March 13, 2019

Code of Business Conduct and Ethics a template for Holy Gardens

PAGSASANAY SA TAGUMPAY For kaizen reports: You must post pictures under this template duly classified. Answer and provide pictures for all headings. COMPLY AND UNDERSTAND. 1. Pics of office (storage, files)/chapel, cr. Also post pictures of your staff in complete uniform daily with id for am talk) STRICT COMPLIANCE 2. Pics of site (the park) beautification/construction 3. Pics of warehouse inside and outside; SHOW INVENTORIES AND LOCKS 4. Pics of inventory of equipment (especially of those non operating) and materials 5. Pics of operational equipment

We  benchmarked   Aboitiz Code of Business Conduct and Ethics,  We have a code that is truly ours and reflect the leaders thinking and the rest of the group

Memorandum:

To   All

Subject:   Amendment of our Code of Conduct and Discipline

Date:   March 13, 2019.

Amendment,upgrading of our Code of Conduct and Discipline  V.3

Our Code of Conduct and Discipline is hereby upgraded to include offenses which are blatantly being disregarded by many of our staff, they being not there.  We intend to make  our CCD more inclusive and exhausttive and intend to pursue this strictly.  As of now, these have been disregarded and not implemented well, hence the low state of morale and performance

Amended Code of Conduct and Discipline


                                  CODE OF ETHICS AND BUSINESS CONDUCT
                                                     for Holy Gardens Group

Background:  and explanatory note

     A corporation is a fiction and a creation of law. Corporations have been most successful in the history of men in creating new products and wealth;  governments which tend to be compromising and are engaged in politics hamper the governments achievement of goals

     Men run it as an organization and it can only be good and bad as the men who are in it:  those who are leading and managing this  and the  people who follow the leaders and managers.  It is a simple proposition if the men who are in it:

                       1.  Are passionate
                       2.  Have integrity and are honest;
                       3.  Have good manners and right conduct and good values... (can be learned in kindergarten)

    This rests on  foundation of good moral values, fear of God and his commandments, a strong sense of being a good citizen ie love of country and fellow men

    We are Gods stewards of his creation and we are held responsible to use our gifts to multiply these resources for the good of all and not for us alone.  We are held accountable for our actions.  With our talent and leadership, we can make this world a better place here and now:   lessen pain, suffering, and poverty.  We can leave our legacy as good men here an now and not when are dead.  When we are dead, we are dead.

      The purpose of this code is to enable the organization the  corporation follow a codified collection of behavior processes and policies to achieve a common goal  -  a team to win and beat competition.  But people who are in it come with various backgrounds:    internal :  heredity, level of motivation, tendencies,  and external:  environment, family education,  work experience.  Thus they come in with their own set of value and principles and highly visible when they start talking about past jobs while under the employ of the present organization


   Even highly educated people lack integrity even from Ivy schools;  many companies complain of MBA graduates who are not only incompetent but are crooks.  Blame this on the original sin.  Blame this on selfishness  and indolence (laziness) which many claim are the root of evil... In  the organization if the bad practices persist or the incumbent bring in practices from other organization, and other value  system, chaos and disorder ensues.  Bad values of people can destroy corporate values (wealth creation process)

    In an existing organization departments and functions become too enamored with their daily tasks and their function to the detriment of the corporate goals, become misaligned, and disagreements and quarrel come as result.  The purpose of this code is to come together, to work together and that means success.

    We can not let the sense of good and bad in organization be left to chance.  That is why we have the People Department we have training and endless stream of communication from memos, websites and am talk to remind people of our code, system and values.  We have this manual, the CCD, MC Chart of Accounts with the corresponding accounting system for people to subscribe to..

That would be easier if there is a uniform level of hearing, understanding, acceptance from all people.  It is a lot easier if people empty their cups (sunnao) and practice the

           3 fold duty of an employee:     obedience, loyalty and diligence

          ABCD doctrine   -   ACCEPT BELIEVE COOPERATE AND DANCE WITH THE MUSIC



I. Objective 

   We have this code:

    1.  To be aligned with our vision and still maintain to be good citizens men and women
    2.   To ensure our success as corporate organism;
    3.   To continue to be a good citizen of this country and children of God.

