Anti-Bribery and Corruption Policy

The Company’s Anti-Bribery and Corruption Policy was established to ensure that Company employees and personnel meet the standards and controls against graft and corruption as prescribed by relevant laws and regulations. Under said Policy, acts or attempts of corruption and bribery should be reported to the Company’s Human Resources Department, Internal Audit Group, or the employee’s immediate supervisor. The investigation and punishment (if merited) of any such act shall be guided by the Company’s Manual on Corporate Governance, Code on Employee Discipline, and the Revised Penal Code of the Philippines. The Company’s Anti-Bribery and Corruption Policy is available on the Company’s website.

*For 2023, no incidents involving violations of the Anti-Bribery and Corruption Policy were reported

Policy on Insider Trading

The Company’s Policy on Insider Trading was established to safeguard the fairness and integrity of the securities market in the Philippines and to protect and maintain the confidence and trust of the Company’s investors and shareholders. Under said Policy, the Company’s directors, officers, employees, and their respective representatives are prohibited from buying or selling Company securities while in possession of material information not yet generally available to the public. Any act, attempt or allegation of prohibited insider trading shall be dealt with appropriately and swiftly. The investigation and punishment (if merited) of any act, attempt or allegation of prohibited insider trading shall be guided by the Company’s Manual on Corporate Governance, Code on Employee Discipline, the Securities Regulation Code of the Philippines, as well as other laws and regulations pertaining to the said subject. The Company’s Policy on Insider Trading is available on the Company’s website.

Policy on Conflict of Interest

The Company’s Policy on Conflict of Interest was crafted to recognize the duty of loyalty expected from the directors, officers, and employees toward the Company and its shareholders. Under said Policy, directors, officers, and employees shall ensure that they do not have any business interest or activity that will interfere with the proper performance of their duties and functions. Any potential conflict of interest shall immediately be disclosed. An actual or potential material conflict of interest should be reported to the immediate superiors, Senior Management, or the BOD. The procedure for reporting and the protection afforded by the Company’s Whistleblower Policy shall apply in each reported instance of violation. The Company’s Policy on Conflict of Interest is available on the Company’s website.

Whistleblower Policy

The Company’s Whistleblower Policy was established to promote a culture that encourages internal accountability and communication without fear of retaliation. Under the Policy, the identity of the Whistleblower and the information disclosed shall be kept confidential. Moreover, no retaliatory action against the Whistleblower shall be entertained nor tolerated by the Company. Furthermore, the Company shall take disciplinary action against any member who violates the confidentiality of any disclosure including the identity of the Whistleblower, or is found to have committed, initiated, or was otherwise involved in the commission of any retaliatory action against the Whistleblower. The Company shall also take disciplinary action, which may include employment termination, against any person found to have maliciously made a false or misleading disclosure. A Whistleblower may make a disclosure on any act that:

1. is contrary to law and Company rules, regulations, policies, or values;
2. adversely affects Company image and reputation;
3. is unreasonable, unjust, unfair, or discriminatory;
4. has an undue or improper exercise of powers and prerogatives; or
5. has similar actions which are against Company interest or contrary to Company values.

The Policy provides a mechanism to address reports on said acts and grievances of any whistleblower. The Company’s Whistleblower Policy is available on the Company’s website.

Material Related Party Transactions Policy

The Company’s Material Related Party Transactions (Material RPTs) Policy was issued to promote good corporate governance and ensure the protection of the Company’s shareholders, especially the minority investors. It covers all entities within the First Gen conglomerate. The Policy states that the Company and its shareholders shall only enter into Material RPTs (as defined in the Policy) when terms and conditions are fair, at arm‘s length and beneficial to both parties. Under the Policy, the Company’s directors have the overall responsibility of ensuring that Material RPTs are handled with integrity and in a sound and prudent manner. The Material RPTs shall also comply with applicable laws and regulations to protect the interests of the Company’s shareholders and other stakeholders. In the case of an abusive Material RPT, a Material RPT found to have been entered into not on an arm’s length basis or one which unduly favors a related party, Senior Management shall provide directions on how to cut losses and allow recovery of losses or opportunity costs incurred by the Company. Directors, officers, and employees found to have been remiss in their duties in handling Material RPTs shall be penalized according to the Company’s Manual on Corporate Governance, Corporate Code of Conduct and Ethics, and Code of Discipline, as well as other applicable rules, regulations, and policies. The Company’s Material RPTs Policy is available on the Company’s website.

