Ethical dilemma is a situation a person faces in which a decision must be made about the

appropriate behavior. A simple example of an ethical dilemma is finding a diamond ring, which
necessitates deciding whether to attempt to find the owner or to keep it
RESOLVING ETHICAL DILEMMAS
In recent years, formal frameworks have been developed to help people resolve ethical
dilemmas. The purpose of such a framework is in identifying the ethical issues and deciding on
an appropriate course of action using the person's own values. The six-step approach that follows
is intended to be a relatively simple approach to resolving ethical dilemmas:
1. Obtain the relevant facts.
2. Identify,' the ethical issues from the facts.
3. Determine who is affected by the outcome of the dilemma and how each person or group
is affected.
4. Identify the alternatives available to the person who must resolve the dilemma.
5. Identify the likely consequences of each alternative.
6. Decide the appropriate action

Corruption is the abuse of private and public office for personal gain. It includes acts of bribery,
embezzlement, nepotism, kickbacks and state capture. This is often associated with and
reinforced by other illegal practices such as bid rigging, fraud, or money laundering, extortion.

- Simply defined, corruption is receiving, asking for or giving any gratification to induce a
person to do a favor for private gain. This act covers not only public corruption involving
misuse of public power by elected politician or appointed civil servant but also private
corruption between individuals and businesses.

A broader definition of corruption follows:

"Corruption is the misuse of entrusted power (by heritage, education, marriage, election,
appointment) for private gain. It covers not only the politician and the public servant but also the
CEO, CFO and but other employees of a company." It involves wrong doing on the part of an
authority or powerful party through means that are illegitimate, immoral or incompatible with
ethical standards.
- Corruption often results from patronage and is associated with bribery.
A much more difficult, scientific definition for the concept 'corruption' was developed by
Professor (emeritus) Dr. Petrus Van Duyne:
- is an improbity or decay in the process in which a decision-maker consents to deviate or
demands deviation from the criterion which should rule his or her decision-making, in
exchange for a reward or for the promise or expectation of a reward, while these motives
influencing his or her decision-making cannot be part of the justification of the decision."

In general, corruption is a form of dishonesty or criminal activity undertaken by a person an

organization entrusted with a position of authority, often to acquire illicit benefit.

Corruption may take place in any of the following forms/ways:

 A company paying a bribe to win the public contract to build the local highway, despite
proposing a sub-standard offer.
 A politician redirecting investments to his hometown rather than to the region most in
need.
 Public official embezzling funds for school renovation to build his private villa.
 A private company manager recruiting an ill-suited friend for a high level position.
 Or, local officials demanding bribes from ordinary citizens to get access to a new water
pipe. A salesman bribing the purchasing manager of a company to give preference to his
products.
At the end of the day, those hurt most by corruption are the world's weakest and most vulnerable.

AND HOW DOES A PERSON BECOME CORRUPT

Corruptions spread when there are opportunities, when risk is minimal in comparison to benefits
obtained or when one is confronted with issues like
 Career advancement
 Earning of more income
 Financial problems caused by illness, loss of property, etc.
Those engaged in corruption learn how to be dishonest. The next corrupt actions become easier
to do unless one is firmly rooted on solid principles and has been nurtured in an upright manner.
ILL EFFECTS OF CORRUPTION
Economically,
- Corruptions add up to 10% of the total costs of doing business in any part of the world
and up to 25% of the cost of procurement programs in developing countries.
- Corruption leads to waste or the inefficient use of public resources.
In the Philippines, figures from 1960 to 2016 indicate that an average of P550 billion is last
yearly to crime, corruption and tax evasion. This amount could clearly have been used more
efficiently and effectively poverty alleviation or education instead
 Corruption corrodes public trust, undermines the rule of law, and ultimately delegitimizes
the state.
 Africa's 700 million people under 30 are seeking opportunities with dignity and if
mismatch between aspirations and fulfilment continues, this could lead to apathy,
discontent and turn them to radical extremists and join terrorist groups.