II. Coverage


The Code of Ethics and Business Conduct covers the HGMP Group: Memorial Park Group, (the SBUs) Crematorium Columbarium Chapel Services, and Memorial Plans

III. Purpose 

   The purpose of this Code of Ethics and Business Conduct (the “Code”) is to set basic principles to guide you in your day to day activities as an employee (including those who work part time or on fixed or temporary contracts), supplier or contractor,   officer or director of  Holy Gardens Group  and its group of companies  It should be read together with other Company policies and procedures. It does not cover every legal or ethical issue that you may encounter. We  can not  attempt to anticipate the myriad issues that arise in a business as diverse and dynamic as that of the Company.

    However, by following this Code and  HGMP Group policies and procedures, by adhering to the letter and the spirit of all applicable laws and regulations, and above all, by applying sound judgment to your activities, you can demonstrate your commitment to the  Holy Gardens  Group of CUSTOMER SERVICE, EXCELLENCE, LEARNING, AND CHANGE It is  also expected that  customers,  suppliers, business partners and joint venture partnerships to follow the principles of the Code and practice the highest ethical standards when dealing with the companies within the HGMP Group.

The important operational words for us to abide with this Code are:

        1.  FOCUS
        2.  ATTENTION
        3.  REVERENCE
        4.  UNDERSTANDING
        5.  COMPLIANCE


IV. Core Values of  Holy Gardens Group

Our Core Values identify us and reflect how we behave as corporate citizens. giving capable and intelligent direction in the  management of the business  We keep our word.   We believe that customers are key and paramount to business success,they pay our wages.  . We are process oriented.  We work hard as professional,  We are accountable for our actions and their consequences.  We believe in excellence and we a multi-disciplinary approach to achieve our business goals. We work interdependently while promoting cooperation and mutual respect.

We learn one new thing a day.  We believe in shared learning.  We encourage our people to learn one new thing a day by reading books,  keeping  journal of things learned, and  reflecting daily on how he can be better than before and others,  

We constantly look for better ways to provide efficient systems, quality services and products because we believe in change for the better  and excellence

Responsibility: We adhere to good corporate governance (this is dictated by Security and Exchange
                          Commission, the creator of corporations

1.  We provide intelligent and capable direction in the governance of this business

2.  We want to be efficient and effective in the management of our resources:  money, manpower, methods and materials and equipment

3.  "We recognize the impact of corporate activities in the community where we operate. We advocate sustainability and caring for our environment.  We attempt under various advocacies to return the  blessings we have received from society and environment

4.   We create more wealth to create more jobs and employment
       This is an  important task because alms giving only give a meal to a person, but giving jobs and giving employment create hope and lessens poverty.  As we recruit agents so that they will earn money, as we create more products and services and more companies to continue providing employment to many.
        It is not about making more money;  it is about helping others who are impoverished or those who have problems.

5.    We  create wealth for  for all our stakeholders, ensuring they have a fair share of the value creation we are involved in.  We engage in wealth creation activities that are legal, fair and within bounds of ethical business practices.


 V. The Guiding Principles of the Code 

1.  Honesty and integrity
2.  Hard work
3.  Keeping our word
4.  Caring for each other and malasakit for the company
5.  Treating each other with respect and being true to oneself
6.  Obedience, discipline, and determination

VI. Commitment to Compliance:

      Follow both the Letter and the Spirit of the Law and the Company Policies

      As a company involved in real estate development and regulated by various government agencies, and with Lending Investor and Memorial Plan companies.  all  companies under the Holy Gardens Group are subject to numerous laws and regulations. It is your responsibility as director, officer or employee to know and understand the laws applicable to your job responsibilities and to comply with both the letter and the spirit of these laws. This requires that you avoid not only actual misconduct but also even the appearance of impropriety. Assume that any action you take ultimately could be publicized, and consider how you and the Company would be perceived. When in doubt, stop and reflect. Ask questions; speak up. You are strongly encouraged to discuss freely any concerns. In particular, if you are unclear about the applicability of the law to your job responsibilities, or if you are unsure about the legality or integrity of a particular course of action, you should seek the advice of your (a) supervisor; (b) the Legal and Compliance Services Team; (c) the People Office  or (d) the Chief Compliance Officer. You should never assume that an activity is acceptable merely because others in the industry engage in it. Trust your instincts—if something does not appear to be lawful or ethical, it may not be.

