Generally, these policy statements were lifted from the existing company policies and procedures including Code of Ethics, Code of Conduct, Charitable Contribution Policy and Manual of Corporate Governance.
Illegal or unethical behaviour by a colleague or co-employee, regardless of his or her level of authority, should not be condoned.
It is the responsibility of each employee to report legitimate concerns so that problems can be properly resolved and corrective measures
instituted. An officer or employee or employee who becomes aware of any violation on Code of Ethics should immediately notify his
Department / Division Head. The Division / Department Head shall in turn immediately inform the Human Resources Department (HRD).
HRD shall conduct or manage the necessary actions or investigation of any reported violations of this Code. In case Senior Management
or any Board Member is involved, the same shall be referred to Audit Committee. (Reference - Code of Ethics, Implementation and Monitoring
of the Code, Section III.2)
Conflict of Interest Policy
Directors, Senior Management and employees shall avoid apparent conflicts of interests between private interests,
including the private interests of family members, and the interests of the Company, unless prior approval has been obtained from
the appropriate approving authority as designated in applicable policies of the Company. Any actual or apparent conflict of interest,
and any material transaction or relationship that could reasonably be expected to give rise to a conflict of interest, must be immediately
disclosed to the Human Resources Department or to the Corporate Secretary, in case any member of the Board is involved.
Directors, Senior Management and employees shall avoid any activity and interest that could significantly affect the objective or
effective performance of duties and responsibilities in the company, including business interests or unauthorized employment
outside the company, the receipt from and giving of gifts of unusually high value to persons or entities with whom the Company relates,
as well as insider dealing.
Directors, Senior Management and employees shall base all business decisions and actions on the best interests of the company.
Whenever opportunities arise, constantly advance the Company’s legitimate interest. (Reference - Code of Ethics, The Norms
of Business Conduct and Ethics, Conflict of Interest, Section II.5)
Respect for Trade Secrets/Use of Non-public Information (Insider Trading Policy)
Directors, Officers and employees shall maintain and safeguard the confidentiality of information entrusted by the Company,
customers, business partners or such other parties with whom the Company relates, except when disclosure is authorized or legally mandated.
Directors, Officers and employees should not trade the company’s securities using price sensitive information that is not normally
available publicly, and obtained by reason of position, contact within, or other relationship with the Company. (Reference - Code of Ethics,
The Norms of Business Conduct and Ethics, Confidentiality, Section II.3)
Related Party Transactions Policy
Overlapping interests in the company shall be disclosed to the Board and any material transaction involving such interests
shall be similarly disclosed. Related party transactions shall be disclosed fully to the Board. Prior Board approval shall be obtained for
related party transactions.
Related party transactions shall be conducted in terms that are at least comparable to normal commercial practices to safeguard the best interest
of the Corporation, its stockholders, creditors, policyholders and claimants. (Reference - Revised Manual of Corporate Governance, Accountability
and Audit, Section F.3, page 23)
Policies Related to Health, Safety and Welfare of Employees
The Company is committed in providing and maintaining a safe, secure and healthy work environment. In turn, the employee has
the responsibility to work safely, to keep work areas and common areas in the company neat and clean, not just to reduce the chances of injury
but also to make the office a more attractive and pleasant place to work in.
Employees are urged to report to their immediate superior or to the General Services Department accidents or any condition or practice which is
unsafe, whether or not these result in personal injury or no matter how minor they might seem to be. (Reference - Code of Conduct, Policy
Provision, Rules of Conduct, Health, Safety, Security and Proper Use of Company Assets, Section III.11.3, page 6)
In order to ensure the promotion of employee health and well-being, the company offers health care benefits covered by the health insurance
provider of the Company.
Employees are involved in deciding, planning and implementing employee activities and programs such as
sports and summer outing events, company parties and employee uniform. (Reference – Annual Corporate Governance Report, page 49)
Policies Related to Employees Training and Development Programme
New employees are given orientation on the Company’s policies and procedures and made to undergo basic insurance and
reinsurance training. Depending on their work assignment and employee development plans, employees undergo or are sent to specialized
training courses. (Reference - Annual Corporate Governance Report, page 50)
Enterprise Risk Management
In its desire to have a very good culture of managing risk, PhilNaRe is setting up a significant number of embedded processes,
resources, and structures to address risk management needs. These range from our internal audit systems, insurance and risk finance, IT security,
compliance processes, quality management and an array of line management interventions. The risk policy document provides an integrated framework
so that our risk management efforts are optimized.
PhilNaRe’s Board of Directors monitors the Company’s Risk Management performance in a structured way, and PhilNaRe has an unwavering commitment
to these practices. It is, therefore, imperative that all divisions, operations, and business functions cooperate with the Board’s intent to
maintain a system of risk management excellence. PhilNaRe’s policy generally applies to all levels of organization, from the Board of Directors to
its officers and staff. (Reference - Enterprise Risk Management Policy Framework)
Corporate Social Responsibility Initiatives
PhilNaRe has established a Charitable Contribution Policy. It focuses on the company’s commitment among others to expand
access to insurance products for individuals that are not currently reached or are underserved by the insurance industry, community relations
and philanthropic priorities and enhancement of employee engagement programs. It also encourages senior leadership involvement with charitable
organizations, such as serving its Board.
The Charitable Contribution Policy requires a comprehensive review be performed on all organizations receiving grants, donations,
or contributions from any party associated with PhilNaRe. Its comprehensive review is designed to identify the ultimate organizational
recipients of PhilNaRe’s charitable grants and donations and to ensure that the individuals who manage and control the recipient charitable
organizations are not associated with illicit activities. The collection, review and screening of the relevant information with regard to each
recipient charitable organization must be documented. (Reference - Corporate Social Responsibility Policy and Procedures, June 19, 2014)