Unified Code of Conduct for Business – Integrity Initiative

Unified Code of Conduct for Business – Integrity Initiative

Unified Code of Conduct for Business

As a signatory of the Integrity Pledge, we are committed to upholding the highest standards of ethics in all our transactions. We firmly believe that securing profit at the expense of integrity is an unacceptable and unsustainable way of conducting business. Now is the time to drive the momentum towards the creation of fair market conditions in the Philippines. We express this collective commitment by adopting the Unified Code of Conduct for Business (UCC). We aim to institutionalize and promote honesty, transparency, and fairness in the business community by adhering to this Code.

Top Management

Our top management leads by example by consistently demonstrating the value of conducting business with integrity. Our officers strongly communicate our organization’s position against bribery *, corruption**, and unethical business practices within the company and the broader public; comply with all the requirements of government regulatory bodies; and prohibit cover-ups and falsified reports that conceal improper transactions. Management strongly supports integrity practices and allocates sufficient resources for their implementation.

Human Resources

We strive to instill a culture of integrity among our employees. The management maintains open lines of communication with employees, particularly on matters relating to honesty, transparency, and integrity in business transactions. In the spirit of fairness and due process, all employees have the right to file and respond to complaints against practices suspected to be illegal or unethical. We have appropriate tools to confidentially receive, monitor, and act on internal and external complaints. Employees filing complaints will be protected from all types of retaliation, while those involved in unethical practices will be subject to commensurate disciplinary actions. We have instituted training programs on business ethics covering all levels of the organization.

Sales and Marketing

We clearly communicate rules and guidelines on giving/receiving gifts, entertainment, tokens of hospitality, and contributions to/from public and private organizations and their representatives. Employees and all third parties engaged by our company to act as our intermediaries, agents, or representatives are not permitted to offer, promise, or give, as well as demand or accept concessions— directly or indirectly—in order to obtain, retain, or secure any undue advantage in the conduct of business. We abide by existing laws when transacting with government agencies (as stipulated under RA 6713 – Code of Conduct and Ethical Standards for Public Officials and Employees and RA 3019 – Anti-Graft and Corrupt Practices Act).

Finance and Accounting

We require all our employees to ensure that all books and records they create or are responsible for are complete and accurate.  Our financial records conform to standard accounting principles, comply with Securities and Exchange Commission requirements on disclosure and transparency, and abide by anti-money laundering laws (RA 9160) and international conventions. We pay taxes in compliance with all laws.


A track record of integrity and compliance with existing laws is a prerequisite when we vet third party consultants, suppliers, intermediaries, and agents. Our company has transparent procurement procedures, provides equal opportunities for all suppliers, and prohibits collusion between and among our employees and suppliers. Recognizing that the Integrity Initiative is sustained through widely shared ethical practices within the business community, we enter into integrity pacts*** with our suppliers and ensure that they comply with the provisions of our pact. Contracting a third party to bribe or commit corrupt practices on behalf of the company is strictly prohibited.


We comply with laws and regulations pertaining to supply chain management. We do not tolerate any breaches in existing laws in exchange for undue advantage and unethical concessions or favors. We pay correct duties and taxes based on transparent assessments of goods and services. Employees are not penalized for refusing to pay bribes or facilitation payments even if it results in failure to meet deadlines or loss of revenue.

Implementation and Monitoring

We will continually strive to align our operations to the principles contained in this Code and periodically assess and monitor our compliance to it. We will continue to share best practices with the business community to strengthen ethical business processes in the Philippines.



* The United Nations Convention Against Corruption defines bribery as “the promise, offering or giving, directly or indirectly, of an undue advantage to any person who directs or works, in any capacity, for a private sector entity, for the person himself or herself or for another person, in order that he or she, in breach of his or her duties, act or refrain from acting.”

** Corruption as misusing one’s position—or inducing others to do so—to improperly enrich himself/herself, or those close to him/her.

*** Transparency International defines integrity pacts as written agreements between parties involved in procurement to refrain from bribery and collusion.

This Unified Code of Conduct for Business was launched on 14 September 2011 at the 1st Integrity Summit: Marriott Hotel Manila, Philippines


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