Company Policies

Employees, directors, stakeholders, clients, service providers and other third parties are encouraged to report, in good faith, knowledge of any misconduct, irregularity or act detrimental to the interests of the Bank and its stakeholders.

The reporting party or otherwise referred to as the “whistleblower” has choice of communication channels to report any knowledge of misconduct or irregularity. The report may be through the normal channel of reporting bank concerns which is through the direct supervisor/manager of the personnel or officer involved in the reportable behavior. However, if the reported misconduct or irregularity is not acted upon by the direct supervisor or in the judgment of the whistleblower, the direct supervisor is not in a position to address his report, the whistleblower may email his/her report to: #WhistleBlowingCommittee@eastwestbanker.com or call any of the following Designated Officers:

Officer Direct Line

• HR Head
  (+632) 8575-3093
• Chief Audit Executive
  (+632) 8464-2500 Local 2121
• Chief Risk Officer
  (+632) 8575-3384
• Chief Compliance Officer
  (+632) 8575-3829

If the issue to be reported is serious and sensitive, the whistleblower may directly approach the President and CEO or the Chairman of the Board of Directors. A member of the Board of Directors reporting an activity under this policy may raise his concerns to the Chairman of the Audit Committee, Chairman of the Corporate Governance Committee or the Chairman of the Board of Directors.

The whistleblower may disclose his/her identity or opt to remain anonymous. However, sufficient information must be provided to aid in the investigation of the reported misconduct, irregularity or improper activity. The whistleblower should refrain from obtaining evidence for which he/she does not have right of access but his/her cooperation in the investigation, if needed, is expected.

Ample protection is accorded to a whistleblower which includes, among others: (i) Confidentiality of identity and of the information reported; (ii) Non-retaliation against the whistleblower; (iii) Protection and security of his/her person and his/her family; (iv) Transfer to another unit; and/or, (v) Reinstatement to the same or comparable position and back benefits and pay, if warranted by the circumstances.

On the other hand, any person implicated in the reported act is accorded the right to be informed of the act he/she is alleged to have committed, its penalties or consequences, the right to counsel of his own choice, the right to be heard and present evidence on his/her defense, and the right to be informed of the resolution of the investigation or action taken.

This policy sets forth a reporting process beyond the normal reporting line to provide an alternative venue for reporting any irregularity, misconduct or suspicious activities to the Management but this is without prejudice to established procedures of the Bank in handling disciplinary cases under its Code of Ethics and Discipline.

The Bank, in its commitment to ensure the transparency and fairness in dealing with all its stakeholders, has established policies to avoid potential conflict of interest. Conflict of interest is defined as any situation in which the Bank’s directors, officers and employees have a competing interest against the Bank or its customers.

As a general rule, all Directors, Officers and Employees of the Bank shall not engage in any transaction that may be construed as having conflict of interest with the Bank or its customers. Although, it is not possible to enumerate all situations which could constitute a conflict, the facts and merits of each situation shall determine the interest in question to bring it within the area of potential conflict. Conflict of interest of all employees shall be governed by the Code of Ethics and Discipline and any inquiries and request for clarification on this matter shall be referred to the Human Resources Group. This shall be discussed with the employee’s immediate Supervisor and Chief Compliance Officer.

In case of doubt, any material matter that poses conflict of interest shall be vetted by the Corporate Governance and Compliance Committee and endorsed to the Board for approval.

The Bank is committed to preserving the confidentiality and preventing the misuse of any sensitive, confidential or material information. It is the Bank’s policy that, unless the information has been widely disseminated to the public, any director, officer and employee who has sensitive or material information about the Bank or its products or services, cannot apply for, acquire or dispose of such financial products or Bank securities to which the inside information relates, or enter into an agreement to do any of those things, either for himself or for another person. Information generally would be considered widely disseminated if it has been disclosed broadly to the marketplace, such as through a press release, SEC filing, PSE disclosure, or placement on the Bank’s website as may be warranted by the situation. By contrast, information would likely not be considered widely disseminated if it is available only to limited people within the Bank.

As a listed Bank, it is governed by the Philippine Stock Exchange (PSE) and the Securities and Exchange Commission (SEC) on disclosure of trading transactions of its Directors and Principal Officers. Principal Officers of the Bank shall pertain to all Bank officers with a rank of Senior Vice President and up, all Heads of the Governance units regardless of rank and Unit Heads of the key business units regardless of rank. All Bank Directors and Principal Officers shall observe the pre-clearance of trade prior to engaging in any trading transactions. They shall likewise inform the Investor Relations Office and the Office of the Corporate Secretary on their trading transactions no later than one (1) banking day after the transaction is executed.

In line with the Bank’s thrust to promote transparency, any Related Party transaction shall be on an arms-length basis and no favorable or special treatment shall be afforded to such related party unless the same treatment shall be accorded to all parties similarly interested in such dealing.

