Supplier Code of Conduct

1. Introduction:

It is the policy of PhilTower to conduct our business in an honest and ethical manner. We are committed to professionalism, fairness, and integrity in all our business dealings and relationships wherever we operate and to implement and enforce effective systems to counter corruption, bribery and maintain high ethical standards.

PhilTower is committed to respect the law and advance social and environmental responsibility. The purpose of this Supplier Code of Conduct is to ensure that our Suppliers share our commitment to such responsible business practices.

This Supplier Code of Conduct is to be accepted and applied by both international and local suppliers.

If a business partner, supplier or subcontractor fails to follow our integrity standards as summarized in this Code, PhilTower reserves its right to withdraw from the business relationship.

2. Compliance with law:

The Supplier shall comply with all applicable laws and regulations.

3. Workers’ Rights and Protection:

3.1 Universal Human Rights:

The Supplier shall respect and promote human rights as stated in the UN Universal Declaration of Human rights. Suppliers must conduct its business in a manner that respects human rights, including the rights of their own employees, subcontractors and suppliers.

Suppliers must ensure that it neither knowingly assists in violating human rights nor benefits from human rights abuse by a state or through their private of public security forces.

3.2 Harsh treatment and Harassment:

Workers shall not suffer nor be threatened to suffer any kind of inhumane treatment, including corporal punishment, verbal and sexual abuse, coercion, etc.

3.3 Involuntary Labor:

PhilTower has zero tolerance for all forms of modern slavery, including child labor and human trafficking. The supplier shall not use any form of forced labor, debt, etc. Employees and contractors should be free to leave work or terminate their employment after the agreed notice period. Workers will never be deprived of their identity documents or work permits by the contractor.

3.4 Working Hours:

The supplier shall respect local laws regarding daily and weekly working hours including laws relating to overtime, leave, and working days. Workers must have one full day off per week.

3.5 Wages:

Workers must be paid at the agreed rate equal to or greater than the minimum wage. All overtime must be compensated according to local law. Salary deductions as disciplinary measures are prohibited.

3.6 Equal Opportunity Employment:

The supplier shall not discriminate against any worker based on color, ethnicity, religion, political affiliation, sexual orientation, gender, age, union membership, or marital status in any hiring or employment practices, including in the access of employees to promotion, rewards, and training. The supplier must acknowledge the added value of diversity in the workplace and encourage under-represented groups such as women, minorities, disabled persons, etc. to join the company.

3.7 Health Status and Privacy:

The supplier will not seek unnecessary information on the health of workers or potential workers by any means. If the supplier receives information about the health status of workers or potential workers, the supplier will not communicate them to any third party. Discrimination, harassment, or dismissal of workers on the basis of their health status, especially HIV status, is prohibited.

3.8 Protection from Occupational Hazards:

Suppliers shall always abide by PhilTower Health and Safety Policies when undertaking any work on behalf of PhilTower. All workers must be efficiently protected from safety hazards at the workplace. All relevant risks must be identified and mitigated through proper design, engineering, and administrative controls, preventive maintenance, and safe work procedures, and the appropriate PPE provided. Workers must not be discouraged from raising safety issues. Workers using machinery must be protected by means of physical guards, interlocks, barriers, and training and preventive maintenance. Exposure of workers to biological, chemical, and physical hazards including radio frequency fields will be identified, measured, and mitigated. When necessary, workers must be provided with the appropriate PPE.

3.9 Emergency Preparedness
The supplier will also protect its workers from identified emergency risks like fire, flooding, war, aggressive weather by adopting PhilTower’s Emergency Preparedness.

3.10 Occupational injuries and Illnesses
The supplier will effectively track and record the occupational injuries and illnesses of its workers and provide them with appropriate treatments when necessary. The suppliers shall also access and mitigate the causes of harm.

3.11 Conflict Minerals
The supplier will effectively prevent the use of conflict minerals (tin, tantalum, tungsten and in some cases, gold) from the supply chain by tracking and recording the source of minerals, such that the minerals are not from affected regions of conflict nor has the trade contributed to financing armed groups.

4. Prohibition of Child Labor

4.1 Banning Child Labor
PhilTower prohibits the use of child labor in our operations. Following ILO recommendations, children must not be employed by the supplier and its own direct suppliers unless they have reached the age of 18.

4.2 Age Verification
To mitigate the risk of employing underage persons, Suppliers must ensure that appropriate checks are undertaken to verify age prior to a job offer. Where reasonably practicable, these checks should include checking of recognized forms of identification e.g., driver’s license, ID etc.

