The Anti-Bribery & Anti-Corruption ("ABAC") Policy & Guidelines (referred to as the "Policy & Guidelines") outlines the guidelines and procedures for MR. D.I.Y. Philippines any regulations or directives issued by relevant authorities will take precedence over the existing operational policies and procedures outlined herein and shall be supplementary to this Policy and Guidelines. 

The Policy & Guidelines apply to the following parties:

a. Directors of MR. D.I.Y. Philippines, both executive and non-executive, unless specified otherwise in this Policy & Guidelines;

b. All employees within MR. D.I.Y. Philippines; and

c. Suppliers, subcontractors, consultants, agents, representatives, and other entities engaged in work or services for or on behalf of the MR. D.I.Y. Philippines.

The primary objectives of this Policy & Guidelines are as follows:

a. To establish ABAC principles organization-wide;

b. To ensure consistent application of standardized ABAC policies and guidelines throughout MR. D.I.Y. Philippines by all relevant personnel; and

c. To enforce strict adherence to the ABAC Policy & Guidelines in all business operations within MR. D.I.Y. Philippines.

i. Commits to preventing bribery and corruption within the Group's business conduct;

ii. Approves the ABAC Policy & Guidelines;

iii. Ensures alignment of ABAC Policy & Guidelines with the Group's strategy;

iv. Oversees ABAC governance, ensuring effective ABAC management system implementation, maintenance, and review, including the Policy & Guidelines; and

v. Promotes a suitable ABAC culture within the Group.

i. Provides overall guidance on establishing, implementing, and periodically reviewing ABAC Policy & Guidelines;

ii. Integrates ABAC Policy & Guidelines into key functions like HR, procurement, and finance, enhancing controls to support ABAC Policy & Guidelines requirements;

iii. Allocates resources for a robust ABAC Policy & Guidelines;

iv. Offers adequate training and awareness programs for Group employees;

v. Communicates ABAC Policy & Guidelines internally and externally;

vi. Cultivates an appropriate ABAC culture within the Group; and
vii. Supports relevant management personnel in preventing and detecting bribery and corruption.

i. Ensures ABAC Policy & Guidelines compliance within the Group;

ii. Reports non-compliance cases to ARMC, along with follow-up action status;

iii. Addresses inquiries about MR. D.I.Y. Philippines’ ABAC Policy & Guidelines and practices within the Group; and

iv. Facilitates periodic corruption risk assessments.

i. Implements ABAC Policy & Guidelines, enhancing controls for relevant functions under their responsibility;

ii. Adheres to ABAC Policy & Guidelines requirements; and

iii. Reports suspected bribery or corruption through MR. D.I.Y. Philippines’ whistleblowing channel.

Any updates, improvements, or amendments to this Policy & Guidelines require authorization and approval by the CEO. Changes will clearly indicate new, modified, or deleted policies/procedures for version control.

a. MR. D.I.Y. Philippines employs a Corruption Risk Management Framework following ISO 37001:2016 and Adequate Procedures Guidelines. The framework covers governance, structure, assessment, and risk integration into Group operations to ensure continuous monitoring of identified corruption risks.

b. The ARMC, comprising Senior Management and selected HODs, oversees and ensures accountability for identified corruption risks and corresponding controls. Risk parameters like financial impact, customer relationships, and reputation/media assess risk consequences in and impact severity, guided by MR. D.I.Y. Philippines’ risk appetite.

c. Risk Register is developed to capture potential corruption scheme(s), possible root causes, existing key controls and impact are maintained for the Group. The risks are then evaluated based on the likelihood of occurrence and criticality of impact (i.e., Low, Medium, High and Extreme) to provide a basis for Management in the strategic decision-making process and mitigation of corruption risks.

d. ARMC of MR. D.I.Y. Philippines shall conduct regular risk assessment i.e., on a yearly basis and/or when there is a change in law or circumstance of the business to ensure the identified corruption risks remain relevant and adequate mitigating controls are discussed and implemented.

e. Specific anti-corruption plans shall be identified by the respective Heads of Department and reported to the CEO / CFO for review and monitoring.