Other significant and serious repercussions of corruption are:

1. If allowed to take root in society, it can lead to a breakdown in social order and lives are
affected when ordinary people are prevented from receiving all the essential service that
they are entitled to Corruption may have drastic impacts like most of the public funds are
used on the leisure and lifestyle of influential people instead of allotting them on
hospitals, schools and other basic needs of general public.
2. It creates unfair competition and increases the cost of doing business. Every form of
corruption is bad for economic growth and could result to tarnished reputation of an
entire country. Corruption causes businesses to flee from the country because
businessmen find it a constant threat for their progress.
3. Corruption is cancer that spreads rapidly all over the body. Corruption in Australia,
Canada and few European countries has dropped extensively due to adoption of concrete
measures. Nevertheless, corruption in developing and underdeveloped countries
(especially Afghanistan and Somalia) is still a critical problem. D

There is a growing worldwide concern over corruption at the present time. A consensus has now
been reached that corruption is universal. It exists in all countries, both developed and
developing, in the public and private sectors as well as is non-profit and charitable organizations.
Allegations and charge of corruption now play a more central role in politics that at any other
time. Governments have failed careers of world-renowned public figures ruined and reputation
of well-respected organizations and business firms badly tarnished on account of it.
Major corruption arises whenever major events involving large sums of money, multiple parties
or huge quantities of products are at stake. Corruption also flourishes in situation involving high
technology (e.g. purchase of a technologically far-advanced aircraft) or in situations that are
chaotic and a number of actions is very large such as natural disasters, civil war and betting in.
international sports tournaments. Major corruption thrives on a broad base of small corruption
payments or bribes. In the end, all corruption costs are absorbed by the consumers and the
taxpayers.

PS. PRINT 149-152

THE PHILIPPINES CORRUPTION REPORT⭑
The Former Secretary of Finance reported in 2016 that the Philippines loses P200 billion from
smuggling and P400 billion from tax evasion perpetuated through collusion with some
personalities in the government agencies. P2.6 trillion is lost annually in corruption globally.

Judicial System
Corruption risks are high in the judicial system. Bribes and irregular payments in return
for favorable judicial decisions are common. The judiciary is formally independent, but the rich
and powerful have frequently influenced proceedings in civil and criminal cases. Procedural
fairness and transparency are severely undermined by nepotism, favoritisni, and impunity.
Companies do not have sufficient faith in the independence of the judiciary and they rate the
efficiency of the legal framework in settling disputes and challenging regulations as poor.
Investment disputes can take several years to resolve due to a lack of resources, understaffing,
and corruption in the court system. Low salaries for judicial officials are said to perpetuate the
problem of bribery.

The judiciary is underfunded by the state and often depends on local sponsors for resources and
salaries, resulting in non-transparent and biased court decisions. Foreign investors have noted
that the inefficiency and uncertainty in the judicial system are disincentives for investment,
investors regularly decline to file disputes due to the perception of corruption among personnel
and the complex and slow litigation processes. Enforcing a contract takes much longer than the
regional average, but the costs involved are significantly lower.

In one recent case, a businessman filed an administrative complaint in the country's Supreme
Court against Makati City judge for allegedly asking for a PHP 15 million bribe in exchange for
a favorable ruling in an insurance claim. At the time of review, no further updates on the case
were available.

Police
There is a high-risk of corruption when dealing with the police. The national police force
is widely regarded as one of the most corrupt institutions in the country. Reports of the police
and military engaging in corruption, extortion, and being involved in local rackets are
widespread. Companies report that they cannot rely on the police services. More than half of
firms pay for private security. Businesses rate the National Police's commitment to fighting
corruption as 'poor'. President Duterte has accused several police generals of being involved in
the trafficking of illegal drugs.
 In one corruption case, Police Commissioner Mr. Sombero, is under investigation for
allegedly facilitating a PHP 50 million bribe from gambling tycoon Jack Lam, who tried to bribe
immigration authorities in order to release approximately 1,300 Chinese nationals who were
working in his resorts illegally.

Public Services
Companies contend with a high corruption risk when dealing with the public services.
Approximately half of business executives reported being asked for a bribe by someone in the
government in 2017. Nearly three out of five business reported expecting to give gifts in order to
get things done', but only one in ten reported expecting to give gifts to get an operating license.

Irregular payments and bribes in the public services sector sometimes occur. Philippine
officials involved in processing documents related to civil and property registration and building
permits are more likely to solicit bribes compared to officials dealing with other types of
services. Inefficient government bureaucracy is ranked as the most problematic factor for doing
business in the Philippines. Civil servants often do not have the resources or abilities to fulfill
their tasks free from corruption and red tape. Furthermore, civil servants are generally not
recruited in a competitive manner, appointments are based on a practice of patronage.

