“The Seascape Inn Resort” Owned by: Ma. Sofia S. Pedernal Kareen I. Bartolo Reign Xei B. Catimbang Laurenz E. Burao Charles Toshiharu E. Tan (ABM 12-A) CODE OF CONDUCT AND ETHICS In Seascape Inn Resort, we feel that honesty, integrity, and fairness are valuable qualities in our industry. All employees of our organization must ensure that our entire honesty, loyalty, and ethical behavior enhance the organization's reputation. This Code of Conduct lays out the expectations for employee behavior as well as guidance for dealing with various scenarios. I. COMPLIANCE WITH LAWS, RULES AND REGULATIONS The Company maintains its awareness of and strives for constant compliance with all applicable laws, rules and regulations. The Company is committed to offering a work and business environment that provides confidence to its Representatives and guests that the Company conducts itself in a manner which is in adherence with applicable laws, rules and regulations. • • • II. You are responsible for knowing, understanding and complying with the rules and regulations of the Company. Please see the most current Vail Resorts Employee Handbook for a detailed description of the relevant programs, policies and procedures. The Company shall comply with all laws, rules and regulations enacted by any governmental entity, including all environmental, health and safety laws and regulations. The Company shall safeguard all physical, financial, informational and other Company assets. CONFLICT OF INTEREST Make sure that there is no conflict of interest in your dealings with customers, contractors, colleagues and any stakeholder. The Company has adopted policies regarding potential conflicts of interests in an effort to promote honest and ethical conduct. The Company desires to maintain a reputation of responsible and fair business practices. III. CORPORATE OPPORTUNITIES You are prohibited, without the consent of the Executive Management or the Board of Directors as the case may be, from 1) Taking for your own personal account, business opportunities arising from the use of Company property, information or your position within the Company. 2) Using Company property, information or your position for personal gain 3) Competing with the Company directly or indirectly IV. USE AND DISCLOSURE OF CONFIDENTIAL INFORMATION The Seascape Inn desires to offer full, fair, accurate, timely and understandable disclosure in financial and other reports filed by the Company for purposes of investor information and other public communications. The Company has established internal controls and procedures to ensure the accuracy of all information provided by the Company in connection with such disclosures. Disclosing directly or indirectly to anyone outside the Company, during their employment or thereafter, confidential information concerning the Company. Examples of such information include: • • • • • • Financial data Development plans and strategies Business plans and strategies Customer and supplier lists Marketing and advertising plans and strategies Organisation Charts, grade and salary data and policy and procedure manuals. Using directly or indirectly any confidential information concerning the Company subsequent to the end of their employment with the Company. V. GIVING AND RECEIVING GIFTS Make sure that you do not ask for any gift or favor from anyone if that gift or favor it may influence on the way you do on your job. Do not offer any gift or favor to anyone in order to influence that person in the way that he/she does the job and never offer any payment to anyone, in order to exert any influence on the way that person does business. Be aware that while moderate business entertaining is acceptable, you must be guarded against hospitality that appears to be aimed at influencing the way someone does his/her job. You should turn down invitations to meals or entertainment that are excessive in nature or frequency, so as to avoid loss of objectivity when conducting the Company’s business. You must always strictly abide by the entertainment policy of the Company, which is guided by the highest ethical standards. VI. SAFEGUARD AND PROPER USE OF COMPANY ASSETS Keep a record of all assets - see different types of business assets. Carry out regular asset checks, including stock and inventory checks. Carry out a risk assessment for different types of assets. Restrict access to assets such as stock, cash or data, where appropriate. VII. PERSONAL CONDUCT AND ETIQUETTE This will be the set of behavior rules you live by, guiding every action you take in life. Try to set behavior standards for yourself that are realistic and flexible. Be aware that Personal conduct whether on or off duty that adversely affects the image or reputation of the Company is not acceptable. Deal in straight, honest, courteous and efficient manners with anyone you come into contact with in public or in private. VIII. PROPER ACCOUNTING AND DOCUMENT RETENTION The Company shall follow General Accepted Accounting Procedures (GAAP), as well as all generally accepted accounting principles, standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts. IX. DEALING WITH AUDITORS Any person in a position of providing approvals listed within this Code shall maintain written records of these approvals and shall make them available to auditors or investigators, if necessary. No employee shall make a false or misleading statement to any internal auditor or investigator or any external auditor or investigator engaged by the Company during the performance of their duties. X. REPORTING ILLEGAL OR UNETHICAL BEHAVIOUR As an employee of the Company, you are encouraged to report promptly on any inappropriate practices or actions according to the guidelines enclosed in the Whistleblowing Policy. XI. INFORMATION SYSTEMS POLICIES The Code is a set of policies and procedures that set forth the way the Company and its employees should behave and operate in order to achieve the ethical principles of this Company. By consistently applying such policies and procedures and conducting our business practices according to the following principles, we are able to offer evidence of what we believe in as a Company in the course of business and in our position in the community. The Code applies to and should be followed by all employees, consultants, agents and anyone acting on behalf of The Seascape Inn, its subsidiaries and associated business units (hereinafter collectively referred to as “Representatives” or “You”). You are responsible for being aware of the applicable procedures and policies of the Code and to understand that business results never take precedence over compliance with the Code. XII. RESPONSIBILITIES TO THE COMMUNITY Communities also have rights and responsibilities, both to the members of the community and other communities that they are a part of. An empowered community understands these relationships and