Insider Trading Policy

Prohibition of Insider Trading

Insider trading and abusive dealing is prohibited. Any change in personal shareholdings in the Company of the Directors and key officers resulting from open market transactions or the grant of shares from incentive-based schemes implemented by the Company are reported to the SEC, PSE and PDEx within specified deadlines. The Company strictly enforces and monitors compliance with its policy on insider trading, which prohibits the buying or selling of Company securities during prescribed periods by covered persons, which include members of the Board of Directors, all members of the Management Team, consultants, advisers, and other employees who have been made aware of undisclosed material information with respect to the Company and its operations. This restriction is expanded to include the immediate family members of the parties mentioned.

Ayala Land also practices a Trading Black-out Policy which covers ten (10) trading days before and three (3) trading days after the date of disclosure of quarterly and annual financial results. For cases of non-structured disclosure of other material information, the black out covers three (3) trading days before and after the date of disclosure.

All members of the Company’s Management Team are mandated to submit an annual certification signifying that they have not transacted in the Company’s shares during any of the previous year’s trading black-out periods. The process of certification is conducted during the month of January of each year. There has not been any case of insider trading involving company directors and management in the last seven years.