MC No. 15 s.2017 - Integrated Annual Corporate Governance Report (I-ACGR)

SEC FORM � I-ACGR INTEGRATED ANNUAL CORPORATE GOVERNANCE REPORT GENERAL INSTRUCTIONS A. Use of Form I-ACGR This SEC Form shall be used as a tool to disclose Publicly-Listed Companies' compliance/non- compliance with the recommendations provided under the Code of Corporate Governance for Publicly-Listed Companies, which follows the "comply or explain" approach, and for harmonizing the corporate governance reportorial requirements of the SEC and the Philippine Stock Exchange (PSE). B. Preparation of Report These general instructions are not to be filed with the report. The report shall contain the numbers and captions of all items. The I-ACGR has four columns, arranged as follows: RECOMMENDED CG COMPLIANT/ ADDITIONAL EXPLANATION PRACTICE/POLICY INFORMATION NON- COMPLIANT Contains CG Practices/ Policies, The company The company The PLCs shall provide labelled as follows: the explanations for shall indicate shall provide any non-compliance, pursuant to the "comply compliance or additional or explain" approach. (1) "Recommendations" � non- information to derived from the CG Code compliance support their for PLCs; with the compliance (2) "Supplement to recommended with the Please note that the Recommendation" � practice. recommended explanation given should derived from the PSE CG CG practice describe the non- Guidelines for Listed compliance and include Companies; how the overall (3) "Additional Principle being Recommendations" � CG recommended is still Practices not found in the CG being achieved by the Code for PLCs and PSE CG company. Guidelines but are expected already of PLCs; and *"Not Applicable" or (4) "Optional "None" shall not be Recommendation" � considered as practices taken from the sufficient explanation ASEAN Corporate Governance Scorecard *Items under (1) � (3) must be answered/disclosed by the PLCs following the "comply or explain" approach. Answering of items under (4) are left to the discretion of PLCs.

C. Signature and Filing of the Report a. Three (3) copies of a fully accomplished I-ACGR shall be filed with the Main Office of the Commission on or before May 30 of the following year for every year that the company remains listed in the PSE; b. At least one (1) complete copy of the I-ACGR shall be duly notarized and shall bear original and manual signatures c. The I-ACGR shall be signed under oath by: (1) Chairman of the Board; (2) Chief Executive Officer or President; (3) All Independent Directors; (4) Compliance Officer; and (5) Corporate Secretary. d. The I-ACGR shall cover all relevant information from January to December of the given year. e. All reports shall comply with the full disclosure requirements of the Securities Regulation Code. SEC Form � I-ACGR * Updated 21Dec2017

SEC FORM � I-ACGR INTEGRATED ANNUAL CORPORATE GOVERNANCE REPORT 1. For the fiscal year ended ......................................... 2. SEC Identification Number ............................. 3. BIR Tax Identification No. ............................... 4. Exact name of issuer as specified in its charter ................................................................. 5. .................................................................................................. 6. (SEC Use Only) Province, Country or other jurisdiction of incorporation or organization Industry Classification Code: 7. ....................................................................................................... .............................................. Address of principal office Postal Code 8. .................................................................................. Issuer's telephone number, including area code 9. ........................................................................................................................................ Former name, former address, and former fiscal year, if changed since last report. SEC Form � I-ACGR * Updated 21Dec2017

INTEGRATED ANNUAL CORPORATE GOVERNANCE REPORT COMPLIANT/ ADDITIONAL INFORMATION EXPLANATION NON- COMPLIANT The Board's Governance Responsibilities Principle 1: The company should be headed by a competent, working board to foster the long- term success of the corporation, and to sustain its competitiveness and profitability in a manner consistent with its corporate objectives and the long- term best interests of its shareholders and other stakeholders. Recommendation 1.1 1. Board is composed of directors with Provide information or link/reference collective working knowledge, experience to a document containing or expertise that is relevant to the information on the following: company's industry/sector. 2. Board has an appropriate mix of 1. Academic qualifications, industry competence and expertise. knowledge, professional 3. Directors remain qualified for their positions experience, expertise and individually and collectively to enable relevant trainings of directors them to fulfill their roles and responsibilities 2. Qualification standards for and respond to the needs of the directors to facilitate the selection organization. of potential nominees and to serve as benchmark for the evaluation of its performance Recommendation 1.2 Identify or provide link/reference to a 1. Board is composed of a majority of non- document identifying the directors and the type of their directorships executive directors. Recommendation 1.3 Provide link or reference to the 1. Company provides in its Board Charter company's Board Charter and Manual on Corporate Governance and Manual on Corporate Governance a relating to its policy on training of policy on training of directors. directors. SEC Form � I-ACGR * Updated 21Dec2017

2. Company has an orientation program for Provide information or link/reference first time directors. to a document containing information on the orientation 3. Company has relevant annual continuing program and trainings of directors for training for all directors. the previous year, including the number of hours attended and Recommendation 1.4 topics covered. 1. Board has a policy on board diversity. Provide information on or Optional: Recommendation 1.4 link/reference to a document 1. Company has a policy on and discloses containing information on the company's board diversity policy. measurable objectives for implementing its board diversity and reports on progress in Indicate gender composition of the achieving its objectives. board. Recommendation 1.5 Provide information on or 1. Board is assisted by a Corporate Secretary. link/reference to a document 2. Corporate Secretary is a separate containing the company's policy and measureable objectives for individual from the Compliance Officer. implementing board diversity. 3. Corporate Secretary is not a member of Provide link or reference to a the Board of Directors. progress report in achieving its objectives. SEC Form � I-ACGR * Updated 21Dec2017 Provide information on or link/reference to a document containing information on the Corporate Secretary, including his/her name, qualifications, duties and functions.

