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Code of Ethics Sm Investment Corporation

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Code of Ethics Sm Investment Corporation
Bulanday, Monica Patricia Camille A. 4MKTG02
Social Responsibility Prof. Stella A. Yanuaria August 31, 2010

SM INVESTMENTS CORPORATION

Code of Ethics/Policies

SMIC adopted a Code of Ethics on September 21, 2007 to re-affirm the company's commitment to the highest standards of ethics, good governance, competence and integrity in pursuing the company's mission and vision to serve the best interest of its customers, stakeholders and the country. The Code provides that the company strives to render adequate, reliable and efficient customer service at reasonable cost. The company also protects shareholders' and investors' interests, including their rights to a fair return of investment and accurate and timely information.

The Code mandates a fair and transparent process for the evaluation and selection of suppliers of goods and services. It likewise requires an effective monitoring and control system to prevent fraud and other malpractices.

The Code prohibits the solicitation or acceptance of gifts by any director, officer or employee of the company from any business partner, except only for gifts of nominal value or those given for the company's charitable projects. It further prohibits conflict of interest, insider trading, corruption and other illegal acts.

The Company selects, develops and compensates the best people to manage the company. It aims to provide its employees with adequate benefits as well as a safe workplace and environment. It also supports health, educational, social, livelihood and other charitable projects nationwide.
Revised Code of Ethics

In March 2009, SM Investments Corporation revised its Code of Ethics, which serves as a guiding principle for its directors, officers and employees in the performance of their duties and the conduct of their transactions with business partners. The Code reflects the

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