SEC n, Role of the Human Resources Group 62
• Title IV Effectivity 62
• UNETHICAL, CORRUPT AND OTHER

• PROHIBITED PRACTICES
• I.
II.
Employee Responsibility
Trust and Confidence
67
67
• III.
IV.
Unbecoming and Unethical Practices
Corrupt Practices
67
70
• V.
VI.
Other Prohibited Practices
Reporting of Violations
71
73
•
•
•
TABLE OF CONTENTS POLICIES & PROCEDURES
•
CONFLICT OF INTEREST
I.
Objectives 77
•
II.
Scope
III.
Definitions
77
77 •
IV.
V.
Reference
General Policies and Guidelines
78
78 •
VI. Waiver or Relaxation of the Policy .79
•
•
VII. Liability for Violation 79
VIII.Application to Globe Consultants and Direct Project Hires 79
IX. Policies and Guidelines in Handling Conflict-Of
Interest Prior to Hiring and Engagement
X. Policies and Guidelines in Handling Conflict-Of
Interest of Existing Covered Employee
79
80
••
XI. Transitory Provisions
WHISTLEBLOWER
80
••
I.
II.
Introduction
Policy and Coverage
85
85
•
III.
IV.
Definitions
Form and Contents of Disclosure
86
86 •
V.
VI.
Reporting Allegations of Suspected Improper Activities
Evaluation of the protected disclosure and investigation
87
•
of the suspected improper activity 88
•
••
VII. Roles, Rights and Responsibilities of Whistleblowers,
Investigation Participants, and Subjects of the Investigation 89
A. Whistleblowers 89
B. Investigation Participants 90
C. Investigation Subjects
VIII. Whistleblower Protection Policy
90
92 •
IX. Dissemination and amendment of the policy 93
•
FORM •
Related Party Disclosure Form (F-HRG-43) 97
•
•
•
•
•
•
Policies and Procedures on
CODE OF CONDUCT
•
•
•• Code of Conduct
TITLE I PHILOSOPHY ON DISCIPLINE £:,,='·%m*=;=; _%*=*a··· =-==.===---!II
E very employee is expected to observe the highest standards of accountability,
• performance, punctuality, honesty, integrity, courtesy, and teamwork, and thus,

contribute to the achievement of the Company's goals of customer satisfaction,
• service excellence and profitability.
•
The Company adheres to the principle that the best form of discipline is self-discipline.
Employees must be able to discipline themselves without the compulsion of law or fear
•
of punishment. It is not enough that the employee should avoid doing "wrong" - he
should, consciously and as a personal commitment "do the right things the right way"
• for the right purpose at the right time.

Although disciplinary action may be imposed for any wrongdoing, the overall intent is
• more on the prevention of the infraction rather than the administration of the penalty.
•
• ART. 1. Coverage - This Code shall
apply to all employees of Globe Telecom,
results in a finding that two or more
violations defined in the Code have been
• Inc., Innove Communications, GXI,their

subsidiaries and affiliates.
committed, the penalty for the most
serious offense shall be applied.
• ART. 2. Uniformity of Penalties - ART. 5. Responsibility of Superiors -
• Discipline must be enforced

consistently. It shall be applied uniformly
It is the duty of every superior to
maintain discipline within his area
• to offenders similarly situated. of responsibility. He shall be strictly

accountable for the proper discipline
• ART. 3. Impersonal Imposition

of Discipline - The imposition of
and job performance of all subordinates
under him. failure of which, he shall be
• disciplinary action shall be directed

against the employee's wrongdoing, not
held responsible as provided elsewhere
in this Code. Correspondingly, each
• against his person or personality.

The identity of an employee who
superior shall be given sufficient
authority and power to effectively
• is the subject of a Code of Conduct

process and information on any Code
discharge the foregoing responsibilities.
• proceedings should be maintained in

confidence to the extent possible given
ART. 6. Responsibility of Employees-
It shall be the duty of every employee
• the legitimate needs of the law and the

fact-finding process.
to familiarize himself with all the
provisions of this Code. Ignorance of
• ART. 4. Single Penalty - Only one

or unfamiliarity with the provisions of
this Code shall not excuse any violation
•
penalty shall be imposed for each thereof.
offense. If an administrative charge
•
arising from one act or omission
•
•
POLICIES & PROCEDURES -
ART. 7, Obligation to Report
_
•
Wrongdoing - It shall be the duty
of every employee to report to o
~~VAL.u
~ •
management with reasonable dispatch
any information in their possession about
We take
ownership of •
any offense which has been, is being,
or is about to be committed, Failure to
our actions.
•
do so will subject the employee to the
appropriate disciplinary action, 1 •
The protection of the reporting party's
identity will be maintained to the extent
(a) Verbal Warning; 1
•
possible, within the legitimate needs of
law and the fact-finding process, Where
(b) Written Reprimand; 3
(c) Suspension; I, •
appropriate, the protected disclosure
protocols will be followed as specified in
(d) Demotion; sand
•
our Whistleblower policy,
(d) Dismissal. 6
In the imposition of the aforesaid •
ART. 8. Duty of Superior to Act on
the Report - It shall be the duty of the
penalties. the Company may consider
any attendant aggravating or mitigating •
superior to act immediately upon all
reports of violations, otherwise, he shall
circumstances,
•
be guilty of failure on the job, ART. 11. Separate Civil or Criminal
Action - The imposition of any of the
•
ART. 9. Effect of Disciplinary Action
on Career Improvement - An employee's
abovementioned penalties shall be
without prejudice to any civil. criminal
•
record of offenses shall diminish or
remove, as the circumstances may
or other actions which the Company
may decide to take against the erring
•
warrant, an employee's eligibility for
merit increases, promotion, incentives. or
employee.
The Code shall be a living document.
•
similar improvement in his job situation. as such, may be changed from time to
time. as may be required by any change
•
ART. lO.lmposable Penalties - The
following are the imposable penalties
in laws, rules and regulations that may
pertain to the behavior of employees. •
•
under this Code: Code update shall follow our HR policy
change. approval and cascade process,
•
1
2
In relation to Policies and Procedures Manual on Whistleblower (PM-HRG06-009/00)
Verbal warning is a penalty which cautions the erring employee to refrain from committmg the same offense
•
l
in the future under pain of a more severe penalty, This is documented as a recall mechanism
Written reprimand is a penalty more severe than warning in the sense that it is accompanied by censure,
rebuke or sharp scolding, •
4 Suspension is the temporary separation of an employee from service, When the penaity of suspension is
imposed, the number af days shall be understood to be working days,
•
S Demotion is the transfer at an employee to a lower rank or positian with or without the carrespanding
reduction in salary,
•
6 Dismissal is the permanent separation of an employee from service,
•
•
•
• CODEOF CONDUCT
•
ART.12. Non-Exclusivity - Acts and prerogative of the Company to discipline
omissions which may not fall under its employees.
•
the offenses specified in this Code but This Code does not preclude the
are clearly prejudicial to the interest Company from applying the just causes
•
of the Company shall be meted out for dismissal under the Labor Code and
the appropriate disciplinary sanctions. special laws.
• in consonance With the inherent
• TITLE III OFFENSES AND PENALTIES --------

I
• CHAPTER I OFFENSES AGAINST CORPORATE VALUES'INVOLVING
HONESTY AND INTEGRITY
• ART.13. Corruption/Extortion/ (g) gives due course or approval to a
• Bribery - Any employee who directly or

indirectly demands. requests. solicits.
document knowing it to be false
or erroneous.
• receives. or accepts any commission.

share. or consideration. monetary or ART.15. Theft. Pilferage or
• otherwise. for himself or for another

person. in connection with any contract
Misappropriation - Any employee who
steals. misappropriates. or attempts
• or transaction entered into by the

Company or in connection with the
to steal or misappropriate. funds or
properties belonging to the Company or
• performance of his duties. or by reason co-employee. shall suffer the penalty of

of his position or office. shall suffer the Dismissal.
• penalty of Dismissal.
ART. 16. Perjury or False Testimony -
Any employee who makes untruthful
•
ART.14. Fraud Against the Company-
The penalty of Dismissal shall be sworn statements or gives false
•
imposed against any employee who: testimony on a matter subject of official
inquiry or investigation by the Company.
(a] makes a false representation of shall suffer the penalty of Dismissal.
• facts;
ART. 17.Falsification - The penalty of
•
(b) employs any kind of deception;
Dismissal shall be imposed against any
(c) makes a false or fraudulent claim employee who:
• against the Company;

(d) initiates or participates in any (a) Falsifies any company document
• action intended to defraud the

Company'
or record;
(b) Enters false information on any
• (e) obtains payment benefit. or gain company document or record;
•
from the Company to which he is (c) Makes untruthful statements in a
not entitled. narration of facts; or
• (fl knowingly honors a forged

signature for his own benefit or
(d) Uses a falsified document or
certificates.
• that of another person; or
•
•
POLICIES & PROCEDURES
•
••
ART. 18. Conflict of Interest 7 - It held by the spouse of the
is the obligation of every employee to employee or his relative
declare and divulge in writing to the within the fourth degree of
Company his own involvement in any consanguinity or affinity; or
conflict of interest with the Company.
Failure on the part of an employee to
divulge the same to the Company shall
(ii) the former employer of the
employee within two (2)
•
be penalized with Dismissal.
years prior to the date of the
transaction in question.
•
•
In general, conflict of interest will be
(b) Directly or indirectly having
deemed to exist where an employee
financial or pecuniary interest
•
has or may possibly have a financial or
in any business, contract or
personal interest divergent with or in
transaction over which the
conflict with his professional obligations,
or where financial or other personal
employee has the occasion to
intervene or take part in his •
•
considerations may compromise, or
official capacity, or which will
have the appearance of compromising
require his endorsement or
the employee's judgment in the
administration, management, decision-
approval;
(c) Outside employment, •
•
making and discharge of his official
functions. Personal interest is not directorship, officership,
•
confined to the personal involvement of partnership, consultancy,
the employee himself - it may also arise distributorship, or agency in
•
from the employee's family" or close any company or enterprise
personal relationship? with a contractor, which adversely affects the
•
sub-contractor. customer, competitor, employee's working efficiency
creditor or any other entity that does and productivity;
business with the Company.
While the following list of conflict of
(d) Access to sensitive information
which may be of value to a
•
interest situations is not exhaustive, it
illustrates the types of situations that fall
person or entity where the
controlling interest is held by:
•
within the purview of this Code: (i) the spouse of the employee
or his relatives within
•
•
(a) Being in an official capacity to
the fourth degree of
negotiate, procure, endorse or
consanguinity 01' affinity; or
approve a transaction for and
behalf of the Company. either by (ii) the former employer of the
employee within two (2) •
himself or through a middlemen
or agent, with: years prior to the date of the
transaction in question. •
(il a person, or entity where
the controlling interest is
•
In relation to Policies and Procedures Manual on Conflict of Interest (PM-HRG06-007/02) •
•
7
8 Family relationship sholl include the spouse or relatives by consanguinity or affinity to the fourth degree
9 Close personal relationship shall include close friendship or professional employment by the employee
giving rise co or assuring free access to such employee.
•
•
•
•
CODEOF CONDUCT
•
(el Having a spouse or relative
within the fourth degree of ~~VAl.~
consanguinity or affinity with o ~
• individuals in the employ of a We value
our commitment
••
competitor or business partner;
to our
(fl Investments or other pecuniary customers.
or material interest. directorship.
officership. partnership.
• employment. consultancy.
distributorship. or agency or or excessive favors from a
contractor; sub-contractor;
• sub-agency in a contractor;
sub-contractor; customer; customer; competitor; creditor;
or any other entity that does
• competitor; creditor; or any

other entity that does business business with the Company or
• with the Company or which is in which is in competition with the

competition with the business of business of the Company;
• the Company;
(g) Borrowing money or property
(il Pre-empting the Company in
the purchase of any asset which
• from. or otherwise incurring any

debt to. any of the individuals.
the Company is interested in
acquiring;
• companies or enterprises
mentioned above;
UJ Taking for oneself. or passing
on to a relative or associate a
• (hl Solicitation or acceptance. business opportunity which

became known to the employee
•
whether directly or indirectly.
of payments. commissions. because of his position in the
Company.
•
rebates. services or gifts of more
than nominal value. excessive
•
entertainment. or improper
• CHAPTER II OFFENSES AGAINST CORPORATE VALUES INVOLVING

