Code of Ethics Sm Investment Corporation

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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 Company’s mission, vision and values statement. The salient provisions of the Code pertain to compliance and integrity, relationship with business partners, employee welfare, shareholder rights and protection of company information. Some of the important provisions of the Code are as follows: * All employees are required to immediately report to the management all suspected or actual fraudulent or dishonest acts. * Solicitation or acceptance of gifts in any form from any business partner is prohibited, except for gifts of nominal value. Any conflict of interest must be promptly disclosed to the management.

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