4. Corporate Secretary attends training/s on Provide information or link/reference corporate governance. to a document containing information on the corporate Optional: Recommendation 1.5 governance training attended, 1. Corporate Secretary distributes materials including number of hours and topics covered for board meetings at least five business days before scheduled meeting. Provide proof that corporate secretary distributed board meeting Recommendation 1.6 materials at least five business days 1. Board is assisted by a Compliance Officer. before scheduled meeting 2. Compliance Officer has a rank of Senior Provide information on or Vice President or an equivalent position link/reference to a document with adequate stature and authority in the containing information on the corporation. Compliance Officer, including his/her 3. Compliance Officer is not a member of name, position, qualifications, duties the board. and functions. 4. Compliance Officer attends training/s on corporate governance. Provide information on or link/reference to a document containing information on the corporate governance training attended, including number of hours and topics covered Principle 2: The fiduciary roles, responsibilities and accountabilities of the Board as provided under the law, the company's articles and by-laws, and other legal pronouncements and guidelines should be clearly made known to all directors as well as to stockholders and other stakeholders. Recommendation 2.1 1. Directors act on a fully informed basis, in Provide information or reference to a good faith, with due diligence and care, document containing information on and in the best interest of the company. how the directors performed their duties (can include board resolutions, minutes of meeting) Recommendation 2.2 SEC Form � I-ACGR * Updated 21Dec2017

1. Board oversees the development, review Provide information or link/reference and approval of the company's business to a document containing objectives and strategy. information on how the directors performed this function (can include 2. Board oversees and monitors the board resolutions, minutes of implementation of the company's business meeting) objectives and strategy. Indicate frequency of review of Supplement to Recommendation 2.2 business objectives and strategy 1. Board has a clearly defined and updated Indicate or provide link/reference to vision, mission and core values. a document containing the company's vision, mission and core 2. Board has a strategy execution process values. that facilitates effective management performance and is attuned to the Indicate frequency of review of the company's business environment, and vision, mission and core values. culture. Provide information on or Recommendation 2.3 link/reference to a document 1. Board is headed by a competent and containing information on the strategy execution process. qualified Chairperson. Provide information or reference to a Recommendation 2.4 document containing information on the Chairperson, including his/her SEC Form � I-ACGR * Updated 21Dec2017 name and qualifications

1. Board ensures and adopts an effective Disclose and provide information or succession planning program for directors, link/reference to a document key officers and management. containing information on the company's succession planning 2. Board adopts a policy on the retirement policies and programs and its for directors and key officers. implementation Recommendation 2.5 Provide information on or 1. Board aligns the remuneration of key link/reference to a document containing information on the officers and board members with long- company's remuneration policy and term interests of the company. its implementation, including the relationship between remuneration 2. Board adopts a policy specifying the and performance. relationship between remuneration and performance. Provide proof of board approval 3. Directors do not participate in discussions Provide information on or or deliberations involving his/her own link/reference to a document remuneration. containing measurable standards to align performance-based Optional: Recommendation 2.5 remuneration with the long-term 1. Board approves the remuneration of senior interest of the company. executives. 2. Company has measurable standards to align the performance-based remuneration of the executive directors and senior executives with long-term interest, such as claw back provision and deferred bonuses. Recommendation 2.6 SEC Form � I-ACGR * Updated 21Dec2017

1. Board has a formal and transparent board Provide information or reference to a nomination and election policy. document containing information on the company's nomination and 2. Board nomination and election policy is election policy and process and its disclosed in the company's Manual on implementation, including the criteria Corporate Governance. used in selecting new directors, how the shortlisted candidates and how it 3. Board nomination and election policy encourages nominations from includes how the company accepted shareholders. nominations from minority shareholders. Provide proof if minority shareholders 4. Board nomination and election policy have a right to nominate candidates includes how the board shortlists to the board candidates. Provide information if there was an 5. Board nomination and election policy assessment of the effectiveness of includes an assessment of the the Board's processes in the effectiveness of the Board's processes in nomination, election or replacement the nomination, election or replacement of a director. of a director. Identify the professional search firm 6. Board has a process for identifying the used or other external sources of quality of directors that is aligned with the candidates strategic direction of the company. Optional: Recommendation to 2.6 1. Company uses professional search firms or other external sources of candidates (such as director databases set up by director or shareholder bodies) when searching for candidates to the board of directors. Recommendation 2.7 SEC Form � I-ACGR * Updated 21Dec2017

1. Board has overall responsibility in ensuring Provide information on or reference that there is a group-wide policy and to a document containing the system governing related party company's policy on related party transactions (RPTs) and other unusual or transaction, including policy on infrequently occurring transactions. review and approval of significant RPTs 2. RPT policy includes appropriate review Identify transactions that were and approval of material RPTs, which approved pursuant to the policy. guarantee fairness and transparency of the transactions. Provide information on a materiality threshold for RPT disclosure and 3. RPT policy encompasses all entities within approval, if any. the group, taking into account their size, Provide information on RPT structure, risk profile and complexity of categories operations. Provide information on voting system, Supplement to Recommendations 2.7 if any. 1. Board clearly defines the threshold for disclosure and approval of RPTs and categorizes such transactions according to those that are considered de minimis or transactions that need not be reported or announced, those that need to be disclosed, and those that need prior shareholder approval. The aggregate amount of RPTs within any twelve (12) month period should be considered for purposes of applying the thresholds for disclosure and approval. 2. Board establishes a voting system whereby a majority of non-related party shareholders approve specific types of related party transactions during shareholders' meetings. Recommendation 2.8 SEC Form � I-ACGR * Updated 21Dec2017

1. Board is primarily responsible for approving Provide information on or reference the selection of Management led by the to a document containing the Chief Executive Officer (CEO) and the Board's policy and responsibility for heads of the other control functions (Chief approving the selection of Risk Officer, Chief Compliance Officer and management. Chief Audit Executive). Identity the Management team 2. Board is primarily responsible for assessing appointed the performance of Management led by the Chief Executive Officer (CEO) and the Provide information on or reference heads of the other control functions (Chief to a document containing the Risk Officer, Chief Compliance Officer and Board's policy and responsibility for Chief Audit Executive). assessing the performance of management. Recommendation 2.9 1. Board establishes an effective Provide information on the assessment process and indicate performance management framework frequency of assessment of that ensures that Management's performance. performance is at par with the standards set by the Board and Senior Management. Provide information on or link/reference to a document 2. Board establishes an effective containing the Board's performance performance management framework management framework for that ensures that personnel's performance management and personnel. is at par with the standards set by the Board and Senior Management. Recommendation 2.10 SEC Form � I-ACGR * Updated 21Dec2017

