bank of the philippine islands 2018 asean corporate ... · 2018 asean corporate governance...

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Bank of the Philippine Islands 2018 ASEAN Corporate Governance Scorecard Questionnaire As of July 2018 Page 1 of 30 C. Role of Stakeholders Guiding Reference Yes/No Supporting Documents C.1 The rights of stakeholders that are established by law or through mutual agreements are to be respected. Does the company disclose a policy and practices that address : C.1.1 Stipulates the existence and scope of the company's efforts to address customers' welfare? OECD Principle IV (A): The rights of stakeholders that are established by law or through mutual agreements are to be respected. In all OECD countries, the rights of stakeholders are established by law (e.g. labour, business, commercial and insolvency laws) or by contractual relations. Even in areas where stakeholder interests are not legislated, many firms make additional commitments to stakeholders, and concern over corporate reputation and corporate performance often requires the recognition of broader interests. Global Reporting Initiative: Sustainability Report (C1.1 - C.15) International Accounting Standards 1: Presentation of Financial Statements Yes The Bank seriously takes its responsibility in developing and sustaining relationships with its stakeholders, internal and external. Its stakeholders may be grouped into two: those who are directly affected by its business operations and outcomes, and those who guide and influence the Bank in carrying out its business. The first group consists of investors, clients, employees, suppliers and the community at large, while the latter includes government and regulatory agencies, non-government and civil society groups and industry organizations. The Bank’s engagement with stakeholders takes on various forms and is carried out through a range of information, communication and consultative activities and disclosures. The Bank conducts dialogues about its role in society, products and services, business performance and other issues, at the business unit and Group levels. This active engagement has allowed the Bank and its stakeholders to: Identify our most significant stakeholder groups and their specific interests, and determine the most significant issues from the economic, environmental and social sustainability perspective. Become more responsive in addressing various concerns, from customer service to financial solutions, systems, promotion-related complaints, shareholder return, operational strategies, business outlook, regulatory compliance, employee conduct, and employee salaries, benefits and financial assistance. Integrate the outcomes of our stakeholder engagement with well- established risk management processes, allowing us to address potential risks and align the management of sustainable issues with our business processes and strategies. Innovate and improve our products, services, systems, operational C.1.2 Explains supplier/contractor selection practice? Yes C.1.3 Describes the company's efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development? Yes C.1.4 Elaborates the company's efforts to interact with the communities in which they operate? Yes C.1.5 Describe the company's anti-corruption programmes and procedures? Yes C.1.6 Describes how creditors' rights are safeguarded? Yes

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Page 1: Bank of the Philippine Islands 2018 ASEAN Corporate ... · 2018 ASEAN Corporate Governance Scorecard Questionnaire ... its role in society, products and services, business performance

Bank of the Philippine Islands 2018 ASEAN Corporate Governance Scorecard Questionnaire As of July 2018 Page 1 of 30

C. Role of Stakeholders Guiding Reference Yes/No Supporting Documents

C.1 The rights of stakeholders that are established by law or through mutual agreements are to be respected.

Does the company disclose a policy and practices that address :

C.1.1 Stipulates the existence and scope of the company's efforts to address customers' welfare?

OECD Principle IV (A): The rights of stakeholders that are established by law or through mutual agreements are to be respected. In all OECD countries, the rights of stakeholders are established by law (e.g. labour, business, commercial and insolvency laws) or by contractual relations. Even in areas where stakeholder interests are not legislated, many firms make additional commitments to stakeholders, and concern over corporate reputation and corporate performance often requires the recognition of broader interests. Global Reporting Initiative: Sustainability Report (C1.1 - C.15) International Accounting Standards 1: Presentation of Financial Statements

Yes The Bank seriously takes its responsibility in developing and sustaining relationships with its stakeholders, internal and external. Its stakeholders may be grouped into two: those who are directly affected by its business operations and outcomes, and those who guide and influence the Bank in carrying out its business. The first group consists of investors, clients, employees, suppliers and the community at large, while the latter includes government and regulatory agencies, non-government and civil society groups and industry organizations.

The Bank’s engagement with stakeholders takes on various forms and is carried out through a range of information, communication and consultative activities and disclosures. The Bank conducts dialogues about its role in society, products and services, business performance and other issues, at the business unit and Group levels.

This active engagement has allowed the Bank and its stakeholders to:

• Identify our most significant stakeholder groups and their specific interests, and determine the most significant issues from the economic, environmental and social sustainability perspective.

• Become more responsive in addressing various concerns, from customer service to financial solutions, systems, promotion-related complaints, shareholder return, operational strategies, business outlook, regulatory compliance, employee conduct, and employee salaries, benefits and financial assistance.

• Integrate the outcomes of our stakeholder engagement with well-established risk management processes, allowing us to address potential risks and align the management of sustainable issues with our business processes and strategies.

• Innovate and improve our products, services, systems, operational

C.1.2 Explains supplier/contractor selection practice?

Yes

C.1.3 Describes the company's efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development?

Yes

C.1.4 Elaborates the company's efforts to interact with the communities in which they operate?

Yes

C.1.5 Describe the company's anti-corruption programmes and procedures?

Yes

C.1.6 Describes how creditors' rights are safeguarded?

Yes

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processes and practices. The Bank’s Credo and Core Values clearly state its policy with respect to recognition and protection of the rights of key stakeholders. The Bank also operates on a framework of shared values which emphasizes the importance of all stakeholders and how their interests are integrated into the business of the Bank.

For its clients/customer welfare:

Our Sustainability Strategy and Framework of shared value guides our thrust to become every Filipino’s Banking Champion. We innovate for operational efficiency, empower our people and society, use resources efficiently, and continue to build stakeholder trust focused on three main areas:

Financial wellness – We help individuals, communities and businesses grow their funds and build their wealth by facilitating financial wellness opportunities, a range of innovative programs and more accessible investment options.

Financial inclusion – We continually strive to widen our reach by developing products and services that address the needs and preferences of clients coming from low-income and underserved segments. We adhere to the ideals that true prosperity can only be achieved when everyone is involved.

Sustainable development investments – We promote investments in industries that strengthen urban and countryside development. Advocating and advancing shared value financing, we also stimulate business innovation through cleaner, low carbon, and resource efficient technologies.

For customers: In terms of service architecture, the Bank’s active engagement with Customers is done through: BPI Customer Care Department - These include financial wellness events such as those launched with the personal finance symposia with Suze Orman and participation in the Money Summit and Wealth Expo. BPI Contact Center and BPI Express Online - Customer feedback system is obtained through the BPI Contact Center and our website. Feedback received is handled by our Customer Care Department which is dedicated to attend and take appropriate action on customer complaints.

