Insider Trading Policy

Century Properties Group, Inc. prohibits insider trading. The Company strictly enforces and monitors compliance with its policy on insider trading, which covers securities transactions by its officers, directors, employees, and subsidiaries.

If an officer, director or any employee of the Company has material, nonpublic information relating to the Company, it is the Company’s policy that neither that person nor any related person, may buy or sell securities of the Company or engage in any other action to take advantage of, or pass on to others, that information.

To avoid even the appearance of impropriety, additional restrictions on trading Company securities apply to directors and members of executive management.

The Company has adopted this policy to avoid damage to its reputation for integrity and ethical conduct. We all strive to establish a reputation for observing the highest standards of conduct, even the appearance of improper conduct must be avoided.

Changes in personal shareholdings of the Company’s officers, directors, and employees resulting from open market transactions are reported to the Securities and Exchange Commission, the Philippine Stock Exchange, and Philippine Dealing & Exchange Corp. within prescribed deadlines.