    You are duty bound also to comply with existing laws and policies, practices and processes of the company and likewise ask the same from other co workers

      Read, understand, and obey... COMPLY


VII. Commitment to Each Other: Dealing with Team Members 


    A. Treat Team Members with Respect and Dignity Consistent with our core values, and in respect of individuals and diverse cultures, the Holy Gardens  Group is committed to a workplace in which all individuals are treated with dignity and respect. Each individual should have the ability to work in an environment that promotes equal employment opportunities and prohibits discriminatory practices and activities, including harassment. Therefore, it is expected of all directors, officers and employees to ensure that all inter-relationships among persons in the workplace will be professional and free of bias, harassment bullying  or violence. Every one should think  unselfishly to make others successful.  No one should through his maneuvering or laziness or incompetence make the job of others hard... Any misconduct, including discrimination, gossips,, intrigues, false fake news about co workers, dishonesty, plagiarism, quarrelling, power play, turf battle, politics, negligence in the job, not putting in enough work in the day,  harassment, retaliation or other forms of unprofessional behavior, even if not unlawful, may subject you to disciplinary action, up to and including termination. In addition, conduct that is unlawful may subject you to civil, and in some cases, criminal liability.

ACT PROFESSIONALLY.  BE CIVIL

B. Promote a  Clean, Orderly, Safe and Healthy Working Environment

      The Holy Gardens  Group is committed to conducting its businesses in compliance with all applicable environmental and workplace health and safety laws and regulations. Employees:  officers and staff are enjoined to take responsibility for the workplace cleanliness and to CLEAN AS YOU GO IN, PRACTICE 5S AND TPM IN THE  THE ABSENCE OF JANITORIAL OR MAINTENANCE STAFF (cleaning and maintaining their own equipment and tools)   It strives to provide a safe and healthy work environment for employees and to avoid adverse impact on and injury to the environment and communities in which it conducts its business. Achieving this goal is the responsibility of all directors, officers and employees.

REMEMBER 5S


VIII. Commitment to our Stakeholders: Dealing with Customers, Suppliers, Business Partners and the Public

      A. Fair Dealing The Company values the contribution of its clients, business partners, suppliers and other stakeholders as it strives to achieve its corporate mission and vision. In recognition of the contributions of its valued shareholders, the Company is committed to engage in fair practices when dealing with them. Suppliers should be paid promptly and fairly We can not quarrel with customers JV partners (unless they are)  They are stakeholders of the company and our success depend on their continued support

     The Holy  Gardens  Group seeks to outperform its competition fairly and honestly through superior performance. Every director, officer and employee must therefore always keep the best interests of the Company’s customers  paramount and endeavor to deal fairly with suppliers, competitors, the public and one another. No one should take unfair advantage of anyone through manipulation, abuse of privileged information, misrepresentation of facts or any other unfair dealing practices, and or greasing favors with any one in power

BEING PART OF A COMMUNITY

B. Gifts and Entertainment

     Gifts and entertainment may create an inappropriate expectation or feeling of obligation. You and members of your family are discouraged from accepting gifts or special favors (other than an occasional non-cash gift of nominal value) from any person or organization with which the Company has a current or potential business relationship. Furthermore, business gifts to, and entertainment of, customers, suppliers and business partners in connection with business discussions or the development of business relationships are only appropriate if they are in the ordinary course of business and their value is modest. Care must be exercised when giving gifts or extending hospitality to avoid being perceived as trying to influence a decision or outcome.

C. Bribery and Corruption 


      The Group conducts its business in an ethical manner at all times and in compliance with applicable laws and regulations, including laws on bribery and corruption of jurisdictions where it conducts its businesses. As an officer, employee or agent acting on behalf of the Company or any of its group companies, you are expected to act professionally, fairly and with integrity in all of your business dealings and shall endeavor to ensure compliance with this Code in order to counter bribery and corruption.  Tong pats being practiced by Accounting GT or engaging in maintenance of plots as sideline is prohibited.

D. Provide Fair and Truthful Disclosures to the Public 

       The Company has a responsibility under existing laws and governance to communicate effectively so that its stakeholders and the public are provided with full and accurate information in all material respects. To the extent that you are involved in the preparation of materials for dissemination to the public, you should be careful to ensure that the information in these materials are truthful, accurate and complete. In particular, the Company’s senior financial officers, executive officers and directors shall endeavou to promote full, fair, accurate, timely and understandable disclosures in the Holy  Gardens Group of companies’ public communications, including documents that the Company files with or submits to the Securities and Exchange Commission and other regulators. If you become aware of a materially inaccurate or misleading statement in a public communication, you must report it immediately to the Office of the Corporate Secretary, Corporate Information Officer, Chief Compliance Officer or the Board Audit Committee of the Board of Directors of AEV.


