Business Integrity Channels
The Company’s business integrity channels are communication facilities that enable individuals to freely report fraud, violations of laws, rules, and regulations, or misconduct to people of authority without fear of retaliation. These secured channels provide concerned individuals all possible means to come forward and report their concerns either through electronic mail, telephone, fax, post mail, website or face-to-face discussions.
The ultimate goal is to give employees, third-party business partners, and other stakeholders every possible means for coming forward, so that they report information to top management or to the Board of Directors, rather than turning to the media.
The Ayala Land Business Integrity Channels shall be spearheaded by the Ayala Land Ethics Committee. The Ethics Committee, which has a direct reporting line to the Audit and Risk Committee, shall be chaired by the Head of Human Resource Division, and will be composed of selected members from the Internal Audit Division (IAD), Risk Management Division, and Ayala Group Legal Counsel. The committee evaluates and resolves concerns received via the business integrity channels to ensure just and prompt resolution. The Ayala Land Business Integrity Channels shall receive all reports from whistleblowers about the following:
• Conflicts of Interests
• Misconduct or Policy Violations
• Theft, Fraud or Misappropriation
• Falsification of Documents
• Financial Reporting Concerns
• Retaliation Complaints
The Ayala Land Business Integrity Channels shall accept reports made anonymously. The whistleblower who files a report may choose to provide the manner by which he can be contacted without jeopardizing his anonymity. Such means shall include, but is not limited to using an e-mail address, or a mobile number, among others. If the whistleblower chooses to identify himself, the recipient of the report from any of the Reporting Channels shall ask the whistleblower if he is willing to be identified in the course of the investigation.
After the investigation has been completed, and the report is substantiated, the Committee shall inform the Respondent’s Company HRD about the report for appropriate action. The Respondent’s Company HRD shall coordinate with the Committee in conducting full
investigation in accordance with applicable Company policies and procedures.
The Committee shall ensure confidentiality of information. It shall treat all reports, including the identity of the whistleblower, confidential, unless compelled by law to reveal such information. By reporting through any of the Ayala Land Business Integrity Channels, a whistleblower is protected from any retaliation against him, provided that the report is made in good faith. Cases of retaliation against any whistleblower may be reported through any of the Ayala Land Integrity Business Channels.
The retaliation complaint shall be dealt with in accordance with this policy, or other relevant Company policies and procedures, and any applicable laws.