Insider Trading Policy

Directors, Officers, Employees, and insiders are prohibited from trading in securities of the Company while in possession of material nonpublic information

Further, they are enjoined from trading in the Company’s securities from the time they acquire possession of such information and up to two (2) trading days from the day the price sensitive information becomes public, unless a longer black-out period is mandated by the Securities and Exchange Commission or the Philippine Stock Exchange.

“Insider” shall include any person who, by reason of their position or dealings with the company, comes into possession of material nonpublic information.  It shall also include a spouse or relatives by affinity or consanguinity within the second degree, legitimate or common-law, of the directors, officers, employees, or insider.

Information should be considered "material nonpublic" if: (a) It has not been generally disclosed to the public and would likely affect the market price of the security after being disseminated to the public and the lapse of a reasonable time for the market to absorb the information; or (b) would be considered by a reasonable person important under the circumstances in determining his course of action whether to buy, sell or hold a security.

Directors, Officers, and Employees are enjoined to disclose to the Company any transactions or dealings in the Company’s securities within two (2) trading days after any such transaction.