GOOD PERSONAL BEHAVIOR AND CONDUCT
I
•
I
ART. 19. Sexual Harassment - In of employment. promotions.
•
a work-related or employment compensation. privileges or other
environment. sexual harassment is considerations;
•
committed: (c) When refusal to grant the
sexual favor results in limiting.
(a) When sexual favor is solicited
• as a condition for hiring. re-

employment. or continued
segregating. or classifying the
employee which in any way
• employment of an employee; or
would discriminate. deprive.
or diminish employment
• (bl When sexual favor is solicited

as a condition for granting
opportunities or otherwise
adversely affect said employee;
•
favorable terms. conditions
•
POLICIES & PROCEDURES _ •
•
••
(d) When sexual advances impair the ART. 23. Discourtesy or Disrespect
employee's rights or priviieges to co-employees - Discourtesy or
under existing labor laws; or disrespect to co-employees shall be
(e) When the sexual advances result penalized as follows:
in an intimidating. hostile. or
offensive environment for the
First Offense - Seven (7) days
Suspension
•
•
employee. Second Offense - Fifteen (15) days
Suspension
Any employee who commits the Third Offense - Dismissal
aforementioned
whether
acts, regardless of
the demand, request or ART. 24. Drunkenness - Any
•
requirement is accepted. shall suffer the
employee who reports for work under
the influence of liquor. or who drinks
•
ART. 20. Immoral or Indecent
alcoholic beverages during working
hours (except on official functions) shall •
Conduct - Any employee who engages
in immoral. indecent. or lascivious
be penalized as follows:
•
•
behavior. including the use of profane or First Offense - Seven (7) days
Suspension
obscene language in addressing another
Second Offense - Fifteen (15) days
person. within the company premises
during working hours or while on duty Third Offense
Suspension
- Dismissal
•
ART. 25. Use or Possession of
•
•
First Offense - Three (3) days Prohibited Drugs - Any employee
Suspension
who uses or is found in possession
Second Offense - Seven (7) days
•
Suspension of prohibited or regulated drugs or
Third Offense - Fifteen (15) days narcotics shall be dismissed and/or dealt
•
Suspension with in accordance with the law under
Fourth Offense - Dismissal
the Comprehensive Dangerous Drug Act
•
(RA no. 9165).
ART. 21. Fighting Within Company
Premises - Any employee who quarrels,
ART. 26. Smoking in Prohibited
physically assaults. or engages in a fight
with a co-employee or any other person
Places- Smoking in designated smoke-
free zones in the employment premises •
within company premises shall suffer the
is strictly prohibited. Violation of this
rule shall subject the employee to the •
ART. 22. Threats or Coercion -
following penalties:
•
Threatening, intimidating. or coercing a
co-employee or a third party within the
First Offense
Second Offense
-
Verbal Warning
-
Written Reprimand
•
•
company premises shall be penalized as Third Offense -
One (1) day Suspension
follows: Fourth Offense -
Seven (7) days
Suspension
Suspension
Fifth and Subsequent Offense-Fifteen (15)
days Suspension
•
Second Offense - Fifteen (15) days
Suspension If the smoking was done in a place
•
•
Third Offense - Dismissal where smoking poses a threat to the
•
• CODE OF CONDUCT
• safety and security of company. the ART. 28. Failure to Report Loss
• penalty shall be as follows: Incident Occurrence - Failure to report

a loss incident occurrence. such as
• First Offense
Second Offense
- Fiheen (15) days
Suspension
Dismissal
motor vehicle accident involving a
service vehicle of the Company. property
• ART. 27. Gambling - Any employee

damage. etc. by an employee entrusted
therewith or in physical posession
• who indulges In gambling in any form at

any time within the company premises
thereof. shall be penalized as follows:
• shall be penalized as follows:

Suspension
• First Offense -Written Reprimand Second Offense - Fifteen (15) days

Suspension
Second Offense Fifteen (15) days
Suspension Third Offense - Dismissal
• Third Offense - Dismissal
• CHAPTER III ANTI-CUSTOMER OFFENSES

,
i
I
• ART. 29. Discourtesy Against ART. 31. MisinformatIOn - Giving
•
Customers - Discourtesy towards false. inaccurate. misleading. incomplete.
any customer in any form or delayed. or no information to customers.
•
aspect. including. but not limited when the employee knows. should
to rudeness. arrogance. insolence. know or is in a position to obtain such
•
impoliteness. disdain. contentiousness. information. resulting in inconvenience.
ungraciousness. incivility. or discomfort. dissatisfaction. or expense
•
inconsiderateness in word or action. to customer. shall be penalized as
shall be penalized as follows: follows:
• First Offense Three (3) days

Suspension
First Offense
Second Offense
- Verbal Warning
- Written Reprimand
• Second Offense
Third Offense
- Seven (7) days
Suspension
- Fifteen (15) days
Third Offense - Three (3) days
Suspension
•
Fourth Offense - Seven (7) days
Suspension Suspension
Fourth Offense Dismissal Fifth Offense - Fifteen (15) days
• ART. 30. Unauthorized Disclosure of Sixth Offense

Suspension
- Dismissal
• Information - Divulging the customer's

personal information. call details. billing ART. 32. Neglect of Customer - Failure
• statement. account and history. and or refusal to respond. assist or attend to

other confidential matters without the concerns of a customer or failure or
• proper authorization. shall be penalized refusal to provide prompt. efficient. and

as follows: courteous service to a customer shall be
•
First Offense Fifteen (15) days
Suspension First Offense - Verbal Warning
• Second Offense - Dismissal Second Offense

Third Offense
- Written Reprimand
- Three (3) days
• Suspension
•
POLICIES & PROCEDURES - _ •
Fourth Offense - Seven (7) days time. causing the customer to terminate •
Fifth Offense
Suspension
- Fifteen (15) days
his call. or setting the Automatic
Distribution
Call
on "busy" mode resulting in •
•
Suspension
Sixth Offense - Dismissal unanswered calls. shall be penalized as
follows:
•
Incompetence in responding and
attending to the concerns of the First Offense - Verbal Warning
•
customer shall be dealt with similarly. Second Offense - Written Reprimand
ART. 33. Mishandling a Customer - Suspension
Disengaging
call. transferring
or dropping the customer's
the customer's call to
Fourth Offense - Seven (7) days
Suspension
•
an invalid channel thereby leaving the
customer's concern unresolved. leaving
Fifth Offense
Sixth Offense
- Fifteen (lS) days
Suspension
- Dismissal •
the workstation for a long period of
•
CHAPTER IV OFFENSES AGAINST JOB PERFORMANCE
•
ART. 34. Failure on the Job - Any
employee who demonstrates his refusal
to dismissal depending
the offense.
on the gravity of
•
or inability without justifiable reason to
perform his duties and responsibilities; ART. 36. Failure to Provide Guidance/
•
or to accomplish
productivity
the performance
standards thereof shall be
and Failure of Management- Failure of a
superior to provide basic orientation.
•
meted a penalty depending upon the
gravity or frequency of the offense and
training or guidance to subordinates
in discharge of their duties and
•
on whether the situation is temporary or
remediable or permanent and incurable.
responsibilities, leading to violation of
company policies or existing laws shall
•
Where the acts amount to gross and
habitual neglect of duty or analogous to
be meted with a penalty ranging from
suspension to dismissal depending on
•
it. the penalty shall be as follows: the gravity of the offense.
•
First Offense - Verbal Warning
Second Offense - Written Reprimand
ART. 37. Sleeping While on Duty -
Sleeping while on duty shall be
•
•
Third Offense - Three (3) days penalized as follows:
Suspension
Fourth Offense -Seven (7) days First Offense - Verbal Warning
Fifth Offense
Suspension
- Fifteen (15)days
Second Offense - Written Warning
Third Offense - Seven (7) days
•
•
Sixth Offense - Dismissal Fourth Offense - Fifteen (lS) days
•
Suspension
ART. 35. Non-Observance of Standard Fifth Offense - Dismissal
Operating Procedures - Willful or
intentional non-observance of standard
operating procedures for direct or
ART. 38. Absence Without Leave
- Any employee who absents himself
•
indirect personal gain shall be meted
with a penalty ranging from suspension
from work without the previous notice
•
•
•
• CODE OF CONDUC'"
• to his immediate superior shall be First Offense - Verbal Warning
• penalized as follows:
• First Offense - Two (2) days Suspension

Suspension Fourth Offense - Fifteen (15) days
Suspension
•
Second Offense Three (3) days
Suspension Fifth Offense - Dismissal
• Suspension
Fourth Offense - Fifteen (15) days
ART. 41. Limiting Work Output - Any
employee who deliberately spends
•
Suspension
more time than reasonably necessary
Fifth Offense - Thirty (30) days
Suspension to perform his job or task, or incites.
• Absence without leave for fifteen

(15) days or more shall be considered as
others to do the same shall be meted
with a penalty ranging from suspension
• gross and habitual neglect of duty. for

which the penalty of Dismissal shall be
to dismissal depending on the gravity of
the offense
• imposed.
ART. 42. Loitering and Abandonment
• ART. 39. Tardiness - Any employee

who reports for work late for two (2)
of Post - An employee who idles
away his time within or outside of the
• times. or accumulates one (1) hour

tardiness. within a 7 day attendance
company premises, or abandons his post
during working hours, shall be penalized
• monitoring cycle. shall be penalized as

follows:
as follows:
• First Offense - Verbal Warning

• Third Offense Three (3) days

Suspension
Suspension
Fourth Offense - Fifteen (15) days
Suspension
• Fourth Offense - Seven (7) days

Suspension
Fifth Offense Dismissal
•
Fifth Offense - Fifteen (15) days
Suspension ART. 43. Malingering - Any employee
Sixth Offense - Dismissal who feigns illness or disability for
• For the above sixth offense to merit

purposes of avoiding work. duty or
service. or for other personal reason,
• dismissal. the first up to the sixth

offense must be committed within one
•
calendar year. i.e.. January to December First Offense - Fifteen (15) days
Suspension
of the same year
Second Offense Dismissal
• ART. 40. Unauthorized Undertime-

The penalty of Dismissal shall be
•
Any employee who leaves his workplace
imposed if the employee submits a
during his work time or prior to the
falsified medical certificate to justify his
•
expiration of his work schedule. or
feigned illness or disability.
leaves his workplace for more than one
(1)
•
hour thereof without the approval ART. 44. Improper Use of Sick Leave-
of his superior, shall be penalized as An employee who: (a) avails of his sick
•
follows: leave without informing his superior
•
auout the nature of his illness; (b)
•
extends his approved sick leave without
pnot notification; or (c) refuses to be o
~~VALU~
We are U' •
examined by the company-designated
physic Ian while on sick leave. shall be
relentless in
our pursuit of
•
penalized as follows: outstanding
performance
•
•
First Offense • Written Reprimand
Second Offense Seven (7) days
Suspension
1 hird Offense - Fifteen (15) days
Suspension
•
Fourth Offense Dismissal
ART. 45. Culpable Delay in Disposing

First Offense
Second Offense
Seven (7) days
Suspension
Fifteen (15) days •
Disciplinary Cases " Any official who
Third Offense
Suspension
Thirty (30) days
•
•
unreasonably delavs the resolution of Suspension
disciplinary cases shall be meted out the Fourth Offense Dismissal
followrng penalty
CHAPTER V OFFENSES AGAINST TEAMWORK •

ART. 46. Insubordination - AI Company. 01 weakeninq or destroyinq
•
Company Iules and regulations
intended to be complied
are
with by all
the trust and confidence of others In
him. or undermining or destroying the
•
employees. and any direct order given by
superior relating to work assignment
il
authority of his superior over others shall
be penalized as follows:
•
must be promptly obeyed.
Penalty shall be suspension or
Suspension
•
outright dlsmissal depending
qravi ty of the offense
upon the Second Offense - Dismissal
•
ART. 47. Abuse of Authority
-
ART. 49. Withholding of
Cooperation- Any employee who
•
Abusing the exerc se of one s authority
or taking undue advantage of such
refuses 01 falls to cooperate With or who
deliberately withholds cooperation front,
•
authority to gain undue favors or
advantage for oneself or to oppress,
or who refuses or fails to help, assist
and provide team support to fellow
•
hal ass. and otherwise prejudice another
shall be penalized either by suspension
employees, whether peers. superiors. or
subordinates when such cooperation
•
or outright dismissal. depending upon
the gravity of the offense.
and teamwork are needed to ensure
the performance or completion of
•
ART. 48. Sowing Intrigues - Any
any company operation or to protect
Company's interests. shall be penalized
•
•
employee who spreads or disseminates
as follows:
false. inaccurate, misleading information
•
about an employee with the intent of First Offense - Fifteen (15) days
Suspension
damaging. tarnishing or besmirching
Second Offense - Dismissal
•
his reputation or standing within the
•
•
• CODE OF CONDUC T
•
ART. SO. Withholding of misleading, Incomplete, or delayed
Information- Any employee who Information to a fellow employee which
•
refuses or fails without justifiable results in: damage to the quality of
reason, to communicate with 0 provide the Company's products and services;
•
information to a fellow employee when customer dissatisfaction; errors, delays,
such information or communication inefficiencies. higher costs, and similar
•
is authorized or needed to ensure the disruptions or irregularities in operations,
performance or completion of any losses or foregone revenues; lowering of
•
company operation, or for any employee employee productivity or morale; wrong
to make sound decision, or to protect or unsound decisions, or any other
•
the Company's interests shall be disruption or damage to the Company's
penalized as follows: effectiveness and efficiency in achievinq
•
Its goals, objectives and standards In an'!
Suspension area of its operations. shall be penalized
• Second Offense - Dismissal as follows'
First Offense Seven (7) days
•
ART. 51. Giving False Information- Suspension
Any employee who has the Second Offense - Fifteen (15) days
•
responsibility to give correct Information Suspension
who deliberately or through culpable Third Offense - Dismissal
•
negligence, gives false, Inaccurate,
• CHAPTER VI OFFENSES AGAINST THE GOOD NAME

