JBUGAYONG, Inc.

CODE OF ETHICS AND BUSINESS CONDUCT

Adopted by the Board of Directors 01/01/2023

1. Introduction

1.1 This CODE OF ETHICS AND BUSINESS CONDUCT of JBUGAYONG Inc. serves
as our ethical commitment and as a guide to proper business conduct for all of our
stakeholders. We, at JBUGAYONG Inc., are committed to doing business legally, ethically
and in a transparent manner.

The success of our business is based on the trust we earn from our employees, customers
and shareholders. We gain credibility by adhering to our commitment to fairness and
reaching our goals solely through ethical conduct.

1.2 JBUGAYONG Inc., is open to any questions at any time and will not allow
punishment or retaliation against anyone for reporting a misconduct in good faith.

Managers and leaders have a higher responsibility for demonstrating, also through their
actions, the importance of this Code. Managers and leaders are responsible for promptly
addressing every raised ethical question or concern. Employees must cooperate in
investigations of potential or alleged misconduct.

We are committed to making efforts to apply our values and norms also throughout the
entire value chain of our own suppliers, sub-contractors, service providers and business
partners.

1.3 This document applies to all staff who work for the JBUGAYONG Inc.,(including
officers, directors, managers, team leaders, employees, temporary, agency, interim,
sub-contractor or consultant staff), and also include other organizations who do business
with us.

The Board of Directors of the company adopted this Code because:

(a) JBUGAYONG Inc., expects its staff to be impartial and honest in all affairs
relating to their job.
(b) All staff bear a responsibility in general, to be of good faith and do nothing to
destroy the trust necessary for employment.
(c) All staff are expected to adhere to this Code in their professional, as well as
personal conduct, treat everyone with respect, honesty and fairness.
(d) Non-compliance to this Code is considered as misconduct that could warrant
disciplinary action, including termination of employment or other contract in
deserving cases.
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366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

2. Honest and Ethical Conduct

2.1 By doing its business in an ethical and honest manner, the Corporation aims to
achieve high standards of integrity.

2.2 Each director, officer, and worker is expected to act professionally and follow ethical
business conduct standards when interacting with clients, partners, service providers,
rivals, workers, and others.

2.3 Key Values (or pillars of Ethics):

(a) Honesty
(b) Integrity
(c) Loyalty
(d) Responsibility
(e) Accountability
(f) Reliability
(g) Respect for others
(h) Obedience to the law and the rules/regulations of the company

3. Conflict of Interests

3.1 Our decisions will be based on fair and impartial evaluations to prevent any
domination. When an employee's personal interests—which may be connected to friends,
family, customers, competitors, suppliers, or contracting entities—interfere with or have the
potential to interfere with the company, this is referred to as having a "conflict of interest."
Anyone with a conflict of interest question should consult management as it is not always
simple to determine whether a conflict of interest exists.

3.2 Conflicts of interest could arise:

● Being employed (you or a close family member) by, or being in economic relation
with an actual or potential customer, competitor, supplier or contractor.
● Hiring or supervising family members or closely related persons.
● Serving as a board member for another company or organization.
● Owning or having a substantial interest in a customer, competitor, supplier or
contractor.
● Having a personal interest, financial interest or potential personal gain in any
company transaction.
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366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

3.3 It is the senior employee's responsibility to notify his or her management if coworkers
start having romantic relationships with one another in order to ensure that there isn't a
conflict of interest now or in the future.

4. Privacy, Security and Confidentiality

4.1 Security, protection and proper use of company assets

4.1.1 We are responsible for the security, protection and for the economic use of
company resources. Our resources, including time, material, equipment and
information are provided for legitimate business use only. Occasional personal use is
permissible as long as it is lawful, does not affect job performance or disrupts
workplace morale.

4.1.2 All staff are obliged to follow appropriate security measures and they should
treat company property, whether material or intangible, with respect and shouldn’t
misuse company assets or use it carelessly.

4.2 Privacy, personal data protection

4.2.1 We value everyone's privacy rights and are conscious of the necessity for our
clients, staff members, and other partners to have faith in the proper use of their
personal data for appropriate business purposes.

4.2.2 Our staff will adhere to legal requirements, implement compliance techniques,
and follow pertinent protocols to ensure that the handling and processing of
personal information is legal.

5. Health, Safety and Environment

5.1 We are committed to keeping a healthy atmosphere and we offer clean, safe, and
healthy working conditions. We are dedicated to reducing the negative effects of our
operations on the environment. We work to limit the consumption of hazardous pollutants
like garbage as well as the use of finite resources like electricity and water.

5.2 Every law, rule, and regulation pertaining to health, safety, and environmental
protection must always be followed and complied with by all employees.

6. Harassment, Discrimination and Bullying

6.2 We provide equal opportunity in work and we do not tolerate any discrimination or
harassment or any form of abuse. No one shall be subject to direct or indirect discrimination
on the basis of any characteristic or circumstance that is irrelevant to
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366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

employment, including but not limited to gender, marital status, age, race, national origin,
color, religion, or political opinion, disability, sexual orientation, employee representation,
property, birth, or other status. It is forbidden to engage in any form of victimization,
bullying, or discriminating behavior.