The total number of procedures required to set-up operations, including registering the
company with local government and getting a construction permit, are significantly higher than
regional averages. Getting electricity takes significantly less time than elsewhere in the region.

Land Administration
Corruption risks in the land administration are high. Two out of five companies report
expecting to give gifts when obtaining a construction permit. Property rights are formally
recognized and protected in the Philippines, but in practice. the law is not always upheld.
Businesses have insufficient confidence in the protection of property rights.
Corruption and arbitrariness in the application of the law are common. Multiple agencies
are responsible for land administration, which has led to overlapping procedures for land
valuation and title registration: this has made the process costly.
The court system is slow to resolve land disputes. Land records are not properly managed
due to a lack of trained personnel and funds. Foreigners are not allowed to directly own land, but
they may lease land for up to 50 years with a possible one-time extension of 25 years.
 Expropriation is possible under Philippine law; the law calls for fair market value
compensation, but coming to a mutually acceptable price can be a lengthy process in the court
system. Registering property takes nine procedures in the Philippines, which is double the
regional average. However, the total time required is less than half of the regional average.

Tax Administration
There is a high risk of corruption when dealing with the tax administration. Around one
in seven companies indicate they expect to give gifts in meetings with tax officials. Tax
regulations are among the most problematic factors for conducting business in the Philippines.
Companies indicate that they perceive that only a fifth of businesses in their line of business pay
their taxes honestly. Officials at the Bureau of Internal Revenue (BIR) are believed to be prone
to corruption and known for embezzlement and extortion. A typical example of this can be found
in a recent case in the city of Bacolod; an officer with the BIR was caught extorting PHP
125,000 from a local company. Businesses rate the BIR's commitment to fighting corruption as
poor. On a more positive note, there are signs that the BIR is pursuing more cases of tax evasion.
Companies make twenty-eight tax payments a year, which is higher than the regional
average.

Customs Administration
There is a high risk of encountering corruption when dealing with the customs
administration. Companies indicate that irregular bribes and payments in import and export
procedures are very common.
About a quarter of companies indicate they expect to give gifts when obtaining an import
license. A business survey indicates that the Bureau of Customs (BOC) was the only agency
receiving a rating of 'very bad' when it came to its commitment to fighting corruption.
Companies cite burdensome import procedures and corruption at the border as being among the
most problematic factors for importing. The efficiency and time predictability of procedures are
rated as poor. Border compliance costs in the Philippines are significantly higher than the
regional average, whereas the time required is in line with the regional average.
The Bureau of Customs (BOC) has indicated that smuggling of goods, among which
cigarettes, vehicles, and oil, into the Philippines has led to the evasion of taxes worth at least
USD 1 billion yearly. Consistent fud in the form of under- invoicing when importing and
exporting costs the state USD billions in revenues each year. In 2016, the BOC alleged one of its
employees accepted as much as USD 4 million in bribes monthly.
Public Procurement
There is a very high risk of corruption in the public procurement sector, which is subject
to rampant corruption, irregularities, and inconsistent implementation of legislation. Likewise,
more than a fifth of businesses report they expect to give gifts in order to win a government
contract. Two in five companies indicate that most companies in their sector give bribes in order
to win contracts. Diversion of public funds, as well as favoritism in the decisions of public
officials, is very common. The public sector is obliged to procure goods and services from
companies with at least 60% Philippine ownership. Local-level public procurement lacks
transparency, fostering a culture of corruption through the misuse of the pork barrel system;
which are funds for discretionary use by representatives for projects in their respective districts.
Philippine law allocates responsibility for monitoring, investigating and sanctioning irregularities
in public procurement to a number of different state institutions, leaving potential misconduct,
inefficiency and impunity unchecked.

Natural Resources
Companies operating in the natural resources sector face a high risk of corruption. The
Philippines has shown marked improvements in its natural resource governance in the past few
years, the country has a good enabling environment and its regulatory quality and control of
corruption are judged as adequate. However, poor value realization and revenue management
have caused the country's overall resource governance to be judged as "weak. The Philippines
has been working to achieve compliance with the Extractive Industries Transparency Initiative
(EITI) since joining in 2013. Some mining contracts are publicly disclosed via the EITI portal.
While transparency in the sector has improved, poor regulation and overlapping policy
responsibilities between local and central governments have meant that small-scale mining is still
a contentious issue.
Government corruption has allowed mining companies to evade government regulations,
which has resulted in large-scale deforestation, flattened mountaintops and water pollution. The
government responded by cracking down on illegal mining operations; and as of 2017 Secretary
of the Environment Gina Lopez shut down 28 of the country's 41 mining companies for polluting
the environment. However, Lopez was removed from her job by Congress in May 2017 after
mounting complaints from the pro-mining lobby.