1. Board oversees that an appropriate Provide information on or internal control system is in place. link/reference to a document showing the Board's responsibility for 2. The internal control system includes a overseeing that an appropriate mechanism for monitoring and managing internal control system is in place and potential conflict of interest of the what is included in the internal Management, members and shareholders. control system 3. Board approves the Internal Audit Charter. Provide reference or link to the company's Internal Audit Charter Recommendation 2.11 1. Board oversees that the company has in Provide information on or link/reference to a document place a sound enterprise risk management showing the Board's oversight (ERM) framework to effectively identify, responsibility on the establishment of monitor, assess and manage key business a sound enterprise risk management risks. framework and how the board was 2. The risk management framework guides guided by the framework. the board in identifying units/business lines and enterprise-level risk exposures, as well Provide proof of effectiveness of risk as the effectiveness of risk management management strategies, if any. strategies. Provide link to the company's Recommendation 2.12 website where the Board Charter is 1. Board has a Board Charter that formalizes disclosed. and clearly states its roles, responsibilities and accountabilities in carrying out its fiduciary role. 2. Board Charter serves as a guide to the directors in the performance of their functions. 3. Board Charter is publicly available and posted on the company's website. SEC Form � I-ACGR * Updated 21Dec2017

Additional Recommendation to Principle 2 Provide information on or 1. Board has a clear insider trading policy. link/reference to a document showing company's insider trading policy. Optional: Principle 2 Provide information on or 1. Company has a policy on granting loans link/reference to a document showing company's policy on to directors, either forbidding the practice granting loans to directors, if any. or ensuring that the transaction is conducted at arm's length basis and at Indicate the types of decision market rates. requiring board of directors' 2. Company discloses the types of decision approval and where there are requiring board of directors' approval. disclosed. Principle 3: Board committees should be set up to the extent possible to support the effective performance of the Board's functions, particularly with respect to audit, risk management, related party transactions, and other key corporate governance concerns, such as nomination and remuneration. The composition, functions and responsibilities of all committees established should be contained in a publicly available Committee Charter. Recommendation 3.1 1. Board establishes board committees that Provide information or link/reference focus on specific board functions to aid in to a document containing the optimal performance of its roles and information on all the board responsibilities. committees established by the company. Recommendation 3.2 SEC Form � I-ACGR * Updated 21Dec2017

1. Board establishes an Audit Committee to Provide information or link/reference enhance its oversight capability over the to a document containing company's financial reporting, internal information on the Audit Committee, control system, internal and external audit including its functions. processes, and compliance with applicable laws and regulations. Indicate if it is the Audit Committee's responsibility to recommend the 2. Audit Committee is composed of at least appointment and removal of the three appropriately qualified non- company's external auditor. executive directors, the majority of whom, including the Chairman is independent. Provide information or link/reference to a document containing 3. All the members of the committee have information on the members of the relevant background, knowledge, skills, Audit Committee, including their and/or experience in the areas of qualifications and type of accounting, auditing and finance. directorship. 4. The Chairman of the Audit Committee is Provide information or link/reference not the Chairman of the Board or of any to a document containing other committee. information on the background, knowledge, skills, and/or experience Supplement to Recommendation 3.2 of the members of the Audit 1. Audit Committee approves all non-audit Committee. services conducted by the external Provide information or link/reference auditor. to a document containing information on the Chairman of the SEC Form � I-ACGR * Updated 21Dec2017 Audit Committee Provide proof that the Audit Committee approved all non-audit services conducted by the external auditor.

2. Audit Committee conducts regular Provide proof that the Audit meetings and dialogues with the external Committee conducted regular audit team without anyone from meetings and dialogues with the management present. external audit team without anyone from management present. Optional: Recommendation 3.2 1. Audit Committee meet at least four times Indicate the number of Audit Committee meetings during the year during the year. and provide proof 2. Audit Committee approves the Provide proof that the Audit appointment and removal of the internal Committee approved the auditor. appointment and removal of the internal auditor. Recommendation 3.3 1. Board establishes a Corporate Provide information or reference to a document containing information on Governance Committee tasked to assist the Corporate Governance the Board in the performance of its Committee, including its functions corporate governance responsibilities, including the functions that were formerly Indicate if the Committee undertook assigned to a Nomination and the process of identifying the quality Remuneration Committee. of directors aligned with the company's strategic direction, if 2. Corporate Governance Committee is applicable. composed of at least three members, all of whom should be independent directors. Provide information or link/reference to a document containing SEC Form � I-ACGR * Updated 21Dec2017 information on the members of the Corporate Governance Committee, including their qualifications and type of directorship.

3. Chairman of the Corporate Governance Provide information or link/reference Committee is an independent director. to a document containing information on the Chairman of the Optional: Recommendation 3.3. Corporate Governance Committee. 1. Corporate Governance Committee meet Indicate the number of Corporate at least twice during the year. Governance Committee meetings held during the year and provide Recommendation 3.4 proof thereof. 1. Board establishes a separate Board Risk Provide information or link/reference Oversight Committee (BROC) that should to a document containing be responsible for the oversight of a information on the Board Risk company's Enterprise Risk Management Oversight Committee (BROC), system to ensure its functionality and including its functions effectiveness. 2. BROC is composed of at least three Provide information or link/reference members, the majority of whom should be to a document containing independent directors, including the information on the members of the Chairman. BROC, including their qualifications and type of directorship 3. The Chairman of the BROC is not the Chairman of the Board or of any other Provide information or link/reference committee. to a document containing information on the Chairman of the 4. At least one member of the BROC has BROC relevant thorough knowledge and experience on risk and risk management. Provide information or link/reference to a document containing SEC Form � I-ACGR * Updated 21Dec2017 information on the background, skills, and/or experience of the members of the BROC.

Recommendation 3.5 Provide information or link/reference 1. Board establishes a Related Party to a document containing information on the Related Party Transactions (RPT) Committee, which is Transactions (RPT) Committee, tasked with reviewing all material related including its functions. party transactions of the company. Provide information or link/reference 2. RPT Committee is composed of at least to a document containing three non-executive directors, two of information on the members of the whom should be independent, including RPT Committee, including their the Chairman. qualifications and type of directorship. Recommendation 3.6 1. All established committees have a Provide information on or link/reference to the company's Committee Charter stating in plain terms committee charters, containing all their respective purposes, memberships, the required information, particularly structures, operations, reporting process, the functions of the Committee that resources and other relevant information. is necessary for performance evaluation purposes. 2. Committee Charters provide standards for evaluating the performance of the Provide link to company's website Committees. where the Committee Charters are disclosed. 3. Committee Charters were fully disclosed on the company's website. Principle 4: To show full commitment to the company, the directors should devote the time and attention necessary to properly and effectively perform their duties and responsibilities, including sufficient time to be familiar with the corporation's business. Recommendation 4.1 SEC Form � I-ACGR * Updated 21Dec2017

