CONFLICT OF INTEREST POLICY
The Company expects everyone in the organization, from the ordinary rank and file up to the Members of the Board of Directors, in the performance of their duties, to be objective, fair and to act for and in the best interests of the Company. Private and personal interests should never interfere with one’s duties, and one’s position should never be used as leverage for personal or financial gain or advancement. Any situation which may constrain or oblige one to favor or give a co-employee or business partner whom one may have had or has a personal, commercial, familial or other significant relationship an unfair advantage should be avoided.
The following and analogous acts are prohibited:
Self-dealing and Cronyism
Accepting gifts, benefits and/or favors from business partners
Unauthorized use of confidential information
Outside employment or moonlighting that compromise or interfere with one’s commitment and duties to the organization
Using Company time and property for personal advantage/advancement
To eliminate or reduce Conflict of Interest Situations, every employee, officer and director is required to disclose any potential conflict of interest (including but not limited to holdings, connections and/or association with any outside business entities and organizations), and is prohibited from receiving or accepting gifts or favors from business partners. Supplier sponsored trainings/conferences are subject to the approval of the Executive Office. The Human Resources and Administration Division (HRAD) of the Company is mandated to provide a mechanism by which employees can declare or disclose their potential conflict of interest.
INSIDER TRADING POLICY
To ensure the Company’s adherence to applicable securities laws and regulations on Insider Trading, and that Company’s investors are given equal opportunity, the Company’s directors and officers are required to report their beneficial ownership of the Company’s shares to the Securities and Exchange Commission and the Philippine Stock Exchange within two (2) to trading days from their appointment or election. In case of changes in their beneficial ownership, such changes should be reported within two (2) trading days from the date of the acquisition, disposal, or change in their shareholdings.
Copies of the reports filed with the Securities and Exchange Commission should be submitted to the Company’s Compliance Officer and/or Corporate Secretary within the same period.
For purposes of reportorial requirements, a director’s or officer’s beneficial ownership shall include not only shares directly owned by said director or officer, but also shares:
(i) held by members of his immediate family sharing the same household;
(ii) held by a partnership in which he is a general partner;
(iii) held by a corporation of which he is the controlling shareholder;
(iv) subject to any contract, arrangement or understanding which gives him voting power or investment power with respect to such shares.
All directors, officers, employees and agents (including consultants, third party contractor) of the Company in possession of material non public information and their immediate family are prohibited from:
(i) Dealing in Company shares from the time the director, officer, employee or agent acquired such material non public information and until two trading days after the material non public information is disclosed to the public;
(ii) Disclosing or passing such material non public information to any person, except if disclosure is made to (i) a person who is duty bound to maintain trust and confidence to the Company (i.e. auditors, investment bankers, legal counsels, and financial advisers) and (ii) a person who agrees in writing to maintain the material information in the strictest confidence and not use the information to trade in the Company’s shares or for material benefit;
(iii) Dealing with the Company’s shares during blackout periods imposed by the Compliance Officer.
The prohibition shall apply even after the director, officer, employee and agent has ceased to be employed or connected with the company so long as the information have not yet been made public.
POLICY AND DATA RELATING TO HEALTH SAFETY & WELFARE OF EMPLOYEES
Ensuring employees continues growth
The Company believes and is committed to the continuous growth of its employees. Guided by its Learning Framework –the 3 Cs of Corporate Education—the company ensures that employees go through a holistic learning experience geared towards fully imbibing the business of Splash. This starts with helping employees appreciate the history of the company, its values, and culture (Corporate Citizenship), moving on to understanding the “Splash Way” of doing business (Contextual Framework), and then mastering the competencies necessary to execute individual roles (Core Workplace Competencies).
Employees’ Individual Development Plans are defined in their respective Employee Competency Profiles prepared yearly to ensure responsiveness of enhancement initiatives. The company employs the most effective and needs-appropriate learning methodologies such as classroom training, blended learning, on-the-job training, coaching, mentoring, and even e-learning. The company ensures all its employees, and not just a few ones, are given opportunities for growth and development by setting a yearly minimum training hours target which forms part of employees’ annual performance deliverables.
Safety & Welfare
It is the intention of the Company to provide a safe working environment for its employees. Every employee is expected to know, follow, and enforce the safety standards, and participate in the safety programs set by the Company. Violation of safety/sanitary/ housekeeping rules (such as CGMP, HAACP, etc.) is a punishable offence under the Company’s Code of Conduct.
Anti Sexual Harassment Policy
Sexual harassment violates the dignity of individuals and is considered a grave and terminable offense under the Company’s Code of Conduct.
In the interest of providing a safe and healthy work environment, smoking is not allowed within Company premises, including company issued motor vehicles.
RELATED PARTY TRANSACTIONS POLICY
Business Units under the Splash Corporation are diversified in its operations; hence, one business unit may be a customer of another business unit and so on. While each business unit operates distinctly or as separate entity from each other, the group is created to operate in a manner that will provide synergy and maximization of opportunities to increase shareholder value within the parameters allowed by law. Intercompany transactions are therefore inevitable.
To standardize, regulate and monitor transactions within the Group as well as to improve transparency and strengthen internal control within the context of good corporate governance, transactions with related parties are expected to comply with the requirements of applicable tax law, rules or regulations and shall be subject to appropriate corporate approvals and disclosures.
The Company espouses Ethical Governance as one of its core value. Employees and non-employees are encouraged to report questionable practices and activities without fear of retaliation, discrimination and harassment. In addition to the Company’s operational reporting procedures, reports may be submitted through any of the following:
|by Mail||Splash CorporationAttn: Audit Committee
5/F W High Street
11th Avenue corner 28th St.
Bonifacio Global City, Taguig City
|By Phone||(02) 491-7654|
Reports will be kept confidential to the extent possible, consistent with existing law and the need to conduct an adequate investigation. The protection offered under the Whistleblower Policy however, will not apply to reports made in bad faith..