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The BPI Contact Center is equipped to operate on a 24-hour, 7-days a week basis to allow customers easy access to assistance and information most especially should they encounter any problems and difficulties for any banking needs. The Bank also has its Risk Management and Compliance Units which focus on fraud monitoring to assist customers should there be any concerns on ATM use or possible fraud- related incidents such as unauthorized withdrawals, non-dispensing machines or card captures. BPI Facebook and Twitter Accounts, BPI Express Mobile – The Bank also enhanced its social media presence through Facebook and Twitter. Our official Twitter account (@talktobpi) and Facebook fan page (www.facebook.com/bpi) disseminates and addresses customer service information and concerns. In addition, the Bank also dominates the mobile arena with its mobile app, BPI Express Mobile, which allows greater servicing and reach of Bank customers and communication of announcements as well as provision of answers and solutions to frequently asked questions. With regards health and safety of customers, the Bank has as a matter of policy, ensured that all bank premises follow proper health and safety protocols, i.e., ban on smoking, ban on firearms, disaster preparedness (fire, earthquake, etc.), special access ramps for PWDs, pest prevention and more. In support of the foregoing, the Bank also secures customer feedback through customer satisfaction surveys. Through the Mystery Client Survey (MCS), the Bank tracks service standards at every point of customer interaction in all BPI branches and kiosks nationwide. It also uses the Net Promoter Score (NPS) survey to know if clients would recommend BPI to their friends/relatives. In addition it commissions third-party research agencies to conduct face-to-face interviews with respondents. These surveys mostly probe into customer satisfaction with BPI’s products, services and personnel. These also include problem handling and solicitation of suggestions or comments for improvement. The Bank likewise conducts telephone surveys through third-party agencies who call on its clients and ask questions, and online surveys through a questionnaire posted in BPI Express Online. In 2017, the Bank, through its Customer Experience Management Office (CXMO) established the BPI Customer Assistance Program to establish guidelines that will help ensure that all feedback from customers and potential customers are well handled in alignment with the Bank’s

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consumer protection policies. The designated Customer Assistance Officers underwent onsite training to equip them in their function in addressing customer issues and to ensure compliance with the Bank’s Consumer Protection Program. The need to conduct continuous information and education campaign on the Financial Consumer Protection Program has been a major priority of the unit. To deepen customer engagement and address specific customer needs, CXMO spearheaded the conduct of the Service Quality Review (SQR) where various business units present their performance updates on their defined service quality goals to the Bank's Customer Experience Council. The Customer Experience Council includes top executives of the Bank. A Customer Feedback Database was also created to strengthen the role of the frontliners in addressing and reporting customer issues. For 2017, the Bank tracked and monitored customer issues and feedback concerning its products and services (the table below shows the number of customer complaints we received for the past three years, and the number of customer transactions recorded for the same year). Action plans were implemented to ensure that the most pressing and important issues raised by customers were resolved within the committed turn-around times.

2015 2016 2017

Complaints (in thousands)

291.5 306.0 437.5

Transactions (in millions)

1,268.1 1,341.4 1,442

For its suppliers/contractor selection:

In ensuring a global supply chain for its business of banking, the Bank operates with a focus on two areas:

• Sustainability. At all times, our goal is to work collaboratively with our supply chain partners on sustainability. Our supply chain must not only be sustainable; it must also work towards improving the lives of workers, their communities and the environment. It is essential that our suppliers promote fair and sustainable development and comply with national laws and internationally recognized standards and conventions for ethical, environmental and social conditions.

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• Governance. From a governance standpoint, the commercial transactions with our suppliers should be economically beneficial to all parties involved and relationships should be based on the principle of fair and honest dealings, and be in compliance with internal policies that are in place to stop fraud, money laundering, bribery and corruption as well as be in adherence with local or international laws and regulations.

BPI has an established Supplier Accreditation and Dis-accreditation Policy that covers all processes involved in the contracting of suppliers, service providers, and business partners, and all personnel involved in the administration and execution of these processes. The policy focuses on giving equal opportunities for qualified suppliers and contractors. BPI operates on the principle of transparency with suppliers and works collectively with suppliers to ensure their adherence to the policy.

The policy involves the formation of centralized accreditation committees for all services that are common across units, i.e., professional, legal counsel, IT project management, janitorial, messengerial, security, etc. Accreditation of parties is based on:

• Legitimacy of the party being accredited; suppliers with whom BPI has regular and recurring dealings should have good management and governance processes in place to ensure compliance with the policy.

• Capacity for continuous business operations to sustain delivery of the required goods/services or the performance of business arrangements; suppliers must ensure that their systems and procedures are sufficient to mitigate any potential negative impact on BPI’s brand and reputation.

• Quality of and reasonableness of the prices for the goods / services / business arrangements being offered and; suppliers must make reasonable efforts to monitor their supply chain as well, ensuring their sub-contractors are also aware of, and compliant with, the aims of the policy.

• Track record on reliability, qualifications, professional activities and credit worthiness.

The policy also states the grounds for dis-accreditation as well as the processes for pre-termination, removal, inclusion in the bank's official Negative Data system and, if needed, activation of a Business Continuity Plan.

For supplier/contractor selection activities:

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The bank actively engages suppliers.

It has established processes for accreditation, vendor selection and suppliers audit to assure qualified suppliers of equal opportunity when bidding for projects with the Bank.

All accreditation of suppliers, contractors, and service providers are subject to regular renewal to maintain their active status with BPI and must meet Unibank Accreditation Standards.

All employees, departments and divisions are regularly advised to update and review their respective list of suppliers to meet accreditation requirements.

During the annual review as well as in any application for accreditation, all related policies, such conflict of interest, related party transactions, among others, are applied and enforced to ensure that the bank and the counterparties are protected by fairness, accountability and transparency. BPI reserves the right to randomly review the supplier’s policies, procedures or any other document related to adherence to BPI’s Supplier Policy. The Bank has invested in an automated procurement system, the Ariba Spend Management System, a procurement software solution with one of the broadest set of capabilities on the market that allows for the Bank’s integration with the a large supplier network comprised of the pre-enabled suppliers. This allows easy supplier and catalog enablement, and provides automated tools and approval flows with global reach. It also gives the Bank comprehensive monitoring of its procurement with easily configurable dashboards and reports. Examples of supplier activities facilitated through the Ariba Spend Management System:

1) Strategic sourcing: 84 including IT-related (laptop/desktops) Logistics, ATM/CAM and selected Branch office supplies, etc.;

2) Construction-related projects for branches: 261; 3) Repairs (both branches and Head Office): 276

The Bank ensures that there is a cascade of policies (requirements, criteria) to suppliers and provides real-time updates on procurement-related concerns (cost, terms of payment, mode of shipment, warranties). Apart from the accreditation process, these are also communicated through emails, letters and memos.

