Ethics Policy
"At Geltech, good behavior is good for business."
Geltech Metal & Engineering Services is committed to doing business in accordance with the laws and the highest ethical standards. The company and its employees strive to promote a culture of good governance by adhering to and upholding its core values of "Integrity" and "Quality" in their interactions with one another and with the company's stakeholders.
By INTEGRITY we mean that we shall act righteously, morally, and legally. We shall be honest in all the things that we do and do the right thing the right way.
By QUALITY we mean that we put quality as integral to our practices. Audit systems are in place to ensure that quality standards are implemented and maintained.
In its pursuit of excellence, Geltech Metal is committed to its values and principles, and we believe that we must act in accordance with them at all times. All employees are required to demonstrate the character necessary to meet the standards outlined in this code.
Geltech Metal is committed to:
- operates within the framework of applicable laws and regulations as well as business ethics
- conduct our business with integrity and quality
- treat each other and our community with respect
- provide a safe and secure work environment for each other's growth and development
- communicate clearly and honestly
- act legally and ethically
- report misconduct and support others who report misconduct
- adhering to our code of conduct and internal policies.
Here are the expectations that we should apply to our daily decisions and behavior in order to carry out our responsibilities with complete integrity and quality.
Expectations from Everyone. Simple questions to help employees make the right decisions:
- Why am I doing this? Is it ethical?
- Is it legal?
- Is it the right thing to do?
- Is it in accordance with the code?
- Will it boost the company's credibility?
If the answer to any of these questions is "NO", don't do it. If in doubt, ask guidance from management and/or the HR department.
In full compliance with the aforementioned policy statements, Geltech aims to uphold the highest standards of ethics including:
1. BUSINESS INTEGRITY: Geltech Metal is committed to closing any gaps between our intentions and actions, ensuring that our interactions with customers, employees, suppliers, and regulators are consistent with our stated goals and objectives, and focusing on conducting ourselves in an honorable manner within the organization.
The Management will always treat bribery, corruption, extortion, and embezzlement with zero tolerance.
a. Prohibition of Bribery: Geltech Metal is committed to making all forms of bribery illegal in our operations. Any form of bribery will not be tolerated. All employees are prohibited from giving, offering, or promising a bribe to anyone, as well as accepting a bribe from anyone, whether the bribe is direct or indirect.
Bribery can take many forms, including:
1. Kickbacks: This is the exchange of favors or compensation in return for a particular favorable treatment or decision. It involves a percentage of money that has already been received, usually as a result of coercion, pressure, or a secret agreement.
2. Bribing a Witness (Whistleblower): If a witness demands, receives, or accepts a bribe in exchange for altered testimony.
3. Rewards: Bribery entails offering a reward in exchange for the individual agreeing to comply. (e.i. “I will do something for you in return for something I will do for you.”)
b. Prohibition of Corruption: This refers to the abuse/misuse of entrusted power for personal gain. Dishonest behavior and/or practices by those in positions of power, such as managers, are strictly prohibited.
The following are some examples of fraudulent activity that is not tolerated at Geltech:
1. Payroll Fraud
2. Cash Theft
3. False Invoicing
c. Prohibition of Extortion: Geltech Metal prohibits the use of negative acts of violence or making threats to gain compliance from another. (e.i. “I will harm you if you do not perform this act for me.”) Blackmail, protection schemes and ransom are also prohibited.
d. Prohibition of Embezzlement: We will never try to trick any of our stakeholders financially. Geltech ensures that no records are tampered with in order to conceal illegal activity.
Any violation of these prohibitions may result in disciplinary action, immediate dismissal and, in the worst-case scenario, imprisonment.
By turning a blind eye to illegal or unethical behavior, the organization's integrity, honesty, and transparency suffer. To mitigate this, all employees are encouraged to always speak up if they see wrongdoing.
2. NO IMPROPER ADVANTAGE
a. Prohibition of Soliciting or Accepting Advantages
1. Members of Geltech Metal are prohibited to solicit or accept any advantages in the course of their duties.
2. The term "advantages" refers to more than just monetary, financial, and other material benefits. Non-monetary benefits, whether tangible or intangible, such as free service, favor, preferential treatment, and so on, are also included.
3. Never solicit any advantages from clients, suppliers, or anyone else who has a formal alliance with Geltech's business.
4. Regardless of whether the offeror has any business dealings with Geltech, all employees should always decline a personal advantage offered if accepting it would cloud your objectivity, cause you to act against Geltech's interests, or lead to perceptions or allegations of improper behavior.