AND SECURITY OF THE COMPANY
I:
• ART. 52. Injuring Company

Reputation- Any employee who causes
data)' or assistinq any person to access
such confidential informa lion, shall
• damage 01 injury to the reputation and

Image of the Company in the eyes of
suffer the penalty of Dismissal
• other people, such as by spreadinq

false Iumor about the Company,
ART. 54. Concealing or Withholding
Information - Concealing or withholdin«
• embarrassinq. ridiculing, 01 mocking

the Company by word and/or action in
from the appropriate authorities within
the Company any informat on any
• the presence of other people, whether

employees or not, or criticrzinq the
wrongdoing, or threat/danger to the
well-being or safety of the Company's
• Company in public, shall suffer the

followmq penalty'
personnel. customers. property.
Interests. or to the profitability of the
• First Offense - Fifteen (15) days

company's
depending
operations shall be penalized
upon the gravity of the
•
Suspension
Second Offense Dismissal offense
• ART. 53. Revelation of Confidential

Information - Revealing or releasing
ART. 55. Damage to Company
Property - Any employee who causes
• confidential information pertaining to

the Company (including. but not limited
damage to company property
suffer the following penalty:
shall
• to trade secrets, marketing or financial
•
•
POLICIES & PROCEDURES --- _
•
•
First Offense - Fifteen (15) days was deliberately done or was caused by
Suspension
the employee's deviation from standard
Second Offense - Dismissal
•
operating procedures, the penalty shall
If the damage to company property be Dismissal.
CHAPTER VII OFFENSES AGAINST SECURITY, SAFETY,

•
HEALTH AND ENVIRONMENT
•
•
ART. 56. Refusal to Cooperate With ART. 58. Carrying Deadly Weapons-
Security Personnel- Any employee Unless authorized by the Company,
•
who refuses to cooperate with security employees are not allowed to carry
personnel in the performance of their within company premises, including
•
duties shall be penalized as follows: company sponsored events, firearms,
knives, explosives. and other deadly
First offense - Verbal Warning
•
Second Offense
weapons. Violation of this rule shall
- Written Reprimand
Third Offense - Seven (7) days subject the employee to suspension or
•
Suspension outright dismissal, depending upon the
Fourth Offense - Fifteen (15) days gravity of the offense.
Suspension
Fifth Offense - Dismissal ART. 59. Failure to Wear Prescribed
Uniform - Any employee who does not •
ART. 57. Unauthorized Use of
Company Property - Company facilities
wear the prescribed uniform while on
duty shall be penalized as follows: •
and/or equipment are to be used as may
be required by the regular work of the First Offense - Written Reprimand
•
employee and as the nature of work
may require. No company facility and/
Second Offense - Three (3) days
Suspension
•
•
Third Offense - Six (6) days Suspension
or equipment maybe used other than
Dourth Offense - Dismissal
that for company purposes without the
previous authorization of the company
official concerned. Any employee who
ART. 60. Improper Wearing of
Company 10 - While inside the company
•
uses company property for personal
purposes, or takes or removes company
premises, employees should wear his
Identification Card on his chest for
•
property from the usual area, shall be
immediate security identification. Failure
to comply with this rule shall subject the
•
First offense
Second Offense
- Verbal Warning
- Written Reprimand
employee to the following penalties:
•
•
Third Offense - Seven (7) days Second Offense - Written Reprimand
Suspension
Fourth Offense
Fifth Offense
- Fifteen (15) days
Suspension
- Dismissal
Fourth Offense
Suspension
- Seven (7) days
•
•
Suspension
Fifth Offense - Fifteen (15) days
Suspension
Sixth Offense - Dismissal
•
•
•
'.• ART. 61. Unauthorized Use of Another
CODEOF CONDUCT
ART. 66. Failure to Act on a
• Employee's ID - Any employee who

uses the Identification Card of another
Preventive/Corrective Action Request
(peAR) - All operating units of the
• employee for the purpose of gaining Company, including employees involved
•
entry to the company premises or in operations and maintenance of
offices shall be penalized as follows: buildings, facilities or sites; or those
••
involved in the implementation of
Suspension projects, i.e., construction and telecom
Second Offense - Fifteen (15) days works; and those involved in other
Suspension activities relating to site management,
Third Offense - Dismissal are obliged to strictly comply with
• ART. 62. Allowing Another Employee

Safety, Health & Environmental
Management policies and procedures of
• to Use His ID - Any employee who

allows his Identification Card to be used
the Company. Any Preventive/Corrective
Action Request (PCAR)must be acted
• by another employee shall be penalized

as follows:
upon with dispatch.
•
Failure to act or close a Preventive/
First Offense - Seven (7) days Corrective Action Request (PCAR)on a
Suspension
• Second Offense - Fifteen (15) days

Suspension
matter relating to non-compliance with
standard operating procedures resulting
• in business interruption, loss of service

Third Offense - Dismissal
or fatal accident shall be penalized with
ART. 63. Climbing Tower Without
•
Dismissal. Ifthe omission did not result
Authotization to Climb - Any
in business interruption. loss of service
employee who climbs a tower without
•
or fatal accident, the penalty shall be as
an Authorization to Climb shall be follows:
penalized by either suspension or
• outright dismissal depending upon the

First Offense
Second Offense
- Written Warning
- Ten (10) days
•• ART. 64. Tampering Safety Systems-

Tampering Fire Protection Appliances
and Life Safety Systems, such as fire
Third Offense
Suspension
- Dismissal
ART. 67. Poor Housekeeping

Sanitation - Clean and healthy
and
• alarms, fire extinguishers, smoke

detectors, etc., shall be penalized either
surroundings is conducive to work
and appealing to customers. All
• by suspension or by outright dismissal

depending upon the gravity of the
employees, therefore. are obliged to be
safety conscious and concerned with
• offense. the preservation of health and good

housekeeping. Spitting, throwing papers,
• ART. 65. Commission of Unsafe

Acts - Commission of unsafe acts and
cigarette butts. trash, etc. on the floor,
including improper use of toilet facilities
• hazards that endanger co-employees

and company property shall be
are strictly prohibited. Violation thereof
• penalized either by suspension or by

outright dismissal depending upon the
• gravity of the offense.
•
•
~

First Offense - Verbal Warning Fourth Offense - Seven (7) days
_
•
Second Offense
Third Offense
- Written Reprimand
- Three (3) days Fifth Offense
Suspension
- Fifteen (15) days
•
•
Sixth Offense - Dismissal
TITLE IV RULES OF DISCIPLINARY PROCEEDINGS

•
RULE I PRELIMINARY PROVISIONS
SECTION 1. Responsibility of Line
Management 10 - The maintenance
of order and discipline is basically a
SECTION 2. Nature of Disciptinary
Proceedings - Disciplinary proceedings
••
•
or administrative investigations shall
Line Management responsibility. Thus, be summary in nature. The rules of
•
enforcement of rules, including the procedure and evidence as applied
conduct of disciplinary proceedings, in judicial proceedings shall not be
•
is a Line Management function. He or controlling. The Company shall use all
she shall be assisted by HR, Internal reasonable means to ascertain the facts
•
Audit, Legal and/or Security as may be in each case speedily and objectively. all
warranted by the circumstances of each in the interest of due process.
•
case.
RULE II FACT -FINDING

SECTION 1. Gathering of Evidence-
INQUIRY
to be conducted for the purpose of •
Upon receipt of a report. verbal or
written. signed or unsigned. that
determining the veracity of the report
and gathering the necessary evidence. •
a violation of company rules and
regulations has been committed or is
which may be in the form of documents
or sworn statements of witnesses. For •
being committed. the Immediate or
Next Level Superior concerned shall
this purpose. the Immediate Superior
shall be assisted by Security. Internal •
immediately cause a fact-finding inquiry Audit. HR and/or Legal Divisions.
•
RULE III ADMINISTRATIVE PROCEEDINGS
•
SECTION 1. Notice of Administrative
Charge - If the evidence gathered shows
SECTION 2. Contents of the Notice of
Administrative Charge - The Notice of
•
that an infraction has been committed.
the Immediate or Next Level Superior.
Administrative
the Immediate
Charge shall be signed by
Superior and noted by the
•
in close coordination
Head/Group
with the Division
Head. shall issue a Notice
Division Head/Group Head. and shall:
•
of Administrative Charge against the
employee concerned.
(a) Specify the particular
omissions committed
acts or
by the
•
employee; and
•
10 Line Management refers to all the officers of the Section. Department, Division or Group where the employee
•
•
concerned is assigned.
•
•
•
_______ CODEOF CONDUCT
(b) Direct the employee to explain SECTION 5. Answer/Explanation -
• within twenty-four (24) hours

from receipt why no disciplinary
Within twenty-four (24) hours from
receipt of the Notice of Administrative
• action should be taken against

him.
Charge. the employee shall submit his
written answer. Twenty Four (24) hours
• If the continued presence of the extension may be requested by an

employee as provided by law.
•
employee poses a serious and imminent
threat to the property of the Company SECTION 6. Administrative Heanng -
• or to the life of co-employees. the

employee concerned shall be placed
Upon receipt of the answer/explanation.
or if the employee does not submit any
•
under preventive suspension. and this
answer/explanation. the Immediate
matter shall be stated in the Notice of
Superior with HR shall determine
• Administrative Charge.
SECTION 3. Period 01 Preventive

whether or not there is a necessity to
conduct administrative hearing.
• Suspension - The preventive suspension If the Immediate Superior (IS)and

HR deem it proper to conduct an
•
shall last for thirty (30) days only. The
disciplinary proceedings should be administrative hearing. the ISshall send
to the employee a written notice stating
•
terminated within this 30-day period. If
the disciplinary proceedings could not be the date. time and place of hearing.
terminated during the 30-day period due In the conduct of the administrative
• to a cause attributable to the fault of the hearing. the Immediate Superior may
shall be assisted by HR. Internal Audit.
•
employee. such period of delay shall not
be considered in reckoning the 30-day Legal and/or Security.
•
period. Cases involving sexual harassment
shall be heard by a Committee on
SECTION 4. Non-Accrual of Salaries
•
Decorum composed of representatives
and Benefits During Preventive from:
Suspension - During the 30-day period
•
(a) HR;
of preventive suspension. the employee
is not entitled to salaries and benefits. (b) Legal;
• unless he is later exonerated of the

charge.
(c) Security; and
• To ensure that the employee is not

(d) Union. if a union member is
involved.
•
paid any salaries and benefits during
The administrative hearing shall
the period of his preventive suspension.
be summary in nature and shall be
•
the Immediate Superior shall notify
limited to factual issues not clear or
Payroll and Timekeeping about the
ascertainable from the evidence at
preventive suspension of the employee.
• The Immediate Superior shall likewise

notify the Security Division about the
hand. The employee shall be given
ample opportunity to be heard and if
• preventive suspension to enable it to

retrieve the Identification Card and other
he so desires. he may be assisted by his
lawyer or representative. However. the
• company-issued property.
participation or presence of such lawyer
or representative shall not be allowed to
•
•
POLICIES & PROCEDURES •
unduly delay or in any way detract from
--- -- ------------
(a) Payroll and Timekeeping; •