1. The Directors attend and actively Provide information or link/reference participate in all meetings of the Board, to a document containing Committees and shareholders in person or information on the process and through tele-/videoconferencing procedure for conducted in accordance with the rules tele/videoconferencing board and regulations of the Commission. and/or committee meetings. 2. The directors review meeting materials for Provide information or link/reference all Board and Committee meetings. to a document containing information on the attendance and 3. The directors ask the necessary questions participation of directors to Board, or seek clarifications and explanations Committee and shareholders' during the Board and Committee meetings. meetings. Provide information or link/reference Recommendation 4.2 to a document containing 1. Non-executive directors concurrently serve information on any questions raised or clarification/explanation sought by in a maximum of five publicly-listed the directors companies to ensure that they have sufficient time to fully prepare for minutes, Disclose if the company has a policy challenge Management's setting the limit of board seats that a proposals/views, and oversee the long- non-executive director can hold term strategy of the company. simultaneously. SEC Form � I-ACGR * Updated 21Dec2017 Provide information or reference to a document containing information on the directorships of the company's directors in both listed and non-listed companies

Recommendation 4.3 Provide copy of written notification 1. The directors notify the company's board to the board or minutes of board meeting wherein the matter was before accepting a directorship in another discussed. company. Indicate the number of board Optional: Principle 4 meetings during the year and 1. Company does not have any executive provide proof Indicate the required minimum directors who serve in more than two quorum for board decisions boards of listed companies outside of the group. 2. Company schedules board of directors' meetings before the start of the financial year. 3. 4. Board of directors meet at least six times during the year. 5. Company requires as minimum quorum of at least 2/3 for board decisions. Principle 5: The board should endeavor to exercise an objective and independent judgment on all corporate affairs Recommendation 5.1 Provide information or link/reference 1. The Board has at least 3 independent to a document containing information on the number of directors or such number as to constitute independent directors in the board one-third of the board, whichever is higher. Recommendation 5.2 SEC Form � I-ACGR * Updated 21Dec2017

1. The independent directors possess all the Provide information or link/reference qualifications and none of the to a document containing disqualifications to hold the positions. information on the qualifications of the independent directors. Supplement to Recommendation 5.2 1. Company has no shareholder agreements, Provide link/reference to a document containing information by-laws provisions, or other arrangements that directors are not constrained to that constrain the directors' ability to vote vote independently. independently. Provide information or link/reference Recommendation 5.3 to a document showing the years IDs 1. The independent directors serve for a have served as such. cumulative term of nine years (reckoned Provide information or link/reference from 2012). to a document containing information on the company's policy 2. The company bars an independent on term limits for its independent director from serving in such capacity after director the term limit of nine years. Provide reference to the meritorious 3. In the instance that the company retains justification and proof of an independent director in the same shareholders' approval during the capacity after nine years, the board annual shareholders' meeting. provides meritorious justification and seeks shareholders' approval during the annual Identify the company's Chairman of shareholders' meeting. the Board and Chief Executive Officer Recommendation 5.4 1. The positions of Chairman of the Board and Chief Executive Officer are held by separate individuals. SEC Form � I-ACGR * Updated 21Dec2017

2. The Chairman of the Board and Chief Provide information or link/reference Executive Officer have clearly defined to a document containing responsibilities. information on the roles and responsibilities of the Chairman of the Recommendation 5.5 Board and Chief Executive Officer. 1. If the Chairman of the Board is not an Identify the relationship of Chairman independent director, the board and CEO. designates a lead director among the independent directors. Provide information or link/reference to a document containing Recommendation 5.6 information on a lead independent 1. Directors with material interest in a director and his roles and responsibilities, if any. transaction affecting the corporation abstain from taking part in the Indicate if Chairman is independent. deliberations on the transaction. Provide proof of abstention, if this Recommendation 5.7 was the case 1. The non-executive directors (NEDs) have Provide proof and details of said separate periodic meetings with the meeting, if any. external auditor and heads of the internal audit, compliance and risk functions, Provide information on the frequency without any executive present. and attendees of meetings. 2. The meetings are chaired by the lead independent director. Optional: Principle 5 SEC Form � I-ACGR * Updated 21Dec2017

1. None of the directors is a former CEO of Provide name/s of company CEO for the company in the past 2 years. the past 2 years Principle 6: The best measure of the Board's effectiveness is through an assessment process. The Board should regularly carry out evaluations to appraise its performance as a body, and assess whether it possesses the right mix of backgrounds and competencies. Recommendation 6.1 1. Board conducts an annual self-assessment Provide proof of self-assessments of its performance as a whole. conducted for the whole board, the 2. The Chairman conducts a self-assessment individual members, the Chairman of his performance. and the Committees 3. The individual members conduct a self- assessment of their performance. 4. Each committee conducts a self- assessment of its performance. 5. Every three years, the assessments are Identify the external facilitator and supported by an external facilitator. provide proof of use of an external facilitator. Recommendation 6.2 Provide information or link/reference 1. Board has in place a system that provides, to a document containing information on the system of the at the minimum, criteria and process to company to evaluate the determine the performance of the Board, performance of the board, individual individual directors and committees. directors and committees, including a feedback mechanism from 2. The system allows for a feedback shareholders mechanism from the shareholders. Principle 7: Members of the Board are duty-bound to apply high ethical standards, taking into account the interests of all stakeholders. Recommendation 7.1 SEC Form � I-ACGR * Updated 21Dec2017

1. Board adopts a Code of Business Conduct Provide information on or and Ethics, which provide standards for link/reference to the company's professional and ethical behavior, as well Code of Business Conduct and as articulate acceptable and Ethics. unacceptable conduct and practices in internal and external dealings of the Provide information on or discuss how company. the company disseminated the Code to its Board, senior 2. The Code is properly disseminated to the management and employees. Board, senior management and Provide a link to the company's employees. website where the Code of Business Conduct and Ethics is posted/ 3. The Code is disclosed and made available disclosed. to the public through the company website. Provide information on or link/reference to a document Supplement to Recommendation 7.1 containing information on the 1. Company has clear and stringent policies company's policy and procedure on curbing and penalizing bribery and procedures on curbing and penalizing company involvement in offering, paying Provide proof of implementation and and receiving bribes. monitoring of compliance with the Code of Business Conduct and Ethics Recommendation 7.2 and internal policies. 1. Board ensures the proper and efficient Indicate who are required to comply implementation and monitoring of with the Code of Business Conduct compliance with the Code of Business and Ethics and any findings on non- Conduct and Ethics. compliance. 2. Board ensures the proper and efficient implementation and monitoring of Disclosure and Transparency compliance with company internal policies. SEC Form � I-ACGR * Updated 21Dec2017

