Business Ethics And Compliance

San Miguel Corporation stands firm in its commitment to the highest standards of integrity, fairness, and honesty in all of its business affairs. Upholding these principles is not just a matter of good practice, but a fundamental pillar of the Company’s success. We believe that to build a truly sustainable enterprise, a culture of good governance must permeate throughout all levels of the organization. Thus, we have implemented policies and programs that promote ethical business practices. At the heart of our efforts is our Manual on Corporate Governance, which serves as a comprehensive guide to implementing and institutionalizing the principles of good governance throughout the entire San Miguel Group.

Pursuant to this, we also established a Corporate Governance Committee, which is responsible for overseeing the implementation of our corporate governance framework, ensuring that the policies and procedures remain relevant, and periodically evaluating the performance of the Board and executive management.

Our dedication to good governance is further evidenced by the requirement that the Board of Directors and key officers attend continuing training on corporate governance, including courses on developments in business and regulatory environments and emerging risks relevant to the Company. First-time Directors receive orientation on their duties and responsibilities, covering SEC-mandated topics on corporate governance, and an introduction to the Company’s business, Articles of Incorporation, and Code of Business Conduct and Ethics.

Our Code of Ethics and Conduct reflects our unwavering commitment to ethical business practices, fair dealings, respect for trade secrets and confidential information, and the responsible use of Company funds and assets. Our Compliance Officer ensures that the Code of Ethics is properly disseminated to all directors, senior management, and employees. Furthermore, all employees are provided with a copy of the SMC Employee Handbook and are required to acknowledge receipt of the same. By acknowledging, employees state that they understood its contents and commit themselves to comply with the items contained therein, including SMC’s core purpose and values and the policies governing the Company’s activities.

We also have policies in place to promote proper business conduct. Our Whistle-blowing Policy encourages our employees, suppliers, and other stakeholders to report any suspected wrongdoing within the organization. This policy protects informing employees and others from retribution or retaliation by ensuring confidentiality. All bona fide cases are investigated, and if necessary, audited. Critical concerns are communicated through the proper channels, and if they are related to anticorruption, then they are referred to the Audit Committee of the Board.

Under our No Gifts Policy, we ask our employees not to accept personal favors or gifts from individuals or entities doing business with the Group, including in matters of hiring and awarding of contracts. Transactions with the government and regulators are done with the highest level of transparency to foster trust with our stakeholders.

We have a Conflict of Interest Policy that requires all directors, officers, and employees to disclose any potential conflicts of interest. The expectation is that employees’ actions are made in the best interest of the Group.

Under our No Gifts Policy, we ask our employees not to accept personal favors or gifts from individuals or entities doing business with the Group, including in matters of hiring and awarding of contracts. Transactions with the government and regulators are done with the highest level of transparency to foster trust with our stakeholders.

Furthermore, we prioritize the protection of sensitive information through our Information Security Management System. By carefully classifying and managing information, we are able to protect data against theft, cyberattacks, and other forms of malicious activity. At the same time, we recognize the importance of transparency and collaboration with our stakeholders, and we classify information as public to ensure that the right people have access to the right information.

At San Miguel, our dedication to good corporate governance is not just a matter of good practice — it is a fundamental pillar of our success. Our efforts to promote responsible and ethical business conduct, through our policies and training programs, serve as a testament to our commitment to excellence in all aspects of our business operations.

In 2022, there were zero reported incidents of corruption in the Group. Moreover, there were no legal actions regarding anti-competitive behavior and violations of antitrust and monopoly legislation that were pending or completed during the period.

Our Manual on Corporate Governance, Code of Ethics and Conduct, and other policies are found on SMC’s company website at https:// www. sanmiguel.com.ph/page/company-policy.