 IX. Commitment to the Group: Advance and Protect the Company’s Interests 

     A. Corporate Opportunities You owe a duty to the Company to advance its interests. No director, officer or employee may use their position or corporate property or information for personal gain; and no director, officer or employee may take for themselves company opportunities for sales or purchases of products, services or interests. Business opportunities that arise as a result of your position in the Company or through the use of corporate property or information belong to the Company.

BEING LOYAL


B.  Proprietary and Confidential Information 

     Proprietary and confidential information generated and gathered in our business is a valuable Company asset. The protection of this information is critical to the Company’s reputation or its integrity and its relationships with its clients, and in doing so, ensures compliance with the complex regulations governing the financial services industry and other industries in which the Company has presence and business activities. Accordingly, you should maintain all proprietary and confidential information in strict confidence, except when its disclosure is authorized by the Group or required by law. For this purpose, each employee shall undertake to sign a nondisclosure agreement as part of its commitment to the Company. “Proprietary information” includes all non-public information that might be useful to competitors or the disclosure of which could result in damages to the Company, its customers or stakeholders. It includes, for example, intellectual property rights, business plans, personal employee information and unpublished financial information. You should therefore, also respect the intellectual and other property rights of other companies. “Confidential information” of the Company include those with whom the Company has a confidential obligation, information about  Holy Gardens group, its subsidiaries and its clients that is generally not known to the public, or information obtained from other parties with whom the Group has a relationship with and would have an expectation of confidentiality. The unauthorized use or distribution of proprietary or confidential information violates Holy Gardens  policy and could be illegal. Such use or distribution could result in negative consequences for both the Company as well as the individuals involved, and could merit potential legal and disciplinary actions. Your obligation to protect the Group’s proprietary and confidential information continues even after you leave the Group. You must return all such information in your possession upon your departure or termination of employment

"A FISH IS HOOKED FROM ITS MOUTH"
THE  VIII COMMANDMENT  - "Thou shall not steal"

 C. Company Systems and Assets 


    The Company policies regulate the use of its telecommunication and mixed media communication systems, including telephones, computer networks, electronic mail and remote access capabilities. These systems and properties should generally be used only for legitimate company business and activities. Under no conditions may you use these systems to view, store, or send unlawful, offensive or other inappropriate materials. Or even alter such systems and processes without prior consultation of approval.   You may obtain copies of  HGMP policies from the Human Resources Department. In addition, protecting the Company’s assets against loss, theft, waste, or other misuse is the responsibility of every employee, officer and director. Any suspected misuse should be reported to your supervisor or to the Chief Human Resources Officer of HGMP

    Company assets must be subject to safekeeping, security procedures, maintenance, inspection,  labeling and constant inventory and regular report monitoring and/or visual inspection and subject to photos and or CCTV monitoring. .   Assets that are to be used by employees and staff are subject to MR and clearance are required from resigning employees to recover assets and indebtedness;    Fidelity bond and references and clearances are required from all
recruits to prevent losses of assets.  New comers are not to be given fiscal responsibilities when newly hired

PARABLE OF THE TALENTS;  MULTIPLYING THE GIFTS ASSETS THAT GOD HAS GIVEN YOU

D. Prevent the Misuse of Inside Information 

   Using inside information to trade securities, or to “tip off” a family member, friend or any other person, is illegal. All non-public information about Holy Gardens , the Group or its clients or counterparties that may have a significant impact on the price of a security or other financial instrument, or may influence a reasonable investor to likely consider important in making an investment decision, will be treated as inside information. As employee, you may never, under any circumstances, trade, encourage others to trade, or recommend the trade of securities or other financial instruments based on (and in some circumstances, while in the possession of) inside information. The misuse of inside information may result in disciplinary action by the Company, up to and including termination of your employment. Misusing inside information may also end any career in the securities industry and result in civil and criminal penalties, including imprisonment. To protect against insider trading or even the appearance of insider trading, HGMP has strict policies governing directors, officers and employees trading, which vary depending upon your position and where you work at HGMP  or in the companies under the Group. You are required to familiarize yourself and comply with these policies. If you have any questions about your ability to buy or sell securities, you should contact the Legal and Compliance Services Department.

E. Conflicts of Interest 

   All directors, officers and employees have an obligation to act in the best interests of the Company. You should avoid any activity, interest, or association outside the Company that could impair your ability to perform your work objectively and effectively (including spending Company time or other business endeavours) or that could give the appearance of interfering with your responsibilities on behalf of the Company or its clients. It is not possible to describe every situation in which a conflict of interest may arise.

