Company Policies

CODE OF BUSINESS CONDUCTS & ETHICS

Code of Business Conducts and Ethics guides the Directors, senior management and employees in the conducts of their business, dealings, actions and decisions that must be in compliance with principle of good governance. It should be aligned in the principle of integrity, core values, honesty, fairness, professionalism, team cooperation, with concern in the company they work for, for the company’s sustainability.

CONFLICT OF INTEREST

For the Directors to conduct himself in a manner that consist of taking advantage of his position in a transaction. He must not act for his own interest but for the interests of the beneficiaries of the trust, the corporate shareholders, and his clients. He must avoid any act of self-dealing which include misappropriation or usurpation of corporate assets or opportunities.

All members of the senior Management are expected to avoid any transaction that would lead to a conflict of interest or any transaction that could sow a seed of doubt as to their loyalty to the corporation. They must also avoid any act of self-dealing as it is considered wrongful conduct. The members of the senior management are expected to be persons who act in Good Faith and maintain trust, special confidence, and candor in their dealings with other persons. They are expected to disclose to a higher management official any probable conflict of interest that may arise.

Employees are expected to avoid any transactions that would sow a seed of doubt of conflict of interest. They must also avoid any self-dealing transactions as it is wrongful conduct. They must maintain to be a person who has duties of Good Faith, trust, special confidence, and candor toward another person. Disclosure to a senior management official is expected in case that probable conflict of interest will arise.

CONDUCT OF BUSINESS AND FAIR DEALINGS

The Directors of the corporation are expected to conduct fair business transactions with the corporation. They must also ensure that they act for the benefit and best interest of the corporation and not for their personal gain. Further, it is expected that the directors will devote their time and attention in the proper and effective performance of their duties and responsibilities.

The company commits itself to the achievement of growth and development. It seeks to be a catalyst for growth and development and to be an active partner in creating wealth and enriching the lives of many people in the host community. It also pledges to be a good corporate Taxpayer by adhering religiously to all governmental laws, rules and regulations.

Employees are expected to conduct business in a manner consistent with the company’s commitment to the achievement of growth and development. The company, through its employees, seeks to be a catalyst for growth and development and to be an active partner in creating wealth and enriching the lives of many people in the host community, as well as being a good corporate taxpayer by adhering religiously to all governmental laws, rules and regulations.

RECEIPT OF GIFTS FROM THIRD PARTIES

Reasonable, fair and customary gifts on certain occasions and gifts or tokens considered to be within the parameters of the business relationship are acceptable provided these will not create or result to any conflict of interest. However, should any gift be considered incommensurate or inappropriate to the specific occasion, said gift must be returned to the giver to avoid any feeling or expectation that it should be repaid or reciprocated to the detriment of the company.

COMPLIANCE WITH LAWS & REGULATIONS

The Board ensures that the corporation efficiently and effectively complies with relevant laws and regulations. The Board also warrants that the corporation conducts its business in accordance with good business practices.

Senior management ensures that the Board’s stated policy of efficient and effective compliance with relevant laws and regulations is implemented. Further, senior management ensures that the corporation conducts its business in accordance with good business practices.

Employees shall act in a manner consistent with the policy that the corporation shall efficiently and effectively comply with relevant laws and regulations. Further, employees shall conduct business in the name of the company in accordance with good business practices.

RESPECT FOR TRADE SECRETS/USE OF NON-PUBLIC INFORMATION

The Directors of the corporation ensures that all trade secrets and non- public information are kept confidential. The Board guards these trade secrets and non-public information with utmost privacy so as to protect the general interest of the corporation.

All senior management officials of the corporation signed a confidentiality agreement before the start of their tenure. These confidentiality agreements ensure that safeguards are in place and that the senior management officials will respect and protect the trade secrets of the company. The senior management officials are prohibited from using any learned non-public information to their advantage and to the prejudice of the company.

All employees of the corporation signed a confidentiality agreement at the beginning of their employment which mandate them to respect the trade secrets of the company. They are also prohibited from using any learned non- public information to their advantage and to the prejudice of the corporation.

USE OF COMPANY FUNDS, ASSETS AND INFORMATION

All company funds, assets and information are solely to be used for the corporation’s disposal and for the corporation’s business purpose and benefit. These are not for personal consumption and may not be used by any person for his own personal benefit. Any violation of this policy will be accordingly penalized upon proper investigation. Misappropriation and embezzlement of the same for personal gain is a violation of company rules and regulations.

EMPLOYMENT & LABOR LAWS & POLICIES

The Board ensures compliance with existing employment and labor laws and policies. Company rules and regulations are always in conformity with existing labor standards and are conscientiously observed for the purpose of promoting a healthy and safe working environment.

The company commits itself to implementing programs which will promote a healthy work environment that is beneficial not only to employees but to customers, shareholders and the community as well. The company also commits to provide information and resources that will assist their workers in making healthy lifestyle choices and achieving and maintaining good health.

DISCIPLINARY ACTION

Reprimand is the penalty to be imposed against a director for first violation of company rules and policies. Suspension is the penalty for a second violation. The gravity of the violation involved will be the basis of the duration of the suspension. A maximum penalty of removal from office will be imposed upon the director concerned in case of a third violation.

Any violation of company rules and regulation will be a ground for disciplinary action. The penalties that may be imposed include reprimand, suspension or even dismissal from work depending on the gravity of the violation. Civil and criminal charges may also be filed against the erring member of the senior management depending on the nature of the violation and circumstances of the case.

Any violation of company rules and regulation will be a ground for disciplinary action. The penalties that may be imposed include reprimand, suspension or even dismissal from work depending on the gravity of the violation. Civil and criminal charges may also be filed against the erring employee depending on the nature of the violation and circumstances of the case.

WHISTLE BLOWER

All senior management officers are expected to comply with the rules and regulations of the company. They are also obligated to faithfully implement and effectuate each and every company rule with regard to investigations of every violation without exposing the employee making the report to any fear of reprisal.

All employees are expected to comply with the rules and regulations of the company. They are also obligated to faithfully implement and effectuate each and every company rules with regard to investigation of any violation.

CONFLICT RESOLUTION

Resolution of conflicts are discussed and approved by the Board.

Exhaustion of remedies in the administrative level is resorted to before any resort to judicial action.

RELATED PARTY TRANSACTION

All transactions are on arm’s length basis. Stockholders provide assistance to the operating entities for the importation of equipment, parts and supplies, mining costs, use of facilities like, housing and other equipment and manpower are given as accommodation in exchange for assistance in the operation.