PREVENTION OF CORRUPTION
Corruption in Singapore is under control. However, a clean system is not a natural state of
affairs. Corruption comes from weakness of human nature greed, temptation, the desire to amass
wealth or to obtain business through unfair means. Even with harsh penalties, corruption cannot
be eradicated completely.
Below are some measures businesses and organizations can adopt to help prevent
corruption in the work-place.
a) Clear Business Processes- Having defined workflows, clear directives on financial
approving authorities, and standard procurement instructions can help flag irregularities
in a business or organization. These processes should be reviewed on regular basis to
ensure they are updated to the shifting business environment. Diligent record-keeping and
regular audits are also good practices to deter corrupt activities.
b) Policy on Gifts and Entertainment- Gifts and entertainment are often offered in the
legitimate course of business to promote good relations. However, if it is too frequent or
lavish, or done with the deliberate intention to gain an unfair business advantage, such
gifts and entertainment can be tantamount to corruption, regardless of whether the
recipient is able to fulfill the request of the giver. The risk of corruption can be reduced
by setting a policy on when gifts and entertainment may be given and accepted and what
records need to be kept. Your business partners should be aware of your organization's
gift and entertainment policy too.
c) Declaration of Conflict of Interest- Conflict of interest occur when a personal interest
or relationships is placed before the business interest, and can lead to corrupt activities
such as giving or accepting bribes. In order to safeguard the business interest, a
declaration system that is applicable to all levels of employees may be instituted. The
company may provide a declaration form for conflict of interest for employees, and then
use the information to take the most appropriate course of action. This could include
excluding the employee from engaging in the work or transferring the employee to
another department or post.
d) Convenient Corruption Reporting System- The corruption reporting system is a key
function to control corruption and bribery risks, and can comprise a whistle-blowing
policy or feedback channel where staff can conveniently raise concerns and feel protected
from being identified or retaliated against. One way to do this would be by allowing
reports to be filed anonymously through a publicized email address or phone number.

EFFORTS TO CURB CORRUPTION THROUGH LEGISLATION

- The Anti-Graft and Corrupt Practices Act criminalizes active and passive bribery,
embezzlement, extortion, abuse of office and conflict of interest in the public sector.

- Bribery of public officials and trading in influence are also criminalized in the Anti-Red
Taps Act. The Act forbids office-holders from accepting any gifts or material benefits in
exchange for any government permit or license.
 - Under the Revised Penal Code, gifts are classified as indirect bribery. An exception is
made for gifts of insignificant value given as a token of friendship in line with local
customs. Facilitation payments are not addressed in the law. Private sector bribery is not
criminalized. Under the Code, public officials are required to regularly file a statement of
their assets and liabilities. In case of any discrepancy between the official's asset
declaration and the amount of property or financial assets actually possessed, the official
is subject to immediate dismissal. Punishments for corrupt acts include imprisonment of
up to ten years, a fine, removal from office, and/or confiscation of property.

- The Anti-Money Laundering Act criminalizes money laundering and organized crime.

- The Act Establishing Code of Conduct and Ethical Standards for Public Officials
and Employees formulates standards for the personal integrity and accountability of civil
servants.

- The Government Procurement Reform Act requires competitive and transparent

bidding. Philippine legislation does not contain any provisions on protecting
whistleblowers who report on corruption.

- The Philippines has ratified the United Nations Convention against Corruption.
Companies should note that the legal anti-corruption framework in the Philippines is
complicated and poorly enforced; there is a lack of cooperation between law enforcement
agencies, and officials are rarely prosecuted and convicted for corruption crimes.