6.3 Every employee is expected to follow the highest standards of behavior in all verbal
and written interactions based on mutual respect, and must refrain from any type of
harassment, slander or any activity that could be seen as offensive, intimidating,
humiliating, spiteful or insulting.

7. Professionalism and Office Conduct

7.1 JBUGAYONG Inc., is committed to professionalism and proper office etiquette.

Therefore, all employees must adhere to the proper office standard operating procedures
(SOP’s) set by the company:

7.1.1 Dress Code

JBUGAYONG Inc., dress code policy is designed to help us all provide a

consistent professional appearance to our customers and colleagues. Our
appearance reflects on ourselves and the company. The goal is to be sure that
we maintain a positive appearance and not to offend customers, clients, or
colleagues.

(a) Employees are expected to dress in [casual, business casual, smart

casual, business] attire unless the day’s tasks require otherwise.
(b) Employees must always present a clean, professional appearance.
(c) Everyone is expected to be well-groomed and wear clean clothing, free of
holes, tears, or other signs of wear.
(d) Clothing with offensive or inappropriate designs or stamps are not
allowed.
(e) Clothing should not be too revealing.
(f) Clothing and grooming styles dictated by religion or ethnicity are exempt.

7.1.2 Dress Code Violations

Managers or supervisors are expected to inform employees when they are
violating the dress code. Employees in violation are expected to immediately
correct the issue. This may include having to leave work to change clothes.

Repeated violations or violations that have major repercussions may result in

disciplinary action being taken up to and including termination.
 www.Jbugayong.ph
366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

7.1.3 Cell Phone Use Guidelines:

The following are JBUGAYONG Inc.’s basic guidelines for proper employee cell
phone use during work hours. In general, cell phones should not be used when
they could pose a security or safety risk, or when they distract from work tasks:

(a) Never use a cell phone while driving.

(b) Never use a cell phone while operating equipment.
(c) Do not use cell phones for surfing the internet or gaming during work
hours.
(d) Avoid using work cell phones for personal tasks.
(e) Avoid using personal cell phones for work tasks.
(f) Do not use cell phones during meetings.
(g) Do not use cell phones to record confidential information.

We realize cell phones can be great tools for our employees. We encourage
employees to use cell phones when:

(a) For making or receiving work calls in the appropriate place and situation
to do so.
(b) For other work-related communication, such as text messaging or
emailing in appropriate places and situations.
(c) To schedule and keep track of appointments.
(d) To carry out work-related research.
(e) To keep track of work tasks.
(f) To keep track of work contacts.

7.1.4 Disciplinary Action:

Improper use of cell phones may result in disciplinary action. Continued use of
cell phones at inappropriate times or in ways that distract from work may lead to
having cell phone privileges revoked.

Cell phone usage for illegal or dangerous activity, for purposes of harassment, or
in ways that violate the company confidentiality policy may result in an employee.
 www.Jbugayong.ph
366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

8. Fairness

8.1 The company depends on its relationship with the stakeholders which revolves
around trust and respect that is in compliance with the laws, rules and regulations. The
company and its employees at any level are not to take advantage of others through
manipulation, concealment, abuse of confidential information, falsifying of material facts, or
any other unfair dealing. Doing so violates the Code of Ethics.

8.2 Our business partnerships are based on mutual respect and rewards that are
compliant with the law on competition. We sell services based on their quality, functionality,
and affordable cost, and we are committed to ethical and fair competition. We will not
illegally collaborate or coordinate our efforts with other businesses; we will make separate
pricing and marketing decisions. We won't engage in or support illegal boycotts of specific
customers, nor will we offer or solicit improper fees or gratuities.

8.3 Any form of assault against the impartiality of a tendering process is not
permitted.We refrain from engaging in conduct that undermines the credibility of
competitors as well as the reputations of any business partners.

8.4 We do not withhold payments from our partners out of malice or in violation of the
law, and we do not permit such behavior in our supply chain. We also oppose the unethical
"debt chain" approach.

8.5 Each member of our staff is accountable for upholding all competition, consumer
protection, and fair marketing laws while performing their duties. Consumers and business
partners must be treated fairly and equally, and goods and services must be advertised in a
way that is truthful, accurate, and reveals all pertinent information (fair marketing and
advertising).

9. Gifts and Hospitality

9.1 Employees may accept modest, unsolicited gifts and business entertainment,
but never money or gift cards.

9.1.1 We should avoid any actions that create a perception that JBUGAYONG Inc.
provides favorable treatment to outside entities in exchange for business courtesies
such as gifts, gratuities, meals, hospitality, entertainment or other benefits.