Principle 8: The company should establish corporate disclosure policies and procedures that are practical and in accordance with best practices and regulatory expectations. Recommendation 8.1 1. Board establishes corporate disclosure Provide information on or policies and procedures to ensure a link/reference to the company's comprehensive, accurate, reliable and disclosure policies and procedures timely report to shareholders and other including reports distributed/made stakeholders that gives a fair and available to shareholders and other complete picture of a company's financial stockholders condition, results and business operations. Supplement to Recommendations 8.1 1. Company distributes or makes available Indicate the number of days within annual and quarterly consolidated reports, which the consolidated and interim cash flow statements, and special audit reports were published, distributed or revisions. Consolidated financial made available from the end of the statements are published within ninety (90) fiscal year and end of the reporting days from the end of the fiscal year, while period, respectively. interim reports are published within forty- five (45) days from the end of the reporting period. 2. Company discloses in its annual report the Provide link or reference to the principal risks associated with the identity company's annual report where the of the company's controlling shareholders; following are disclosed: the degree of ownership concentration; 1. principal risks to minority cross-holdings among company affiliates; shareholders associated with and any imbalances between the the identity of the company's controlling shareholders' voting power and controlling shareholders; overall equity position in the company. 2. cross-holdings among company affiliates; and 3. any imbalances between the controlling shareholders' voting power and overall equity position in the company. Recommendation 8.2 SEC Form � I-ACGR * Updated 21Dec2017

1. Company has a policy requiring all Provide information on or directors to disclose/report to the link/reference to the company's company any dealings in the company's policy requiring directors and officers shares within three business days. to disclose their dealings in the company's share. 2. Company has a policy requiring all officers to disclose/report to the company any Indicate actual dealings of directors dealings in the company's shares within involving the corporation's shares three business days. including their nature, number/percentage and date of Supplement to Recommendation 8.2 transaction. 1. Company discloses the trading of the Provide information on or corporation's shares by directors, officers link/reference to the shareholdings of (or persons performing similar functions) directors, management and top 100 and controlling shareholders. This includes shareholders. the disclosure of the company's purchase of its shares from the market (e.g. share Provide link or reference to the buy-back program). company's Conglomerate Map. Recommendation 8.3 Provide link or reference to the 1. Board fully discloses all relevant and directors' academic qualifications, share ownership in the company, material information on individual board membership in other boards, other members to evaluate their experience executive positions, professional and qualifications, and assess any experiences, expertise and relevant potential conflicts of interest that might trainings attended. affect their judgment. SEC Form � I-ACGR * Updated 21Dec2017

2. Board fully discloses all relevant and Provide link or reference to the key material information on key executives to officers' academic qualifications, evaluate their experience and share ownership in the company, qualifications, and assess any potential membership in other boards, other conflicts of interest that might affect their executive positions, professional judgment. experiences, expertise and relevant trainings attended. Recommendation 8.4 1. Company provides a clear disclosure of its Disclose or provide link/reference to the company policy and practice for policies and procedure for setting Board setting board remuneration remuneration, including the level and mix of the same. Disclose or provide link/reference to the company policy and practice for 2. Company provides a clear disclosure of its determining executive remuneration policies and procedure for setting executive remuneration, including the Provide breakdown of director level and mix of the same. remuneration and executive compensation, particularly the 3. Company discloses the remuneration on remuneration of the CEO. an individual basis, including termination and retirement provisions. Disclose or provide reference/link to company's RPT policies Recommendation 8.5 1. Company discloses its policies governing Indicate if the director with conflict of interest abstained from the board Related Party Transactions (RPTs) and other discussion on that particular unusual or infrequently occurring transaction. transactions in their Manual on Corporate Governance. SEC Form � I-ACGR * Updated 21Dec2017

2. Company discloses material or significant Provide information on all RPTs for the RPTs reviewed and approved during the previous year or reference to a year. document containing the following information on all RPTs: Supplement to Recommendation 8.5 1. Company requires directors to disclose 1. name of the related counterparty; their interests in transactions or any other conflict of interests. 2. relationship with the party; Optional : Recommendation 8.5 3. transaction date; 1. Company discloses that RPTs are 4. type/nature of transaction; conducted in such a way to ensure that 5. amount or contract price; they are fair and at arms' length. 6. terms of the transaction; Recommendation 8.6 7. rationale for entering into the SEC Form � I-ACGR * Updated 21Dec2017 transaction; 8. the required approval (i.e., names of the board of directors approving, names and percentage of shareholders who approved) based on the company's policy; and 9. other terms and conditions Indicate where and when directors disclose their interests in transactions or any other conflict of interests. Provide link or reference where this is disclosed, if any

1. Company makes a full, fair, accurate and Provide link or reference where this is timely disclosure to the public of every disclosed material fact or event that occur, particularly on the acquisition or disposal Identify independent party of significant assets, which could adversely appointed to evaluate the fairness of affect the viability or the interest of its the transaction price shareholders and other stakeholders. Disclose the rules and procedures for evaluating the fairness of the 2. Board appoints an independent party to transaction price, if any. evaluate the fairness of the transaction Provide link or reference where these price on the acquisition or disposal of are disclosed. assets. Provide link to the company's Supplement to Recommendation 8.6 website where the Manual on 1. Company discloses the existence, Corporate Governance is posted. justification and details on shareholder agreements, voting trust agreements, confidentiality agreements, and such other agreements that may impact on the control, ownership, and strategic direction of the company. Recommendation 8.7 1. Company's corporate governance policies, programs and procedures are contained in its Manual on Corporate Governance (MCG). 2. Company's MCG is submitted to the SEC and PSE. 3. Company's MCG is posted on its company website. Supplement to Recommendation 8.7 SEC Form � I-ACGR * Updated 21Dec2017

1. Company submits to the SEC and PSE an Provide proof of submission. updated MCG to disclose any changes in Provide link or reference to the its corporate governance practices. company's Annual Report containing the said information. Optional: Principle 8 1. Does the company's Annual Report Provide link or reference to where this is contained in the Annual Report disclose the following information: a. Corporate Objectives b. Financial performance indicators c. Non-financial performance indicators d. Dividend Policy e. Biographical details (at least age, academic qualifications, date of first appointment, relevant experience, and other directorships in listed companies) of all directors f. Attendance details of each director in all directors meetings held during the year g. Total remuneration of each member of the board of directors 2. The Annual Report contains a statement confirming the company's full compliance with the Code of Corporate Governance and where there is non-compliance, identifies and explains reason for each such issue. SEC Form � I-ACGR * Updated 21Dec2017