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For its Employee welfare/training and professional development:

It is the Bank’s policy to continue to provide a range of training programs designed along the Bank’s business objectives. These development programs are aimed at honing the skills and capabilities of our employees in carrying out their daily duties, as well as preparing them to assume higher responsibilities as the next leaders of the organization. We use a blended learning approach that includes workshops, coaching/mentoring, instructor-led training sessions, and web-based training courses. We also design and facilitate leadership and management training programs for supervisors, functional managers, and senior managers to support our investment in leadership development. Mid-level officers take part in the BPI Leadership Excellence Acceleration Program (BPI LEAP). BPI LEAP has become a benchmark in training and development.

By ensuring that our staff, specialists, and officers are trained, steeped in best practices, and exposed to an environment that nurtures continuous learning, we are able to provide the highest quality service to our customers.

In general, the Bank’s Learning and Development program for our employees takes a holistic approach to learning and development and is categorized into the following training programs for everyone:

1. Leadership and Management Development – Programs that provide opportunities for BPI Leaders to develop their ability to lead, inspire and motivate their team members and organization. This would also cover Professional Effectiveness Programs that would develop Personal Leadership

2. Functional – Programs that develop and strengthen specific functional and technical competencies required from the individuals so they can perform their functional tasks effectively

3. Core and Team Effectiveness – Programs that would provide foundational knowledge and competencies for any member of the BPI team. This would also cover programs and interventions for teams.

The Bank also has in place a merit-based performance incentive mechanism. One of our major incentives for deserving officers is the grant of an annual performance bonus (PB), which is directly related in amount to the size and quality of the bank’s annual earnings. Our PB

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payouts are based not only on an officer’s individual productivity and performance relative to assigned targets, but also on a relative comparison to the performance of peers within their rank.

Another testament to BPI’s commitment of offering greater value to its employees—and aligning management’s interest with shareholders—is its equity-linked incentive plan to its all its officers, including junior officers from Assistant Manager and up (with eligibility requirements): Executive Stock Purchase Plan (ESPP).

A major initiative of the Bank under its long-term incentive program, the Executive Stock Purchase Plan (ESPP) was launched in 2013. The ESPP gives the officers the opportunity to buy shares of stock in BPI, at a discounted price based on the volume weighted average of BPI’s share price for the past 30 days.

Management believes that this stronger alignment between the interests of BPI officers and interests of shareholders will benefit all stakeholders, i.e., more robust earnings and a healthier balance sheet will be reflected in a stronger and higher stock valuation.

BPI also ensures a sound Compensation and Rewards Systems that is aimed at attracting, retaining and motivating its employees.

1. Compensation must reflect internal equity -recognizes the differences in the relative values of the jobs/ in the organization and the competencies required to perform the job and establishes appropriate pay for each type of job/role to achieve internal equity.

2. Compensation must be externally competitive - conducts regular salary review to ensure that the BPI total remunerations levels compare favorably with those prevailing in the market.

3. Compensation emphasizes rewards based on performance - potential to assume bigger responsibility and higher position is recognized; meritorious performance and contribution to the company's growth is rewarded.

(Source: Human Resources Management Group)

For environmentally-friendly value chain and communities care:

Our efforts towards financial inclusion and capacity building are targeted to rebuild social capital - the perceived role of business in society, or the expectation of business contribution to society in return for its license to

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operate. Our sustainability strategy gives us an opportunity to offer products and services in previously underserved markets and obtain additional sources of revenue. By meeting the need to extend credit and financial services to low-income populations and small businesses while avoiding predatory and irresponsible lending practices, we are able to create long-term value and enhance social capital.

By providing banking access to the country’s underserved communities, we also gain a higher and diversified deposit funding base that positions us well to protect shareholder value. This expansion of services to new customers brings new revenue and increased market share as well. Finally, as we manage our lending risk by improving financial literacy initiatives with these new customers, we are also likely to increase interest income, lower credit risks, and reduce the cost of capital.

We create sustainable value by innovating and factoring environmental and social dimensions into our business and risk models. By enabling positive environmental and social externalities through our renewable energy lending programs, we can lower reputational risks, enhance intangible assets and capture new market share.

By embedding corporate social responsibility into our business and processes, we link our non-financial performance with our business strategy. This enables us to focus our efforts on long-term value drivers that contribute to the success of our Bank and progress for society as a whole. BPI is mainstreaming corporate responsibility to bring about positive and sustainable change.

Sustainable development investments – We promote investments in industries that strengthen urban and countryside development. Advocating and advancing shared value financing, we also stimulate business innovation through cleaner, low carbon, and resource efficient technologies.

Corporate social responsibility is embedded in the bank's business, and is also carried out through its employee volunteerism program, BPI Bayan, and its social development arm, BPI Foundation.

The Foundation carries out the various programs of its three-fold advocacy—entrepreneurship, education, and environment—in partnership with government agencies, civic organizations and NGOs, and

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educational institutions.

For environmentally-friendly value chain: The Bank’s active engagement in support of an environmentally friendly value chain is done through: Our efforts towards financial inclusion and financial wellness or capacity building are integrated into our value chain and targeted to rebuild social capital - the perceived role of business in society, or the expectation of business contribution to society in return for its license to operate. Our sustainability strategy gives us an opportunity to offer products and services in previously underserved markets and obtain additional sources of revenue. By meeting the need to extend credit and financial services to low-income populations and small businesses while avoiding predatory and irresponsible lending practices, we are able to create long-term value and enhance social capital. By providing banking access to the country’s underserved communities, we also gain a higher and diversified deposit funding base that positions us well to protect shareholder value. This expansion of services to new customers brings new revenue and increased market share as well. Finally, as we manage our lending risk by improving financial literacy initiatives with these new customers, we are also likely to increase interest income, lower credit risks, and reduce the cost of capital. Total number of microfinance clients = 2,300 Average account size for Easy Saver = 19% vs 2015 We create sustainable value by innovating and factoring environmental and social dimensions into our business and risk models. By enabling positive environmental and social externalities through our renewable energy lending programs, we can lower reputational risks, enhance intangible assets and capture new market share. Top 3 industries capitalized = energy, conglomerates, and government (68.8% of total capitalization) Distribution of investments through corporate client loans = 19.1% to provinces, 80.9% to metropolitan areas Total disbursed loans through Sustainable Energy Finance =

