CG-Related Policies

Code of Conduct and Business Ethics

EDC’s Code of Conduct and Business Ethics was launched on September 13, 2004 when EDC was still a government-owned and controlled corporation. Even then, EDC constantly keeps itself agile and flexible, striving to be at par – or even better than – the world’s best, in the face of rapidly-changing rules of business engagement brought about by globalization, the impact of information technology, the increased demand for accountability and transparency by the company’s stakeholders and stockholders alike.

The Code provides company’s mission, vision and credo, as well as the policy guidelines and key principles to help EDC and its employees and officers re-align their personal values, actions and concepts of business behavior and governance based on enduring moral values. The Code likewise encourages the right actions through sometimes difficult choices and to act with unflinching integrity when faced with situations involving ethical issues.

The Code states the values that motivate the Company and its workforce to persevere and aim for excellence while maintaining favorable relations with co-workers as well as with other stakeholders. We believe and practice teamwork, trust, respect/courtesy, integrity, and social responsibility.

Likewise, the Code lays down the key principles which guide in dealing with investors, principal stakeholders and critical issues and concerns facing the Company, such as the Government, the Employees, EDC’s Business Partners, the Environment, the Communities around the Company, Company Books and Records, Confidential Information, a Healthy and Safe Workplace, and the Media, among others.

Code of Conduct and Discipline

On the other side of the coin is EDC’s employee Code of Conduct and Discipline which became effective September 16, 2011. The Code of Conduct and Discipline prescribes the norms of conduct and standards of behavior to instill a strong sense of discipline among its employees. These standards of behavior will serve as guideposts in ensuring that our employees embrace and live the Company’s core values.

Conflict of Interest Policy

EDC’s Conflict of Interest Policy is generally covered under EDC’s Personnel Manual and as such serves as a guide to all EDC personnel in the conduct of their day-to-day transactions in EDC. Recently revised in order to address the ever-changing needs of a private corporation, the policy provides the guidelines and directives for all Directors, officers and all other employees, as well as their relatives within a certain degree of affinity or consanguinity, in order to avoid any conflict of interest between their personal interest and that of the Company in dealing with suppliers, customers, and all other organizations or individuals doing or seeking to do business with the Company.

Instances identified under Conflict of Interest include, but are not limited to, the following: (a) interest in any group or organization which has, or is seeking to have, business or financial dealings with the Company or where there is an opportunity for preferential treatment to be given or received; (b) sale or lease any kind of property, facilities or equipment to the Company; (c) participation or involvement, direct or indirect, in any transaction involving any person, firm, corporation or any business enterprise with which the Company, directly or indirectly, has a commercial relationship, where such participation or involvement is improper or undesirable in the interest of the Company; (d) accepting commissions, share in profits, gifts in cash, gift certificates, etc. from an organization, firm or individual doing or seeking to do business with the Company; (e) accepting appointments in the national or local government in any capacity, run for elective office, or actively engaged in partisan political activities, when it may tend to prejudice the Company.

In addition to the instances covered by the definition of “Conflict of Interest”, the policy provides the accepted exceptions thereto, as well the guidelines on the procedure for actions against involved personalities charged with having Conflicts of Interest, emphasizing the need for due process.

Guidelines on Trading Rules and Restrictions

Since EDC’s listing in the Philippine Stock Exchange in December 13, 2006, the Company has continued to observe strict compliance with the Exchange’s Trading Rules and Restrictions, emphasizing the need for transparency and fairness in its transactions in order to fully apprise its investors of its current activities.

One of the matters which were given much importance is the principle of transparency, wherein directors and officers are required to disclose their stock transactions involving company security, using SEC Forms 23-A and 23-B whenever necessary.

Another matter given much importance is the manner by which the Company, its Directors and officers treat material information which they may come by in the Company. Management has advised time and again that material information should be treated delicately so as to comply with the PSE and SEC Rules on Disclosure.

At present, a consolidated Company Manual on the Guidelines on Disclosure Rules and Trading Restrictions is under review for future implementation in EDC.

Fraud Policy

The corporate fraud policy is established to facilitate the development of controls which will aid in the detection and prevention of fraud against the Company and promotion of consistent organizational behaviour by providing guidelines and assigning responsibility for the development of controls.

The policy defines fraud and enumerates the instances wherein fraud is committed, and designates the office primarily responsible for investigating corporate fraud cases. It emphasizes that in the process of investigating corporate fraud cases, the Company shall, at all times, accord all indivuals concerned with all the rights and privileges emanating from due process.

Whistleblower Policy

EDC’s Whistleblower policy is intended to encourage and enable employees and others to raise serious concerns within the company prior to seeking resolution outside the company. The EDC whistleblower policy is a guarantee that no person who reports a violation of company policies shall suffer harassment, retaliation, or adverse employment consequence.

The EDC Whistleblower Policy identifies who could be whistleblowers, laying down the matters which are reportable thereunder, the procedures for whistleblowing, as well as their  rights and responmsibilities under the said policy.

In furtherance of EDC’s good governance initiatives and in consonance with its internal Fraud Policy and the Code of Conduct and Business Ethics, the Company’s Internal Audit Department (IAD) made available a hotline to enable and encourage employees to report serious concerns of irregularities and wrongdoings. All reports will be acted upon and treated with strict confidentiality in accordance with the provisions of EDC’s Protected Disclosure Policy.