JG Summit Holdings, Inc.

Overview

Governance Statement Company Strategy and Objective Articles of Incorporation and By-laws

Board and Board Committees

Board Profile Board Structure Board Meetings Board Committees Board Development

Shareholders

Ownership Structure Rights and Equitable Treatment of Shareholders Annual Stockholders' Meeting Enterprise Risk Management Internal Controls

Stakeholders

Employees, Customers, Suppliers and Creditors Medium of Communication

CG Manual and Policies

Revised Corporate Governance Manual Code of Business Conduct and Ethics Anti-Bribery and Anti-Corruption Policy Board Diversity Policy Board Nomination and Election Policy Conflict of Interest Policy Corporate Disclosure Policy Dividend Policy Health, Safety and Welfare Policy Insider Trading Policy Protection of Creditors’ Rights Policy Succession Planning and Remuneration Policy Supplier Accreditation Policy Whistleblowing Policy

Compliance Reports

Annual and Sustainability Report Integrated Annual Corporate Governance Report (I-ACGR) Compliance Manual

Code of Business Conduct and Ethics

The fundamental principle of the Code is the expectation that all our directors, officers and employees are required to conduct their dealings in the interest of JG Summit and the conglomerate and in accordance with the highest legal and ethical standards. Thus, everyone must observe the company’s core values, acceptable norms, and the policies indicated in the Code in all of our business activities and future endeavors.

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1. Conflicts of Interest

We must ensure that our business decisions always reflect our independent judgment and discretion, and are based on the best interest of JG Summit. We must avoid situations where our personal interest conflicts with the interests of JG Summit. Our employees that recommend, endorse, or approve the procurement/sale of goods and services should make a conscious effort to avoid any conflict of interest situation in transactions that they are involved in.

2. Gifts

We shall not directly or indirectly seek nor accept, offer or give any gift from or to any third party intended to influence judgment or create a sense of obligation or as a condition or result of doing business with JG Summit. We may give or accept advertising novelties or gifts only during the Christmas Season. There are no restrictions in the value of the gifts that an employee may receive and accept. However, we must always evaluate if acceptance of an offered gift constitutes a potential conflict of interest. Accepted gifts, with an estimated value of over Php 2,000 must be reported or disclosed by the employee to the concerned BU GM, or Corporate Center Head and Integrity and Ethics Council

3. Solicitations for Company Sponsored Employee-Related Activities and Events

The company may seek or solicit gifts and sponsorships from third parties for company sponsored employee-related events or activities that are explicitly approved by the concerned Group BU GM, BU GM or Corporate Center Head and can only be done once per calendar year and must be coursed through and accounted for by BU Human Resources.

4. Business Meals

With management approval, our company permits normal business meals within the bounds of good taste that have a valid business purpose, the reciprocal customary courtesies between employees of JG Summit and their business associates, and similar customary and reasonable expenditures to promote general business goodwill. Our participation in these events should not be excessive in scale, expense or frequency, not prohibited by law or known client or company business practice.

5. Bribes

We must never directly nor indirectly solicit, accept or offer bribes. If any person offers a bribe in any form, we must report it immediately to our supervisor, department head, or a representative of Human Resources.

6. Personal Use of Suppliers, Contractors, and Professional Service Providers

We must be careful when personally using the services or purchasing the goods of a person or entity that does or seeks to do business with us. To avoid conflict of interest, fair value must be paid for those services or goods. Fair value refers to the price that would generally be charged to the public for those goods or services.

7. Financial Interest in Third Parties

We must not have a substantial (at least 10%) financial interest in entities with which we or employees under our supervision do business with on behalf of JG Summit. Participation in a mutual fund or similar investment vehicle that holds stock or securities in these entities is permissible since we would not be exercising investment discretion.

8. Loans

We must not accept a loan from any person or entity doing business with or seeking to do business with JG Summit; unless the loan is from an established financial institution in accordance with its normal lending practices and at interest rates that are generally available to and known by the public.

9. Outside Business Activities

If an employee practices or plans to practice his profession become associated with any outside business or if the employee is currently associated with any outside business, these must be disclosed.

10. Competition with the Company

A substantial financial interest in any person or organization that competes with JG Summit must be disclosed.

11. Confidential Information

The Corporate Planning Head or Corporate Communications Head will respond to all requests for information about JG Summit, whether from organizations, individuals, or the media. For listed companies and their subsidiaries, disclosure to the public or to the media can only be done after disclosure to the SEC and PSE by the listed company’s authorized officers.

12. Preservation and Protection of JG Summit’s Resources

If we are custodians of assets or funds, we must safeguard these assets with honesty and integrity. We must always ensure that these assets are efficiently, effectively, and responsibly utilized.