MR. D.I.Y. Philippines acknowledges the cultural significance of gift-giving in the Philippines, while emphasizing the imperative of upholding operational integrity. Furthermore, we recognize the value of fostering positive relationships with vendors, customers, and government officials through responsible gift and corporate hospitality practices, donations, and sponsorships. The following policies and procedures are designed to preserve our company's reputation and shield our employees from allegations of bribery, corruption, or inappropriate external influence for personal gain.

i. Purchase requisition pertaining to gift and corporate hospitality shall be a reasonable amount, subject to the approval of the CFO and in line with the Limit of Authority (“LOA”). Such gifts and hospitality shall fulfil ALL the following conditions prior to approval:

1. They are intended to maintain good rapport with the vendors/ customers of the Group and government officials;

2. They are limited, customary and lawful under the circumstances;

3. They do not have or perceived to be affecting action(s) or decision(s) of the receiving party;

4. There shall be no expectation of any specific favour, benefit or advantages from the intended recipients;

5. There shall not be any corrupt/ criminal intent; and

6. The giving out of gifts or corporate hospitality shall be transparent.

ii. Purchase of gift or corporate hospitality, subject to the fulfilment of condition as stipulated in Clause VIII (a), is only permitted to the respective HODs and above within the Group.

iii. Any purchase of gift or corporate hospitality in nature exceeding PHP 10,000.00 requires second approval from the CEO.

iv. Purchase requisition pertaining to gift and corporate hospitality for government officials from the public sector, it shall be restricted to the statutory limit assigned by the applicable laws and regulations of the respective countries. However, gifts in the form of cash or cash equivalent shall never be given or offered to any public or government officials.  

v. Purchase requisition on gift or corporate hospitality shall be indicated with purpose of requisition, including client or vendor name or representative details.

vi. In the event of any dispute between any internal practice, existing policy and or procedure already embedded within the constitution of the organization prior to the commencement of this ABAC Policy & Guidelines. All disputes on limits set in Section H of this ABAC Policy & Guidelines shall prevail over all other documentation.

i. Under no circumstances that an employee of the Group shall receive or solicit for personal gift from an external party.

ii. Although the general principle is to immediately refuse or return such gifts, accepting a gift on behalf of MR. D.I.Y. Philippines is allowed only in very limited circumstances, whereby refusing the gift is likely to seriously offend and may sever MR. D.I.Y. Philippines’ business relationship with the Third Party. However, in no circumstances may an employee, director or his/her family/household members accept gifts in the form of cash or cash equivalent.

iii. Any gift received by an employee of the Group from an external party(s) requires declaration to the CEO.

i. Employees of the Group shall exercise proper care and judgment prior to accepting entertainment from an external party. This is vital to safeguard the Group’s reputation and to protect its employees from allegations of soliciting bribes or corruption. 

ii. Any entertainment received by an employee of the Group from an external party(s) requires declaration to the CEO.

a. All Corporate Social Responsibility (“CSR”) related sponsorships and donations shall be made in accordance with MR. D.I.Y. Philippines’ policies with prior approval by the CEO.

b. Given the nature of MR. D.I.Y. Philippines’ business, government agencies or local authority bodies may request for sponsorship and/ or donations in respect of CSR events. As part of MR. D.I.Y. Philippines’ commitment to corporate social responsibility and sustainable development, as a general matter, MR. D.I.Y. Philippines provides such assistance in appropriate circumstances and in an appropriate manner.

c. Such requests shall be examined for legitimacy and not be made to improperly influence a business outcome. The proposed recipient shall be a legitimate organization and appropriate due diligence shall be conducted to ascertain whether any public officials are affiliated with the organization. Any red flags shall be resolved before committing any funds to the program. Even requests determined to be legitimate shall be carefully structured to ensure that the benefits reach their intended recipients.

d. If any employees or Directors are in any doubt as to whether a charitable contribution or social benefit is appropriate, Management shall seek legal consultation accordingly.

a. The Policy & Guidelines, in accordance with MR. D.I.Y. Philippines’ commitment to contribute to the community coupled with its values of integrity and transparency, all sponsorships and donations shall comply with the following:

i. ensure such contributions are allowed by applicable laws; 

ii. obtain all the necessary internal and external authorizations; 

iii. be made to well established entities having an adequate organizational structure to guarantee proper administration of the funds; 

iv. be accurately stated in the company’s accounting books and records; and

v. not to be used as a means to cover up an undue payment or bribery; 

b. Examples of red flags to look out for are as follows: 

i. The proposed recipient /organization have affiliations with a Public Official or their relatives are involved; 

ii. The contribution is made on behalf of a Public Official; 

iii. There is a risk of a perceived improper advantage for MR. D.I.Y. Philippines; or

iv. The proposed recipient is based in a high-risk country, the request comes from a high-risk country, or the activity takes place in a high-risk country. 

