Insider Trading Policy

In accordance with the Corporation’s Insider Trading policy, Covered persons are prohibited from trading Ayala Land securities during the following designated blackout periods, whether or not in possession of material non-public information:

a. Five (5) trading days before, and two (2) trading days after the disclosure of quarterly and annual financial results; and

b. Two (2) trading days after the disclosure of any material information other than quarterly and annual financial results.

Covered Persons
All directors, key officers, employees, consultants, advisors of the Corporation, and members of their immediate families who are living in the same household.

Covered persons possessing material non-public information are further prohibited from communicating, directly or indirectly, said information to any person, from the time they obtained knowledge, until the material non-public information is disseminated to the public, and two (2) trading days have lapsed from the disclosure thereof in order for the market to absorb such information.

Reporting of Trades of Covered Persons
All members of the Board of Directors and key officers, including the Controller, Chief Audit Executive, Chief Risk Officer, Treasurer, Corporate Secretary, and Assistant Corporate Secretary, shall report their trades to the Office of the Compliance Officer within three (3) business days from dealing such securities. This shall be subsequently reported to the SEC and PSE in compliance with existing rules and regulations. All other Covered Persons shall likewise report their trades (if any) of the Corporation’s securities to the Office of the Compliance Officer, quarterly, within ten (10) days from the end of each quarter, by sending an email to

Violation of this policy shall be subject to disciplinary action under the Corporation’s Code of Conduct, without prejudice to any civil or criminal proceedings which the Corporation or regulators may file for violation of existing laws. Insider trading under the law may be subject to penalty for damages or fines and/or imprisonment.