Responsible Asset Protection Policy

First Gen established its Responsible Asset Protection Policy to protect and promote human rights and safeguard, at the highest standards, the Company’s assets—its personnel, equipment, inventory, information, facilities, and partner communities. In protecting its assets, the Company adheres to the Lopez Values and the Voluntary Principles on Security and Human Rights, which include the following principles: capacity and competency of security personnel; security risk assessment and management; human rights training; and communication, organization awareness, and support. The Company likewise adheres to applicable national laws and local ordinances in protecting its personnel, assets, and information. A grievance mechanism is offered to ensure:

1. the complainant’s confidentiality;
2. a thorough assessment of the credibility and severity of the allegation or incident; and
3. implementation of appropriate corrective actions, if needed.

The Responsible Asset Protection Policy is available on the Company’s website.

Quality Policy

First Gen developed its Quality Policy to guide the Company in its pursuit of quality performance. The Policy details the establishment and maintenance of a Quality Management System (QMS) that covers asset monitoring and control, development of energy-related businesses, and provision of resource management and support services to all its subsidiaries. Specifically, the Company commits to the following:

1. providing quality service that ensures customer satisfaction;
2. enhancing competitiveness by meeting the requirements of international standards and going beyond compliance with legal requirements;
3. participating in shaping energy industry policies;
4. adopting the best technology in the power generation industry;
5. managing the business risks and capitalizing on opportunities; and
6. implementing consistent best management practices.

In doing its business, the Company commits to protecting and preserving the environment and supporting the communities it serves. As stated in the Policy, First Gen executes the necessary measures to ensure the Quality Policy is understood, observed, and integrated into the employees’ way of life. The First Gen Quality Policy is available on the Company’s website.

Environmental, Safety, and Health Policy

The Environmental, Safety, and Health (ESH) Policy was developed to manifest First Gen’s commitment to protecting and preserving the environment and providing its employees with a safe and healthy workplace. This Policy commits to developing and implementing an environment, safety, and health management system covering all its projects by:

1. complying with all applicable laws and regulations in the country and setting internal ESH standards;
2. providing and equipping its personnel with required resources, knowledge, and skill to effectively carry out their functions in a safe manner;
3. assessing and managing environmental impacts and occupational safety and health risks using appropriate technologies; and
4. carrying out its ESH programs to ensure the safety and well-being of its employees in the workplace, with efficient resources use.

The ESH Policy is adopted in the operations and activities of the Company’s operating assets. Management ensures that the ESH Policy is communicated to and understood by its employees, contractors, and other stakeholders through orientations, formal discussions, and robust implementation prior to, during, and post-activity engagements. The ESH Policy is available on the Company’s website.

CSR Policy

The Corporate Social Responsibility (CSR) Policy guides the Company’s CSR department and Community Relations (ComRel) teams in developing CSR programs. The Company upholds the CSR principles of the Lopez Group by providing relevant, responsive, and sustainable programs that aim to improve our stakeholders’ quality of life. Specifically, it details the allocation of funds for CSR programs and the monitoring and evaluation of the environmental and social impacts of the Company. The CSR programs are led by the Office of the President, implemented by the CSR and ComRel teams per subsidiary, and complemented by the employees.

The four procedures that are followed when enforcing the Policy are:

1. stakeholder management, a process that manages the relationship and participation of stakeholders throughout the life of the project;
2. CSR and ComRel programs, which detail the process of developing, implementing, monitoring, and evaluating the impacts of the CSR programs;
3. donations and sponsorships, which cover the criteria for the donations and sponsorship requests to pass; and
4. employee volunteerism, which supports the volunteer activity planning process, the actual volunteer work, and the documentation of contributions and pertinent data by the CSR department.

The Policy includes a stakeholder feedback and grievance mechanism. Through the said mechanism, the Company can document concerns of stakeholders and monitor the actions taken by the Company to address such concerns.The Policy was cascaded across the subsidiaries, new employees, and external stakeholders. First Gen’s CSR department and the ComRel teams of relevant subsidiaries have a stakeholder map, issue and risk map, stakeholder engagement plan, CSR Plan, and Impact and Risk Monitoring. The CSR Policy is available on the Company’s website.