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135% vs 2015 Potential GHG emissions reduction through SEF-financed projects = 120% vs 2015 (4,420.3 thousand tCO2e/year) Total loans through Agribusiness = 72% vs 2015. Electricity consumption intensity = 35,316 kWh/branch Distribution of transactions by channel = 12.6% traditional channels, 87.4% electronic channels Number of retail clients with Express Online accounts = 33% Number of corporate clients with E-link accounts = 29% Energy Audit In March 2016, BPI Sustainability Office met with General Services Division to recommend an Energy Audit for the Bank with the intention of identifying areas of improved efficiency and design resulting in reduced consumption and cost. The project contracted an energy management expert for technical analysis and advisory. BPI Sustainability Office facilitated the search for the best suited service provider (7 bidders) and provided baseline data for the pilot energy audit. The pilot study was completed in December 2016. As of January 2017, there are ongoing discussions on how to move forward with the results of the study. For communities: The Bank’s active engagement in support of the communities it serves is done through: Memberships Volunteerism Activities Dialogues and Fora Events CSR Activities Financial education and empowerment. 1. Manny and Me - To equip more Filipino people with the right financial mindset and financial management tools, BPI Foundation launched Manny and Me – a financial literacy program tailor-fit for kids in primary school. Manny and Me educates the basics of financial management to children, while providing guidance to teachers and parents in order to sustainably

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support their growth and development into financial wellness. 2. Financial Education for Overseas Filipinos and their Families Program – In partnership with ASKI Global, BPI Foundation has trained over 1,000 Overseas Filipinos in Hong Kong and 600 family members in the Philippines on financial literacy, as well as introduced the concept of entrepreneurship as an alternative mode of income. 3. Transform Program - To uplift the ultra-poor (people who earn less than P13.00 per day), the Foundation has partnered with International Care Ministries Foundation to educate marginalized communities on Values, Health and Livelihood. Since 2015, 36 communities in Visayas and Mindanao. Financial inclusion. 1. The Business of Mainstreaming Sustainability – After the completion of the 4-year study “Business Risk Assessment and the Management of Climate Change Impacts”, BPI Foundation, in partnership with World Wide Fund for Nature-Philippines, identified agriculture and water as areas of priority for economic development. The program aims to identify inclusive business models, improve the entrepreneurial capacity of farmers, and introduce more environmentally sustainable agricultural practices. Sustainable development. 1. BPI Sinag - Social enterprises are a new breed of inclusive businesses, however, most of them fail within the first three years. To address this, BPI Foundation launched BPI Sinag in 2015 to capacitate and incubate up and coming social enterprises. At the end of the program, five outstanding social entrepreneurs were awarded with seed funding, a BPI Family Ka-Negosyo credit line and a customized 6-month mentorship program. 2. BPI Show Me, Teach Me - Since the program started in 2010, in partnership with the Department of Trade and Industry, the program has capacitated 2,988 MSMEs from 52 cities across the country, helping them to gain knowledge on product design in order for them to grow or start their businesses. Employee Volunteerism.

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Total of over 6,000 employee volunteers mobilized in programs that tackle: 1. Environmental sustainability to improve economic activity 2. Life skills development to increase per capita income 3. Financial education programs to foster financial inclusion among the unbanked and under-banked segments. Employee Driven Volunteering By year end, the Bank recognized the top 10 programs nationwide that focused on environmental sustainability programs to improve economic activity, life skills development programs to increase per capita income, and financial education programs to foster financial inclusion among the unbanked and under-banked segments. Social Innovation Lab (SoIL) For its initial launch in 2016, it has sent 23 senior officers to work with three cooperatives in Negros province. For Anti-corruption and Anti-bribery:

The Bank puts the highest premium on sound, responsible and effective corporate governance and as such, it has enabled and equipped the Bank’s employees with a Code of Conduct, to combat risks in corruption and bribery. The Bank does not tolerate bribery, corruption or improper payments of any kind in all business dealings. Employees are expected not to offer, promise, give or authorize others to give anything in excess of a certain value, either directly or indirectly, to any client, person or entity for the purpose of corruptly influencing the recipient, secure an advantage, avoid a disadvantage or obtain or retain business.

Guidance on the Bank’s anti-corruption and anti-bribery program is captured more thoroughly in detail through its Standards on Conflict of Interest under Request or Acceptance of Fees, Commissions, Gifts.

The Bank also has internal policies in compliance with BSP regulations which provide rules of engagement for outsourcing/vendors to ensure that service providers and personnel do not violate any of the Bank’s rules and regulations, standards of conduct, policies, guidelines, work

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instructions and procedures, including the Conflict of Interest, anti-corruption and anti-bribery policies.

For creditors protection:

The Bank’s active engagement in support of safeguarding creditor’s rights is done through:

A holistic bank-wide and group-wide effort is made to ensure that consumer protection standards are not only embedded in the corporate culture of the Bank but permeate in all dealings with customers, creditors, etc, in the provision of products and services. These standards include:

1. Disclosure and Transparency The Bank ensures proper and full disclosure of terms and conditions and applies enhanced documentation and communication modes in the provision of products and services as well as customer service. This includes compliance with regulations and voluntary codes concerning product and service information and labeling as required, for example, by the Philippine Deposit Insurance Corporation (“Insured by PDIC up to P500,000”). It also includes securing clearance from the Advertising Standards Council (ASC) and Department of Trade and Industry (DTI) prior to release of advertising or promotional materials.

2. Protection of Client Information Security guidelines and protocols for client information are heightened, supported by appropriate employee management and training and IT security infrastructure. The Bank protects the privacy of clients in accordance also with Republic Act 10123, otherwise known as Data Privacy Act of 2012.

3. Fair Treatment The Bank also ensures the fair, honest and professional treatment of customers, creditors through the provision of affordable products and services suited to their needs and based on a good repayment capacity. Various support units also regularly issue notices through bulletins and circulars to proactively share information on customer availment of these products and services, procedural and documentary requirements and service rules. For the bank branches, customer feedback concerning our branches that passes through our

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Customer Care Department, is referred to Branch Service Rules, which reviews existing branch policy procedures to check if there are changes that can be made to improve service and attain customer and creditor satisfaction and convenience.

4. Effective recourse Customers and creditors are also afforded accessible, affordable, independent, fair, accountable, timely and efficient means for resolving complaints with their financial transactions. Venues and mechanisms for complaint handling and redress are in place.

The Bank strives to have a comprehensive and responsive customer feedback system. Customers and creditors easily dial 89-100 or send an email via BPI Express Online ([email protected]) to relay their complaints, inquiries or concerns on our products and services.

