Whistle-Blowing Policy

A. COVERAGE

All Employees of Century Properties Group, Inc.

B. STATEMENT OF PURPOSE

Century Properties Group, Inc. (CPGI) is committed to realizing and sustaining the highest standards of integrity, trustworthiness  and accountability in all aspects of its operations. CPGI employees are expected to exhibit and exercise prudence, honesty, and impartiality in the conduct of their job and engagement with their superiors, colleagues and customers.

The Whistle-blowing Policy intends to ensure that incongruous behaviors and conduct of employees, regardless of their rank, will not compromise the reputation and interest of the Company and its organization. The policy serves as a supplemental internal control mechanism of the Company to protect the its shareholders, investors, customers and workers.

C. STATEMENT OF POLICY

The policy is aimed to accord absolute confidentiality and protection of the legitimate whistle-blower, and procedures to adhere to ensure objectivity of any proceedings. This policy also serve to assure protection against any unfair removal from office and/or capricious disciplinary action, in cases where the information given yielded negative results due to lack of supporting evidence beyond the control of the whistle-blower.

D. GENERAL POLICIES AND PROCEDURES

  1. Issues and Matters that are Focus of this Policy
    1. Negligence, dereliction, impropriety, malpractice or deception relating to established control mechanism but not limited to accounting and finance.
    2. Direct violations of the Company Code of Conduct, and other implementing rules and regulations
    3. Defiance of legal or statutory requirements
    4. Damaging conduct or unethical behavior likely to prejudice the reputation of the Company
    5. Offenses or breach of civil and criminal law
    6. Jeopardizing the health and safety of the persons
    7. Analogous infractions or concealment of any of the above
  1. Confidentiality and Protection

 

The Company shall ensure full confidentiality of the whistle-blower and treating all sensitive disclosures, verified and for corroboration. If disclosures are deemed verified information, it is the responsibility of the Company to provide protection and reasonable treatment to the whistle-blower or information source. The protection guaranteed by this policy  assured the whistle-blower or information source against unwarranted disciplinary action or constructive dismissal. The Company assure, in cases where the information given yielded negative results due to lack of supporting evidence, the same protection shall be accorded to the whistle-blower against unfair removal from office and/or capricious disciplinary action.

The Company shall take necessary action against anybody who instigate or threatens an employee to stop or disavow any reports under this policy. The eering employee who instigates or threatens a co-employee or information source will be  subjected to disciplinary action.

 

  1. Implementing Guidelines

 

a.  An employee who has substantial information, evidence or legitimate issue may report directly with the officers of the Corporate Governance Committee thru the Office of the Human Resources and Administration. The Committee will verify the report and will decide on the prospect of the case. Based on its merit, the Committee may assign to a specific officer or create an independent investigating body to further review and resolve the case.

b. Reports and disclosure format shall be made in writing and signed by the source. The whistle-blower or information source identity must be made known to the Corporate Governance Committee only. Supporting documents are valued but not obligatory. However, at the minimum, relevant details of employee disclosures are necessary to ascertain the reliability of the report.

c. Reports and disclosure should be sent to any of the following channels:

  • VIA MAIL

Chairman of the Corporate Governance Committee

thru The Office of the Human Resources and Administration

Century Properties Group, Inc.

21F Pacific Star Building

Sen. Gil Puyat Ave. cor. Makati Ave.,

Makati City, Philippines

  • VIA EMAIL

cpgicorpgovernance@gmail.com

 

  • Marked the envelop or include in the email subject “Private and Confidential”.
  • Anonymous complaints will not be honored

 

d. Prior to any review and investigation, the designated officer of the Corporate Governance Committee shall acknowledge the receipt of the disclosure or report, and provide feedback on the prospect of the case.

e. The investigation procedure shall be carried out consistent with the established rules of proceedings articulated in the Company’s Code of Conduct & Discipline.

f. The investigation shall be in collaboration of the following:

  1. Good Governance Committee
  2. Corporate Human Resources
  3. Internal Audit
  4. If necessary, may be referred to the External Auditor or Labor Legal Counsel

g. Libelous, maliciously false and malevolent report to defame any employee and take advantage of this policy for personal agenda shall be subjected to disciplinary action.

 

E. EFFECTIVE DATE

This policy shall be effective on May 12, 2014. Thus, this policy supplants previous policies.