ANTI-BRIBERY AND CORRUPTION POLICY

Etiqa Life and General Assurance Philippines, Inc. Anti-Bribery and Corruption Policy Statement

Etiqa Life and General Assurance Philippines, Inc. (ELGAP) is committed to conduct its business dealings with integrity. To achieve this commitment, ELGAP has adopted a zero tolerance approach against all forms of Bribery and Corruption in carrying out its daily operations.

ELGAP has put in place an Anti-Bribery and Corruption (“AB&C”) framework which includes policies, procedures, pre-approval processes, risk assessments, due diligence on third parties and associated persons*, and employee training programme.

This AB&C Policy sets out the guiding principles for ELGAP to address and manage Bribery and Corruption risks in all its dealings within and outside ELGAP. Compliance to this AB&C Policy is mandatory and ELGAP, its Directors and Employees and Associated Persons (AP) (where applicable) are to strictly comply with the following principles:

1. Giving or receiving bribes in participating in any form of Bribery and Corruption in its business dealings is strictly prohibited;
2. The engagements of APs and dealings with Customer and Third Party must not be for the purpose of inducing or obtaining or retaining business, gaining an unfair advantage or influencing a government or regulatory decision for ELGAP or for Personal Gain;
3. The giving or receiving of gifts and entertainment, including donations and sponsorships, whether directly or indirectly with the intention to bribe, to retain or gain a business advantage, or for Personal Gain is strictly prohibited; and
4. Actual or potential Conflict of Interest which could result in actual or potential Bribery and Corruption risk to ELGAP is prohibited.
5. Directors and employees are strictly prohibited from making facilitation payments. Associated persons performing services for or on behalf of ELGAP are also required to comply with the above principles, where relevant.

* A person is associated with ELGAP if the person is a broker, partner or agent of ELGAP or if the person performs services for or on behalf of ELGAP.