Customer feedback received by our BPI Contact Center is immediately forwarded by our Fulfillment Banking unit to the Customer Care Department (CCD), which is dedicated to attending and taking action on customer complaints. Other feedback channels include a personal visit to the concerned unit or department, letters to the department, and those sent directly to the Office of the President or to the Bangko Sentral ng Pilipinas.

5. Financial Education and Awareness The Bank includes financial literacy initiatives in the provision of products and services to customers, creditors to give them the knowledge, skills and confidence to understand the Bank’s products and services for proper evaluation and decision-making.

In addition to the aforementioned safeguarding measures for creditors or customers, the Bank also provides its institutional creditors or investors with protection through its full disclosure mechanisms in place and done through the Banks’ various information dissemination channels, Investor Relations, website, bank announcements at branches, etc.

For Anti-corruption and anti-bribery: The Bank’s active engagement in support of its anti-corruption programs and procedures is done through:

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All directors, officers and employees undergo trainings and briefings on the Bank’s various anti-corruption programs and procedures, i.e., Code of Conduct, Conflict-of-Interest, Related Party Transactions, etc.. New employees immediately undergo said trainings while continuing education is also provided through e-learning courses within the Bank’s intranet. Among others, the Bank’s policies on conflict-of-interest, insider trading, whistleblowers and other guidelines are embodied in the Bank’s Corporate Governance Manual and included in the Bank’s Management and Operating Manual and Personnel Policy Manual, each of which is recorded in electronic databases readily accessible for guidance of Bank employees. Aside from availability in these databases, Bank policies are regularly announced via internal email-facility to ensure constant top-of-mind awareness of the need to comply with these policies. These are also posted regularly where employees can be reminded of such on a daily basis, i.e., elevators. For creditors: Financial Consumer Protection Framework For 2017, the Bank tracked and monitored customer issues and feedback concerning its products and services (the table below shows the number of customer complaints we received for the past three years, and the number of customer transactions recorded for the same year). Action plans were implemented to ensure that the most pressing and important issues raised by customers were resolved within the committed turn-around times.

2015 2016 2017

Complaints (in thousands)

291.5 306.0 437.5

Transactions (in millions)

1,268.1 1,341.4 1,442

For investors and market:

As with our stockholders, we treat our investors as strategic partners for growth, and we are accountable to them for our long-term, engaged capital. We put a premium on ensuring prompt, timely and full disclosure

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to our investors, especially given the rapid evolution of the banking industry and the shifting structure of the financial markets.

We engage our investors through an investor relations program, carried out by our Investor Relations Office, whose responsibilities include:

• Reaching out to all shareholders to inform them of corporate activities; • Communicating the banks' direction, strategies, financial condition, and

operating performance to investors, shareholders, research and sales personnel of securities and investment houses;

• Timely reporting of corporate actions and financial performance in compliance with Philippine SEC and PSE rules;

• Quarterly updating of databases relative to financial performance; and • Serving as resource for publications and other external communication

initiatives of the bank's Corporate Communications office. The Company’s policy statement with respect to recognition and protection of the rights of key stakeholders is disclosed in the reports below, together with other relevant information. Links/Sources: BPI WEBSITE

Governance> “Role of Stakeholders” https://www.bpiexpressonline.com/p/1/807/role-of-stakeholders https://www.bpiexpressonline.com/p/1/808/clients https://www.bpiexpressonline.com/p/1/809/employees https://www.bpiexpressonline.com/p/1/810/suppliers https://www.bpiexpressonline.com/p/1/811/stockholders https://www.bpiexpressonline.com/p/1/812/minority-stockholders https://www.bpiexpressonline.com/p/1/906/environment-friendly-value-chain https://www.bpiexpressonline.com/p/1/813/investors https://www.bpiexpressonline.com/p/1/814/communities Governance> “Code of Business Conduct and Ethics” https://www.bpiexpressonline.com/p/1/806/code-of-business-conduct-and-ethics Sustainability https://www.bpiexpressonline.com/p/1/298/bpi-foundation-home

ANNUAL REPORT FOR 2017 https://www.bpiexpressonline.com/media/uploads/5b3c5e7d0bf95_BPI_IR_2017_Cultivating_an_Integrated_Approach_2.pdf

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C.1.7 Does the company have a separate report/section that discusses its efforts on environment/economy and social issues?

OECD Principle V (A): Disclosure should include, but not be limited to, material information on: (7) Issues regarding employees and other stakeholders. Companies are encouraged to provide information on key issues relevant to employees and other stakeholders that may materially affect the long term sustainability of the company.

Yes Sustainability/Corporate Responsibility Report: The Bank understands that sustainability reporting provides internal and external stakeholders with the non-financial information needed to understand the context that banks operate in today. BPI considers the most appropriate way to report its data externally, for example, within its annual report, in a stand-alone sustainability report, through its website or through Integrated Reporting. In 2014, BPI published a stand-alone sustainability report. In 2015 and 2016, the Bank adopted an integrated report. The Bank has adopted the standard/framework: G4 Framework by the Global Reporting Initiative (GRI). The Company discloses activities, data and information with respect to its activities on recognition and protection of the rights of key stakeholders in the reports below, together with other relevant information. Links/Sources: BPI WEBSITE

Who We Are Who We Are> “Awards” https://www.bpiexpressonline.com/p/1/760/awards Governance> “Role of Stakeholders” https://www.bpiexpressonline.com/p/1/807/role-of-stakeholders https://www.bpiexpressonline.com/p/1/808/clients https://www.bpiexpressonline.com/p/1/809/employees https://www.bpiexpressonline.com/p/1/810/suppliers https://www.bpiexpressonline.com/p/1/811/stockholders https://www.bpiexpressonline.com/p/1/812/minority-stockholders https://www.bpiexpressonline.com/p/1/906/environment-friendly-value-chain https://www.bpiexpressonline.com/p/1/813/investors https://www.bpiexpressonline.com/p/1/814/communities Governance> “Code of Business Conduct and Ethics” https://www.bpiexpressonline.com/p/1/806/code-of-business-conduct-and-ethics Sustainability https://www.bpiexpressonline.com/p/1/298/bpi-foundation-home

ANNUAL REPORT FOR 2017 https://www.bpiexpressonline.com/media/uploads/5b3c5e7d0bf95_BPI_IR_2017_Cultivating_an_Integrated_Approach_2.pdf

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C.2 Where stakeholder interests are protected by law, stakeholders should have the opportunity to obtain effective redress for violation of their rights.

C.2.1 Does the company provide contact details via the company's website or Annual Report which stakeholders (e.g. customers, suppliers, general public etc.) can use to voice their concerns and/or complaints for possible violation of their rights?