5. Ethics & Integrity
PhilTower suppliers must commit themselves to the highest standard of ethical conduct and integrity. The promotion of business ethics and the fight against corruption are not only right but are key elements of long-term business development. Neither PhilTower, its employees, nor partners may offer or accept bribes in any form, including financial payments, gifts, offers of employment or other favours.

5.1 Bribery
PhilTower does not pay bribes to anyone, whether they represent a public agency or a private company. The giving or receiving of bribes of any description, regardless of amount, is not allowed.

A “bribe” involves promising, authorizing, giving or offering payment of money or anything of value (including gifts, meals, entertainment, cash offers, employment, educational placement, charitable donations to individuals of entities related to individuals) or providing any other benefit or advantage directly or indirectly corruptly to induce recipient to misuse his/her position to obtain an unfair advantage.

In some circumstances, demands or requests for bribes may be accompanied by a form of pressure such as the threat of lost business or even physical harm. We request suppliers and subcontractors to inform us if they believe that they are under pressure to pay a bribe while working on PhilTower’s behalf.

5.2 Facilitation Payment
Neither PhilTower employees nor our partners or Suppliers may offer “facilitation payments”. Facilitation or “grease payments” are small value payments made to public officials to speed up a routine administrative process which the public official is obliged to perform by law e.g. visa, obtain stamp or signature on a document such as a permit, to enable goods clearance at customs or jump a queue.

5.3 Gifts & Gratuities
PhilTower and its business partners may offer and accept reasonable gifts and hospitality given in the normal course of business. However, in all cases they must ensure that the gift or benefit is offered as an expression of goodwill and not in expectation of a return favour. Suppliers must ensure that any gift or hospitality:
− Is not excessive
− Is for bona fide business purpose
− Is given and received transparently
− Complies with applicable laws
− Complies with the rules of the receiving organization
− Is not given or received frequently between the same individuals
− Is properly recorded
Suppliers must not:
− Solicit or request gifts or hospitality from an individual or organization
− Give or receive gifts or hospitality when engaged in a bidding process
− Give or accept cash or cash equivalents (vouchers or loans)
− Provide or accept any gift or hospitality that is inappropriate, indecent, illegal or could cause reputational damage to PhilTower.
− Pay for any gift or hospitality personally to avoid the approval process or recording requirements

5.4 Honoring Contracts
All obligations within contracts entered into between PhilTower and suppliers must be adhered to. It is not permitted to work “outside” of contracts unless agreed in writing with PhilTower.

5.5 Protecting Confidential Information
Suppliers may receive or encounter information about PhilTower’s business activities, contracts, projects, structure, financial situation or performance. Such confidential information must not be disclosed to any third party without prior written permission from PhilTower. Disclosure of such information to employees of the supplier must be restricted to a need-to-know basis and in accordance with applicable regulations and prevailing industry practices. Requesting, receiving, sharing, distributing and the use of confidential information relating to amongst other things, competitors’ proposals, to gain competitive advantage or market awareness is strictly prohibited.

5.6 Intellectual Property
Suppliers must actively support and respect intellectual property rights, regardless of existence and effective application of local regulation. Suppliers may not advertise any contract with PhilTower without prior written approval from PhilTower.

5.7 Fair Business Practices
The supplier must uphold standards of fair business, competition, advertising, and competition and ensure that information given to the customers is not misleading.

5.8 Conflict of Interest
Suppliers must inform PhilTower if there is an actual or apparent conflict of interest that may affect the integrity or impartiality of the parties’ business relationship. Suppliers are duty bound to report:
− Any financial interest that a PhilTower employee may have within their organization.
− Any direct family member or indirect relationships between any member of the supplier’s organization and PhilTower.

6. Health, Safety and the Environment
Our suppliers and subcontractors must ensure a safe working environment for employees, including by applying all applicable health, safety, environment and social (HSES) regulations.

6.1 Environment
The supplier should acknowledge that “in order to achieve sustainable development, environmental protection shall constitute an integral part of the development process and cannot be considered in isolation from it”. Therefore, the supplier should strive to minimize the adverse environmental impact of its products and services during the whole product life cycle i.e., production, transport, use and disposal and recycling.

6.1.1 Permits and Reporting

The supplier must possess all updated environmental permits necessary and comply with all local environmental reporting requirements for any activity related to PhilTower manufacturing, transportation, and local operations.

6.1.2 Waste Reduction and Treatment

The supplier must strive to reduce or eliminate the waste generated by all of its activities. This objective will be achieved through the enhancement of maintenance and cleaning processes, modes of transportation, as well as the substitution, reuse, and recycling of materials. Liquid waste and wastewater must be reduced and controlled prior to discharge.