VIGILANCE OF CIVIL SOCIETY

Philippine civil society is active and is represented by a wide variety of different
organizations. Public participation is high and civil society organizations (CSOs) enjoy a high
level of social capital. CSOs are normally not included in formal decision-making, but they play
a large role in initiating legislation and steering debate in Congress. There are a multitude of
watchdog organizations monitoring implementation of policy.
The Constitution guarantees freedoms of speech and of expression, but in practice these
freedoms are not consistently upheld. The media environment is largely privately owned and
diverse, and the state generally exercises very little censorship. The views represented in the
mainstream media are heavily influenced by the oligarchical owners of many of the outlets.
The Philippines is the second most dangerous country in the world for journalists to operate
in, as measured by the number of journalist deaths. The state is not directly responsible for the
violence, which can mostly be blamed on local strongmen and criminals and the weakness of the
authorities.
 The existence of libel and defamation laws remains a problem and are frequently used by
officials and powerful individuals to try to silence journalist. The media does frequently report
on high-level corruption cases. Independent observers report that bribes and other incentives are
often used by high-level officials to motivate journalists to create one-sided reports for the
official's benefit. Internet access is widely available, but there are concerns about the government
trying to install some degree of censorship. The Philippine press is classified as 'partly free.

Improvement of business ethics is a common concern of everybody. It is imperative that all

parties involved manufacturers, sellers, consumers, government and relevant organizations must
participate in improving business ethics. Unless there is a concerted effort on the part of
everybody, we cannot effectively remind businessmen and professional of their ethical
responsibility to each other, to their customers and clients.
Unethical practices are ever present. Even people who have not yet been victims of these
practices are vaguely aware that they exist and agree that something must be done to rid the
world of them. Accordingly, various approaches to improving business ethics have been brought
forward not only in the Philippines but also in other countries.

THE INTEGRITY INITIATIVE CAMPAIGN

In 2010, a private sector-led campaign aiming to strengthen ethical standards in business,
the Integrity Initiative was organized after the Philippines received a grant from Siemens. The
Makati Business Club (MBC) and the European Chamber of Commerce of the Philippines
(ECCP) serve as the Integrity Initiative Secretariat
The Integrity Initiative is a multisectoral campaign that seeks to institutionalize integrity
standards among various sectors of society business, government, judiciary, academe, youth,
civil society, church and media. Led by the private sector, the initiative aims to help in
diminishing, if not fully eradicating, the vicious cycle of corruption in the Philippines, which has
not only exacerbated poverty but also obstructed the development of a competitive business
environment that operates on a level playing field.
Ultimately, the Integrity Initiative hopes to build trust in government, a more equitable
society and fair market conditions. This will result in improved competitiveness and increased
business confidence, which will evident with the increase in domestic and foreign investments,
and more employment generated for Filipinos. Subsequently, with more Filipinos employed in a
vibrant and dynamic Philippine economy, the alleviation of poverty should become inevitability.
Through the initiative, the Philippines will become a benchmark in the transformation process of
any country regarded as highly corrupt to one that fosters an ethical and progressive business
environment.
 To achieve this goal, consultations, roundtable discussions and public forums involving
business leader compliance officers, corporate governance experts, academics and practitioners
from small and medium enterprises to Fortune 500 companies. "An Integrity Compliance
Handbook" containing the key documents and toolkits in Integrity Initiative was published for
the use of organizations to promote ethical business practices.

Since 2010, MBC and ECCP have been joined by various organizations and industry
associations in taking an active role in promoting honesty and transparency in Philippine
business. As of 2018, a number of the organizations and industry associations have been taking
active participation in this movement. With the active participation of these organizations, is
hoped that the problem of massive graft and corruption in the Philippines will be minimized if
not totally eliminated.
Appendix G shows a partial list of organizations who are actively participating in the
"Integrity Initiative" Campaign against Corruption.

Corporate Values
The increasing scrutiny by regulators, lobbyists, non-government organizations,
consumer groups and the media have the potential to affect a business firm market perception
and hence value. It is therefore important that the organization's values, and its code of conduct,
address the legal and other obligations owed to important stakeholders, including, for example,
trade practices laws, privacy laws, employment laws, occupational health and safety, equal
opportunity in the workplace, superannuation and environmental regulations.
Managing, protecting and enhancing reputation has become one of the greatest challenges
facing today's board. The reputation of a business is a critical factor in the determination of its
value. The values and ethics of the organization need to be explicitly managed.

