Anti-Bribery and Anti-Corruption Policy

1. Anti-Bribery and Anti-Corruption Policy

1. Introduction

Phil-Tower Consortium Inc. (PhilTower) constructs and manages the telecommunications infrastructure that all regions and all members of our society need to connect. We are committed to the highest standards of professional competence and integrity.

PhilTower never offers or accepts bribes. We abide by all applicable anti-bribery and anti-corruption laws. Our policies and practices are compatible with Philippine law as well as the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and other equivalent national and international anti-corruption legislation.

This policy applies to all PhilTower directors and employees as well as to subcontractors, consultants and other third parties who work on the company’s behalf.

2. No bribes

We do not pay bribes to anyone, whether they represent a public agency or a private company. We understand bribery to include any inducement to secure a commercial or other advantage that is incompatible with the bribe-receiver’s duties and responsibilities. We do not offer or accept bribes in any form, whether these include monetary payments, gifts, favors or offers of employment.

3. Business Partners

PhilTower works with a wide range of subcontractors, suppliers, consultants and other third parties. We select our business partners on the basis of price, professional competence and integrity. We expect all third parties to abide by the same standards as our own when working on our behalf, and this includes a commitment not to offer or accept bribes. If a third party fails to follow our integrity standards, we reserve the right to withdraw from the business relationship.

4. No “facilitation payments”

“Facilitation payments” are small bribes paid to individual officers to speed up legitimate transactions such as customs clearances or applications for utility connections. PhilTower will not make such payments, even where they are customary, and we will not authorize others to make them on our behalf.

5. Gifts, entertainment and hospitality

Offering or receiving gifts, entertainment and hospitality is often a legitimate part of the process of commercial relationship-building. However, it is essential to ensure that these are offered as an expression of goodwill and not in expectation of a return favor.

PhilTower will never offer or accept gifts or other benefits that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty. A gift that is made in the expectation of receiving something in return could be seen as a bribe. For further guidance, please see the Gifts, Entertainment and Hospitality policy.

6. Books and records

PhilTower will always keep accurate books and records, and our accounts are fully audited. All financial transactions must be supported by documentation in accordance with the Finance department’s procedures. We will never make hidden or under-the-table payments.

7 .Conflicts of interest

PhilTower directors and employees must avoid any conflicts of interest where their personal interests conflict with those of the company. Similarly, they may not use commercially sensitive information gained while working for PhilTower for personal benefit, for example by sharing it with a potential supplier with whom they have a personal or family connection.

We must avoid even the appearance of a conflict. Anyone who thinks that they may have a conflict should raise the matter with their manager, the Director of Finance or the Chief Legal Counsel, sharing all necessary details.

If there is a potential for a conflict, the interests of PhilTower must take priority.

8. Political donations

PhilTower has a strict policy of political neutrality. We do not make donations either in cash or in kind to political parties, candidates or electoral campaigns.

We reserve the right to make our position known on matters of public policy that may affect our company or industry. However, we will always do so ethically and transparently.

9. Charitable donations and sponsorships

As part of our community engagement, PhilTower may make donations or sponsorships to civil society organizations that serve a legitimate philanthropic or educational purpose.

We will keep a careful record of all such donations, and we will only work with organizations that are themselves transparent and accountable. We expect to see clear accounts of how our money is spent.

10. Responding to extortion

All PhilTower’s financial accounts are properly recorded and subject to audit. We do not make illicit payments in the form of “protection money” or “revolutionary taxes”. If it is unsafe for our employees or subcontractors to operate in any specific region or sub-region, we reserve the right to withdraw.

The safety of our employees and subcontractors is paramount. On rare occasions, individual PhilTower employees or people working on our behalf may face a demand to make a payment against a threat to their physical safety, for example when travelling in a remote area. In such circumstances, they may use their judgement on whether it is necessary to pay to ensure their own safety. However, if they feel the need to make a payment under physical duress, they must report the incident to a senior PhilTower manager as soon as possible. Senior management will then draw up a strategy to minimise the risk of future similar incidents. A payment to secure a commercial objective such as the granting of an essential permit does not qualify as “duress”.

11. Responsibilities

All PhilTower directors, employees, subcontractors and other third-party suppliers acting on PhilTower’s behalf are required to abide by this policy.

PhilTower managers are responsible for ensuring that their team members understand the policy and know how to apply it in the course of their specific work and duties.

12. Training

All PhilTower employees are required to undertake training in our Anti-bribery and Anti-corruption policy on joining the company, followed by regular refresher training at least once a year.

13. Raising concerns and reporting breaches

If PhilTower employees have any concerns or questions about the application of this policy, we encourage them to consult their managers in the first instance. Alternatively, they may contact the Director of Finance, the Human Resources Manager or the Chief Legal Counsel.

If PhilTower employees or external stakeholders become aware of an actual or suspected breaches of this policy, they should contact the Chief Legal Counsel.

We will always respect the confidentiality of whistleblowers unless we are required by law to disclose information to the investigating authorities. We will not penalise any employee who raises concerns or reports suspected breaches of this policy that ultimately turn out to be unfounded.

14. Disciplinary issues

We take breaches of the policy very seriously. We will take disciplinary action – potentially including dismissal – against any employee who pays a bribe or facilitates a bribery payment.

 

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