OECD Principle IV (B): Where stakeholder interests are protected by law, stakeholders should have the opportunity to obtain effective redress for violation of their rights. The governance framework and processes should be transparent and not impede the ability of stakeholders to communicate and to obtain redress for the violation of rights.

Yes For any issues and concerns, the Bank discloses on its website and annual reports, its regular customer service and venues for stakeholders to communicate directly with the Bank. For customer inquiries, comments or feedback, the Bank provides its 89-100 hotline as well as toll-free numbers providing local and international access (1-800-188-89100 for domestic toll-free calls (available to PLDT subscribers); and 63 + 2 + 89-10000 for mobile phone and international access). The Bank’s customer centers can also be contacted thru mobile (Text us your thoughts via SMS. Send FEEDBACK to 0917-8910000), electronic mail as well as social media sites. For specific concerns of stakeholders, i.e., suppliers, investors, etc. there are assigned contact persons as disclosed on the company website and on its annual report. Apart from providing online, telephone and mobile, email, social media, etc. touch points for any concerns, the Bank also has a Whistleblower Policy for reporting of violations or suspected violations or similar concerns. These contact details are all provided on the company website as well as through its Annual Report. Below are the disclosures of such contact details on the website and Annual Report: Corporate Information BANK OF THE PHILIPPINE ISLANDS 6768 Ayala Avenue Makati City 0720 Philippines (632) 818 5541 to 48 www.bpiexpressonline.com BPI Stock Transfer Office c/o Marian J. Machado 16/F BPI Building 6768 Ayala Avenue Makati City 1226 (632) 816 9898, 816 9068, 816 9067 [email protected]

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BPI Investor Relations Office c/o Rhodora M. Lugay 16/F BPI Building 6768 Ayala Avenue Makati City 1226 (632) 845 5944, 816 9333 [email protected] Office of the Corporate Secretary c/o Atty. Angela Pilar B. Maramag 19/F BPI Building 6768 Ayala Avenue Makati City 1226 (632) 816 9705 BPI Sustainability Office c/o Diane Faith S. Figueroa 16/F BPI Building, 6768 Ayala Avenue, Makati City 1226 [email protected] Customer Inquiries 89-100 or [email protected] Supplier, Creditor Inquiries 89-100 or [email protected] Media Inquiries Strategic Brand Management c/o Tricia Marie C. Quiambao 18/F BPI Building, 6768 Ayala Avenue, Makati City 1226 [email protected] Whistleblower Reports [email protected] The Company provides venues and contact details for stakeholders to communicate their concerns, disclosed in the reports below, together with other relevant information. Links/Sources:

MANUAL OF CORPORATE GOVERNANCE

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“Code of Business Conduct and Ethics”, “Whistleblower Policy”, Sec. III. A.-F., pp. 74-83, “Stockholders’ Rights and Protection of Minority Stockholder Interests”, Sec. VII., A.-B., pp. 91-93 https://www.bpiexpressonline.com/media/uploads/5ae94beaa7698_BPI_Corporate_Governance_Manual_030218.pdf

BPI WEBSITE Contact Us https://www.bpiexpressonline.com/p/0/112/contact-us Governance> “Business Conduct and Ethics>”Whistleblower Policy”, “Insider Trading Policy”, etc. https://www.bpiexpressonline.com/p/1/806/code-of-business-conduct-and-ethics Who We Are https://www.bpiexpressonline.com/p/1/776/about-bpi

ANNUAL REPORT FOR 2017 (Glossy) Corporate Information, A160-A161 https://www.bpiexpressonline.com/media/uploads/5b3c5e64d03f3_5b022be335f5a_2017_IR_Company_Information.pdf

ANNUAL REPORT FOR 2017 (SEC FORM 17-A) Bank operations towards client needs and satisfaction, Part 1, Item 1., A.(2), p. 8 https://www.bpiexpressonline.com/media/uploads/5b173c7a6c5a7_SEC17A_2017_PSE_Upload_FINAL.pdf

C.3 Performance-enhancing mechanisms for employee participation should be permitted to develop.

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C.3.1 Does the company explicitly disclose the health, safety, and welfare policies and practices for its employees?

OECD Principle IV (C): Performance-enhancing mechanisms for employee participation should be permitted to develop. In the context of corporate governance, performance enhancing mechanisms for participation may benefit companies directly as well as indirectly through the readiness by employees to invest in firm specific skills. Firm specific skills are those skills/competencies that are related to production technology and/or organizational aspects that are unique to a firm. Examples of mechanisms for employee participation include: employee representation on boards; and governance processes such as works councils that consider employee viewpoints in certain key decisions. With respect to performance enhancing mechanisms, employee stock ownership plans or other profit sharing mechanisms are to be found in many countries.

Yes For its Employees:

BPI discloses on its website, its Annual Corporate Governance Report and on various annual reports which are likewise posted on the company website and/or on PSE EDGE the Bank’s health, safety and welfare policies for its employees. Relevant information on all health, safety and welfare programs of the Bank are likewise regularly issued on company bulletins or broadcast through electronic mail to employees and made available on the company intranet database. These are as follows:

BPI strives to be an employer of choice by providing a safe, secure and conducive working environment for its employees. It continually safeguards their rights and provides equal opportunity for people to realize their fullest potential and make them agents of change for their communities. This drive to be recognized as an employer of choice leads us to implement best workplace practices and continue to engage our employees so that they in turn give our customers a more positive experience. Welfare Global institutions benchmarking corporate employee engagement initiatives have reported that the Bank has strength in three main employee engagement drivers: career development and opportunities, goal clarity, and leadership. The Bank has also introduced more initiatives to boost competency development among its officers and staff; worked to accelerate promotions; and identified the right metrics to better align human resource measures with corporate strategy. Moreover, it introduced a number of employee engagement to sustain or further boost employee commitment. Bank employees undergo regular performance evaluations based on their individual accomplishments vis-a-vis their responsibilities, as well as that of the business unit or the Bank. This takes into consideration our earnings performance, asset quality, business volume, customer satisfaction, and corporate governance, among other things. From 2015 onwards, career planning and progression has also been made faster – employees may now be promoted regardless of time in rank. Employees who have been at the same level for at least five years will be regularly evaluated for promotion. Promotion criteria have likewise been revised such that previous automatic disqualifiers (for example, tardiness) are now given

C.3.2 Does the company explicitly disclose policies and practices on training and development programmes for its employees?

Yes

C.3.3 Does the company have a reward/compensation policy that accounts for the performance of the company beyond short-term financial measures?

