It is the policy of the Company to treat complaints seriously and expeditiously. To this end, the Company adopted a procedure on handling complaints and whistleblowing to govern the receipt, retention and treatment of complaints regarding (i) the Company’s accounting, internal accounting controls or auditing matters and (ii) breaches of the Company’s policies, including the Policy for the Prevention of Insider Trading, Code of Business Conduct and Ethics, Disclosure Controls and Procedures, Guidelines for Corporate Communications, Document Retention Policy and any fraud risk mitigation strategy, and to protect the confidential, anonymous reporting of such concerns. These procedures apply to all of the directors, officers and employees of the Company and its subsidiaries, as well as third parties.
Under the Company’s Policy and Procedures for Handling Complaints and Whistleblowing, below is the procedure for handling complaints:
- Written complaints may be submitted to the Human Resources Officer, in hard copy or via email. Complaints may also be submitted through a telephone hotline that will be received by a third-party contractor specifically engaged to provide the hotline services or by an internal person specifically designated to receive hotline calls. The complainant need not leave his/her name or other personal information.
- The complaint will be reviewed by designated Complaint Reviewers who will thereafter direct the complaints to the Head of Legal and Head of Internal Audit for investigation. The results of investigation shall be reported to the Audit Committee and Corporate Governance Committee of the Company.
Complaints are promptly and thoroughly investigated to verify its accuracy and to ensure that no malicious or unfounded complaints or reports will be entertained. The Company takes seriously those filing complaints or reports knowing them to be untrue or unfounded.
In no event will there be any retaliation against anyone for reporting an activity that he or she in good faith believes to be a violation of any law, rule or regulation. Any supervisor or other employee intimidating or imposing sanctions on an employee for reporting a Complaint will be disciplined, which may include termination of employment. Employees who believe that they have been retaliated against by the Company, its employees, contractors, subcontractors or agents, for providing information to or assisting in an investigation or proceeding conducted by a governmental authority or a person with supervisory authority over the employee (or another employee who has the authority to investigate or terminate misconduct) in connection with conduct that the employee reasonably believes constitutes a violation of rule or law, may seek redress through governmental agencies.
Conflict of Interest Policy
The Company aims to conduct business according to the highest ethical standards and has adopted a Code of Business Conduct and Ethics, which covers conflict of interest situations, and a separate Conflict of Interest Policy to ensure that the Company and its subsidiaries conduct their business consistent with the highest standards of business ethics. These apply to all the directors, officers, employees, agents and subcontractors of MCP and its subsidiaries.
A conflict of interest can occur when an employee’s private interest interferes, or appears to interfere, with the interests of the Company as a whole.
All apparent, potential, and actual conflicts of interest should be scrupulously avoided and any transactions between an employee and the Company which involves a potential conflict of interest should only be entered into after receipt of the appropriate approval.
All situations that reasonably would be expected to give rise to a conflict of interest must also be disclosed to the Company.
Insider Trading Policy
Preventing insider trading is necessary to comply with securities laws and to preserve the reputation and integrity of the Company, as well as that of all persons affiliated with it.
All directors, officers and employees, including members of their respective households, the parent of the Company and its subsidiaries (“Relevant Persons”) are subject to the rules set forth in the Company’s Insider Trading Policy. All such Relevant Persons are mandated to refrain from trading while in possession of material non-public information and from “tipping” others.
This policy also sets out the prohibited activities applicable to all Relevant Persons and the limits, including the required approvals, by which such Relevant Persons may be allowed to trade in the Company’s securities.
Violation of the provisions of the provisions of this policy could result in serious sanctions, including dismissal from employment of the relevant employee.
Related Party Transactions
The Company’s policy on Related Party Transactions (RPT) sets forth general principles relating to, and the Company’s policy for, identifying and reviewing related party transactions involving the Company or any of its subsidiaries.
Material RPTs require the approval of the Audit Committee in accordance with the RPT Policy and RPT Guidelines. In addition, for RPTs that are also related or connected party transactions for the Company’s parent company, the necessary approval from said parent company’s management, Audit Committee, Board of Directors or independent shareholders must also be obtained.
All transactions shall be checked against the list of related parties. If the same is a related party transaction, it shall be forwarded to the Vice President, Finance. If the related party transaction is considered as not material and is not unusual in its terms and nature, the Vice President, Finance can authorize the approval without need of further approval. However, if it is a material or unusual related party transaction, the Audit Committee shall evaluate and determine whether to recommend the approval of the transaction.
Policy Relating to Health, Safety and Welfare of Employees
The Company is committed to promoting the safety, health and welfare of its employees. To this end, the Company has issued policies that are intended to develop and promote a safer and healthier working environment that will enhance work productivity and efficiency. At present, the Company has exisiting policies related to health and safety:
- Drug-Free Workplace Policy
The Company resolved to develop and maintain a drug-free environment. This policy seeks to promote and protect the employees’ health, safety and well-being and discourage and prevent them from engaging in prohibited drug-related activities.
For this purpose, the Company established a Drug-Free Workplace Committee composed of representatives from the Human Resources department, Legal department, the Company’s Medical Doctor and a representative appointed by the employees. The Committee is responsible for dissemination of information through relevant education programs and implementation of pre-employment, random and mandatory drug tests for employees, among others.
- Policy on HIV, STD and AIDS
The Company enacted this policy to prevent and control the spread in the workplace of sexually transmitted diseases (“STD”), including human immunodeficiency virus (“HIV”) and acquired immune deficiency syndrome (“AIDS”). This policy also intends to protect the right to privacy, dignity and non-discrimination of an employee found infected with the above diseases.
In the case of employees found infected with STD, HIV, or AIDS-related illness, the Company will provide assistance and adopt measures to accommodate their needs, including a referral system and access to diagnostic and treatment services for appropriate medical evaluation and monitoring. The employee shall also be provided information on his or her responsibilities towards other co-employees. An employee shall not be terminated or suspended from work on the sole basis of actual, perceived or suspected STD, HIV or AIDS status.
- Policy on Smoking in Company Premises
This policy aims to spread awareness among the employees on the health hazards of smoking through periodic health seminars and programs. It also seeks to protect and enhance the indoor air quality and contribute to the healthful environment by designating areas that may be used for smoking.