Code of

business and Ethics

The business activities of Victorias Milling Company, Inc. (VMC) are guided by a set of fair and ethical policies that should be applied by its employees whenever crucial decisions or choices have to be made. As a company, VMC adheres strictly to the Code of Conduct as it believes that work becomes more effective and success more likely when all activities are guided by a strong set of business principles. As representatives of VMC, employees are expected to conduct themselves with integrity at all times even outside of work.

This Code of Conduct is applicable to all directors, officers, and employees of VMC.

A. COMPLIANCE

1. We conduct our business honestly, following Philippine laws and regulations as well as VMC’s policies, rules, and regulations.

2. We personally adhere to the standards and restrictions imposed by Philippine laws and regulations as well as VMC’s policies, rules, and regulations in and out of work.

B. CONDUCT OF BUSINESS AND FAIR DEALINGS

1. We treat our customers, suppliers, business partners, competitors, colleagues, and government agencies/employees with respect and fairness at all times.

2. We do not take advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other form of unfair dealing practice.

3. We treat everyone with respect while always acting in good faith, with integrity, and with a strong sense of professionalism.

C. CONFIDENTIALITY OF INFORMATION

1. We strictly observe, maintain, and safeguard VMC’s rules on confidentiality of information. These include restrictions to the access of classified information and the release of such information to other companies, agencies, parties, or the general public. When in doubt, VMC’s employees are expected to consult their legal department.

2. We follow VMC’s policies and laws regarding business records retention. It is our duty to protect company documents and records against unauthorized or improper alteration, forgery, concealment, or destruction.

D. PROPER USE OF COMPANY PROPERTY

1. We are responsible for the proper use of all company assets and resources. These include, but are not limited to, the following: information, facilities, equipment, software, vehicles, and supplies owned, leased or possessed by VMC.

2. We use company assets and resources efficiently, responsibly, and only for legitimate business purposes.

E. ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. We do not offer, promise, or give bribes to obtain, retain, or facilitate business or any other type of transaction on behalf of VMC.

2. We do not request, agree to accept, or take bribes from any person or organization in relation to any transaction on behalf of VMC.