9.1.2 However, employees may accept unsolicited business courtesies of modest

value that promote successful working relationships and goodwill with our business
partners. A good rule of thumb is whether you would be comfortable telling your
manager about the courtesy or having it be known by the public. Be transparent.
 www.Jbugayong.ph
366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

9.1.3 Employees who award business or who can influence the allocation of
business must be particularly careful to avoid actions that create the appearance of
favoritism or that may adversely affect the company’s reputation for impartiality and
fair dealing

9.1.2 We may accept and offer occasional gifts and hospitality that are customary
and conform to reasonable ethical practices of the market, provided that they are
not inappropriately excessive, not frequent and do not reflect a pattern of frequent
acceptance, does not create the appearance of an attempt to influence business
decisions. Only trivial gifts with low value can be accepted. All other gifts must be
politely refused or, if received through post, returned to the donor. If return is not
possible it shall be offered for charity or community purposes. It is the responsibility
of the person offering, providing, receiving or accepting the gift to decide whether
the gift is appropriate.

9.1.3 Employees may accept:

● Flowers
● Food and drink (such as wine, chocolates, edible arrangements)
● Gifts of a modest value that mark a special occasion, like closing a deal
● Gifts of modest value, like shirts, hats, water bottles and other swag
● Meals or entertainment that are shared with the person who has offered to pay
so long as they are reasonable and infrequent

Employees may not accept:

● Cash or cash equivalents (such as gift cards)

● Expensive gifts including sports and entertainment tickets unless you have
obtained Conformity pre-approval
● Any gifts from a vendor or supplier while negotiating a contract or a deal with
them

9.3.1 In general, receiving business courtesies valued at more than Php 10,000 per
person will not be permitted. Local restrictions may impose lower limits. Please seek
guidance from conformity@jbugayong.com and review the global Policy against
Bribery and Corruption for other limits.

Employees requesting Conformity pre-approval to accept business courtesies

should fill out the business courtesy pre-approval form. For general questions,
please contact conformity@jbugayong.com

9.2 Giving Gifts & Entertainment

9.2.1 As long as we adhere to regional regulations and the recipient's internal

policies, we are permitted to offer small presents, branded swag, hospitality, meals,
 www.Jbugayong.ph
366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

and entertainment. An employee is never allowed to use personal resources or

money to complete tasks that can only be completed using Uber resources.
Business courtesy must be properly recorded in Expense according to established
company procedures.

9.2.2 The same rules apply for both giving and receiving courtesies. To offer or give
courtesies valued above Php 10,000, check first with conformity@jbugayong.com.
Local restrictions may impose lower limits. Please consult with
conformity@jbugayong.com and check the global Policy against Bribery and
Corruption for other limits. You also should seek guidance from the business partner
receiving the courtesy since the policies of the recipient’s company may be more
restrictive. Special rules apply for dealings with governments, so check the next
section.

9.2.3 Employees may give:

● Company swag (like JBUGAYONG branded shirts, hats, water bottles)

● Modest gifts
● Reasonable meals or entertainment to discuss business

Employees may not give:

● Cash or cash equivalents

● Expensive gifts without Conformity approval
● Paid travel without Conformity approval

9.2.4 Employees requesting Compliance pre-approval to give business courtesies

should fill out the business courtesy pre-approval form. For general questions,
please contact compliance@uber.com.

10. Contracting, financial reporting & recordkeeping

10.1 Our financial statements, books, records, and accounting records must accurately
and fairly reflect our transactions. We are dedicated to conducting business with partners
who are engaged in genuine commercial endeavors and who have access to monies from
lawful sources because we detest any forms of money laundering.

10.2 We commit ourselves to fair taxation and to avoid all tax evasion practices,
including such as failing to issue receipts or accounting fake expense invoices.

10.3 Each member of the staff is required to adhere to accounting procedures, ensure
that company transactions are accurately and completely recorded and documented, and
guarantee that all disclosures made in financial reports are complete, truthful, accurate,
timely, and easily understood. Any audit cannot be illegally influenced, tricked, or misled by
any member of staff.
 www.Jbugayong.ph
366 Fule Sahagun Street, Calauan, Baguio City 2600
T/0966-254-9584

11. Reporting and Enforcement

11.1 Disciplinary action

(a) Actions prohibited by this code must be reported to the Audit Committee
Chairman or the company’s outside legal counsel.
(b) After receiving a report of any alleged violation of any part of the code, the
Audit Committee Chairman and the company’s outside legal counsel shall
notify each other of the alleged prohibited action and must then promptly take
all appropriate actions necessary to investigate.
(c) The company ensures prompt and consistent action against violations of the
code.
(d) If the investigation is done, and the Audit Committee determines that a
violation of the Code has occurred, the member/employee shall report to the
full Audit Committee and the Audit Committee will take appropriate
disciplinary actions.

11.2 Waivers

(a) Any violation of this code may be waived at the discretion of the Board of
Directors (in the case of a violation by a director or executive officer) and the
Chief Executive Officer of the Company (in the case of a violation by any
other person).