Insider Trading

Prohibition against Insider Trading

All covered Persons are prohibited from buying, selling, trading or otherwise dealing in the Securities while in possession of material non-public information. All Covered Persons are likewise prohibited from passing such material non-public information to any person who might use such information to deal in the Securities.

A Covered Person should exercise prudence in evaluating whether the non-public information he possesses is material or not. Any doubt should be resolved in favor of treating such non-public information as material.

Details on recent transactions and latest shareholdings of directors and officers of the Company are found in the Statements on Beneficial Ownerships and Public Ownership Reports. These are available on our Investors page under Disclosure and Filings

Trading Blackout Periods

1) Any Covered Person who possesses material non-public information is prohibited to buy, sell, trade or deal in the Securities from the time he acquired such material non-public information and until two [2] trading days after such material information has been made public.

2) Directors, officers, consultants and members of senior management of the Issuer companies are prohibited to buy, sell, trade or deal in the Securities during the following periods:

a. For quarterly and annual financial reports and other structured reports - Ten (10) trading days before and two (2J trading days after public disclosure of quarterly and annual financial reports and other structured reports. 
b. For unstructured reports - Three (3J trading days before and two (2) trading days after public disclosure of material information other than Item (a) above.

Reportorial Requirements of Directors and Officers of the Issuer Companies

Directors and officers of the Issuer Companies are required under the Securities Regulation Code and 
the regulations of the Securities and Exchange commission (SEC) and the Philippine Stock Exchange (PSE) to report their beneficial ownership of the Securities as well as any change in such beneficial ownership.

To ensure that such reportorial requirements are timely complied with, the concerned director or officer must inform the Compliance Officer of his beneficial ownership in the Securities not later than one [1) day after their election or appointment. Thereafter, he must inform the Compliance Officer of any change in his beneficial ownership of the securities not later than one (1] day after the acquisition or disposal of the Securities.

For purposes of the reportorial requirements of the SEC and the PSE, beneficial ownershiD of the director or officer shall include not only the Securities which he directly owns but also the Securities which are:

a.) held by members of his immediate family sharing the same household; 
b.) held by a partnership in which he is a general partner;
c.) held by a corporation of which he is the controlling shareholder; and 
d.) subject to any contract, arrangement or understanding which gives him voting power or investment power with respect to such securities.