5. Employees should decline invitations to lavish or excessive entertainment, whether in nature or frequency.
Employees may accept an advantage only if all of the following conditions are met:
the acceptance would not influence the outcome of a business transaction;
- it will not create an obligation to do something in return;
- it is made in an open and transparent manner;
- it does not occur on a regular or systematic basis;
- it is reasonable and proportionate, and are not lavish or excessive; and
- it is of such a nature and value that refusal appears impolite or unsociable.
Employees may accept reasonable foods and drinks provided by contractors, suppliers, customers or other parties with whom Geltech deals directly in a business capacity for consumption on the occasion, as long as there is no perception that it will, or is intended to, compromise sound business principles.
b. Prohibition of Offering Advantages: As symbolic acts of solidarity, felicitation, or gratitude, legitimate business may necessitate reasonable and proportionate offers of entertainment, sponsorship, or gifts to professional contacts. However, Geltech Metal must ensure the following:
1. Never offer advantages to any person, company, or public official who has business dealings with Geltech, whether directly or through a third party, for the purpose of influencing such person, company, or public official in any dealings with Geltech when Geltech's business is being conducted.
2. Facilitation payments, also known as "grease payments," are payments made to local officials in order to expedite or facilitate actions that the officials are already required to perform. Geltech Metal strictly prohibits any form of facilitation payment.
3. Obtain proper approval from the AVP Finance for any entertainment, sponsorships, gifts, charitable donations (honorarium), or other benefits for which you have been granted permission to offer.
Geltech Metal and its stakeholders are expected to do the following:
- No corrupt business behavior should be practiced, tolerated, or supported in any way.
- Never give, promise to give, solicit or accept any form of improper advantage.
- Check carefully to see if the grant of an advantage is in accordance with Geltech Metal’s business integrity standards.
Prohibition of Conflicts of Interest: Geltech Metal is committed to ensuring that all employees conduct their work objectively and avoid engaging in activities that could impact the Geltech’s or its employees' reputation. It may exist when an employee is involved in an activity or has a personal interest that could interfere with the employee's objectivity in carrying out Geltech duties and responsibilities. Among these activities are:
- Work for customers, suppliers, vendors, or competitors on the side;
- Other activities that may have an impact on the employee's objectivity and work performance;
- Activities that may have a negative impact on the company's and its employees' reputations; and
- Having a financial or business interest in a company that is a supplier, customer, or competitor to Geltech.
Our Commitment
1. Nepotism is prohibited. Geltech Metal will not give a family member or close friend special privileges or advantages at work in lieu of qualification. To prevent this, employees and managers can disclose the relationship and choose not to be involved in the hiring or promotion of that individual or role.
2. Self-dealing is prohibited. We will require our employees not to use their knowledge of company finances or access to funds for personal gain at the expense of Geltech. To avoid this conflict of interest, all Geltech monetary transactions will require the approval of the AVP Finance.
3. Gift issuance is prohibited. Geltech Metal or any of its employees will not accept gifts from external stakeholders in order to gain an advantage. Employees may accept unsolicited gifts that follow reasonable ethical practices, such as:
a. Flowers, fruit baskets, and other small tokens of appreciation for a special occasion.
b. Calendars, pens, mugs, caps, and t-shirts, as well as advertising or promotional items (nominal-value gifts).
c. Trophies and statues inscribed in recognition of a business relationship (symbolic gifts).
4. Insider trading is prohibited. We will make certain that employees who act ethically at all times are assigned to roles that require access to confidential information. To avoid this conflict of interest, employees who continue to act unethically and with bias will be removed from their position especially if they feel a strong temptation to act against the rules.
Guidelines to Avoid Personal Conflict of Interests
- Employees must always act in a fair and unbiased manner.
- When dealing with Geltech business matters, employees must prioritize the needs of the company over their own;
- Employees must avoid financial, business, and other transactions or situations in which their personal interests may conflict with Geltech's business interests;
- Employees must avoid situations or circumstances that may be interpreted as a conflict of interest.
3. DISCLOSURE OF INFORMATION
Effective Use of Information. Geltech Metal will use our technological resources effectively and efficiently to collect, store, control, use, protect, and dispose of other useful information so that it can be used properly and effectively without jeopardizing confidentiality.
Information Security. We will make every effort to prevent piracy and falsification, as well as the dissemination of Geltech-obtained information. When we receive confidential information from one of our stakeholders or a third party, we will keep it confidential and secure.
Personal Information Handling. We will collect, store, control, use, process, and dispose of personal information in accordance with applicable laws and regulations. We will also make every effort to prevent such information from being lost, falsified, or disclosed.
Information Disclosure. Geltech Metal is committed to providing timely, understandable, and relevant information about our financial situation, business policies, activities, and practices to our stakeholders in accordance with applicable rules and regulations. We will make every effort to conduct all business transactions in a transparent, fair, and accurate manner.
