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HANDBOOK ON
Code of
Conduct
Introduction 2
PRIMER ON
Code of Conduct 7
Unethical Practices 25
Conflict of Interest 31
Whistleblower 37
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
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.
o
Code of Conduct apply?
The Code applies to all employees of
responsibilities of
Employees in relation to
important to stress that disciplinary will not excuse any violation
action shall be directed against the committed.
employee's wrongdoing and not
o
penalty be imposed?
Only one penalty shall be imposed
to the extent possible. within
the legitimate needs of law and
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.
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
consideration. monetary or
otherwise. for himself. or for
benefit or that of another
person; or
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
penalty of Dismissal.
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
CODE OF CONDUCT
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
Premises
Quarrelling. physically assaulting
or regulated drugs shall
be dismissed and/or dealt
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.
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
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:
3rd Offense - Dismissal
1st Offense - Fifteen (15) days
Suspension
10. Failure to Report Loss Incident
Occurrence
2nd Offense - Dismissal
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,
shall be penalized as follows:
Suspension
3rd Offense - Dismissal 2nd Offense - Written Reprimand
3rd Offense - Three (3) days
@ What are considered
anti-customer offenses
Suspension
4th Offense - Seven (7) days
Suspension
and what are their
corresponding penalties?
5th Offense - Fifteen (15) days
Suspension
e 1. Discourtesy Against Customers
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 penalized as follows:
shall be dealt with as follows:
1st Offense - Verbal Warning
1st Offense - Three (3) days
Suspension
2nd Offense - Written Reprimand
3rd Offense - Three (3) days
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
6th Offense - Dismissal
CODE OF CONDUCT
similarly. . We take
ownership of
customer's call shall be dealt with procedures for direct or indirect
as follows: personal gain shall be meted a
Suspension
6th Offense - Dismissal
disciplined as follows:
Suspension
01. Failure on the Job 4th Offense - Fifteen (15) days
Suspension
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
2. Non-Observance of Standard
5. Culpable Delay in Disposing
Operating Procedures -
Disciplinary Cases
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
1st Offense - Verbal Warning
Extending beyond the necessary
2nd Offense - Written Reprimand
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
5th Offense - Fifteen (15) days
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
1st Offense - Written Reprimand
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
@ 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:
follows:
2nd Offense
3rd Offense
- Written Reprimand
- Seven (7) days
2nd Offense - Dismissal
4th Offense
Suspension
- Fifteen (15) days
5. Withholding of Information
Refusing or failing without
Suspension
5th Offense - Dismissal justifiable reason. to
communicate information
o 1 Insubordination
Any direct order given by
any company operation. or for
sound decision. or to protect the
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
penalized as follows:
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
gravity of the offense.
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
Company in public, shall suffer
operating procedures, the
the following penalty:
penalty shall be Dismissal.
1st Offense - Fifteen (15) days
Suspension @ What are my obligations
to keep a secure, safe
2nd Offense - Dismissal
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
premises is as follows:
2. Unauthorized Use of Company
Property 1st Offense - Verbal Warning
Misusing company property for 2nd Offense - Written Reprimand
3rd Offense - Three (3) days
personal purposes or removing Suspension
Uniform
Authorization to Climb shall be
Not wearing the prescribed
Suspension
3rd Offense - Six (6) days
Tampering Fire Protection
Appliances and Life Safety
Suspension
Systems, such as fire alarms and
4th Offense - Dismissal
extinguishers, smoke detectors,
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
gravity of the offense.
10. Failure to Act on a Preventive/
Corrective Action Request
1st Offense - Written Warning
2nd Offense - Ten (10) days
(PCAR)
Suspension
3rd Offense - Dismissal
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
1st Offense - Verbal Warning
2nd Offense - Written Reprimand
3rd Offense - Three (3) days
Suspension
4th Offense - Seven (7) days
other circumstances, the penalty Suspension
shall be as follows: 5th Offense - Fifteen (15) days
Suspension
6th Offense - Dismissal
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
Administrative Charge
The Immediate Superior and the
withhold salaries & benefits.
as well as
to Company property or to
life.
9. Administrative Hearing
Whether the employee
PRIMER
Immediate or Next Level Superior
with HR determines whether to
CODE OF CONDUCT
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.
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
conduct. Seeking undue financial and material advantage from transactions for
Globe is a breach of trust between him and the Company.
o
p-a-tices7 which were evident at the time
the contract was entered into. It is
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
Conflict of Interest
A
GIObe employee is above board and, at all times, exercises discretion, prudence
conflict-of-interest situations.
the following:
1. You-or your middleman-doing
possibly engage their services.
@ Can a conflict-of-
transaction);
2. Having a financial interest in a o If your immediate supervisor and
3. Accepting employment or
directorships outside of Globe.
not be compromised. they would
next seek the approval of the HRG
disclosure;
4. Access to sensitive information
in your current function (with
appropriate safeguards from your
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 a protected
o
disclosure?
@ How do I report an
improper activity?
0917-8189934.
above) that we protect and hold in
confidence. 2. Submit a report through the
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
"
whistleblower?
Unless asked to participate, you
He has the right to consult with
protected.
He will be informed of the
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
investigation subject?
3. he extends his full cooperation.
" Once the Disclosure Committee
NOTES
,
TABLE OF CONTENTS POLICIES &: PROCEDURES
CODE OF CONDUCT
Title I
Title II
Philosophy on Discipline
General Provisions
47
ART. 1. Coverage 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. 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
,.