the summary nature of the proceedings. (b) Security Division; and
•
SECTION 7 Decision - After the
termination of the administrative
(c) Human ResourcesGroup.
(d) Union; if a union member is •
hearing. the Immediate Superior
or the Committee on Decorum.
involved
•
shall immediately render a decision
imposing the appropriate disciplinary
SECTION 9. Role of Payroll and
Timekeeping - Upon receipt of the
•
action or exonerating the employee.
if the evidence does not establish any
notice of disciplinary action. Payroll and
Timekeeping shall immediately cut-off
•
infraction.
The decision shall be rendered on
or adjust the salaries and benefits of
the employee who was meted out the
•
the basis of substantial evidence. which
means such relevant evidence which
penalty of suspension. demotion. or
dismissal.
•
a reasonable mind might accept to
support a conclusion and shall state
SECTION 10. Role at Security
•
the factual basis for exoneration or
imposition of the disciplinary action.
Division - Upon receipt of the notice of
disciplinary action. the Security Division
•
The decision shall be signed by the
Immediate Superior and noted by the
shall retrieve the Identification Card and
other properties issued to the employee
•
Division Head/Group Head. In sexual
who was meted out the penalty of
suspension or dismissal.
•
•
harassment cases.the decision shall be
signed by the Committee on Decorum. SECTION 11. Role of the Human
•
Resources Group - Any decision
SECTION 8. Implementation of the rendered in a disciplinary proceeding.
Decision - The Immediate Superior shall
•
whether for or against an employee.
serve the Decision to the employee. shall be filed by the Human Resources
Simultaneous with the service of the
•
Group in the 201 Files of the concerned
decision. the Immediate Superior shall employee.
notify and furnish a copy of the decision
to:
•
TITLE V EFFECTIVITY "'""'=;----------:-========:~~Z!!!
•
This Code of Conduct shall take effect on 06 August
Done in Mandaluyong City on 01 August 2007.
2007.
•
•
•
•
•
•
•
•
• NOTES -------
•
•
•
•
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•
•
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•
•
•
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·1
•
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•
•
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•
•
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J
•
•
Unethical Practices
•
•
•
• Unethical, Corrupt and Other
• Prohibited Practices
• I. EMPLOYEE RESPONSIBILITY m=;;:~~~~Ii\liIIilml~ __
•• I tis every employee's responsibility to protect the interest and integrity of Globe
and to maintain the highest standards of professional conduct expected of all
Globe employees. The employee should. therefore. maintain the highest degree of
honesty. integrity and devotion to duty. with full awareness that any misconduct or
• misdemeanor on his part may constitute a breach of trust and confidence that Globe
has reposed to him.
• II. TRUST AND CONFIDENCE
• The employee. by virtue of his employment. is bound not to betray that trust by
seeking to gain any undue personal or pecuniary advantage (other than the rightful
•
proceeds of employment) from his dealings with or for and in behalf of the Company.
• 3.1. Solicitation of gifts. presents unbecoming and is
• or other personal benefits from

suppliers. contractors. sub-
strictly prohibited.
•
3.1.2. Solicitation of gifts or
contractors of contractors. their other personal benefits
employees or agents. as well
•
from the Covered
potential suppliers. contractors Persons in connection
and sub-contractors. or
•
with or in consideration
from customers or potential of business with the
customers. including but
•
Company or help to be
not limited to persons given by the employee in
applying for accreditation as
•
business with Company
suppliers. contractors or sub- is considered a corrupt
contractors. persons or entities
•
practice and shall be
requesting for type-approval covered by the Corrupt
of equipment. and bidders
••
Practices provision of this
on projects (collectively. policy.
the "Covered Persons") is
considered unbecoming of 3.2. Receipt of unsolicited gifts
from customers or suppliers
an employee and is strictly
• prohibited.
during national festivities such
as Christmas. during which it
•
3.1.1. Requesting the Covered is customary to give or receive
Personsto host any of gifts. is not prohibited. but
•
the activities mentioned must be declared regardless of
in Sec. 3.3 hereof is amount.
•
likewise considered
•
•
POLICIES & PROCEDURES ------------
•
•
3.2.1. Upon receipt of a gift the Sec. 3.2; [ii] food gifts,
employee must within gifts of liquor and gifts
•
48 hours from receipt of personal toiletries
of the gift fill out a gift worth more than Php
•
disclosure form (F-HRG- 3,000 must also be
44) and submit that form declared and approved in
•
together with the gift to accordance with Sec. 3.2.;
the Group Head who shall (iii) a series of gifts given
•
decide whether (1) the within three(3) months
same shall be returned the cumulative value
•
to the giver, or (b) should of which exceeds Php
be surrendered to HRG, 3000 must likewise be
•
or (c) kept by the staff declared and approved in
or the Group. The Group accordance with Sec. 3.2.
•
Head must sign off on 3.3. Unsolicited gifts that are purely
the disposition of the gift due to personal or family
•
and the form must be relationships are not covered
submitted to HRG within by this policy.
•
one week from receipt of
3.4. The foregoing notwithstanding,
the gift.
an employee must return to
3.2.2 As an exception however,
the following may be
the giver any unsolicited gift
of any value received during
•
kept by the employee
and need not be declared:
a period of time when the
giver is subject of evaluation •
(i) company give-aways
Covered Persons bearing
by Globe, including but not
limited to periods of time •
the Covered Person's
name or logo which are
when the vendor is undergoing
shortlisting for tenders, has •
of insignificant value.
such as umbrellas. diaries
been included as a contender
a Request for Proposal, Request
in
•
and planners, T-shirts,
jackets. sports bags and
for Quotation, Request for
Indication of Interest, bidding,
•
the like; (ii) gifts of food,
liquor, and personal
toiletries.
3.2.3. The foregoing
accreditation, product type-
approval, and other similar
activities.
•.1
•
3.5. A customer or supplier's offer
notwithstanding (i) a to sponsor local or foreign
company give-away
•
travel, which travel is not the
worth more than other party's obligation to
P3,OOO however shall be
•
provide under any contract
considered significant or undertaking, should be
and must be declared and
•
declined if it does not meet the
approved by the group following conditions:
head in accordance with
•
•
• UNETHICALPRACTICES
• 3.5.1 It is for contract signings, to by the Company
• training or attendance at
conventions, assemblies
in processing cash
advances and expense
• or otherwise related to
the Company's business
reimbursements related
to the travel.
• and which benefit the

Company; and
3.6 The company encourages its
•
employees and the Covered
3.5.2 It is not in connection Personsto deal with each other
•
with or in consideration on a purely professional basis
of any pending business and to minimize fraternizing
• with the Company; and

3.5.3 Such travel has been
with each other unless such
contact benefits the company.
• endorsed by the Group

Head and approved
Therefore:
3.6.1 Sports activities hosted
• by the President prior

to taking such trip.
by suppliers and vendors
specifically and only
• The Group Head's

endorsement should
for Globe employees,
or exclusively between
• be based on the careful

review of formally
Globe employees and
the vendor's staff and
• documented offer of
travel sponsorship that
employees, whether
individually or in groups,
• sets out the itinerary,

including terms and
are permitted forms of
interaction only if they
• arrangements for
the travel such as: (i)
are (i) unsolicited, (ii)
properly declared prior
• Any required labor

from the employee
totheactualeventand
(iii) the employees'
• such as the rendition

of presentations or
attendance is approved
by the Group Head
• speeches. In this case,

the employee should
concerned.
3.6.2 Short-duration social
• refuse to accept anything

(other than tokens of
activities such as parties,
lunches and dinners
• appreciation) which
can be construed as a
hosted by suppliers and
vendors that have no
• form of compensation.
(ii) Expensesthat will
work-related agenda are
not prohibited provided
• befortheaccountof
the Covered Persons,
they are (i) unsolicited; (ii)
declared prior to the
• including billing
arrangements with the
actual event and (iii) the
employees' attendance
• travel agent and hotel.

This will be referred
must be approved by
the immediate superior
•
•
•
concerned. Moreover.
_
•
these must be of modest
value only. Offers for such o
~~ VAl(/.
We take ~ •
activities where the cost
exceeds Php 1.000 per
ownership &
responsibility
•
head should be declined.
for our actions.
decisions their
•
•
3.6.3 Long-duration social results.
activities which are
3.6.4 All the foregoing
•
work-related such as
team-buildings. product activities hosted by
the Covered Persons
•
workshops, project kick-
offs and the like. hosted except for work-related
activities should be held
•
by suppliers and vendors
are allowed provided outside of office hours.
they are (i) unsolicited.
(ii) declared prior to the
3.6.5 Raffle prizes or gifts
or tokens to be given
•
event and approved
by HRGand the Group
duringanyoftheabove
occasions (whether
•
Head. and (iii)subject to
standards of modesty. as
work-related or not)
should be declared in
•
•
determined by HRG. accordance with the gift
policy stated in Sec. 3.2
hereof.
•
•
IV. CORRUPT PRACTICES
The following are deemed corrupt another, from any person for
practices:
4.1 Directly or indirectly requesting
whom the employee. in any
manner or capacity. has secured •
or receiving any gift. present.
share. percentage or benefit for
or will secure or obtain or
will help to secure or obtain, •
himself or any other person, in
connection with any contract
any contract, purchase or
award from the Company, in •
or transaction between the
Company and any other party.
consideration for the help given
or to be given. •
whether or not the employee.
in his official capacity. has any
4.3 Accepting or having any
•
participation. negotiation.
procurement, endorsement,
member of his family accept
employment in a private
•
approval. or intervention in any
manner whatsoever.
enterprise that has pending
official business with him
•
4.2 Directly or indirectly requesting
during the pendency thereof
or within one year after the
•
or receiving any gift. present
or other pecuniary or material
termination of such official
business.
•
benefit for himself or for
•
•
•
•
UNETHICALPRACTICES
4.5 Divulging valuable information
•
4 4 Causing any undue injury to the
Company or giving any private of a confidential character.
acquired by him in his official
•
party unwarranted benefits.
advantage or preference in capacity. to unauthorized
persons.
•
the discharge of his official
functions through manifest
•
partiality. evident bad faith or
gross inexcusable negligence.
• V. OTHER PROHIBITED PRACTICES
• 5.1 Employees are expected to

exercise due diligence in
Sec. 31. Liability of directors,
trustees or officers. - Directors
• their work and protect the

Company's interest at all
or trustees who willfully and
knowingly vote for or assent to
• times. Therefore, the Company

punishes gross negligence
patently unlawful acts of the
corporation or who are guilty
• in entering on behalf of the

Company, into any contract
of gross negligence or bad
faith in directing the affairs of
• or transaction patently and

grossly disadvantageous to the
the corporation or acquire any
personal or pecuniary interest
• Company, whether or not the

employee benefited thereby.
in conflict with their duty as
such directors or trustees shall
• 511 Gross negligence is the

pursuit of a course of
be liable jointly and severally for
all damages resulting therefrom
• conduct that would

naturally and reasonably
suffered by the corporation, its
stockholders or members and
• result in injury. It is an
utter disregard of the
other persons.
When a director, trustee or
• welfare of the Company

or consciously ignoring
officer attempts to acquire
or acquires, in violation of his
• adverse consequences
which were clearly
duty, any interest adverse to
the corporation in respect of
• evident at the time the

contract was entered
any matter which has been
reposed in him in confidence,
• into. as to which equity imposes a

disability upon him to deal in
•
5.2 All violations of the Conflict
of Interest policy (ref. no. PM- his own behalf, he shall be liable
as a trustee for the corporation
•
HRG06-007)
and must account for the profits
5.3 For members of the Board of which otherwise would have
• Directors. violations of Sections