6.1.3 Dangerous Substances & Gas Emissions

Chemical substances and other materials that could cause damage if released into the environment must be identified and declared to local authorities when required. They must be stored, transported, handled, and disposed of in a manner that minimizes the risk of release into the environment. All emissions of volatile organic, acid, or corrosive chemicals, aerosols, particles, and combustion by-products must be monitored, controlled, and properly handled.

6.2 Performing Supplier WHSE Assessments

Only approved items from the catalog may be purchased by PhilTower personnel. WHSE must review new chemicals, products, or materials with potential health, safety, and environmental impacts as required to ensure that established WHSE requirements can be met prior to being added to the catalog. Requests to purchase chemicals, products, or materials not listed in the catalog or that have not been used at a facility or in an established process must undergo PhilTower’s Change-Management. As part of this process, a WHSE risk assessment must be conducted.

PhilTower guarantees that purchases of supplies and equipment are safe for use by personnel and contractors, with the following requirements:

− Equipment is provided in compliance with countrywide or industry-specific technical specifications, and if appropriate, is tested to ensure its proper functioning;
− Equipment is provided in accordance with legal requirements;
− Risk assessments are conducted before using new equipment or materials through the change-management processes as appropriate;
− Installations are commissioned to ensure that they function as intended before start-up;
− Usage requirements, precautions, or other protective measures are defined and communicated to personnel, including contractors who may be adversely affected.

6.3 Screening Supplier

All suppliers working on behalf of PhilTower who have the potential to be exposed to or interact with significant environmental aspects or OH&S hazards or create hazards in the course of their work are thoroughly evaluated. All suppliers and subcontractors are required to consistently work safely, maintain regulatory compliance, and conduct environmentally sound operations. PhilTower mandates a screening process for suppliers whose services may include environmentally sensitive activities or safety hazards. These services include a broad range of activities such as construction, tower climbing, maintenance, electrical work, fuel-tank maintenance, and asbestos abatement.

The screening process is used to evaluate supplier WHSE performance based on the inherent risk of the services provided, as shown below:

− Suppliers are required to provide the requested WHSE information and data;
− Evaluation to determine whether the supplier meets established benchmarks;
− PhilTower is then notified of the assessment results;
− Approved suppliers must complete an annual update of WHSE performance data from the previous year;
− PhilTower is informed of any changes in a supplier’s status based on the review of the previous year’s data;
− WHSE reviews changes in the supplier’s score and takes appropriate action based on the change.

WHSE requirements for suppliers are documented, and the Supplier Code of Conduct is included in supplier contracts and provided as part of the sourcing process.

7 . Confidentiality
Suppliers must respect the confidentiality of all commercial or technical information acquired while working for PhilTower. Suppliers may not use any such information for their own commercial advantage, for example by sharing it with a competitor or another supplier.

8.  Monitoring the compliance to the Code of Conduct
The supplier should set up a management system to ensure compliance with applicable laws and this supplier Code of Conduct. This management system should include:

− Company commitment: an official company statement that affirms the commitment to comply with applicable laws, regulations, and PhilTower’s Supplier Code of Conduct
− Roles & Responsibilities: an organization chart that identifies responsibilities and accountabilities regarding customer requirement and this Code of Conduct.
− Risk Management Process: a process to identify, measure and manage all business risks, those mentioned in this Supplier Code of Conduct and regarding WHSE, labor practices, environment, and ethics.
− Training: a training program for workers related to this Supplier Code of Conduct and continuous improvement
− Participation: a process to collect and consider employees input and feedback on all issues related to this Supplier Code of Conduct
− Corrective action: a process for prompt correction of deficiencies identified by internal or external sources
− Documentation & Records: records to document compliance to this Supplier Code of Conduct and reports describing issues found and corrections made.

9.  Raising Questions or Concerns
If Supplier has any question on any aspect of this Supplier Code of Conduct, PhilTower encourages them to consult their main PhilTower contacts or the PhilTower Legal Counsel.

10. Whistle-blower Policy
If a supplier knows or suspects that someone within PhilTower or someone performing services on behalf of PhilTower has breached the PhilTower Code of Business Conduct or the suppliers Code of Conduct, it must be immediately reported. Suppliers can be confident that such reports will be fully investigated and can be made without fear of retribution or retaliation. Concerns or allegations should be raised to:

Suppliers must maintain policies that protect the confidentiality of whistle-blowers who may raise concerns about ethical or legal issues within PhilTower or the supplier.

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