CIC’s ETHICS PROGRAM
CIC and its subsidiaries are committed to the highest standards of business ethics – not only because it is beneficial, but mainly because is right. This commitment goes beyond mere compliance with the law, and demands strict adherence to the Code of Ethics and its principles.
In furtherance of this commitment, CIC maintains an Ethics Program that is designed to foster lawful and ethical behavior among the directors, officers, employees, representatives and suppliers of CIC and its subsidiaries, and to prevent and detect unlawful and improper conduct. The Ethics Program consists of, among others, the Code of Ethics, Ethics Training, Annual Ethics Certification, and the Dialog System.
CODE OF ETHICS
At the core of CIC’s Ethics Program is its Code of Ethics.
CIC’s Code of Ethics expresses its fundamental values, establishes rules of conduct and provides guidance for policy formulation and decision-making.
All directors, officers, employees, representatives, and suppliers are contractually expected to comply with the Code of Ethics.
Violation of the Code of Ethics can result in termination of employment or, in the case of representatives and suppliers, cancellation of contract and blacklisting from future engagements.
CIC and its subsidiaries provide regular Ethics Training to its employees and directors. The training is designed to help employees and directors understand and gain familiarity with the Code of Ethics, identify and address actual and possible wrongdoings, gain tools for ethical decision-making, and learn about the
resources available to them in case they have questions or concerns about ethics. It also helps align the individual’s personal values with the company’s values, thus enabling proper and consistent interpretation and application of the Code of Ethics.
To verify employees’ awareness of the Code of Ethics and uncover conflict of interest situations and wrongdoings, each employee is required to submit an Ethics Certification upon on-boarding, and annually within the first quarter of each year, via an online questionnaire. Candidates for employment are likewise
asked, during the application process, to declare possible situations that may give rise to conflict of interest on their part.
Representatives and suppliers who provide products or services to CIC or its subsidiaries are also required to submit an equivalent Ethics Certification at the start of their contract and annually thereafter.
DIALOG OR WHISTLEBLOWING SYSTEM
CIC welcomes questions, suggestions, criticisms, and complaints, and expects all stakeholders to report actual, potential, or suspected impropriety, fraud, misconduct, abuse, waste, and conflicts of interest. CIC’s Dialog System provides a safe alternative channel for everyone – including employees, customers, vendors, business partners – to communicate with higher management regarding any of the above confidentially, anonymously and without fear of retaliation. The availability of this channel serves to discourage wrongdoings, while getting everyone involved.
CIC’s Dialog System uses as its platform the ProActive Hotline Reporting System which is an anonymous internet-based communication and reporting system managed by Punongbayan and Araullo.
All communications via ProActive are visible only to the reporter, CIC’s Ethics Officer and the Ethics Committee of the concerned subsidiary. The system is designed to protect the identity of the reporter, but the reporter has the option to disclose his identity. The recipients of information obtained through the system are duty bound to maintain its confidentiality.
Everyone is expected to report, not just the person who, by his or her function, ought to report it. Even business partners are expected to report. And everyone can be reported – not just employees, but also actual or potential suppliers, providers, and business partners.