37-34 of the Corporation
accrued to the corporation.
• Code of the Philippines. and

violations of the Code of
• Corporate Governance.
•
•
Sec. 32. Dealings of directors, directors or trustees involved •
trustees or officers with the
corporation. - A contract of
is made at such meeting:
Provided. however. That the •
the corporation with one or
more of its directors or trustees
contract is fair and reasonable
under the circumstances. •
or officers is voidable. at the
option of such corporation.
Sec. 33. Contracts between
•
•
corporations with interlocking
unless all the following directors. - Except in cases
conditions are present:
•
of fraud. and provided the
1. That the presence of such contract is fair and reasonable
•
director or trustee in the under the circumstances.
board meeting in which the a contract between two or
•
contract was approved was more corporations having
not necessary to constitute a interlocking directors shall not
•
quorum for such meeting; be invalidated on that ground
2. That the vote of such alone: Provided. That if the I
•
director or trustee was not interest of the interlocking
necessary for the approval of director in one corporation is
•
the contract; substantial and his interest
3. That the contract is fair in the other corporation or
•
and reasonable under the corporations is merely nominal.
circumstances; and he shall be subject to the
•
provisions of the preceding
4. That in case of an officer. the
section insofar as the latter
contract has been previously
•
corporation or corporations are
authorized by the board of
concerned.
directors.
Where any of the first two
conditions set forth in the
Stockholdings exceeding
twenty (20%) percent of the
•
preceding paragraph is absent.
in the case of a contract with
outstanding capital stock shall
be considered substantial
•
a director or trustee. such
contract may be ratified by
for purposes of interlocking
directors.
•
the vote of the stockholders
representing at least two-
Sec. 34. Disloyalty of a
director- Where a director. by •
thirds (2/3) of the outstanding virtue of his office. acquires for
himself a business opportunity
•
•
capital stock or of at least two-
thirds (2/3) of the members in a which should belong to the
meeting called for the purpose: corporation. thereby obtaining
Provided, That full disclosure
of the adverse interest of the
profits to the prejudice of such
corporation, he must account •
to the latter for all such profits
by refunding the same. unless •
his act has been ratified by
a vote ofthe stockholders
•
•
•
• UNETHICAL PRACTICES
• owning or representing at notwithstanding the fact that
• least two-thirds (2/3) of the

outstanding capital stock. This
the director risked his own
funds in the venture.
• provision shall be applicable.
• VI. REPORTING OF VIOLATIONS ---~~------.,
• Employees who witness violations of this policy should report the same to the
Human ResourcesGroup.
•
•
•
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,--------- NOTES •
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Conflict of Interest
• CONFLICTOF INTEREST
• ----------------------------------------
• I.
T
OBJECTIVES
o provide guidelines that would define a conflict-of-interest situation and that
• would direct employees in the manner by which they are to conduct themselves
when placed in such situation/so
• II. SCOPE
• This policy shall apply to all regular employees, officers and directors of Globe
and Subsidiaries, including consultants/project hires seconded to or engaged on a full-
• time basis by Globe, although they are not considered as a Globe regular employee
(hereafter referred to as Covered Employee/s). This will automatically form part of the
• existing Globe Code of Conduct booklet.
• III. DEFINITIONS
Conflict-of-Interest - a situation where a Covered Employee has or possibly
• may have a personal or pecuniary interest divergent or in conflict with his professional
obligations, or where financial or other personal considerations may compromise,
• or have the appearance of compromising, the Covered Employee's judgment in the

administration, management, decision-making and discharge of his official functions.
• Conflict of Interest situations shall include, but are not limited to the following:
•
1. Being in an official capacity to Covered Employee has the
negotiate, procure, endorse occasion to intervene or take
•
or approve a transaction for part in his official capacity,
and in behalf of the Company, or which will require his
•
either by himself or through a endorsement or approval.
middleman or agent, (a) with 3. Outside employment and/or
•
a person, or a company where personally held directorships
the controlling interest is held outside of Globe, except as
•
by a person who is the spouse disclosed by the Covered
of the Covered Employee Employee and approved by his
•
or is related to the Covered Group Head.
Employee within the fourth
4. Access to sensitive information
•
degree of consanguinity or
affinity, or (b) with one who which may be of value to a
person or a company where the
•
is the Covered Employee's
former employer within two (2) controlling interest is (a) held by
a person/s, who is the spouse of
•
years prior to the date of the
transaction in question. the Covered Employee or related
to the Covered Employee within
• 2. Otherwise directly or indirectly

having financial or pecuniary
the fourth degree of affinity
or consanguinity, or (b) who /
• interest in any business,

contract or transaction in
which is the Covered Employee's
former employer within two (2)
• connection with which the
•
•
years prior to the date of the individuals in the employ of •
transaction in question. competitor companies or
business partners. •
•
5. Having a spouse or a relative
within the fourth degree of 6. Such other instances analogous
•
consanguinity or affinity with to the foregoing.
IV. REFERENCE
•
..Wi ,ii 11lIf!!S
PM - HRG06- 008 Unethical, Corrupt and other Prohibited Practices
V. GENERAL POLICIES AND GUIDELINES ----.......,.,...-'-

•
1. It is everyCoveredEmployee's
responsibility to protect the
in three (3) copies to the Group
Head, who shall retain a copy
•
interests and integrity of Globe
and to maintain the highest
for himself and forward the
remaining 2 copies to the Head
•
standards of conduct when
performing his duties and
of the Human Resources Group.
5. Apart from the regular •
responsibilities and in entering
into, negotiating or procuring
disclosure, any Covered
Employee who may, at any •
transactions for and in behalf of
the Company.
time, find himself in any of the
conflict-of-interest situation •
2. Every Covered Employee is
enjoined to exercise utmost
should, within twenty-four
(24) hours from the discovery •
discretion, prudence and mature
judgment in the discharge of
of such, disclose the same in
a written memo to his Group •
his duties and responsibilities
to avoid conflict-of-interest
Head, attaching thereto
the Disclosure form. The •
situations or any appearance
thereof.
procedures in the handling of
conflict-of-interest situations •
3. Covered Employees to be hired of existing Covered Employees
are further explained at a later •
or engaged by the Company are
advised to disclose pre-existing portion of this policy.
•
conflict-of-interest situations
as defined in this policy. The
6. The failure to disclose the
existence of a conflict-of-
•
procedures in the handling of
conflict-of-interest situations
interest situation is deemed by
the Company as an actionable
•
•
prior to hiring or engagement offense. Physical or pecuniary
are further explained at a later damage to the Company is not
•
portion of this policy. an element of this offense;
4. Existing Covered Employees rather, it is the breach of the
must accomplish on an annual
basis on or before the end of
employee's duty of utmost
loyalty to the Company and
•
•
January of each year the Related integrity and honesty in all
Party Disclosure form (F-HRG- acts that the penalty seeks to
43). The form shall be submitted address.
•
•
• VI. WAIVER OR RELAXATION OF THE POLICY --=========m

• The President and the Head of the Human Resources Group are given the joint
•
authority, to waive or relax the conflict-of-interest in their reasonable discretion,
except in the cases where the waiver or relaxation will result in the violation of existing
•
laws, rules and regulations.
VII. LIABILITY FOR VIOLATION =::::;'::::=:'iIIl'il'IA'I_":1
•
1":'"1 ~
A violation of this policy may, under the circumstances, be construed as an

unethical or corrupt practice subject to the consequences under the Unethical, Corrupt
• and Other Prohibited Practices Policy (ref. no. PM-HRG06-008) of the Company.
However, whether or not such violation constitutes an unethical or corrupt practice,
• a violation of this policy may subject the employee to reprimand, suspension or

termination, within the discretion of his Immediate Superior.
• VIII. APPLICATION TO GLOBE CONSULTANTS -:-=miilli£_· ...__ ""*m%iWD~!I!i:.
• AND DIRECT PROJECT HIRES
•
Consultants and project hires of the Company shall be made to sign, as a pre-
condition to engagement of their services, their conformity to this policy. This shall
include the accomplishment of the annual Related Party Disclosure form.
• IX. POLICIES AND GUIDELINES IN HANDLING CONFLICT -

• OF-INTEREST PRIOR TO HIRING AND ENGAGEMENT:
• 1. All Covered Employees for

hiring or engagement must
Human ResourcesGroup and
the President must be sought
• disclose pre-existing conflict-

of-interest situations as
by them.
3. Should the Head of Human
• defined in this policy, Strategic

Staffing for regular employees
Resourcesand the President
also find the conflict-of-
• to be hired and the line

requisitioner for consultants
interest situation acceptable,
the hiring or engagement of the
• and project hires. shall be

tasked with the responsibility
candidate may be pursued.
4. Should at any point in the
• of requiring such disclosure

from the candidate. hiring process, the candidate's
prospective Immediate
• 2. Should the prospective

Immediate Superior and Group
Superior. Group Head, Head of
Human ResourcesGroup or the
• Head of the Covered Employee

find the disclosed conflict-of-
President find the conflict-of-
interest situation unacceptable,
• interest situation acceptable,

vis-a-vis the duties and
the hiring or engagement of the
subject candidate shall not be
• responsibilities of the position,

the approval of the Head of
pursued.
•
•
•
•
X. POLICIES AND GUIDELINES IN HANDLING CONFLICT - •
OF-INTEREST OF EXISTING COVERED EMPLOYEES: ~
•
1. A Covered Employee must not
put himself in a conflict-of-
Superior, Group Head, Head
of Human Resources Group •
interest situation. In the event
a Covered Employee finds
or the President find the
conflict-of-interest situation •
himself in such a situation, he
should disclose the same to his
unacceptable, the Covered
Employee will be afforded one •
Immediate Superior and Group
Head.
(1)month to cure the conflict-
of-interest situation by seeking •
2. Should his Immediate Superior reassignment/redeployment
opportunities to functions •
•
and Group Head find the
disclosed conflict-of-interest where the same conflict-
of-interest situation would
•
situation acceptable, vis-a-vis
the duties and responsibilities not exist or by the Covered
Employee's related party's own
•
of his position, the approval of
the Head of Human Resources relinquishment or removal from
the situation giving rise to the
•
and the President must be
sought by them. conflict. In such an event, the
employee may continue in his
3. Should the Head of Human
Resources Group and the
employment or engagement
under his new assignment with •
President also find the
conflict-of-interest situation
the appropriate safeguards set
in place by his Group Head, as •
acceptable, the Covered
Employee may continue in
needed.
•
•
his current function with the 5. Should the conflict-of-interest
appropriate safeguards set in situation remain after the
•
place by the Group Head, as above one (1)month period, the
needed. employment or engagement
•
of the Covered Employee shall
4. Should at any point in the be terminated for reasons of
above process, the Covered
•
conflict -of-interest.
Employee's Immediate
XI. TRANSITORY PROVISIONS: m.:.~IIISriNII{m.ilNIJW;:~~
any pre-existing conflict-of- •

•
1. The revised Conflict-of-Interest
policy shall be made known interest situation, without
to all Covered Employees at fear of being charged for non-
least one (1)month before its disclosure.
•
•
implementation. 3. Declared conflict-of-interest
2. Upon its announcement and situations shall be addressed
until its implementation, all
Covered Employees shall be
consistent with the provisions
of this policy except as the
•
given the opportunity to declare punitive part thereof.
•
•
• 4. Undeclared conflict-of-
• interest situations discovered

after the implementation of
• this policy shall be treated as

a case of failure to disclose
• the existence of a conflict-of-

interest situation, dishonesty,
• and breach of the Covered

Employee's loyalty to the
• Company.
•
5. The revised Conflict-of-
Interest policy shall take effect
•
on January 1, 2007.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
~:
•
,-------- NOTES •
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Whistleblower
•
• Whistleblower
•
• I.
G
INTRODUCTION -------------.
LOBE is committed to compliance with laws and regulations to which it is subject
• and to conduct Its business In accordance with ethical standards. All officers and
employees of the Company. and all suppliers and business partners of the company. are
• thus required to observe and practice high standards of business and personal ethics in
the conduct of their duties and responsibilities.
• This Policy provides a formal mechanism for employees. suppliers and third parties
to submit reports of improper activities perpetrated by the company's employees.
• officers and directors. and suppliers and partners. that violate laws and regulations.
•
company policies. the company's Code of Conduct. or which violate the company's
ethical standards. Submitted reports will be investigated according to the protocols
established in this policy. and the responsible submission of complaints In good faith
• shall be protected by the company.
• With the promulgation and dissemination of this policy. the company hopes that
persons in possession of information of improper activities will surface this information
• formally and on a timely basis in order to give management the opportunity to take
action and address such improper activities in order to protect company assets.
• interests. and reputation.