c. MR.D.I.Y. Philippines requires employees to use good judgment and common sense in assessing the requests. When in doubt, employees shall seek for legal advice or escalate the matter to the CEO and/or CFO to determine the authenticity of such requests.

d. Donation and sponsorship are only permissible with prior approval by the CEO. All donations and sponsorship payment shall be supported with an official letter of request from the requesting external party and proof of receipt.

e. Donations or sponsorship which are more than PHP 100,000 are subject to approval by the BOD.

a. Facilitation payment to external parties, in particular, government officials, is strictly prohibited as it is seen as a form of bribery and corruption. Extortion payment to an external party, on the other hand, is not categorized as an illegal activity by legal means, as the health, safety and liberty of one is paramount.

b. The CFO shall maintain a record of such an event and report the payment to the relevant authority.

a. Facilitation payment to external parties, in particular, government officials, is strictly prohibited as it is seen as a form of bribery and corruption, unless it can be proven that such payment is legitimate and supported by an official receipt.

b. Facilitation payment shall not be in any way or form be disguised or translated in personnel remuneration package.

c. Subject to the fulfilment of criteria in Clause XII (a), facilitation payment requests may be approved by the CEO.

a. Extortion payment to any party shall not be made unless the employee(s) and or their families health, safety and or liberty are threatened.  

b. Subject to the fulfilment of criteria in Clause XIII (a), extortion payment request may be approved by the CEO.

MR. D.I.Y. Philippines recognizes the objective of due diligence procedures on customers, business partners, suppliers and employees to evaluate the risk of bribery and corruption associated with these parties. This also serves as a basis for decision making, whether to accept or reject before entering into any contractual arrangement or business dealing. 

MR. D.I.Y. Philippines Group shall require due diligence procedures to be applied on the key stakeholders below:

i. Suppliers or agents; 

ii. Customers;

iii. Business partners; and  

iv. Employees.

MR. D.I.Y. Philippines is committed to uphold the highest standard of ethics and integrity in all aspects of its procurement activities by:

i. Adhering to the procurement policies and procedures;

ii. Avoiding dealing with any supplier, sub-contractors, or agents who are known or reasonably suspected of corrupt practices;

iii. Ensuring that all new suppliers/ subcontractors/ agents are subject to background assessment and conflict of interest checkA 'public or government official’ includes, without limitation, candidates for public office, officials of any political party, and officials of state-owned enterprises other than MR. D.I.Y. Philippines. Caution shall be exercised when dealing with public officials. Providing gifts, entertainment or corporate hospitality to public officials or their family/ household members is generally considered a ‘red flag’ situation in most jurisdictions.  prior to registration and acceptance;

iv. Communicating the Policy & Guidelines requirements to supplier, sub-contractors or agents;

v. All contracts / agreements entered with supplier, sub-contractors or agents to incorporate a provision whereby MR. D.I.Y. Philippines retains right to audit third party compliance with the Policy & Guidelines; and

vi. All agents are required to declare their adherence to the Policy & Guidelines requirements via Supplier ABAC Declaration Form. 

A Due Diligence Assessment Form shall be used in guiding MR. D.I.Y. Philippines employees undertake an assessment on the suppliers’, sub-contractors’, or agents’ background and reputation, including their conflict of interest (Please refer to Due Diligence Assessment Form). 

The results and/ or any concern raised during this due diligence assessment shall be communicated to and with approval from the CEO prior to entering into the relationship.

MR. D.I.Y. Philippines shall not provide non-business travel and hospitality for any government official or his/her family/household members without permission from the CEO in consultation with a lawyer.

Other MR. D.I.Y. Philippines’ policies and procedures on gift, entertainment and corporate hospitality shall also be abided by copies of which can be obtained from the Human Resource Department.