Cultural Heritage and Indigenous Peoples (IP) Policy

In support of social justice as one of the Lopez Values, First Gen created its Cultural Heritage and Indigenous Peoples (IP) Policy. The Company believes that IP are valuable partners in its areas of operation, with rights to cultural integration and self-determination, and entitled to have their territories upheld and protected. The Policy was issued in support of the Company’s commitment to human rights, equality and diversity, national development, and compliance with relevant national laws and international conventions entered into by the country. The Company also recognizes that the IP’s diverse skills and knowledge can contribute to the Company’s informed planning, management, and implementation of its projects.

In adherence to the Policy, the Company ensures that its projects undergo consultations with IP-recognized leaders and national institutions and agencies responsible for the promotion and protection of IP, as necessary. Consent from IP must be obtained before consultation as stipulated in Republic Act No. 8371 or the Indigenous Peoples’ Rights Act. In case of conflicts or disputes concerning IP, resolutions shall be reached through discourse founded on traditional laws, cultures, and practices, as far as practicable. The Cultural Heritage and Indigenous Peoples Policy is available on the Company’s website.

Gender Equality and Diversity Policy

In becoming a regenerative business that elevates its stakeholders, the Company initiated its Policy on Gender Equality and Diversity, with guidelines focusing on empowering people regardless of their gender orientation. The Company is committed to integrating gender equality and diversity in its operations, programs, and strategies. The Company believes that in doing so, it contributes to the Company’ s economic performance and long-term success as well as the realization of the full potential of its employees and stakeholders, which leads to a more inclusive society.

The Policy complies with international guidelines on business and human rights, which uphold the fundamental rights of directors, officers, employees, and stakeholders independent of gender, race, culture, religion, ethnic background, and other affiliations.

Beyond the fundamental responsibilities, the Company recognizes that gender equality and diversity improve employee engagement and performance, and create a more robust learning environment. In turn, the Policy also enhances the Company’s ability to attract and retain employees, as well as increase its economic performance, competitive edge, and overall sustainability. The Company has zero-tolerance for all forms of workplace discrimination, including verbal and physical abuse. The Company facilitates access to a grievance redress mechanism for any complaint and the determination of any corrective and remedial action. The Gender Equality and Diversity Policy is available on the Company’s website.

Human Rights Policy

The Company crafted its Human Rights Policy, which outlines the Company’s commitment to recognize and respect human rights based on the principles and values laid out in the Philippine Constitution and related local issuances; UN Declaration of Human Rights; International Covenant on Civil and Political Rights; International Covenant on Economic, Social, and Cultural Rights; and International Labor Organization Declaration on Fundamental Principles and Rights at Work. These principles and values are embedded in the Company policies and the Code of Conduct that every employee must follow. The Company likewise expects its suppliers and business partners to share these values.

Aside from upholding human rights in and of itself, the known benefits derived from adhering to human rights principles include:

1. prevention of regulatory risks;
2. sustenance of business operations;
3. improvement of stakeholder relations;
4. strengthened employee engagement;
5. enhanced corporate image; and
6. access to a new market for products and services.

The Company shall avoid causing adverse human rights impacts in its operations and, should these occur, it shall facilitate access to a grievance redress mechanism. In addition, the Company shall, to every extent possible, prevent or mitigate adverse human rights impacts in the provision of its products or services. The Human Rights Policy is available on the Company’s website.

Anti-Sexual Harassment Policy

Sexual harassment is an unjust, malicious, and unlawful act that violates a person’s dignity, threatens their sense of security, and poisons the work environment. In establishing the Anti- Sexual Harassment (ASH) Policy, the Company aims to eliminate sexual harassment and build a culture that instills and expects integrity, respects human rights, rejects intimidation, and culls offensive behavior. The ASH Policy’s goal is to create a shared responsibility for the Company’s members to contribute toward a work environment that is inclusive, productive, promotes employee wellbeing and security, and fosters concern for the Company workforce. The ASH Policy identifies procedures to be followed in investigating and resolving complaints alleging specifically prohibited conduct and emphasizes the education and training of employees as mechanisms for the prevention of sexual harassment. The Anti-Sexual Harassment Policy is available on the Company’s website.