This Policy does not fundamentally change the responsibility for conducting
• investigations but clarifies normal jurisdictional interests and processes by which

complaints are to be dealt with.
• In all instances the Company retains the prerogative to determine when circumstances
warrant an investigation and. in conformity with this Policy and applicable laws and
• regulations. the appropriate investigative process to be employed.
• II. POLICY AND COVERAGE

This Policy provides a formal (f) violations of the Code of
• mechanism for any person, whether Corporate Governance
•
employed by Globe or not, to submit (g) unethical conduct
information or allegations of suspected-
The following are not covered in this
• (a) violations of the Company's

Corrupt Practices Policy
Policy:
(a) Individual employee grievances
• (b) acts of Company asset

misappropriation
and complaints regarding terms
and conditions of employment
• (c) fraudulent reporting practices will continue to be reviewed

under the applicable personnel
•
(d) violations of the Company's
Stock Transaction Policy policies or collective bargaining
agreement.
•
-.•
(e) violations of the Securities
Regulation Code (b) Complaints of violations of the
company's Code of Conduct
initiated by a superior against (c) Allegations of ISRor other illegal •
a subordinate by way of a
disciplinary action shall be
conduct by the company's
customers, suppliers or vendors •
subject to existing processes on
disciplinary action as provided in
shall be referred to Usage Fraud
Management as part of existing •
the Code of Conduct. processes.
;====::; :' :=:=::; =:::::::,_~~_....=._.;..:':=~1'~ __ •

III. DEFINITIONS ~!m:u:a;· 1!IiIIUI1Il1ll1l
••
•
•
Improper Activity any activity by a activity which is protected under this
Company officer, employee, supplier or Policy.
•
business partner which
Whistleblower. A person making a
(a) Is a violation of the Company's protected disclosure
Corrupt Practices Policy;
(b) Is an act of Company asset
Whistleblower Hotline. A telephone
number designated by the company's •
misappropriation
(c) A fraudulent reporting practice
Enterprise Risk Management (ERM)
group for receiving reports of improper •
(d) A violation of the Company's
activity
•
Stock Transaction Policy
(e) A violation of the Securities
Regulation Code
Whistleblower Portal. The portal set up
for the purpose of receiving Disclosures.
Disclosure Committee. The committee
formed to investigate Disclosures made
•
•
(f) A violation of the Code of
under this Policy •
Corporate Governance
•
(g) Is otherwise unethical Complaint Administrator The person
in charge of administering the
Disclosure. Any communication on, or Whistleblower Portal, and receiving,
allegation of, Improper Activity
Protected Disclosure. Good faith
collating and submitting Disclosures,
keeping track of the status of •
communication that discloses
information that may evidence improper
investigations and making reports to the
Committee •
IV. FORM AND CONTENTS OF DISCLOSURE •
1. A Disclosure may be made 2. A Whistleblower shall have the
•
in any form. No particular
form shall be required. Verbal
option to identify himself and/
or sources of his information
•
disclosures, however, must
be reduced to some form of
(if any), or withhold his identity
and/or that of his sources.
•
writing, and persons receiving
verbal disclosure who wish to
3. Disclosures must allege the
specific facts that have lead •
escalate the same for action to
the Disclosure Committee must
the Whistleblower to believe
that an improper activity has •
reduce the same into writing. been or is being committed.
Disclosures must be coherent, •
•
••
•
•
WHISTLEBLOWER
allege facts rather than to allow for proper assessment
• conclusions or speculations. of the need. nature. extent. and
•
and should contain as much urgency of action thereon.
specific information as possible
• v. REPORTING ALLEGATIONS OF
SUSPECTED IMPROPER ACTIVITIES
•
--~~"!"""'O"' ...........
_
1. Any person who has knowledge 3. ERM shall designate a
• of a suspected improper
activity has the duty to make a
Complaint Administrator
who shall be in-charge of
• Disclosure in accordance with

Sec. V(2) of this Policy.
administering the portal.
and receiving. collating and
• 2. Disclosures may be submitted

or reported through any of the
submitting all Disclosures to
the Disclosure Committee.
• following:
(a) by calling up the
Where. however:
(a) The Disclosure involves a
• designated Whistleblower
Hotline
member of the Board of
Directors. the Disclosure
• (b) through the Whistleblower shall be transmitted directly

to the Corporate Secretary
•
Portal
for handling.
(C) by sending an e-mail to a
• designated e-mail address

for Disclosures
(b) The Disclosure involves
ERM or the Complaint
• (d) by sending a letter to the

designated personnel of
Administrator. the same
shall be sent directly to the
• the company's Enterprise

Risk Management group
Corporate Secretary
(c) The Disclosure involves the
• (ERM) Disclosure Committee. the

Disclosure Committee shall
•
These are by no means the only
endorse the same to the
channels by which Disclosures
Board of Directors.
•
may be received. Persons or
units within the organization 4. The Whistleblower shall receive
a notice that the complaint has
•
who receive Disclosures (in
whatever form. including verbal been received and that it shall
be processed in accordance
•
Disclosures) shall. however.
forward or relay the Disclosures with this Policy.
• to ERM or the Complaint

Administrator for proper
•
handling in accordance with
this Policy.
•
•
•
•
POLICIES & PROCEDURES -------
VI. EVALUATION OF THE PROTECTED DISCLOSURE AND •
INVESTIGATION OF THE SUSPECTED IMPROPER
ACTIVITY •
1. The Disclosure Committee shall makes a mockery of this
•
be composed of the Company's
Corporate Secretary and one
Whistleblower Policy, or
(d) The Disclosure Committee, •
representative each from
Human Resources Group (HRG),
the Corporate Secretary
(in the case of Disclosures •
Internal Audit. ERMand Legal
Services Division. The members
under Sec. 3(a) and (b) or
the Board of Directors (in •
of the Disclosure Committee
shall be persons of known
the case of Disclosures
under Sec.3(c) determines •
objectivity, independence,
integrity, trustworthiness,
that an investigation
should be made. •
sound judgment, and with a
good working knowledge of the 4. If an investigation is warranted,
•
•
operations of the company. the Disclosure Committee
shall either conduct the
2. In the event that the protected
•
investigation or designate a
disclosure involves a member handler who will conduct a
of the Disclosure Committee,
•
fact finding investigation. The
such member shall inhibit handler shall submit to the
himself from taking part in the
•
Committee of his finding of
evaluation, investigation, and
facts. Investigations shall be
reporting of that particular
•
carried out in accordance with
protected disclosure. company policies and best
•
3. The Disclosure Committee shall practices in investigation, and
evaluate the complaint and without compromising the civil
•
determine if an investigation is rights of any person.
warranted. An investigation will S. The Disclosure Committee shall
•
be conducted if: submit to the HRGa Report on
(a) Subject ofthe complaint the result of the investigation
is covered by this
Whistle blower Policy;
for the imposition of the
appropriate disciplinary action,
•
(b) The complaint is supported
by evidence or at least,
if warranted by such result.
6. If the improper activity •
includes sufficient
details which can be
subject ofthe investigation
has a significant financial and •
validated and used as
basis for conducting an
reputation risk impact to the
Company, HRGshall forward •
investigation; and the Report of the Disclosure
Committee to the Office of •
•
(c) The complaint is not
patently false, malicious, the President and the Audit
Committee within ten (10) days
•
intended to harass, or
•
•
•
WHISTLEBLOWER
from receipt of the Report. 8. The Disclosure Committee
• The Audit Committee shall

determine if the report shall be
shall state in its report whether
or not the result of the
• further reported to the Board

of Directors.
investigation shall be included
in the employee's 201file or in
• 7. If the Report of the Disclosure

the vendor accreditation files of
the vendor or business partner ..
• Committee include a finding

of civil or criminal liability on 9. The Complaint Administrator
•
the part of the Investigation shall be responsible for
Subject, HRD shall forward to keeping track of the status
•
the Legal Division a copy of the of investigations and actions
Report ofthe Committee on on Disclosures and preparing
•
Protected Disclosure for the a monthly report to the
filing of the appropriate legal Disclosure Committee on the
• action. actions taken.
• VII. ROLES, RIGHTS AND RESPONSIBILITIES OF

WHISTLEBLOWERS, INVESTIGATION PARTICIPANTS,
• AND SUBJECTS OF THE INVESTIGATION =:;,;;;;===-.....,
•
A. Whistle blowers Persons making a report of
1. Whistleblowers provide alleged improper activities
• initial information should be prepared

related to a reasonable to be interviewed by
investigators.
•
belief that an improper
activity has occurred. 4. Anonymous
The motivation of the whistleblowers must
• whistleblower is irrelevant
to the consideration of the
provide sufficient
corroborating evidence to
• validity of the allegations.

However, the intentional
justify the commencement
of an investigation.
• filing of a false report

is itself considered an
An investigation of
unspecified wrongdoing
• improper activity which

the Company has the right
or broad allegations will
not be undertaken without
• to act upon.
2. Whistle blowers shall
verifiable evidentiary
support. Because
• refrain from obtaining investigators are unable

evidence for which they do to interview anonymous
whistleblowers, it may
•
not havea right of access.
be more difficult to
3. Whistle blowers have evaluate the credibility
• a responsibility to be
candid. They should
of the allegations and
therefore, less likely to
•
set forth all known cause an investigation to
information regarding be initiated.
any reported allegations.
•
•
•
5. Whistleblowers are the investigation subject
_
•
reporting parties, not
investigators. They
the nature of evidence
requested or provided •
are not to act on their
own conducting any
or testimony given to
investigators unless agreed
•
investigative activities,
nor do they have a right
to by the investigator.
3. Requests for confidentiality
•
to participate in any
investigative activities
by participants will be
honored to the extent
•
•
other than as requested possible within the
by investigators. legitimate needs of law
6. Protection of a
whistleblower's identity
and the investigation.
4. Investigation participants
•
•
will be maintained to the have a responsibility to
extent possible within further the investigation
•
the legitimate needs of and assure its timely
law and the investigation. completion. Evidence shall
Should the whistleblower
•
not be simulated, withheld,
self-disclose his or her destroyed, or tampered
identity, the Company will
•
with; testimony shall not
no longer be obligated to be fabricated, altered or
maintain such confidence. withheld, or intentionally
7. Whistle blowers have
a right to be informed
made misleading; and
witnesses shall not be
•
of the disposition of
their disclosure absent
influenced, coached, or
intimidated. Any act in
•
overriding reason as
determined by the
violation of this paragraph
or any other attempt to
•
Committee on Protected
Disclosures.
obstruct the investigation,
shall be considered
•
•
an offense subject to
B. Investigation Participants
disciplinary action.
1. Company employees who
are interviewed, asked to
provide information, or
c. Investigation Subjects
1. A subject is a person or
•
otherwise participate in an
investigation have a duty
persons who is/are the
focus of investigation as
•
to fully cooperate with
the Company-authorized
a result of a Disclosure.
The decision to conduct
•
•
investigators. an investigation is not
2. Participants should an accusation; it is to
•
refrain from discussing or be treated as a neutral
disclosing the investigation fact finding process.
The outcome of the
•
or their testimony with
anyone not connected investigation mayor may
not support a conclusion
•
to the investigation.
In no case should the that an improper act was
participants discuss with committed and, if so, by
whom.
•
•
•
•
WHISTLEBLOWER
2. The identity of a subject subject; and witnesses shall
• should be maintained
in confidence to the
not be influenced. coached.
or intimidated by the
• extent possible given the

legitimate needs of law
subject. Any act in violation
of this paragraph or any
• and the investigation.

3. The Disclosure Committee
other attempt to obstruct
the investigation. shall
• shall determine the

opportune time to inform
be considered an offense
subject to disciplinary
• Subjects of the allegations. action.

Once informed. they 8. Evidence shall not be
•
shall have opportunities withheld. destroyed.
for input during the or tampered with. and
•
investigation. witnesses shall not be
4. Subjects have a duty infiuenced.coached.or
intimidated. and any act of
•
to cooperate with
investigators. They should destruction or tampering,
withholding of evidence.
•
be informed. however. that
they have a right against or any other attempt to
self-incrimination under obstruct the investigation.
• the law.
5. Subjects have a right to
shall be considered
an offense subject to
• consult with a person

or persons of their
disciplinary action.
9. Unless there are compelling
• choice. This may involve

representation, including
reasons to the contrary,
subject should be given
• legal representation.
6. Subjects are free at any
the opportunity to respond
to material points of
•
evidence contained in an
time to retain their own
investigation report.
counsel to represent
• them with regard to the

investigation.
10.Subjects have a right to be
informed of the outcome of
•
the investigation.
7. Subjects have a
responsibility not to 11.Any disciplinary or
• interfere with the

investigation and adhere
corrective action initiated
against the subject as a
• to admonitions from
investigators in this
result of an investigation
pursuant to this shall
•
regard. Evidence shall not adhere to applicable
be simulated, withheld, personnel conduct and
disciplinary procedures.
•
destroyed. or tampered
with by the subject;
testimony shall not be
• fabricated. altered or
withheld, or intentionally
• made misleading by the
•
•
VIII. WHISTLEBLOWER PROTECTION POLICY •
•
.Ih_~"'l%!ilillm! t~il!ll!!i!n~,==I1:i1W
1. Disclosures shall be deemed improper activity reported.