We always seek the best prices and relatives or friends recommendation or pressure should not be entertained in purchasing process.

 Being a supplier of company, or working for competitor, or engaging in sidelines are conflicts of interest;  passing off office sales to agents is a conflict of interest     Sidelines may be engaged to that are not in conflict with the company business need prior approval.

The following, however, are examples of situations that may give rise to a conflict of interest (unless permitted by law and the Group’s policies):

• Accepting special favors as a result of your position with the Company from any person or organization with which the Company has a current or potential business relationship.

• Competing with the Company for a purchase or sale of property, services or any dealings or transactions where the Company has an interest or other interests.

• Acquiring an interest in a transaction involving the Company, its customer, or supplier (excluding routine investments in publicly traded companies).

• Receiving a personal loan or guarantee of an obligation as a result of your position with the Company (other than Company loans enjoyed as employee benefit).

 • Working for a competitor while an employee of the Company.

• Directing business to a supplier owned or managed by, or which employs, a relative or friend. Employees and officers should promptly report any potential relationships, actions or transactions (including those involving family members) that reasonably could be expected to give rise to a conflict of interest to the Human Resources Department of your company.

 Involvement in certain outside activities may also require the prior approval of the Company (particularly if you are a licensed person). You should consult policies applicable to your business unit or division for specific reporting and approval procedures. Directors should also disclose any actual or potential conflicts of interest to the Chairman of the Board of Directors and the Compliance Officer of your respective companies, if applicable, who shall determine the appropriate resolution. All directors must recuse themselves from any Board discussion or decision affecting their personal, business or professional transactions and interests.

Our business dealing with the government officials, instrumentals must not violate Anti Graft and Corrupt Practices act and in conformity with Code of Conduct and Ethics for Government Officials


 F. Maintain Accurate Books and Records 

     The Company must maintain accurate and complete books and records which are critical to the Group’s decision making process and compliance with external reporting, legal requirements and existing accounting standards. Every business transaction undertaken by HGMP  must be recorded correctly and in a timely manner in its corporate books and records, including gifts and hospitality extended to business partners.

     Reports must be submitted on time, and are to be accurate : must have been checked by the maker and a supervisor before passing.  All reports must be submitted as required.  The Company therefore expects you to be prompt, candid and accurate when providing information for these documents. You are specifically prohibited from making false or misleading entries in the corporate books and records. In particular, senior financial officers must endeavor to ensure that financial information included in the corporate books and records is correct and complete in all material respects; neither must errors put the company in bad light to the public and regulators

     Documents that are due to the customers are to handled accurately and promptly;  not doing so is a bad business practice that drives away customers and violates certain laws and may even be prosecuted criminally.

     Reporting to govt officers that need punctuality as that of SSS, Pag Ibig and BIR must be done promptly because delayed or non payment is not mere administrative over sight but criminal..


G. CLEAR  AND CONSTANT COMMUNICATION

           Communication is the key and foundation for company functioning and coordination. Without
      proper communication, the company operations can be dysfunctional and even paralyzed.

     The company has adopted communication policies in the hand book which must be complied with
      regarding cell phones and email.  All staff are enjoined to follow the lines of communications
      direct reports and to depend on formal lines of communications rather than hearsays...  If did not
      come from the superior or not in writing then it is not be believed.   Employees and staff are
      enjoined not to engage in social media diatribe and gossip grape vine...Employees who are
      distant in the sbu must report to the direct reports constantly and initiate such communication.

      All staff must READ REFLECT, UNDERSTAND REALIZE  ACT AND CHECK  all commu-
       nication posts and emails.     All staff must be reachable by their cellphone albeit personal and
       must respond when called even at home or off.

      All employees are enjoined to read the Community site as their bulletin board for announcements,
      read emails daily and respond ASAP.  Employees email accounts are that of the company, the
      pass word are to be kept in custody by the supervisors and HR.   All employees must keep
      accurate file of all communications memo and remember all of them to avoid work accidents
      and problems


X. Commitment to the Environment and our Communities: A Sustainable Business 

    The Company believes that a good company does good. , always making the right long-term decisions that balance interests of people, planet and profit. We are stewards of this earth as directed by the scriptures (Genesis 1:28 and parable of talents) We are in business to do good.  We are here to stay in the service of others as we sell and provide products for the community which they need and which will be useful for their daily lives.  When we develop or do business we do our best in the core business to help the people:  (not by CSR alone) by let us say selling affordable products, to the indigent, and not be concerned with unjust profits alone.   do its best to minimize any environmental impact that may result fr.om our decision and actions. We have advocacies for tree planting to minimize global warming, helping build schools, helping the orphans and senior citizens.

