It is of great importance that the directors, officers and employees of the Company observe high standards of work and personal ethics in the conduct of their duties and responsibilities. As representatives and employees of the Company, they must practice honesty and integrity in fulfilling their responsibilities, and must exemplify the behavior and professional demeanor consistent with all applicable laws and regulations, as well as the Company’s applicable policies and procedures.

This Policy intends to encourage and empower directors, officers, employees or any person to raise concerns on matters pertaining to potential violations of laws, Company policies and procedures, and give the Company opportunity to address the same prior to seeking external remedies. This Policy shall apply to all directors, officers and employees of the Company as well as any person who makes a protected disclosure as defined in this Policy.

General Policy – No director, officer, employee or any person, who in good faith, duly reports a matter covered by this policy shall suffer harassment, retaliation or any adverse consequence in his employment or practice of profession. A director, officer, employee or any person who retaliates against someone who has reported a violation in good faith is subject to disciplinary action up to and including termination of employment.

Definitions – For purposes of the Whistleblowing Policy, the following definitions shall control and apply:
a) “Protected disclosure” shall refer to written deliberate and voluntary disclosure by a director, officer, employee, or any person with relevant information of an actual or potential violation of laws, Company policies and procedures by any director, officer or employee or by any person which affects the Company.
b) “Whistleblower” refers to any person who makes a protected disclosure to his immediate supervisor, other superior officers, or the Internal Audit Department. If the protected disclosure is made to any other company personnel, it shall be referred to the Internal Audit Department.
c) “Retaliatory Action” pertains to negative or obstructive response or reactions to a disclosure taken against the Whistleblower, his family/relatives within the fourth civil degree, and/or those officers and employees supporting him such as, but not limited to, civil, administrative or criminal proceedings commenced or pursued against covered persons in this provision by reason of the disclosure made under this Policy, reprisals against covered persons by forcing or attempting to force any of them to resign, retire and/or transfer, undue negative performance appraisals or disciplinary actions, and such other similar acts.

1. A Whistleblower may make a protected disclosure to his immediate supervisor, other superior officers, or the Internal Audit Department any complaint or report on acts or omissions that are actually or potentially contrary to laws, Company rules, regulations or policies; unreasonable, unjust, unfair, oppressive or discriminatory; or constitutive of an undue or improper exercise of powers and prerogatives. The complaint or report shall indicate his name, department and contact number, and information on the disclosures shall contain sufficient particulars and details of the actual, suspected or anticipated wrongdoing and, as much as possible, be supported by other material evidence, attaching supporting documents if there are any, such that verification can be made regarding the circumstances. The report shall be in the form of a signed and dated handwritten or typewritten letter handcarried or email sent directly to the Internal Audit Manager.

2. A whistleblower shall have the following rights:
a) Protection Against Retaliatory Actions
b) Defense of Privileged Communication
c) No Breach of Duty of Confidentiality – A whistleblower who has an obligation by way of oath, rule or practice to maintain confidentiality of information shall not be deemed to have committed a breach of such duty if he makes a protected disclosure of such information.

3. Any officer to whom a disclosure is made shall have the following obligations:
a) Maintain the confidentiality of the subject matter of the disclosure and of the identity of the whistleblower;
b) Ensure and undertake measures to protect the well-being of the whistleblower; and
c) Report the disclosure in full detail to the Internal Audit Department, within a period of five (5) days from date of disclosure.

4. Upon receipt of the disclosure, the Internal Audit Department shall:
a) Evaluate the disclosure on whether or not it qualifies as protected disclosure under this Policy; and
b) If the Internal Audit Department finds that the same is qualified, to proceed to investigate the disclosure in accordance with its internal rules and with the guidance of the Company’s Audit Committee.

5. The Company will publicize the contact details in order to facilitate the receipt of protected disclosures. Any report covered by this shall be made to:

The Internal Audit Department
Attention: The Internal Audit Manager
Address: unit 506, President Tower, 81 Timog Avenue, Quezon City
Email to: asantonio@crownpvc.com.ph