CODE OF CONDUCT

Integrity is one of Ayala's core values. Strictly abiding by the principle of "doing the right thing", has earned for the Company its strong position of trust among its stakeholders. Ayala believes that integrity starts with the individual; thus, we strive to maintain an exceptional standard of conduct among our employees.

This Code of Conduct applies to all Ayala employees, including senior executives and members of the Executive and Management Committees. It provides an outline of the general expectations and sets standards by which employees are expected to conduct themselves. As it does not cover every conceivable subject, it is recommended that employees refer to its general principles to guide them in their activities.

This Code of Conduct must be read in conjunction with the Company's Human Resources Manual of Policies and Procedures and the Employee Handbook.

Compliance with Philippine Laws and Regulations
Ayala expects its employees to conduct business in accordance with Philippine laws and regulations. Employees are encouraged to consult with Corporate Governance and Legal Affairs whenever there is any doubt concerning the legality of any matter.

Any suspected criminal violations will be reported to the appropriate authorities. Non-criminal violations will be investigated and addressed as appropriate.

Attendance and Office Hours
Ayala expects punctuality and diligence from all its employees. Regular working days are from Monday to Friday and regular working hours are from 7:00 AM to 4:00 PM, except as designated by one's Unit Head in accordance with his/her job assignment with the approval of the Managing Director for Strategic Human Resources and Organization Development.

Sanctions are imposed for frequent tardiness and unauthorized absences.

Ayala observes all regular and special holidays as declared by the President of the Philippines, and company holidays set by the Company President.

For security reasons, the Company discourages employees from remaining inside office premises after 6:00 PM and during weekends unless they are finishing work assignments. Employees are required to display their IDs at all times while inside Company premises.

All employees can only receive guests at the lobby, the 25F Lounge or at the canteen unless the visit is a business or client call. Soliciting agencies, vendors and mendicants are prohibited from entering the Company offices.
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