Yes

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due consideration in the promotion evaluation. Regular employees are also provided with a comprehensive pay and benefits package, which includes a quarterly bonus (inclusive of the required 13th month pay), overtime pay, and leave credits (vacation, sick, emergency, and maternity/paternity). Our compensation package is reviewed regularly. In 2015, the job levels of our information systems group were restructured and rationalized to compete more effectively with the compensation structure of the IT industry. Some non-cash benefits to the IT professionals were also monetized in line with industry practice. The Bank also extends the inherent benefits of being a financial institution by offering our employees and their families our products and services at affordable terms. These include low-interest rates for auto and housing loans, emergency loans, medical and group term insurance, salary and emergency loans. In addition, we provide financial security to employees even after their retirement from the Bank through our retirement benefit plan. The plan defines an amount that employees will receive which is dependent on the employee’s age, years of service and compensation. The Bank also continues to strictly comply with labor laws and regulations and implement best practices in our workplace. The Bank recognizes the existence of company union(s) and the rights to freedom of association and collective bargaining. The Bank does not discriminate on gender, religion, age, race, color, political stand or social background. It strictly enforces non-employment of minors and is against forced compulsory labor. We maintain harmonious relations with our labor unions. The Bank also has an open-door communications policy to address concerns among employees immediately before they escalate. As a requirement in their certification process, the Bank also trains and retrains security personnel, who are not formally part of our workforce and belong to third-party agencies, every two years on human rights-related topics. This is to ensure that they uphold the rights not only of our employees but also of our clients, suppliers and other stakeholders that do business with the Bank.

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The Bank also has various interest clubs to allow employees to pursue their passions and explore talents outside of work while building camaraderie and esprit de corp. The Bank also looks after its retiring employees through the conduct of annual seminars on estate planning, investment opportunities in the Bank and outside, and transition from being an employee to an entrepreneur. There are also counseling programs that help employees face life during retirement. The Bank’s off-boarding program has also been strengthened to further equip BPI retirees as they transition to the next chapter of their lives – among other improvements, processing of documents has been made more convenient and employees who are suffering from ailments may now advance a portion of their retirement funds to help defray medical expenses. Health The Bank believes it must create an environment where its employees have opportunities for development in tandem of their mind and body. Hence, the Bank provides a comprehensive medical program which provides for in-patient and out-patient benefits for employees and dependents. Year-round, there also are sports, recreational, health and wellness programs and physical activities, i.e., running, bowling, basketball, badminton, aerobics and dancing, etc., for all employees. We run education and training programs regarding serious illnesses. Examples of programs implemented are seminars on cancer awareness, prevention of stroke, and basic life support. Aside from health education, we also have risk-control programs in place to assist workforce members and their families regarding serious diseases. This was done through wellness fairs conducted in the head offices and provincial business centers where employees and their families avail of free or discounted services such as vaccinations, bone screening and physical examinations. Safety With regards health and safety of its employees, the Bank, as a matter of policy, ensures that all bank premises follow proper health and safety protocols, i.e., ban on smoking, ban on firearms, special access ramps for

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PWDs, pest prevention and more. Regular disaster preparedness activities are also conducted bank and group-wide (fire, earthquake, etc.) and frequent notices and reminders are broadcast regularly through the Bank’s intranet or posted where employees can easily read them. The Bank also has quality circles which regularly conduct audits and heighten awareness about best practices with regards workplace management towards health and safety. (Source: Management and Operating Manual, Personnel Policy Manual and Annual Reports) Continuing Education/Training and Development It is the Bank’s policy to continue to provide a range of training programs designed along the Bank’s business objectives. These development programs are aimed at honing the skills and capabilities of our employees in carrying out their daily duties, as well as preparing them to assume higher responsibilities as the next leaders of the organization. We use a blended learning approach that includes workshops, coaching/mentoring, instructor-led training sessions, and web-based training courses. We also design and facilitate leadership and management training programs for supervisors, functional managers, and senior managers to support our investment in leadership development. Mid-level officers take part in the BPI Leadership Excellence Acceleration Program (BPI LEAP). BPI LEAP has become a benchmark in training and development. By ensuring that our staff, specialists, and officers are trained, steeped in best practices, and exposed to an environment that nurtures continuous learning, we are able to provide the highest quality service to our customers. In general, the Bank’s Learning and Development program for our employees takes a holistic approach to learning and development and is categorized into the following training programs for everyone:

1. Leadership and Management Development – Programs that provide opportunities for BPI Leaders to develop their ability to lead, inspire and motivate their team members and organization. This would also cover Professional Effectiveness Programs that would develop Personal Leadership

2. Functional – Programs that develop and strengthen specific functional and technical competencies required from the individuals so they can

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perform their functional tasks effectively 3. Core and Team Effectiveness – Programs that would provide

foundational knowledge and competencies for any member of the BPI team. This would also cover programs and interventions for teams at BPI.

The Bank requires every employee to undertake a minimum of five training days every year, ensuring not only their continuous professional improvement but also their being updated on industry developments. For 2017, the Bank conducted, at least, 70 programs which allowed our employees to take, on average, about 2-3 trainings for the year. Here are some highlights of the recent trainings of the Bank:

Course Name Number of Trained Employees

2016 2017

Conflict of Interest 2,612 2,338

BPI Service Plus 2,511 2,183

Information Security Awareness Program

2,713 2,273

Money Laundering and Terrorism Financing Prevention Program

10,948 9,872

Risk Management Overview

1,356 2,453

Values Orientation Workshop

1,984 1,963

Reward/Compensation Policy beyond Short-term Financial Measures:

The Bank, in aligning management’s interest with shareholders, has an equity-linked incentive plan to its all its officers, including junior officers from Assistant Manager and up (with eligibility requirements): Executive Stock Purchase Plan (ESPP). A major initiative of the Bank under its long-term incentive program, the Executive Stock Purchase Plan (ESPP) was launched in 2013. The ESPP gives the officers the opportunity to buy shares of stock in BPI, at a discounted price based on the volume weighted average of BPI’s share price for the past 30 days. Management believes that this stronger alignment between the interests of BPI officers and interests of shareholders will benefit all stakeholders, i.e., more robust

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earnings and a healthier balance sheet will be reflected in a stronger and higher stock valuation. (Source: Human Resources Management Group)

The Company discloses activities, data and information with respect to its activities on recognition and protection of the rights of its employees in the reports below, together with other relevant information. Links/Sources: BPI WEBSITE