61
SEC 5. Answer/Explanation
SEC 6. Administrative Hearing
61
61
SEC 7. Decision
SEC 8. Implementation of the Decision
62
62
Title IV Effectivity 62
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,
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"
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
penalty shall be imposed for each thereof.
offense. If an administrative charge
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,
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
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.
penalty of Dismissal.
ART. 16. Perjury or False Testimony -
Any employee who makes untruthful
facts;
ART. 17.Falsification - The penalty of
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
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
the Company;
(g) Borrowing money or property
(il Pre-empting the Company in
the purchase of any asset which
companies or enterprises
mentioned above;
UJ Taking for oneself. or passing
on to a relative or associate a
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
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
employment of an employee; or
would discriminate. deprive.
or diminish employment
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
penalty of Dismissal.
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
shall be penalized as follows:
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
penalty of Dismissal.
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
First Offense - Seven (7) days
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
First Offense
Second Offense
- Fiheen (15) days
Suspension
Dismissal
motor vehicle accident involving a
service vehicle of the Company. property
aspect. including. but not limited when the employee knows. should
to rudeness. arrogance. insolence. know or is in a position to obtain such
Second Offense
Third Offense
- Seven (7) days
Suspension
- Fifteen (15) days
Third Offense - Three (3) days
Suspension
penalized as follows:
First Offense Fifteen (15) days
Suspension First Offense - Verbal Warning
Suspension
Incompetence in responding and
attending to the concerns of the First Offense - Verbal Warning
customer shall be dealt with similarly. Second Offense - Written Reprimand
Third Offense - Three (3) days
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
Suspension Suspension
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'"
penalized as follows:
Second Offense - Written Reprimand
Third Offense - Seven (7) days
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.
imposed.
ART. 42. Loitering and Abandonment
calendar year. i.e.. January to December First Offense - Fifteen (15) days
Suspension
of the same year
Second Offense Dismissal
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
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
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
Suspension
Second Offense Dismissal offense
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.
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
penalized as follows:
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:
First Offense - Verbal Warning
Third Offense - Seven (7) days Second Offense - Written Reprimand
Suspension
Third Offense - Three (3) days
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
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
First Offense - Seven (7) days
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
Failure to act or close a Preventive/
First Offense - Seven (7) days Corrective Action Request (PCAR)on a
Suspension
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
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.
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.
Administrative Charge.
to a cause attributable to the fault of the hearing. the Immediate Superior may
shall be assisted by HR. Internal Audit.
(a) HR;
of preventive suspension. the employee
is not entitled to salaries and benefits. (b) Legal;
company-issued property.
participation or presence of such lawyer
or representative shall not be allowed to
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 -------
,--------- NOTES
1
J
Policies and Procedures on
Unethical Practices
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.
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.
3.1.2. 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
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.
documented offer of
travel sponsorship that
employees, whether
individually or in groups,
arrangements for
the travel such as: (i)
are (i) unsolicited, (ii)
properly declared prior
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
POLICIES & PROCEDURES
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
result in injury. It is an
utter disregard of the
other persons.
When a director, trustee or
adverse consequences
which were clearly
duty, any interest adverse to
the corporation in respect of
HRG06-007)
and must account for the profits
5.3 For members of the Board of which otherwise would have
Corporate Governance.
POLICIES & PROCEDURES
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
Employees who witness violations of this policy should report the same to the
Human ResourcesGroup.
,--------- NOTES
I
Policies and Procedures on
Conflict of Interest
CONFLICTOF INTEREST
----------------------------------------
Conflict of 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
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,
Conflict of Interest situations shall include, but are not limited to the following:
degree of consanguinity or
affinity, or (b) with one who which may be of value to a
person or a company where the
POLICIES & PROCEDURES
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
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.
CONFLICTOF INTEREST
1":'"1 ~
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,
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.
POLICIES & PROCEDURES -
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
CONFLICTOF INTEREST
4. Undeclared conflict-of-
Company.
on January 1, 2007.
~:
,-------- NOTES
Policies and Procedures on
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
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.
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
employed by Globe or not, to submit (g) unethical conduct
information or allegations of suspected-
The following are not covered in this
(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
POLICIES & PROCEDURES _
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.
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
v. REPORTING ALLEGATIONS OF
SUSPECTED IMPROPER ACTIVITIES
--~~"!"""'O"' ...........
_
of a suspected improper
activity has the duty to make a
Complaint Administrator
who shall be in-charge of
following:
(a) by calling up the
Where. however:
(a) The Disclosure involves a
designated Whistleblower
Hotline
member of the Board of
Directors. the Disclosure
Portal
for handling.
(C) by sending an e-mail to a
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
whistleblower is irrelevant
to the consideration of the
provide sufficient
corroborating evidence to
to act upon.
2. Whistle blowers shall
verifiable evidentiary
support. Because
a responsibility to be
candid. They should
of the allegations and
therefore, less likely to
POLICIES & PROCEDURES -
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
should be maintained
in confidence to the
not be influenced. coached.
or intimidated by the
to cooperate with
investigators. They should destruction or tampering,
withholding of evidence.
the law.
5. Subjects have a right to
shall be considered
an offense subject to
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
the investigation.
7. Subjects have a
responsibility not to 11.Any disciplinary or
to admonitions from
investigators in this
result of an investigation
pursuant to this shall
destroyed. or tampered
with by the subject;
testimony shall not be
fabricated. altered or
withheld, or intentionally
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
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
amendment. however. shall be effective after due notice is given to the officers and
employees of the Company.
NOTES
FORM
FORM
Ii~'
~~GIObe
NAME
.
--- I GROUP I DEPARTMENT 1SECTION---
POSITION 1BAND
-
I
:
-
.-
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
NOTES -------