3. The Annual Report/Annual CG Report Provide link or reference to where this discloses that the board of directors is contained in the Annual Report conducted a review of the company's material controls (including operational, Provide link or reference to where this financial and compliance controls) and is contained in the Annual Report risk management systems. Provide link or reference to where 4. The Annual Report/Annual CG Report these are contained in the Annual contains a statement from the board of Report directors or Audit Committee commenting on the adequacy of the company's internal controls/risk management systems. 5. The company discloses in the Annual Report the key risks to which the company is materially exposed to (i.e. financial, operational including IT, environmental, social, economic). Principle 9: The company should establish standards for the appropriate selection of an external auditor, and exercise effective oversight of the same to strengthen the external auditor's independence and enhance audit quality. Recommendation 9.1 Provide information or link/reference 1. Audit Committee has a robust process for to a document containing information on the process for approving and recommending the approving and recommending the appointment, reappointment, removal, appointment, reappointment, and fees of the external auditors. removal and fees of the company's external auditor. 2. The appointment, reappointment, Indicate the percentage of removal, and fees of the external auditor is shareholders that ratified the recommended by the Audit Committee, appointment, reappointment, approved by the Board and ratified by the removal and fees of the external shareholders. auditor. SEC Form � I-ACGR * Updated 21Dec2017

3. For removal of the external auditor, the Provide information on or reasons for removal or change are link/reference to a document disclosed to the regulators and the public containing the company's reason for through the company website and removal or change of external required disclosures. auditor. Supplement to Recommendation 9.1 Provide information on or 1. Company has a policy of rotating the lead link/reference to a document containing the policy of rotating the audit partner every five years. lead audit partner every five years. Provide link/reference to the Recommendation 9.2 company's Audit Committee Charter 1. Audit Committee Charter includes the Provide link/reference to the Audit Committee's responsibility on: company's Audit Committee Charter i. assessing the integrity and independence of external auditors; ii. exercising effective oversight to review and monitor the external auditor's independence and objectivity; and iii. exercising effective oversight to review and monitor the effectiveness of the audit process, taking into consideration relevant Philippine professional and regulatory requirements. 2. Audit Committee Charter contains the Committee's responsibility on reviewing and monitoring the external auditor's suitability and effectiveness on an annual basis. Supplement to Recommendations 9.2 SEC Form � I-ACGR * Updated 21Dec2017

1. Audit Committee ensures that the external Provide link/reference to the auditor is credible, competent and has the company's Audit Committee Charter ability to understand complex related party transactions, its counterparties, and Provide link/reference to the valuations of such transactions. company's Audit Committee Charter 2. Audit Committee ensures that the external Disclose the nature of non-audit auditor has adequate quality control services performed by the external procedures. auditor, if any. Provide link or reference to guidelines Recommendation 9.3 or policies on non-audit services 1. Company discloses the nature of non- Provide information on audit and audit services performed by its external non-audit fees paid. auditor in the Annual Report to deal with the potential conflict of interest. 2. Audit Committee stays alert for any potential conflict of interest situations, given the guidelines or policies on non- audit services, which could be viewed as impairing the external auditor's objectivity. Supplement to Recommendation 9.3 1. Fees paid for non-audit services do not outweigh the fees paid for audit services. Additional Recommendation to Principle 9 SEC Form � I-ACGR * Updated 21Dec2017

1. Company's external auditor is duly Provide information on company's accredited by the SEC under Group A external auditor, such as: category. 1. Name of the audit engagement partner; 2. Accreditation number; 3. Date Accredited; 4. Expiry date of accreditation; and 5. Name, address, contact number of the audit firm. 2. Company's external auditor agreed to be Provide information on the following: subjected to the SEC Oversight Assurance 1. Date it was subjected to Review (SOAR) Inspection Program SOAR inspection, if subjected; conducted by the SEC's Office of the 2. Name of the Audit firm; and General Accountant (OGA). 3. Members of the engagement team inspected by the SEC. Principle 10: The company should ensure that the material and reportable non-financial and sustainability issues are disclosed. Recommendation 10.1 Disclose or provide link on the 1. Board has a clear and focused policy on company's policies and practices on the disclosure of non-financial the disclosure of non-financial information, information, including EESG issues. with emphasis on the management of economic, environmental, social and governance (EESG) issues of its business, which underpin sustainability. 2. Company adopts a globally recognized Provide link to Sustainability Report, if standard/framework in reporting any. Disclose the standards used. sustainability and non-financial issues. SEC Form � I-ACGR * Updated 21Dec2017

Principle 11: The company should maintain a comprehensive and cost-efficient communication channel for disseminating relevant information. This channel is crucial for informed decision-making by investors, stakeholders and other interested users. Recommendation 11.1 1. Company has media and analysts' Disclose and identify the briefings as channels of communication to communication channels used by ensure the timely and accurate the company (i.e., website, Analyst's dissemination of public, material and briefing, Media briefings /press relevant information to its shareholders conferences, Quarterly reporting, and other investors. Current reporting, etc.). Provide links, if any. Supplemental to Principle 11 Provide link to company website 1. Company has a website disclosing up-to- date information on the following: a. Financial statements/reports (latest quarterly) b. Materials provided in briefings to analysts and media c. Downloadable annual report d. Notice of ASM and/or SSM e. Minutes of ASM and/or SSM f. Company's Articles of Incorporation and By-Laws Additional Recommendation to Principle 11 1. Company complies with SEC-prescribed website template. SEC Form � I-ACGR * Updated 21Dec2017

Internal Control System and Risk Management Framework Principle 12: To ensure the integrity, transparency and proper governance in the conduct of its affairs, the company should have a strong and effective internal control system and enterprise risk management framework. Recommendation 12.1 List quality service programs for the 1. Company has an adequate and effective internal audit functions. internal control system in the conduct of its Indicate frequency of review of the business. internal control system 2. Company has an adequate and effective Identify international framework used enterprise risk management framework in for Enterprise Risk Management the conduct of its business. Provide information or reference to a document containing information on: 1. Company's risk management procedures and processes 2. Key risks the company is currently facing 3. How the company manages the key risks Indicate frequency of review of the enterprise risk management framework. Supplement to Recommendations 12.1 SEC Form � I-ACGR * Updated 21Dec2017

