I. BASES OF THE CODE

A. This Code of Ethics is aligned with FAMI’s Vision, Mission Statements and Values.

1. Vision

To be the preferred exchange traded fund in the Philippines. 

2. Mission

As trusted stewards who promote investment literacy, create innovative investment solutions, and provide exceptional customer experience, FAMI and the FMETF will transform Filipinos from savers to investors. 

3. Values

• Teamwork 
• Respect  
• Integrity
• Innovation Passion for Excellence

II. SCOPE OF THE CODE

This code is applicable to all directors, officers, employees, consultants, and advisors of FAMI and all its mutual funds, herein also referred to as members of the FAMI Community.

III. OBJECTIVES OF THE CODE

1. To promote a corporate culture of professionalism and maturity characterized by appropriate work ethics, socially acceptable behavior and high moral standards.

2. To enable all members of the FAMI community to challenge business practices or behaviors that may undermine the principles and guidelines adhered to by the company, thereby, protecting its interests, image, reputation, and integrity in all dealings.

3. To instill among all directors, officers, employees, consultants, and advisors a commitment and dedication to the virtues of honesty and integrity, together with a high sense of prudence, responsibility and efficiency in the conduct of their duties.

4. To ensure that the behavior of all members of the FAMI Community reflects the values that FAMI stands for.

IV. VIOLATIONS OF THE CODE

A. Any individual violating this Code of Ethics is subject to appropriate disciplinary action, up to and including dismissal from employment with FAMI and, if appropriate, prosecution by FAMI.

B. The appropriate disciplinary action is recommended by the Administrative Committee on Discipline (ACD) and approved by the President and the Corporate Governance Committee.

V. ADMINISTRATIVE COMMITTEE ON DISCIPLINE (ACD)

A. The ACD comprised of HRD Officer, Compliance Officer, Head of Finance, and the Immediate Superior/Next Level Superior of the reported employee and / or any relevant individual deemed appropriate by the President to be able to provide necessary and relevant input to the case.

B. The ACD has the responsibility to administer and enforce the provisions of this Code of Ethics by recommending action to the President then the Corporate Governance Committee.

C. The ACD may investigate matters upon its own initiative or as requested from any employee, officer or director. Rules and procedures as to the conduct of its functions and investigations will be drawn up by the members and amended as required.

D. All directors, officers and employees are expected and encouraged to report any suspected violations of the FAMI Code of Ethics or any of its policies or of any statute or regulation to the ACD.

VI. STANDARDS OF BUSINESS AND WORK ETHICS

1. AVOIDANCE OF CONFLICT OF INTEREST

(a) Dealings with our Directors, Officers, Stockholders, and their Related Interests are made in the regular course of business and upon terms not less favorable to FAMI than those offered to other financial institutions.

(b) We do not become engaged in personal activity that directly competes or may potentially compete with the company’s business.

( c)  If any officer or employee or member of his or her family within the first degree of consanguinity invests, directly or indirectly, in a business in excess of 5% of any class of issued or outstanding securities of a corporation or any percentage of ownership in a partnership, or operates a sole proprietorship doing business with FAMI, that investment must be reported to the Corporate Secretary & ACD.

(d) We do not purchase any real or personal property which FAMI owns or in which it has a security interest except in accordance with company’s rules and procedures and with full value being paid/to be paid and the transaction properly documented on the books of FAMI. The property must also have been made available to the general public and the purchase must be subject to applicable Related Party Transactions Policy.

(f) We do not directly or indirectly offer or receive any gift, gratuity, other payment, or entertainment from any person, be they clients, vendors, suppliers, business partners, subordinates, etc. that might affect the employee’s judgment or actions in the performance of his/her duties.

(g) We do not engage in personal lending, trading or other similar business activity, borrowing & lending of money between/among employees and clients, engaging in another employment without management approval, and solicitation of personal business for personal gain from clients, co-employees or the company’s business partners

(h) We do not have outside interests or employments that encroach on the time or attention which should be devoted to our corporate duties, adversely affect the quality of work performed, compete with the activities of FAMI, involve any use of the equipment, supplies or facilities of FAMI, infer sponsorship or support of FAMI on behalf of the outside employment, organization, or adversely affect the good name of FAMI.

(j) No corporate funds are to be used for political contributions without the prior approval of the Chairman of the Board or the President of FAMI.

(k) Any officer or employee desiring to become a candidate for an elective political office or to accept appointment to a national, state or local government office, board, commission committee, or similar entity requiring full time commitment, must have such activity approved through the ACD. If such approval is granted and the officer or employee is subsequently elected or accepts an appointment, he or she must resign from FAMI to avoid conflicting duties.

(l) Any officer/director employee authorized to hold a part time political office shall ensure that his department and behavior as a political official shall at all times be consistent with the standards set forth by FAMI through this Code of Ethics and other related policies, ensuring that his political activities shall not result in any adverse effect on the reputation and stature of FAMI.

2. RESERVATION OF CONFIDENTIAL INFORMATION

a) We do not disclose or provide confidential documents or strategic information to any third party, without expressed written consent of senior authority or the affected client, or unless authorized/required by existing laws. This includes, but is not limited to, information relating to clients, competitors, or suppliers of the company.

b) Disclosure to the public or to the media can only be done after disclosure to the SEC and PSE by the listed company’s authorized officers.