Company's Policies
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1. Whistle Blowing Policy 

ECPI, being a member of the Transnational Diversified Group, Inc., adopts the group-wide policy on Whistleblowing.
Employees should report any suspected or known unethical and improper practice or other wrongful misconduct in violation of the Company’s Code of Conduct and other policies of the Company. Failure to report the same may be seen as compounding or assisting fraud and therefore may constitute improper conduct under the TDG Code of Discipline.

Acts covered by this Policy (“Covered Act”) include but are not limited to the following:

1. commission of a criminal offense against the Company, or any of its shareholders, directors, officers or employees

2. accounting or audit irregularities; i.e. acts related to the misstatement and/or destruction of the Company’s accounting documents, and acts that fraudulently influence, coerce, manipulate, or mislead any independent public or certified accountant engaged in conducting an audit for the purpose of rendering the Company’s financial statements materially misleading

3. falsification of Company records

4. acts meant to defraud the Company

5. solicitation or acceptance of cash, gifts or favors to perform a function, which the employee is required by the job description to perform (e.g., accepting gifts or money from a supplier in order to gain additional business)

6. taking of money or money instruments from the premises of the Company without authoritative permission

7. taking or removal of any merchandise or property from the premises of the Company without permission, including, without limitation, utilization of Company’s goods and/or services to support the employee’s own business

8. any act or omission which causes an employee to be paid for time not actually worked

9. any act or omission in violation of the Company’s Code of Conduct

10. suppression or concealment of any information relating to the above.

2. Conflict of Interest Policy

ECPI, being a member of the Transnational Diversified Group, Inc., adopts the group-wide policy on Conflict of Interest.

Once hired, no employee may engage in any business or undertaking that is directly or indirectly in competition with that of the company and its affiliates or engage directly or indirectly in any undertaking or activity prejudicial to the interests of the company or to the performance of his/her job or work assignments. The same provision will be implemented for a period of one (1) year from the date of an employee’s resignation, termination or separation from the company.

For the avoidance of doubt, the preceding non-compete clause as contemplated herein shall mean that during the aforesaid non-compete period, the resigned/terminated/ separated employee shall not own, manage, operate, consult or be an employee in any business substantially similar to or competitive with the present business of the company and/or its subsidiaries or affiliates or such other business activity which the company and/or its subsidiaries or affiliates may substantially engage in during the term of such employee’s employment. During the said non-compete period, the employee will not be employed or engaged in any capacity whatsoever by any firm or entity, while not engaged in business substantially to that similar to the company and/or its subsidiaries or affiliates, will assign such employee to work for a customer, firm or another entity engaged in such business.

3. Insider Trading Policy

ECPI generally adopts the policies on insider trading as espoused in the Securities and Regulation Code.
An insider cannot sell or buy a security of the issuer, while in possession of material information with respect to the issuer or the security that is not generally available to the public.

A purchase or sale of a security of the issuer made by an insider or such insider’s spouse or relatives by affinity or consanguinity within the second degree, legitimate or common-law, shall be presumed to have been effected while in possession of material non-public information if transacted after such information came into existence but prior to dissemination of such information to the public and the lapse of a reasonable time for the market to absorb such information.

An insider is prohibited to communicate material non-public information about the issuer or the security to any person who, by virtue of the communication, where the insider communicating the information knows or has reason to believe that such person will likely buy or sell a security of the issuer while in possession of such information

4. Related Party Transaction Policy

All related party transactions with ECPI’s Directors, Officers, Stockholders, Related Interests, Affiliates and the likes must be properly identified and reviewed by the Board of Directors and all information disclosed to ensure that the same are made at arm’s length basis.

5. Policy and Data Relating to Health, Safety and Welfare of Employees including company sponsored trainings

The Company adopts the TDG Group-wide policy on health, safety and welfare of employees

a. Every employee should be safety conscious and concerned with the preservation of health and good housekeeping in the workplace. To ensure the safety and protection of employees, office premises, properties and facilities, everyone is required to comply with the health, security and safety policies of TDG.

b. Every employee should undergo the annual check-up with the TMDC to ensure that the employees are fit to work and free from ailments.

c. As part of TDG’s people development program and group-wide quality initiatives, employees are required to attend training programs for quality improvement, as well as for personal and career development. In addition, rotation (transfer or reassignment) is an integral aspect of TDG’s Total Organizational Development Program and it is management’s prerogative to reassign employees to a different role/function, department, or Member Company as part of this program.

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