If approval is given to provide gift, entertainment or corporate hospitality to public officials, the Management shall ensure that the value of gift, entertainment or corporate hospitality shall comply with the applicable laws and regulations, including but not limited to REPUBLIC ACT NO. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) and REPUBLIC ACT NO. 3019 (Anti-Graft and Corrupt Practices Act).

Background screening on shortlisted candidate(s) is required during the evaluation stage of recruitment process (Please refer to Employee Background Check Form).

Key considerations prior to acceptance of shortlisted candidate(s) cover the following:

i. Past criminal records (if any);

ii. Potential fraud, bribery or corruption committed in the previous organisation;

iii. Verification of past employment or institution of learning references, where applicable; and

iv. Conflict of interest, i.e. relationship with any employee, vendor, customer or Director of the Group.

Recruitment due diligence results shall be vetted by the CEO prior to acceptance of the candidate.

Newly recruited employee(s) shall be provided with an onboarding program, including the briefing on MR. D.I.Y. Philippines’ ABAC Policy & Guidelines.

Whistleblowers are encouraged to report in good faith or to raise a concern about any attempted, suspected and actual bribery or corruption activities that violate the Policy & Guidelines at the earliest possible stage.

Upon making a disclosure in good faith, based on reasonable grounds:

i. the whistleblower shall be protected from any form of retaliation within MR. D.I.Y. Philippines Group; and

ii. The whistleblower’s identity will be protected i.e. kept confidential unless otherwise required by law or for purposes of any proceedings by or against MR. D.I.Y. Philippines Group.

Where a whistleblower makes a report not in good faith or reasonably believed not to be true, the whistleblower will not be protected and will be subjected to Disciplinary Action by MR. D.I.Y. Philippines Group in accordance with the Employee Manual  and/or Whistleblowing Policy and Procedures of MR. D.I.Y. Philippines.

The key information or documents below are to be provided by the whistleblower to facilitate further investigation, if required:

Whistleblower’s contact information 

i. Name (*)

ii. Designation

iii. Contact Number 

iv. Email Address (*)

a. Suspect’s information

i. Name

ii. Designation

iii. Contact Number 

iv. Email Address

b. Complaints / concerns

i. Incident date

ii. Affected parties

iii. Incident or event location

iv. Supporting documents (where applicable)

v. Other details or information which may assist the investigation

Whistleblowers shall report their concerns either in letter or via e-mail to the Whistleblowing Unit represented by the Legal Officer at [email protected] or mail the letter by marking “Private and Confidential” to the following address:

To: Corporate Legal Officer/ESG Lead

c/o: MR. D.I.Y. Philippines

Address: 

4F Xeland Building, 

Guerilla St. cor. Mayor Gil Fernando Avenue, 

Sto. Niño, Marikina City 1820, Philippines

a. As part of the internal monitoring process, CFO shall review the underlying controls of ABAC and identify any non-compliance incidents on a quarterly basis.

b. If any of MR. D.I.Y. Philippines Group’s key stakeholders as defined in Clause XIV are found to have breached any ABAC rules and regulations or this Policy & Guidelines, such breach may result to the following actions taken:

Key stakeholders	Actions taken
Employee	Disciplinary action by MR. D.I.Y. Philippines Group in accordance with the Employee Manual  and/or Whistleblowing Policy and Procedures of MR. D.I.Y. Philippines which includes termination of employment.
Suppliers/Agents/Customers	i. Subjected to BOD’s approval, retain business dealings; ii. Discontinue business dealings with immediate effect;  iii. Termination of contract with immediate effect; or iv. Legal proceedings if required.

c. MR. D.I.Y. Philippines shall engage with independent consultants to review and assess the adequacy and implementation of this Policy & Guidelines on a regular basis i.e., every three (3) years. 

a. Annual training and awareness program on ABAC shall be provided to MR. D.I.Y. Philippines employees and key stakeholders as defined in Clause XIV, as appropriate to their roles and considering the bribery risk assessment. This includes annual attestation and declaration conflict of interest (Please refer to Declaration Form for Conflict of Interest).

b. Updates on this Policy & Guidelines with regards to its content as well as regulatory requirements affecting the ABAC practices shall be communicated to MR. D.I.Y. Philippines employees and key stakeholders, defined in Clause XIV.

Marikina City, August 30, 2023.