     We even have generous unbelievable discounts for PWD and senior citizens The Company manages its operations well and utilize resources prudently to achieve financial growth and profitability. and encourage its staff and officers to be resourceful rather than resource oriented...

XI. Enforcement and Administration of the Code 


     A. Implementation of this Code This Code applies to everyone equally, whether you are a director, an officer or an employee of the Company. You are therefore expected to read and follow this Code as well as the implementing policies that may have been prepared to help you further understand this Code. If you are a team leader, you have to ensure that your team members have received the required training which they need to understand their obligations and responsibilities. The Company’s People Assistant/Officer  is responsible for disseminating the contents of this Code to existing and new directors, officers and employees of the Company through the new hires’ orientation (NHO) and other trainings, and by making this Code and other policies available in the Company portal for easy access. Upon completion of the NHO, attendees are required to sign the personal commitment form of this Code which serves as an acknowledgment that such attendee understood and agrees to abide with the principles of this Code. The Human Resources Department shall annually require all directors, officers and employees to declare that they have complied with this Code.

      B. Reporting Violations

You are the Company’s first line of defense against unethical business practices and violations of the law and this Code. If you observe or become aware of any conduct that you believe is unethical or unlawful—whether by another employee, a consultant, supplier, client, or other third party—you must communicate that information to your direct supervisor or, if appropriate or necessary, senior management or to the Company hotline found in the Company portal. They will notify and consult your direct supervisor or the People Assistant /Officer of Holy Gardens  The People Assistnat  of your company shall be responsible for investigating any violations of this Code and imposing sanctions thereof in accordance with the existing and applicable policies.

If you are a supervisor, you have an additional responsibility to take appropriate steps to stop any misconduct that you are aware of or become aware of, and to prevent its recurrence. Supervisors who do not take appropriate action (nagtatakip) may be held responsible for failure to supervise properly.This is command responsibility.   If you prefer to report an allegation anonymously through the Company hotline, you must provide enough information about the incident or situation to allow the Company to investigate properly. The Company will not tolerate any kind of retaliation for reports or complaints regarding the misconduct of others that were made in good faith. Open communication of issues and concerns by all employees without fear of retribution or retaliation is vital to the continued success of the Group. Unless the appropriate Company management learns of a problem, the Company cannot deal with it. Concealing improper conduct often compounds the problem and may delay or hamper responses that could prevent or mitigate actual damage.


C. Consequences of Violating the Code

    If  you are an employee or officer, this Code forms part of the terms and conditions of your employment with the Company. Directors, officers and employees are expected to cooperate in internal investigations of allegations of violations of this Code, and actual violations may subject you to the full range of disciplinary action by the Company. Your company may also report certain activities to its regulators, which could give rise to regulatory or criminal investigations. The penalties for regulatory and criminal violations may include significant fines, permanent bar from employment in the securities industry and, for criminal violations, imprisonment.


D. Review and Amendments

    If the Company shall develop and annually review this Code, including such policies and procedures by which the companies under the HGMP Group will operate to ensure their continued adequacy and relevance to the evolving business, legal and regulatory environment. Any amendments to this Code and related policies and procedures must be approved by the Board of Directors of HGMP Inc. It is your responsibility to be familiar with the Code and all applicable policies and procedures as these may be revised from time to time.


XII. A Personal Commitment 

A truly great, visionary company continuously lives and defends its core values. Only by doing so can the Company realize the potential of its constituent parts and the talents of its people around the world. To reaffirm to the Company and to the Group your commitment to integrity, teamwork, innovation and responsibility, the Company requires that you complete the following acknowledgment. I acknowledge that I have read the Code of Ethics and Business Conduct and understand and agree to abide by its requirements. If I have a concern about possible misconduct, I will raise  the concern with appropriate persons.  I understand the Code is not a contract guaranteeing employment

Signature   _______________________

Date: ___________________________

X Records

    Non Disclosure statement

Added:  3/16/2019   new


                           

General Code of Business Conduct and Ethics benchmarked and paraphrased from AEV 3/13/2019

     


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