4. INTELLECTUAL PROPERTY
Geltech Metal will respect and protect the intellectual property rights of others, as well as customer and supplier information, while working to prevent or eliminate any infringements on our own. It is prohibited to use, copy, distribute, or alter software or other intellectual property without permission.
5. FAIR BUSINESS, ADVERTISING AND COMPETITION
a. Fair Business Practices: Geltech Metal should make the following considerations in order to conduct fair business.
1. Consumer interests are protected, as well as their rights to information, choice, and to be heard.
2. Quality is ensured through inspection and assurance of raw materials, packaging materials, and finished products.
3. Buyers should have accurate product information.
4. Offer consumers honest advertising, reasonable prices, and good value for money.
5. Communicate problems and difficulties immediately, and provide all relevant information about price changes, shortages, or delays to consumers through the use of email or phone call, in order to gain their trust.
b. Prohibition of Unfair Advertising Practices: Geltech Metal is committed to ensuring that our advertisements are fair and accurate, and that no misleading information is included.
c. Prohibition of Unfair Pricing Practices (Competition)
- Geltech Metal will adhere to the main objective of regulating and prohibiting monopolies and combinations in restraint of trade or unfair competition in order to improve the overall welfare of our consumers by providing them with more options at possibly lower prices.
- We will never agree to manipulate the prices of its products that are available to the public and customers.
- Geltech Metal adheres to Republic Act No. 10667, also known as the Philippine Competition Act.
Geltech will prohibit the following business activities in our daily operations:
1. Market Allocation (Monopoly): We will not agree to sell only to customers in specific geographic areas and refuse to sell to or quote intentionally high prices to customers in conspirator companies' geographic areas.
2. Bid Rigging (Secret Agreement): We, or anyone associated with Geltech, will not conspire with other entities to manipulate the market in order to maintain each entity's current market share and price.
3. Price Fixing: We will not participate in a competitor agreement to raise, fix, or otherwise maintain the price at which their goods or services are sold.
6. PROTECTION OF IDENTITY AND NON-RETALIATION
Geltech Metal is dedicated to fostering a "speak up" culture that encourages reporting, fair evaluation, and just and effective resolution of concerns.
1. Geltech Metal strictly prohibits retaliation, harassment or discrimination of any kind against anyone who makes a report in good faith.
2. Employees may raise their concerns without fear of retaliation through Geltech’s communication channels for reporting such as Suggestion Box, Compliance Hotline or directly reporting it to the HR Department.
3. We will ensure all issues/concerns can be reported, evaluated and get an honest, timely response in a structured, known and transparent system, free of conflict of interest or bias; ensure that the employee is protected for reporting.
a. Disclosure of the complainant's name will not be allowed unless the employee has given us permission.
b. Anonymous reporting of concern is available.
4. Employees usually report first to the supervisor. The management will ensure that they know how to constructively respond to employee concerns.
5. Employee rights must be protected even if the person is incorrect or unpleasant in raising the issue.
6. Employee concerns will be addressed in a closed-door meeting with Top Management or HR, or in the case of minor issues, during the general monthly meeting.
7. RESPONSIBLE SOURCING OF MINERALS
Geltech Metal’s Commitment
- To further the goals and objectives of the SEC's rules and regulations governing the supply of conflict minerals.
- To make certain that any tin, tantalum, tungsten, or gold derived from the Democratic Republic of the Congo or any of its neighboring countries (hereinafter referred to as "Covered Countries") will not be used in our manufacturing process.
- To determine whether our manufactured products contain Conflict Minerals, we conducted a supplier evaluation survey to determine whether any Conflict Minerals were used in the materials they supplied to us.
- If we discover the use of conflict minerals produced in facilities that are not considered conflict-free in any material, parts, or components we procure for use in our products, we will make every effort to transition the products to conflict-free status.
8. DATA PRIVACY POLICY
Geltech Metal ensures that data privacy rights are respected and upheld, and that all personal data collected from our stakeholders and other third parties is processed in accordance with the general principles of transparency, legitimate purpose, and proportionality as stated in the Data Privacy Act of 2021.
Geltech Metal has pledged to take steps to protect all personal information against theft, loss, or unauthorized access, copying, modification, use, disclosure, or disposal.
For the purposes of this policy, stakeholders or third parties whose personal information is being collected are considered data subjects.
- The reason or purpose for collecting and processing personal data must be disclosed to data subjects. (e.i. 201 file, statutory reporting)
- Data subjects shall have the right to correct information, particularly if it is incorrect or outdated, and to object to the collection of personal information within the limits permitted by privacy laws.
Geltech Metal shall ensure that personal information is only collected and processed for legitimate purposes by authorized personnel only.
Geltech Metal will investigate all complaints about our compliance with the Data Privacy Act of 2012.
- All complaints about privacy must be handled confidentially.