Need for a Code of Conduct

A code of conduct is a formal expression of the organization's values and ethics. A code of
conduct should:
 guide directors and senior executives, as a minimum, as to the practices necessary to
maintain confidence in the organization's integrity. Other members of staff should also
 have a code of conduct relevant to them which may be the same as that for directors and
senior executives or may be a complementary version;

 promote responsibility and accountability of individuals for reporting and investigating

reports of unethical practices; and ensure compliance with legal and other obligations to
legitimate stakeholders.

An organization's code of conduct recognizes the important role that business ethics play in the
success of today's business, encouraging the board to actively develop an organizational culture
that is established on transparency, accountability and integrity.

One of the most significant accomplishments of the Integrity Initiative is the preparation of
the "Unified Code of Conduct for Business". The Code's purpose is two-fold.
First, it harmonizes existing ethical standards among business operating in the
Philippines. It ensures that different market players adhere to the same rules of the game in order
to create fair market conditions and promote transparency in doing business.

Second, the Code formally communicates the signatories' commitment to upholding high
standards of ethics in all business transactions. It articulates the belief that securing profit at the
expense of integrity is an unacceptable and way of conducting business and that measures have
been taken to enforce and cultivate integrity habits within the signatories' respective
organizations.

THE UNIFIED CODE OF CONDUCT FOR BUSINESS (Integrity Initiative)

Top Management
 Our top management leads by example by consistently demonstrating the value of
conducting business with integrity.
 Our officers strongly communicate our organization's position against bribery, corruption
and unethical business practices within the company and the broader public; comply with
all the requirements of government regulatory bodies; and prohibit cover-ups and
falsified reports that conceal improper transactions.
 Management strongly supports integrity practices and allocates sufficient resources for
their implementation.
Human Resources
 We strive to instill culture of integrity among our employees. The management maintains
open lines of communication with employees, particularly on matters relating to honesty,
transparency and integrity in business transactions.
 In the spirit of fairness and due process, all employees have the right to file and respond
to complaints against practices suspected to be illegal or unethical. We have appropriate
tools to confidentially receive, monitor, and act on internal and external complaints.
Employees filing complaints will be protected from all types of retaliation, while those
involved 'in unethical practices will be subject to commensurate disciplinary actions.
 We have instituted training programs on business ethics covering all levels of the
organization.

Sales and Marketing

 We clearly communicate rules and guidelines on giving gifts, entertainment, tokens of
hospitality, and contributions to/from public and private organizations and their
representatives.
 Employees and all third parties engaged by our company to act as our intermediaries,
agents or representatives are not permitted to offer, promise, or give, as well as demand
or accept concessions- directly or indirectly in order to obtain, retain, or secure any undue
advantage in the conduct of business.
 We abide by existing laws when transacting with government agencies (as stipulated
under RA 6713 Code of Conduct and Ethical Standards for Public Officials and
Employees and RA 3019 Corrupt Practices Act). Anti-Graft and

Finance and Accounting

 We require all our employees to ensure that all books and records they create or are
responsible for are complete and accurate.
 Our financial records conform to standard accounting principles, comply with Securities
and Exchange Commission requirements on disclosure and transparency, and abide by
anti-money laundering laws (RA 9160) and international conventions.
 We pay taxes in compliance with all laws.
Procurement
 A track record of integrity and compliance with existing laws is a prerequisite when we
vet third party consultants, suppliers, intermediaries, and agents. Our company has
transparent procurement procedures, provides equal opportunities for all suppliers, and
prohibits, collusion between and among our employees and suppliers.
 Recognizing that the Integrity Initiative is sustained through widely shared ethical
practices within the business community, we enter into integrity pacts with our suppliers
and ensure that they comply with the provisions of our pact.
 Contracting a third party to bribe or commit corrupt practices on behalf of the company is
strictly prohibited.

Logistics
 We comply with laws and regulations pertaining to supply chain management.
 We do not tolerate any breaches in existing laws in exchange for undue advantage and
unethical concessions or favors. We pay correct duties and taxes based on transparent
assessment of goods and services.
 Employees are not penalized for refusing to pay bribes or facilitation payments even if it
results in failure to meet deadlines or loss. of revenue.

Implementation and Monitoring

 We will continually to align our operations to the principles contained in this Code
periodically assess and monitor our compliance to it. We will continue to share best
practices with the business community to strengthen ethical business processes in the
Philippines.

PS. PRINT P.169- 175