1. Company has a formal comprehensive Provide information on or link/ enterprise-wide compliance program reference to a document containing covering compliance with laws and the company's compliance program relevant regulations that is annually covering compliance with laws and reviewed. The program includes relevant regulations. appropriate training and awareness Indicate frequency of review. initiatives to facilitate understanding, acceptance and compliance with the Provide information on IT governance said issuances. process Optional: Recommendation 12.1 Disclose if the internal audit is in- house or outsourced. If outsourced, 1. Company has a governance process on IT identify external firm. issues including disruption, cyber security, Identify the company's Chief Audit and disaster recovery, to ensure that all Executive (CAE) and provide key risks are identified, managed and information on or reference to a reported to the board. document containing his/her responsibilities. Recommendation 12.2 1. Company has in place an independent internal audit function that provides an independent and objective assurance, and consulting services designed to add value and improve the company's operations. Recommendation 12.3 1. Company has a qualified Chief Audit Executive (CAE) appointed by the Board. SEC Form � I-ACGR * Updated 21Dec2017

2. CAE oversees and is responsible for the Identify qualified independent internal audit activity of the organization, executive or senior management including that portion that is outsourced to personnel, if applicable. a third party service provider. Provide information on company's 3. In case of a fully outsourced internal audit risk management function. activity, a qualified independent executive or senior management Identify source of external technical personnel is assigned the responsibility for support, if any. managing the fully outsourced internal audit activity. Identify the company's Chief Risk Officer (CRO) and provide Recommendation 12.4 information on or reference to a 1. Company has a separate risk document containing his/her responsibilities and management function to identify, assess qualifications/background. and monitor key risk exposures. Supplement to Recommendation 12.4 1. Company seeks external technical support in risk management when such competence is not available internally. Recommendation 12.5 1. In managing the company's Risk Management System, the company has a Chief Risk Officer (CRO), who is the ultimate champion of Enterprise Risk Management (ERM). 2. CRO has adequate authority, stature, resources and support to fulfill his/her responsibilities. Additional Recommendation to Principle 12 SEC Form � I-ACGR * Updated 21Dec2017

1. Company's Chief Executive Officer and Provide link to CEO and CAE's Chief Audit Executive attest in writing, at attestation least annually, that a sound internal audit, control and compliance system is in place and working effectively. Cultivating a Synergic Relationship with Shareholders Principle 13: The company should treat all shareholders fairly and equitably, and also recognize, protect and facilitate the exercise of their rights. Recommendation 13.1 1. Board ensures that basic shareholder rights Provide link or reference to the are disclosed in the Manual on Corporate company's Manual on Corporate Governance. Governance where shareholders' rights are disclosed. 2. Board ensures that basic shareholder rights Provide link to company's website are disclosed on the company's website. Supplement to Recommendation 13.1 1. Company's common share has one vote for one share. 2. Board ensures that all shareholders of the Provide information on all classes of same class are treated equally with shares, including their voting rights if respect to voting rights, subscription rights any. and transfer rights. 3. Board has an effective, secure, and Provide link to voting procedure. efficient voting system. Indicate if voting is by poll or show of hands. 4. Board has an effective shareholder voting Provide information on shareholder mechanisms such as supermajority or voting mechanisms such as "majority of minority" requirements to supermajority or "majority of protect minority shareholders against minority", if any. actions of controlling shareholders. SEC Form � I-ACGR * Updated 21Dec2017

5. Board allows shareholders to call a special Provide information on how this was shareholders' meeting and submit a allowed by board (i.e., minutes of proposal for consideration or agenda item meeting, board resolution) at the AGM or special meeting. Provide information or link/reference 6. Board clearly articulates and enforces to the policies on treatment of policies with respect to treatment of minority shareholders minority shareholders. Provide information on or 7. Company has a transparent and specific link/reference to the company's dividend policy. dividend Policy. Optional: Recommendation 13.1 Indicate if company declared 1. Company appoints an independent party dividends. If yes, indicate the number of days within which the dividends to count and/or validate the votes at the were paid after declaration. In case Annual Shareholders' Meeting. the company has offered scrip- Recommendation 13.2 dividends, indicate if the company paid the dividends within 60 days SEC Form � I-ACGR * Updated 21Dec2017 from declaration Identify the independent party that counted/validated the votes at the ASM, if any.

1. Board encourages active shareholder Indicate the number of days before participation by sending the Notice of the annual stockholders' meeting or Annual and Special Shareholders' special stockholders' meeting when Meeting with sufficient and relevant the notice and agenda were sent information at least 28 days before the out meeting. Indicate whether shareholders' approval of remuneration or any Supplemental to Recommendation 13.2 changes therein were included in the 1. Company's Notice of Annual agenda of the meeting. Provide link to the Agenda included Stockholders' Meeting contains the in the company's Information following information: Statement (SEC Form 20-IS) Provide link or reference to the a. The profiles of directors (i.e., age, company's notice of Annual academic qualifications, date of first Shareholders' Meeting appointment, experience, and directorships in other listed companies) Provide link or reference to the rationale for the agenda items b. Auditors seeking appointment/re- appointment c. Proxy documents Optional: Recommendation 13.2 1. Company provides rationale for the agenda items for the annual stockholders meeting Recommendation 13.3 SEC Form � I-ACGR * Updated 21Dec2017

1. Board encourages active shareholder Provide information or reference to a participation by making the result of the document containing information on votes taken during the most recent all relevant questions raised and Annual or Special Shareholders' Meeting answers during the ASM and special publicly available the next working day. meeting and the results of the vote taken during the most recent 2. Minutes of the Annual and Special ASM/SSM. Shareholders' Meetings were available on Provide link to minutes of meeting in the company website within five business the company website. days from the end of the meeting. Indicate voting results for all agenda Supplement to Recommendation 13.3 items, including the approving, 1. Board ensures the attendance of the dissenting and abstaining votes. external auditor and other relevant Indicate also if the voting on individuals to answer shareholders resolutions was by poll. questions during the ASM and SSM. Recommendation 13.4 Include whether there was 1. Board makes available, at the option of a opportunity to ask question and the shareholder, an alternative dispute answers given, if any mechanism to resolve intra-corporate disputes in an amicable and effective Indicate if the external auditor and manner. other relevant individuals were present during the ASM and/or SEC Form � I-ACGR * Updated 21Dec2017 special meeting Provide details of the alternative dispute resolution made available to resolve intra-corporate disputes