Governance> “Role of Stakeholders” https://www.bpiexpressonline.com/p/1/807/role-of-stakeholders https://www.bpiexpressonline.com/p/1/808/clients https://www.bpiexpressonline.com/p/1/809/employees https://www.bpiexpressonline.com/p/1/810/suppliers https://www.bpiexpressonline.com/p/1/811/stockholders https://www.bpiexpressonline.com/p/1/812/minority-stockholders https://www.bpiexpressonline.com/p/1/906/environment-friendly-value-chain https://www.bpiexpressonline.com/p/1/813/investors https://www.bpiexpressonline.com/p/1/814/communities Governance> “Code of Business Conduct and Ethics” https://www.bpiexpressonline.com/p/1/806/code-of-business-conduct-and-ethics Sustainability https://www.bpiexpressonline.com/p/1/298/bpi-foundation-home ANNUAL REPORT (Glossy), (Note 19 of Audited Financial Statements), pp. (29-30) https://www.bpiexpressonline.com/media/uploads/5b166398df617_BPI_IR_2017_AFS_A1.pdf

ANNUAL REPORT 17-A Bank policies on its employees and activities in their support, ESOP: Part 1, Item 1., A., 1., p. 19, (Note 19 of Audited Financial Statements), pp. (29-30) https://www.bpiexpressonline.com/media/uploads/5b173c7a6c5a7_SEC17A_2017_PSE_Upload_FINAL.pdf

C.4 Stakeholders including individual employee and their representative bodies, should be able to freely communicate their

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concerns about illegal or unethical practices to the board and their rights should not be compromised for doing this.

C.4.1 Does the company have a whistle blowing policy which includes procedures for complaints by employees and other stakeholders concerning alleged illegal and unethical behaviour and provide contact details via the company's website or annual report

G20/OECD Principle IV (E): Unethical and illegal practices by corporate officers may not only violate the rights of stakeholders but also be to the detriment of the company and its shareholders in terms of reputation effects and an increasing risk of future financial liabilities. It is therefore to the advantage of the company and its shareholders to establish procedures and safe-harbours for complaints by employees, either personally or through their representative bodies, and others outside the company, concerning illegal and unethical behaviour.

Yes The Bank established and supports a Whistleblower Policy and program, an important mechanism for preventing and detecting fraud or misconduct, and enabling fast and coordinated incident responses as we establish cause, remedial actions, and damage control procedures. The Bank remains committed to integrity and ethical behavior by helping to foster and maintain an environment where all personnel can act appropriately without fear of reprisal and be treated with utmost confidentiality. A separate and distinct reporting and investigation process beyond the normal reporting lines are in place. Any violation of the bank’s policies and procedures may be reported in writing, in person or through a dedicated and confidential BPI e-mail that has been established for this purpose.

The Policy covers all employees of the BPI group and all wrongful acts that adversely impact the Bank and its stakeholders.

Under the Policy, it is the responsibility of all personnel to comply with the rules and regulations of the BPI group and to report violations or suspected violations in accordance with the Whistleblower Policy. Anybody who knowingly aids, abets, or conceals or otherwise deliberately permits the commission of any irregular or fraudulent act directed against the BPI group shall be considered as guilty as the principal perpetrators of the fraud or irregularity. Hence, all employees of the BPI Group have a duty to cooperate with investigations initiated under the policy.

The policy also presumes that the employees of the BPI group act in good faith and will not make any false accusations when reporting the wrongdoing done by another employee. An employee who knowingly or recklessly makes statements or disclosures that are not in good faith shall be subject to disciplinary action/s, which may include termination.

(1) Employees can report any violation of policies, procedures and applicable laws and regulations which include, but are not limited to, the following: Fraud, Sexual Harassment, Theft, Stealing, Conflict of Interest Information Security Violation, Violation of Bank Policies, Rules and Regulations and any other acts which are inimical to the

C.4.2 Does the company have a policy or procedures to protect an employee/person who reveals illegal/unethical behaviour from retaliation?

Yes

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interests of the BPI group.

(2) The whistleblower may approach any of the following Officers who shall be the designated contacts for the Bank and the primary reporting line:

a. Head of Human Resources Management Group (HRMG) or

b. Chief Internal Auditor or

c. Chief Risk Officer

Under extraordinary circumstances, the whistleblower can also course the complaint through other reporting lines (President or Chairman of the Bank's Audit Committee).

(3) Upon receipt of the whistleblowing report, the Personnel to whom the report was disclosed shall then immediately initiate the investigation upon receipt of the report by turning over the details, documents, if any, of the reported case to the Investigating Unit of the Bank.

(4) The investigation of the whistleblowing report shall follow the due process as stipulated in the standards in handling fraud and irregularities.

Under the Whistleblower Policy, there are provisions on non-retaliation:

(1) An individual who makes a "protected disclosure" shall not suffer harassment, retaliation, or adverse employment consequences. Any person who retaliates against any individual who makes a protected disclosure shall be subject to discipline up to an including termination.

(2) The right of a whistleblower for protection against retaliation does not include immunity for his/her wrongdoing or participation in the reported irregularity and such participation was eventually verified and proven during the course of the investigation.

(3) In case the whistleblower believes he has been retaliated against for whistleblowing, he may seek redress or file a formal complaint to the HRD Group Head, Chief Internal Auditor, or the Chief Risk Officer.

The Bank’s Code of Conduct also encourages employees to report any unethical behavior or activities, following the Whistleblower Policy.

(Source: Human Resources Management Group, Code of Business Conduct

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and Ethics, Personnel Policy Manual, Manual of Corporate Governance and Company website) Information on the Whistleblower Policy, supporting procedures and appropriate infrastructure as well as the Bank’s stance of active engagement with its employees and all other stakeholders to allow them to communicate their concerns or complaints without fear of retaliation, as disclosed in the reports below, together with other relevant information. The Whistleblower Policy and procedures, including contact details, are disclosed in the Annual Report as well as the company’s website. Links/Sources: MANUAL OF CORPORATE GOVERNANCE

“Code of Business Conduct and Ethics”, “Whistleblower Policy”, Sec. III. A.-F., pp. 74-81, “Stockholders’ Rights and Protection of Minority Stockholder Interests”, Sec. VII., A.-B., pp.91-93 https://www.bpiexpressonline.com/media/uploads/5ae94beaa7698_BPI_Corporate_Governance_Manual_030218.pdf

BPI WEBSITE “Contact Us” https://www.bpiexpressonline.com/p/0/112/contact-us Governance> “Business Conduct and Ethics> ”Whistleblower Policy”, “Insider Trading Policy”, etc. https://www.bpiexpressonline.com/p/1/806/code-of-business-conduct-and-ethics Who We Are https://www.bpiexpressonline.com/p/1/776/about-bpi Governance> “Role of Stakeholders” https://www.bpiexpressonline.com/p/1/807/role-of-stakeholders https://www.bpiexpressonline.com/p/1/809/employees