Protected Disclosures if they
are made in good faith and with
In particular. he shall not be
subject to dismissal, demotion,
•
a reasonable belief that there
has been an improper activity
any form of harassment or
discrimination. or current or
•
committed. or that one is being
or about to be committed.
future bias in performance
evaluation. by virtue of his
•
A complaint made in good
faith with a reasonable basis
having made a Protected
Disclosure.
•
for belief shall be deemed a
Protected Disclosure even if it
4. If the Whistleblower is not
an employee. but a vendor. •
subsequently turns out to be
untrue. However. complaints
supplier or business partner.
the Whistleblower shall not •
which are patently false.
simulated. malicious. intended
be denied future business of
the company solely on the •
to harass. slur or cast aspersions
on the character or service
basis of his havinq made a
Protected Disclosure. unless it •
record of a person, or disrupt
the company's operations.
also appears from the facts of
the case that the Whistle blower •
without any reasonable basis
for a belief that an improper
participated in the prohibited
conduct with sufficient •
activity has been committed.
or make a mockery of this
knowledge that the same was
illegal. prohibited. unethical. or •
Whistleblower Policy. shall
not be deemed a Protected
would be to the detriment and
prejudice of Globe. •
Disclosure.
•
shall determine if a Disclosure
is a Protected Disclosure or
may. under exceptional
circumstances. with the
•
•
endorsement of the President
not. In the case of disclosures
and with the approval of the
under Sec. V(3)(a) and (b).
•
Board of Directors. grant
the Corporate Secretary shall
immunity to a Whistleblower
determine if a Disclosure is a
•
who has participated in the
Protected Disclosure or not; and
improper activity reported. In
in case of disclosures under Sec.
V(3)(c) the Board of Directors
shall determine if the Disclosure
any event. immunity may only
be granted to a Whistleblower
•
is a Protected Disclosure or not.
under the following conditions.,
first, the Whistleblower whose
•
•
3. A Whistleblower making a immunity is being sought is
Protected Disclosure shall be not the most guilty ofthe
•
entitled to the protection of subjects of the investigation;
this policy provided that he second that his testimony is
•
himself is not complicit to the absolutely indispensable to
•
• WHISTLEBLOWER
•• the investigation and without

it. the company would not
be able to take appropriate
Protection Officer to ensure
that Whistleblowers are
accorded the proper protection
• action; and third. that he

extends full cooperation to the
under this Policy.
•
8. The members of the Disclosure
investigation. Committee shall likewise be
•
6. A Whistle blower who protected in the reasonable
subsequently withdraws his exercise of their functions
•
Disclosure shall not be entitled under this Policy. and shall be
to the protection of this Policy. indemnified by the company
• 7. The Disclosure Committee shall in the event of suit or claims

designate a representative for all actions taken by them in
• of HRGas a Whistleblower accordance with this policy.
• IX. DISSEMINATION AND AMENDMENT OF THE POLICY

HRGshall be responsible for the public dissemination of this Policy across the
• company. Where necessary. HRGshall arrange for appropriate training to be given

to members of the Disclosure Committee and to persons who will be involved in the
• implementation of this policy.

The Company may amend the provisions of this Whistle blower Policy. Any
• amendment. however. shall be effective after due notice is given to the officers and
employees of the Company.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
NOTES •
•
•
•
•
•
•
•
•
•
•
•
•
•
•••
••
•
•
•
•
•
•
•
•
FORM
• FORM
•
•
•
• Related Party Disclosure Form (F-HRG-43)
• Ii~'
~~GIObe·
•
• NAME
.
--- I GROUP I DEPARTMENT 1SECTION---
POSITION 1BAND
-
• I
:
ootNG BUSINESS WITH GLOBE

COMPANY NAME NATURE Of BUSINESS BUSINESS PARTNERS '" INTEREST (IF YES. 100"""0 natu",)
- -
• -
- -
--
•
-
.-
• RELATED
NAME
PARTY TRANSACTIONS
Of FA .. ill. Y MEMBER
COMPANY NAME NATURE OF BUSINESS NATURE OF TRANSACTIONS 1DEALING WI GLOBE
•
or RELATED PARTY
•
•
•
OTHERS
•
• This is to certify that the information provided and reportedl is complete and accurate.
-.-------------------4
•
EMPLOYEE GROUP HEAD HEAD / HUMAN RESOURCE GROUP
• SIGNATURE / DATE SIGNATURE OVER PRINTED

NAME/DATE
SIGNATURE OVER PRINTED
NAME/DATE
•
• For a guided way to accomplish the Notice to Explain,
please consult HR Labor Relations through 730 2491
•
•
•
•
•
NOTES ------- ••
•
•
•
•
•
•
•
•
•
•
•
•
•
••
•
••
••
•
•
ANNEX “C”
Related Party Transactions (RPTs)
We disclose, review, and approve related party transactions, in accordance with the principles of transparency and
fairness, to ensure that they are at arm’s length, the terms are fair, and they will inure to the best interest of the
Globe, its subsidiaries or affiliates and all shareholders.
The RPTs are disclosed in our financial statement (page 244), annual reports, and other applicable filings in
accordance with the relevant rules and issuance of the SEC and other applicable regulatory bodies. The disclosure
includes, but is not limited to, the name of the related party, relationship with Globe for each RPT, the nature and
value for each RPT. Such disclosure is also made publicly available, for the benefit of all shareholders and other
stakeholders, through our company website and such other media channels as applicable.
Under our RPT policy, shareholders, including minority shareholders, and other stakeholders, are provided with
proper guidelines and procedures for right of action and remedies that are readily accessible in order to redress
corporate conduct in case of abuse on such transactions (e.g. Facebook page, Twitter account, e-mail account, and
hotline numbers), as necessary. The policy contains a whistle-blowing mechanism, provides for the creation of a
dedicated committee for review of material RPTs and also identifies materiality thresholds of such transactions.
The independent directors form the independent committee that is tasked to review and monitor material RPTs,
among others, to ensure our best interest, our shareholders’, and all other stakeholders’, and that the RPTs are
executed with fair and transparent terms prior to endorsement to our Board of Directors for approval.
Non-compliance with any of the provisions of the policy on RPT shall result in the nullification of any agreement or
contract involved in the execution of the RPT. A director, officer, employee, or related party is subject to the
corresponding procedures and penalties under our Code of Conduct and relevant laws, as applicable.
Our independent directors met in 2016 to review and discuss RPTs stated in our Annual and Sustainability Report.
[Source: Globe Telecom 2016 Annual and Sustainability Report (ASR), pp. 120-121]
Our Policy on RPTs and disclosures thereof are also posted on our corporate website for the easy reference of our
customers and stakeholders (http://corporate-governance.globe.com.ph/related-party-transactions.html).
H. Transactions with Related Parties
The Globe Group, in their regular conduct of business, enter into transactions with their major
stockholders, AC and Singtel, associates, joint ventures, and certain related parties. These
transactions include the following:
Entities with joint control over Globe Group – AC and Singtel
 Globe Telecom has interconnection agreements with Singtel. The related net traffic settlements
receivable (included in “Receivables” account in the consolidated statements of financial
position) and the interconnection revenues earned (included in “Service revenues” account in
the consolidated statements of comprehensive income) are as follows:
(In Thousand Pesos) 2016 2015 2014

Traffic settlements receivable – net P
= 70,141 P
= 22,824 P
= 79,191
Interconnection revenues 755,514 725,635 784,965
Interconnection costs 85,148 50,346 112,976
 Globe Telecom and Singtel have a technical assistance agreement whereby Singtel will provide
consultancy and advisory services, including those with respect to the construction and
operation of Globe Telecom’s networks and communication, equipment procurement and
personnel services. In addition, Globe Telecom has software development, supply, license and
support arrangements, lease of cable facilities, maintenance and restoration costs and other
transactions with Singtel.
 The details of fees (included in repairs and maintenance under the “General, selling and
administrative expenses” account in the consolidated statements of comprehensive income)
incurred under these agreements are as follows:

Technical assistance fee P
= 89,400 P
= 67,907 P
= 160,534
Maintenance and restoration costs
126,148 57,551 63,695
and other transactions
Software development, supply,
28,342 7,069 19,642
license and support
The outstanding balances due to Singtel (included in the “Accounts payable and accrued expenses”
account in the consolidated statements of financial position) arising from these transactions are as
follows:

Technical assistance fee P
= 63,510 P
= 57,967 P
= 135,877
Maintenance and restoration costs
and other transactions 22,695 8,985 10,882
Software development, supply,
license and support 17,974 - -
 Globe Telecom, Innove, and BTI earn subscriber revenues from AC. The outstanding
subscribers receivable from AC (included in “Receivables” account in the consolidated
statements of financial position) and the amount earned as service revenue (included in the
“Service revenues” account in the consolidated statements of comprehensive income) are as
follows:

Subscriber receivables P
= 11,463 P
= 12,215 P
= 9,662
Service revenues 24,112 19,338 18,990
 Globe Telecom reimburses AC for certain operating expenses. The net outstanding liabilities
19 | S E C F O R M 1 7 - A
to (included in “Accounts payable and accrued expenses” account in the consolidated
statement of financial position) and the amount of expenses incurred (included in the “General,
selling and administrative expenses” account in the consolidated statements of comprehensive
income) are as follows:

General, selling and administrative P
= 95,717 P
= 48,743 P
= 37,135
expenses
Accounts payable and accrued expenses 24,653 50 755
Joint Ventures in which the Globe Group is a Venturer
 Globe Telecom has preferred roaming service contract with BMPL. Under this contract, Globe
Telecom will pay BMPL for services rendered by the latter which include, among others,
coordination and facilitation of preferred roaming arrangement among JV partners, and
procurement and maintenance of telecommunications equipment necessary for delivery of
seamless roaming experience to customers. Globe Telecom also earns or incurs commission
from BMPL for regional top-up service provided by the JV partners. The net outstanding
liabilities to BMPL related to these transactions amounted to ₱92.86 million and ₱3.11 million
as of December 31, 2016 and 2015, respectively. Balances related to these transactions
(included in “General, selling and administrative expenses” account in the consolidated
statements of comprehensive income) amounted to ₱19.42 million, ₱18.68 million and ₱23.76
million, for the years ended December 31, 2016, 2015, and 2014, respectively.
 In October 2009, the Globe Group entered into an agreement with BPI Globe BanKO for the
pursuit of services that will expand the usage of GCash technology. As a result, the Globe
Group recognized revenue amounting to ₱7.46 million, ₱8.96 million and ₱6.13 million in 2016,
2015 and 2014, respectively. The related receivables amounted to ₱16.3 million and ₱7.47
million as of December 31, 2016 and 2015, respectively.
Transactions with the Globe Group Retirement Plan (GGRP)
 In 2007, Globe Telecom, Innove and GXI pooled its plan assets for single administration by
the GGRP, which was created for the management of the retirement fund. The decisions of
the GGRP are made through collective decision of the Board of Trustees.
The plan is funded by contributions as recommended by the independent actuary on the