how these relationships impact on the community, and other communities that are a part of it. XIII. RELATIONS WITH CONTRACTORS AND SUPPLIERS The Company’s Contract Policy is designed to ensure a uniform and consistent approach to negotiations, agreements and contracts entered into by an employee or anyone acting on behalf of the Company. You are prohibited from accepting any cash, loans, bribes or kickbacks for the purpose of influencing a business decision affecting the Company. If you are engaged in business dealings with governmental entities, you may not provide anything of value to employees of such entities on behalf of the Company for the purpose of influencing or affecting an official action. XIV. RESPONSIBILITIES TOWARDS STAKEHOLDERS AND GOVERNMENT OFFICIALS The Company shall appoint a Corporate Governance/Nominating Committee, a Compensation Committee, and an Audit Committee, in accordance with SEC and NYSE rules and timeframes. The Company Disclosure Committee will be in place to assure that financial and other reports, which require disclosure, are accurately and reliably prepared and reported. The Company shall appoint an Ethics Committee to provide leadership for the Company’s policies in connection with this Code. The Committee shall offer a system of review, guidance and counselling concerning the proper manner in which to achieve the highest level of integrity XV. RECRUITMENT AND EMPLOYMENT PRACTICES Company Managers must make sure that they comply with all occupational health and safety laws and provide good and safe working conditions Company Managers must ensure that the dignity and individuality of every Team Member is respected. The privacy and confidentiality of employee records will be safeguarded. The Company endeavours to provide, equality of opportunity and treatment for all its employees on the basis of merit and ability, in the fields of recruitment, training, promotion, transfer, benefits and discipline, and will not discriminate or harass on the basis of race, sex, religion, colour, ancestry, national origin, handicap status and age. XVI. RESPONSIBILITY FOR APPLICATION OF THIS CODE OF CONDUCT AND ETHICS This Code is not intended to be a comprehensive rulebook and cannot address every situation that employees may face. Company Managers are strictly accountable for the application of this Code of Conduct and Ethics within the operation/ business unit/ department. Company Managers will contact their reporting heads whenever they are in any doubt about any part of this Code. They are responsible for soliciting from their reporting heads any training or other support that they deem necessary for the application of this Code. XVII. ENVIRONMENTAL COMPLIANCE It is our policy to conduct business in an environmentally friendly manner that has the least amount of negative influence on the environment. We are dedicated to reducing and, where possible, eliminating the use of any substance or material that may harm the environment, reducing hazardous waste generation and disposing of all waste in safe and responsible ways, reducing environmental risks by employing safe technologies and operating procedures, and being prepared to respond appropriately to accidents and emergencies. Environmental law violations are punishable by both monetary fines and jail. Employees are expected to follow all applicable environmental regulations. XVIII. POLITICAL PARTY PARTICIPATION Employees are generally discouraged from engaging in political activities that could bring the Organization into disrepute. Employees have the right to express their political beliefs as long as the views expressed are solely their own and do not involve the Organization. During paid Organization time, the employee will avoid any affiliation with or action related to a political party. We do not contribute to political parties at any level of government as a general rule. OUR ADVOCACY “The Seascape Inn Resort” that aims to provides an excitement and happiness to all its visitors and customers will also consider environmental awareness. Environment is not just a simple thing to ignore and waste, it is one of the most important aspects in our lives that we need to protect and conserve. That's why “The Seascape Inn Resort” advocates Environmental Protection and Conservation. The resort is committed to reducing negative environmental impact, with some of the eco-friendly initiatives including the implementation of recycled, local and refillable products, and proper waste segregation. Also, no plastic or disposable items in the rooms, drinking water is served in glass bottles, and reusable bamboo straws are used to serve drinks. And we will include the implementation and signage on how visitors or customers can reduce their environmental impact. We will continuously improve the quality of environmental management by providing innovative solutions and initiatives on conservation, pollution control, waste management, and protection on environment towards environmental stewardship and sustainable development. THE SEASCAPE INN RESORT OUTREACH PROGRAMS Tree Maintenance Trees absorb CO2 and other potentially dangerous gases from the air, as well as creating an ecosystem that provides habitat and food for birds and other creatures. We take care of our trees at The Seascape Inn Resort since they are home to a variety of exotic fauna. Cleaning up the Beach To aid in its conservation, we actively participate in the preservation and cleaning up of the beach as well as the ocean. Clean Up schedules are available at the Front Desk if you want to join us. Garbage Collection Management For proper garbage disposal, color-coded garbage bins are installed around the resort. A healthy atmosphere is one that is clean. Single-Use Plastic Consumption Reduction Every year, an additional eight million tons of plastic are poured into the world's oceans, causing the deaths of marine species. The use of plastic in the tourism industry might contribute greatly to the ever-growing problem because most tourism activities take place in coastal regions and beaches, which the Philippines has in abundance. The increased plastic waste generated as a result of the COVID-19 pandemic response, which was done in the interest of people's health and safety, exacerbated the problem. Desalination of water The development of a desalination plant is in the works to provide the island with a drought-resistant, alternative water supply. Discovery Scouts They are a group of young people that are interested in Our Kids Program is aimed at instilling in children a passion for Mother Nature. The Tree House's afternoon activities begin at 4 p.m. every day. Marine Protected Sanctuary We're the Sea Guardians, and we're here to protect the seas. The health and conservation of our marine ecology are protected by protecting the island's surrounding waters from illegal fishing and caring for our reef.