2. The alternative dispute mechanism is Provide link/reference to where it is included in the company's Manual on found in the Manual on Corporate Corporate Governance. Governance Recommendation 13.5 Disclose the contact details of the 1. Board establishes an Investor Relations officer/office responsible for investor relations, such as: Office (IRO) to ensure constant engagement with its shareholders. 1. Name of the person 2. Telephone number 2. IRO is present at every shareholder's 3. Fax number meeting. 4. E-mail address Supplemental Recommendations to Principle 13 Indicate if the IRO was present during 1. Board avoids anti-takeover measures or the ASM. similar devices that may entrench Provide information on how anti- ineffective management or the existing takeover measures or similar devices controlling shareholder group were avoided by the board, if any. 2. Company has at least thirty percent (30%) Indicate the company's public float. public float to increase liquidity in the market. Disclose or provide link/reference to policies and practices to encourage Optional: Principle 13 shareholders' participation beyond 1. Company has policies and practices to ASM encourage shareholders to engage with the company beyond the Annual Stockholders' Meeting SEC Form � I-ACGR * Updated 21Dec2017

2. Company practices secure electronic Disclose the process and procedure voting in absentia at the Annual for secure electronic voting in Shareholders' Meeting. absentia, if any. Duties to Stakeholders Principle 14: The rights of stakeholders established by law, by contractual relations and through voluntary commitments must be respected. Where stakeholders' rights and/or interests are at stake, stakeholders should have the opportunity to obtain prompt effective redress for the violation of their rights. Recommendation 14.1 1. Board identifies the company's various Identify the company's shareholder stakeholders and promotes cooperation and provide information or reference between them and the company in to a document containing creating wealth, growth and sustainability. information on the company's policies and programs for its stakeholders. Recommendation 14.2 Identify policies and programs for the 1. Board establishes clear policies and protection and fair treatment of company's stakeholders programs to provide a mechanism on the fair treatment and protection of stakeholders. Recommendation 14.3 Provide the contact details (i.e., 1. Board adopts a transparent framework name of contact person, dedicated phone number or e-mail address, and process that allow stakeholders to etc.) which stakeholders can use to communicate with the company and to voice their concerns and/or obtain redress for the violation of their complaints for possible violation of rights. their rights. Provide information on whistleblowing policy, practices and procedures for stakeholders SEC Form � I-ACGR * Updated 21Dec2017

Supplement to Recommendation 14.3 Provide information on the 1. Company establishes an alternative alternative dispute resolution system established by the company. dispute resolution system so that conflicts and differences with key stakeholders is Disclose any requests for exemption settled in a fair and expeditious manner. by the company and the reason for the request. Additional Recommendations to Principle 14 1. Company does not seek any exemption Provide specific instances, if any. from the application of a law, rule or Identify policies, programs and regulation especially when it refers to a practices that address customers' corporate governance issue. If an welfare or provide link/reference to a exemption was sought, the company document containing the same. discloses the reason for such action, as Identify policies, programs and well as presents the specific steps being practices that address taken to finally comply with the applicable supplier/contractor selection law, rule or regulation. procedures or provide link/reference to a document containing the same. 2. Company respects intellectual property rights. Optional: Principle 14 1. Company discloses its policies and practices that address customers' welfare 2. Company discloses its policies and practices that address supplier/contractor selection procedures SEC Form � I-ACGR * Updated 21Dec2017

Principle 15: A mechanism for employee participation should be developed to create a symbiotic environment, realize the company's goals and participate in its corporate governance processes. Recommendation 15.1 1. Board establishes policies, programs and Provide information on or procedures that encourage employees to link/reference to company policies, actively participate in the realization of the programs and procedures that company's goals and in its governance. encourage employee participation. Supplement to Recommendation 15.1 Disclose if company has in place a 1. Company has a reward/compensation merit-based performance incentive mechanism such as an employee policy that accounts for the performance stock option plan (ESOP) or any such of the company beyond short-term scheme that awards and incentivizes financial measures. employees, at the same time aligns their interests with those of the shareholders. 2. Company has policies and practices on Disclose and provide information on health, safety and welfare of its policies and practices on health, employees. safety and welfare of employees. Include statistics and data, if any. 3. Company has policies and practices on Disclose and provide information on training and development of its policies and practices on training employees. and development of employees. Include information on any training Recommendation 15.2 conducted or attended. 1. Board sets the tone and makes a stand Identify or provide link/reference to against corrupt practices by adopting an the company's policies, programs anti-corruption policy and program in its and practices on anti-corruption Code of Conduct. SEC Form � I-ACGR * Updated 21Dec2017

2. Board disseminates the policy and Identify how the board disseminated program to employees across the the policy and program to organization through trainings to embed employees across the organization them in the company's culture. Identify or provide link/reference to Supplement to Recommendation 15.2 the company policy and procedures 1. Company has clear and stringent policies on penalizing employees involved in corrupt practices. and procedures on curbing and penalizing employee involvement in offering, paying Include any finding of violations of and receiving bribes. the company policy. Recommendation 15.3 Disclose or provide link/reference to 1. Board establishes a suitable framework for the company whistle-blowing policy and procedure for employees. whistleblowing that allows employees to freely communicate their concerns about Indicate if the framework includes illegal or unethical practices, without fear procedures to protect the of retaliation employees from retaliation. 2. Board establishes a suitable framework for Provide contact details to report any whistleblowing that allows employees to illegal or unethical behavior. have direct access to an independent member of the Board or a unit created to Provide information on how the handle whistleblowing concerns. board supervised and ensured enforcement of the whistleblowing 3. Board supervises and ensures the framework, including any incident of enforcement of the whistleblowing whistleblowing. framework. SEC Form � I-ACGR * Updated 21Dec2017

Principle 16: The company should be socially responsible in all its dealings with the communities where it operates. It should ensure that its interactions serve its environment and stakeholders in a positive and progressive manner that is fully supportive of its comprehensive and balanced development. Recommendation 16.1 1. Company recognizes and places Provide information or reference to a importance on the interdependence document containing information on between business and society, and the company's community promotes a mutually beneficial involvement and environment- relationship that allows the company to related programs. grow its business, while contributing to the advancement of the society where it operates. Optional: Principle 16 Identify or provide link/reference to 1. Company ensures that its value chain is policies, programs and practices to ensure that its value chain is environmentally friendly or is consistent environmentally friendly or is with promoting sustainable development consistent with promoting sustainable development. 2. Company exerts effort to interact positively Identify or provide link/reference to with the communities in which it operates policies, programs and practices to interact positively with the communities in which it operates. SEC Form � I-ACGR * Updated 21Dec2017