basis of reasonable actuarial assumptions. These assumptions and the funded status of the
pension plan are disclosed in Note 18.2 of the audited financial statements.
The funded status for the pension plan of Globe Group as of December 31, 2016 and 2015
amounted to ₱3,101.55 million and ₱3,217.78 million, respectively (see Notes 15 and 18.2 of
the audited financial statements).
The fair value of plan assets by each class held by the retirement fund, on a pooled basis
follows:
2015 2014
(In Thousand Pesos)
Cash and cash equivalents P
= 192,982 P
= 143,746
Investment in fixed income securities 1,199,764 1,129,892
Investment in equity securities 1,755,411 1,636,204
Loans and receivables 968,782 968,000
Liabilities (968,782) (968,000)
Balance at end of year P
= 3,418,157 P
= 2,909,842
All equity and debt instruments held, except for investment in preferred shares of HALO Group,
debt securities issued by private corporations and long-term negotiable certificates of deposit,
have quoted prices in active market. The remaining plan assets do not have quoted market
prices in active market.
20 | S E C F O R M 1 7 - A
Loans and receivables consist of interest and dividend receivables, receivable on securities
sold to brokers and loan granted by the plan to BHI.
Liabilities pertain to interest and trust fee payables, accrued professional fees and loan granted
to the plan by Globe Telecom.
 As of December 31, 2016 and 2015, the pension plan assets of the retirement plan include
shares of stock of Globe Telecom with total fair value of ₱32.18 million and ₱31.20 million, and
shares of stock of other related parties with total fair value of ₱107.23 million and ₱144.07
million, respectively. Gains arising from these investments amounted to ₱7.55 million, ₱11.75
million and ₱12.91 million in 2016, 2015 and 2014, respectively.
 In 2008, the Globe Group granted a short-term loan to the GGRP amounting to ₱800.00 million
with interest at 6.20%. Upon maturity in 2009, the loan was rolled over until September 2014
with interest at 7.75%. Further, in 2009, the Globe Group granted an additional loan to the
retirement fund amounting to ₱168.00 million which bears interest at 7.75% and is due also in
September 2014.
On September 16, 2014, the maturity of the outstanding balance of loan receivable from GGRP
amounting to ₱968.00 million was extended to September 11, 2017 and the interest rate was
reduced to 5% per annum effective on September 11, 2014. Interest income amounted to
₱44.33 million, ₱49.07 million and ₱68.02 million in 2016, 2015 and 2014, respectively (see
Note 19 of the audited financial statements).
The retirement plan utilized the loan to fund its investments in BHI, a domestic corporation
organized to invest in media ventures. BHI has controlling interest in Altimax Broadcasting Co.,
Inc. (Altimax) and Broadcast Enterprises and Affiliated Media Inc. (BEAM), respectively.
As of December 31, 2016 and 2015, the outstanding balance of loan receivable from GGRP
presented in the “Prepayment and other current assets” of consolidated statements of financial
position amounted to ₱788.00 million (see Note 6) and ₱968.00 million presented in the “Other
Noncurrent Assets” (see Note 11 of the audited financial statements), respectively.
 On August 13 and December 21, 2009, the Globe Group granted five-year loans amounting to
₱250.00 million and ₱45.00 million, respectively, to BHI at 8.275% interest. The ₱250.00 million
loan is covered by a pledge agreement whereby in the event of default, the Globe Group shall
be entitled to offset whatever amount is due to BHI from any unpaid fees to BEAM from the
Globe Group. The ₱45.00 million loan is fully secured by a chattel mortgage agreement dated
December 21, 2009 between Globe Group and BEAM. Interest income amounted to ₱8.06
million, ₱8.04 million and ₱11.30 million in 2016, 2015 and 2014, respectively (see Note 19 of
the audited financial statements).
On August 13, 2014, the maturity of the outstanding balance of loan receivable from BHI
amounting to ₱158.62 million was extended to August 13, 2017 and the interest rate was
reduced to 5% per annum effective August 14, 2014 (see Note 6 of the audited financial
statements)
 On February 1, 2009, the Globe Group entered into a memorandum of agreement (MOA) with
BEAM for the latter to render mobile television broadcast service to Globe subscribers using
the mobile TV service. As a result, the Globe Group recognized an expense (included in
“Professional and other contracted services”) amounting to ₱190.00 million, ₱190.00 million
and ₱155.00 million in 2016, 2015 and 2014, respectively. Effective January 1, 2015, BEAM
charged an increased service fee rate to Globe Group as a result of an amendment to the MOA.
 On October 1, 2009, the Globe Group entered into a MOA with Altimax for the Globe Group’s
co-use of specific frequencies of Altimax’s for the rollout of broadband wireless access to the
Globe Group’s subscribers. As a result, the Globe Group recognized an expense (included in
“General, selling and administrative expenses” account in the consolidated statements of
comprehensive income) amounting to ₱32.49 million, ₱24.85 million and ₱40.88 million in
2016, 2015 and 2014, respectively.
21 | S E C F O R M 1 7 - A
Transactions with Yondu
As a result of Globe Telecom’s sale of its controlling stake in Yondu, transactions are recognized
in the consolidated statement of financial position starting September 16, 2015.
The Globe Group has a VAS sharing agreement with Yondu. Under the agreement, Yondu is
entitled to a 30% share on revenue (included in the “Service revenues” account of the parent
company statements of comprehensive income) for providing mobile contents to Globe and TM
subscribers. The Globe Group’s payout to Yondu on mobile content transactions in 2016 and 2015
amounted to ₱264.30 million and ₱78.85 million, respectively.
Yondu also provides various enterprise solutions-based services to the Globe Group for network,
platform and applications development under its Business Process Outsourcing Unit (BPO) and
mobile content. The Globe Group’s related expenses in 2016 and 2015 amounted to ₱240.21
million and ₱39.32 million, out of which ₱102.32 million and ₱1.42 million were capitalized under
“Asset Under Construction”, respectively.
The outstanding balances of receivable and payables resulting from transactions with Yondu in
2016 and 2015 amounted to nil and ₱345.71 million and ₱74.23 million and ₱373.54 million,
respectively. Dividends receivable amounting to ₱68.74 million and ₱244.49 million was recognized
in the consolidated statements of financial position as of December 31, 2016 and 2015, respectively
(see Note 6 of the audited financial statements).
Transactions with other related parties
Globe Telecom has money market placements and bank balances, and subscriber receivables
(included in “Cash and cash equivalents” and “Receivables” accounts in the consolidated
statements of financial position, respectively) and earns service revenues (included in the “Service
revenues” account in the consolidated statements of comprehensive income) from its other related
parties namely, Ayala Land, Inc., Ayala Property Management Corporation, Bank of the Philippine
Islands, Manila Water Company, Inc., Integrated Microelectronics, Inc., Stream Global Services,
Inc., HRMall, Inc., Honda Cars Philippines, Inc., Isuzu Automotive Dealership, Inc., Iconic
Dealership, Inc., Accendo Commercial Corporation, Affinity Express Philippines, Inc., Alveo Land
Corporation, Asian I-Office Properties, Inc., Avida Land Corp., Avida Sales Corporation, Ayala
Hotels, Inc., Ayala Plans, Inc., Ayala Systems Technology, Inc., Cebu Holdings, Inc., Makati
Development Corporation, myAyala.com, Inc., North Triangle Depot Commercial Corporation, Psi
Technologies, Inc., Roxas Land Corporation., Serendra, Inc., Station Square East Commercial
Corporation, Ten Knots Development, KHI ALI Manila, Inc., Lagoon Development Corporation,
Subic Bay Town Center, Inc., Ayala Aviation Corporation, Laguna AAA Water Corp., Liveit
Solutions, Inc., Liveit Investments, Ltd., Integreon, Inc., Arvo Commercial Corporation, Amaia Land
Corporation., Michigan Power, Philippine Intergrated Energy Solutions, Inc., Southcrest Hotel
Ventures, Inc., Bonifacio Hotel Ventures, Inc. and Westview Commercial Ventures Corporation.
The balances with other related parties are recorded under the following accounts:

Cash and cash equivalents P
= 1,468,905 P
= 1,621,045 P
= 1,385,635
General, selling and administrative expenses 260,312 208,351 171,873
Property and Equipment 425,029 59,417 64,300
Revenues 601,097 509,715 479,923
Accounts payable and accrued expenses 35,314 23,527 15,454
Subscriber receivables (included in “Receivables”
account) 192,795 204,226 218,837
The balances under “General, selling and administrative expenses” and “Property and equipment”
accounts consist of expenses incurred on rent, utilities, customer contract services, other
miscellaneous services and purchase of vehicles, respectively.
These related parties are either controlled or significantly influenced by AC.
22 | S E C F O R M 1 7 - A
Transactions with Key Management Personnel of the Globe Group
The Globe Group’s compensation of key management personnel by benefit type are as follows:
(In Thousand Pesos) 2016 2015

Short-term employee benefits P
= 205,000 P
= 185,000
Share-based payments 81,360 31,282
Post-employment benefits 14,600 52,960
P
= 300,960 P
= 269,242
There are no agreements between the Globe Group and any of its directors and key officers
providing for benefits upon termination of employment, except for such benefits to which they may
be entitled under the Globe Group’s retirement plans.
The Globe Group has no non-interest bearing short-term loans to its key management personnel
in 2016 and 2015.
The summary of balances arising from related party transactions for the relevant financial year
follows (in thousands):
23 | S E C F O R M 1 7 - A
2016
Amount Outstanding Balance \

Property Cash and Amounts Amounts
Revenue and Cash Owed by Owed to
and other Cost and Equipment Equivalents Related Related
income Expenses (Note 7) (Note 30) Parties Parties Terms Conditions
Entities with joint control
over the Company
Singtel P
= 755,514 P
= 329,038 =–
P =–
P P
= 70,141 P
= 104,179 Interest-free, settlement in cash Unsecured, no impairment
AC 24,112 95,717 – – 11,463 24,653 Interest-free, settlement in cash Unsecured, no impairment
Jointly controlled entities

BPI Globe BanKO 7,456 – – – 16,300 – Interest-free, settlement in cash Unsecured, no impairment
BMPL – 19,420 – – – 92,860 Interest-free, settlement in cash Unsecured, no impairment
Associate
Yondu – 504,505 102,321 – 68,740 345,713 Interest-free, settlement in cash Unsecured, no impairment
Other related parties

GGRP 44,334 – – – 788,000 – 3 years, 5%, settlement in cash Unsecured, no impairment
BHI 8,063 – – – 158,620 – 3 years, 5%, settlement in cash The P

= 250.00 million is covered
by a pledge agreement while
the P
= 45.00 million is fully
secured by chattel mortgage
agreement
BEAM – 190,000 – – – – Interest-free, settlement in cash –
Altimax – 32,490 – – – – Interest-free, settlement in cash –
Key management personnel – 300,960 – – – – Unsecured, no impairment
Others 601,097 260,312 425,029 1,468,905 192,795 35,314 Interest-free, excluding cash and Unsecured, no impairment
cash equivalents, settlement in
cash
Total P
= 1,440,576 P
= 1,732,442 P
= 527,350 P
= 1,468,905 P
= 1,306,059 P
= 602,719
24 | S E C F O R M 1 7 - A
2015
Amount/ Outstanding Balance

Property Cash and Amounts Amounts
Revenue and Cash Owed by Owed to
and other Cost and Equipment Equivalents Related Related
income Expenses (Note 7) (Note 30) Parties Parties Terms Conditions
Entities with joint control
over Globe Group
Singtel P
= 725,635 P
= 182,873 =–
P =–
P P
= 22,824 P
= 66,952 Interest-free, settlement in cash Unsecured, no impairment
AC 19,338 48,743 – – 12,215 50 Interest-free, settlement in cash Unsecured, no impairment
Jointly controlled entities

BPI Globe BanKO 8,965 – – – 7,468 – Interest-free, settlement in cash Unsecured, no impairment
BMPL – 18,681 – – – 3,113 Interest-free, settlement in cash Unsecured, no impairment
Associate
Yondu – 118,170 1,420 – 318,711 373,538 Interest-free, settlement in cash Unsecured, no impairment
Other related parties

GGRP 49,071 – – – 968,000 – 3 years, 5%, settlement in cash Unsecured, no impairment
BHI 8,041 – – – 158,620 – 3 years, 5%, settlement in cash The P

= 250.00 million is covered
by a pledge agreement while
the P
= 45.00 million is fully
secured by chattel mortgage
agreement
BEAM – 190,000 – – – – Interest-free, settlement in cash –
Altimax – 24,847 – – – – Interest-free, settlement in cash –
Key management personnel – 269,242 – – – – Unsecured, no impairment
Others 509,715 208,351 59,417 1,621,045 204,226 23,527 Interest-free, excluding cash and Unsecured, no impairment
cash equivalents, settlement in
cash
Total P
= 1,320,765 P
= 1,060,907 P
= 60,837 P
= 1,621,045 P
= 1,692,064 P
= 467,180
25 | S E C F O R M 1 7 - A

GLO 2016 ACGR Annexes A C

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GLO 2016 ACGR Annexes A C

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ANNEX "A"

a Gtobe Tetecom, lnc.

CERTIFICATION OF FULL GOMPLIANCE WITH THE

January 3, 2017 , Taguig City

Preside and Chief Executive Officer

POLICIES AND PROCEDURES ON

• How many times shall penalty be imposed? 7

• What are the responsibilities

• What effects would disciplinary action have on

• one's career improvement?

• On Offenses And Penalties

• What are considered offenses against honesty and integrity?

• What are considered offenses against good personal behavior

• and conduct and what are their corresponding penalties?

• their corresponding penalties? 12

• What offenses are related to job performance?

• Willi be penalized for undertime or leaving work early? 15

• my Company's name and reputation?

• healthy working environment? 16

• The Rules Of A Disciplinary Proceeding

• What are the rules of a disciplinary proceeding? 18

• ON GEN ERAL PROVISIONS r:::::=:;;;::;::::::;;:;;;~-=:;z::;:::~::::;:;;:;;~::m:::::;;::;~:z; .. ;0

• @ To whom does this @ What are the

• Globe. Innove. GXI,their subsidiaries

• consistently and uniformly to

• position within the company. It is or unfamiliarity with the provisions

• against his person or personality.

• The identity of an employee,

• Conduct process, and information

• be maintained in confidence to the

• needs of law and the fact-finding

• @ How many times shall The protection of the reporting

• for each offense. If an offense

• Code. the penalty for the most

@ What effects would

•• The Code shall not prevent the

• ON OFFENSES AND PENALTIES lIi

• @ What are considered

• penalties? in any action intended to

• 0 1. Corruption. Extortion. and/or

• Any employee who directly or

• solicits. receives or accepts

•• another person. in connection

• performance of his duties. or

• suffer the penalty of Dismissal.

• 2. Fraud Against the Company or attempting to steal or

• shall be penalized with

• 2.1. makes a false

• 2.2. employs any kind of Giving false testimony on a

• deception; matter that is the subject of

rise to or assuring free access to such employee •

2. Immoral or Indecent Conduct 6. Drunkenness

Engaging in immoral. indecent Reporting for work under the

• or lascivious behavior. including influence of liquor. or drinking

• 3. Fighting Within Company

• or engaging in a fight with a co-

• company premises shall suffer

• third party within the company

• Shall be penalized as follows: Where smoking threatens

• 1st Offense - Seven (7) days

• 2nd Offense - Fifteen (lS) days follows:

1st Offense - Seven (7) days

1st Offense - Verbal Warning • I