All Related Party Transactions shall be reviewed and vetted by the Corporate Governance and Compliance Committee, which serves as the Board’s Related Party Committee. This Committee is composed of 5 Board members, 3 of whom are independent directors. Furthermore, the Chief Compliance Officer and the Chief Audit Executive sit as non-voting members in the said committee whenever there are Related Party Transactions for vetting. Upon approval, the transactions shall be endorsed and presented to the Board for approval. All approved Related Party Transactions are reported to the Bangko Sentral ng Pilipinas in accordance with the regulatory reporting requirements.

Click here to view the Related Party Transactions (RPT) Manual.

We believe that caring for the health and well being and the safety and security of our employees is important to having sound corporate governance. Thus, we provide HMO and group life insurance coverage to all our full-time employees and a retirement benefit plan that helps them reap the benefits of long years of hard work. Through EastWest’s Learning Academy, we create a learning environment that gives our people opportunities to gain knowledge, continuously hone their skills and sharpen their competencies. We have an employee relations council composed of representatives from various units that ensures that the interests and concerns of our employees are heard and properly addressed.

At EastWest (“The Bank”), we recognize how heavily our clients rely on our systems and services. We also recognize that the unexpected can and does occur – from simple situations to major outages. The Bank has successfully supported critical business activities during typhoons, earthquakes, flooding, and other natural and man-made disasters including the on-going global COVID-19 pandemic.

Prior events clearly have tested Bank’s readiness across virtually all dimensions: safety, systems and telecommunications, physical space, policy, process and procedures. The Bank dedicates significant resources to contingency planning and disaster recovery program. Components of its plans are tested periodically to ensure effectiveness. The Bank considers contingency planning to be an ongoing process, requiring periodic review, to assess various risks and appropriate responses.

EastWest’s Business Continuity and Disaster Recovery Planning Guidelines
The Bank’s plans include the ability to recover from situations including, but not limited to, unplanned evacuations, power outages, major water leaks, fire, loss of water, severe weather, cyber events, pandemic, and any facilities failures that may cause a significant business interruption. Plans are designed to account for business interruptions of various lengths and scope and require that the Bank’s business units are able to recover critical functions according to their time criticality.

Key features of the Bank’s business continuity and disaster recovery planning include annual reviews of the following:

• Mission critical systems and the backup and recovery process for such systems
• Financial and operational risks
• Alternate communications between the Bank and its clients
• Employee safety strategies and communications
• Systems and telecommunications accessibility
• Alternate physical site location and preparedness

The Bank’s business continuity team articulates corporate planning guidelines and coordinates response and event management across all EastWest business units. Each business unit has dedicated business contingency planners to prepare and test its specific plan. The Bank follows enterprise-wide guidelines for contingency planning and disaster recovery from various scenarios. The Bank’s guidelines, which incorporate general industry best practices, include:

• Business Impact Analysis – The Bank is required to identify the time criticality of each business function, as well as the necessary resources to successfully recover. Additionally, the Bank must review annually the time criticality of all business functions.
• Business Contingency Plan – The Bank’s contingency plans include event management procedures, employee communication strategies, alternate site requirements, procedures for notifying clients, recovery management, and alternate site preparation checklists.
• Employee Training and Awareness – The Bank’s contingency plans also address promoting employee awareness with regard to event management and emergency communication tools, drilling evacuation procedures, communicating to employees the criticality ratings for the functions they perform, and identifying employees' roles in a contingency event. Because clear communication during an outage is vital, the Bank has developed a calling tree and protocol for employees who support key functions.
• Alternate Site Recovery Validation – Alternate sites are tested periodically each calendar year. Tests are designed to validate accessibility to critical systems, phones, records, and supplies. The Bank’s alternate site is at a distant location and is not on the same power and telecommunications grid as its primary location.
• Employee Safety – The Bank places emphasis on employee safety. It conduct regular employee training about how to respond during an emergency event as well as the business contingency plan. Periodic evacuation drills are led by trained BCP champions and supervised by on-site security personnel.
• Separate Sites – The Bank’s systems are housed in different locations. The Bank has additional offices for certain order entry and support functions in order to provide backup for certain critical functions if needed. In the event of a site outage, plans are in place to cover critical business functions and phone hotlines. There are pre-established, tested processes for rerouting of critical hotline numbers including client service, relationship management, and product support.
• Contingencies for Inclement Weather – If there is a forecasted weather emergency that could result in an inability to access the primary site, the alternate site would be prepared for use and personnel would be sent there prior to the event. A number of personnel have remote access so they can work from home. Employees can access phone mail and e-mail messages remotely.
• Notification to Clients – Procedures for notifying intermediary clients have been established for relationship managers and client service managers to follow in the event of an outage. Notification will include information regarding length of outage, instructions for contacting client services and relationship management, and support information (e.g., where to send messages, issues pertaining to data transmissions and communications).
• Regulatory Reporting – The Bank’s business contingency plans are designed to ensure that regardless of the length of an outage at a primary location, the Bank’s ability to continue to meet regulatory requirements, as mandated by the BSP would not be impacted.
• Communications with Regulators – The Bank will communicate with its regulatory authorities regarding the nature and extent of any significant outage at a primary location, as required by applicable law and regulation.

Conclusion
We hope this Contingency Planning Statement helps address any questions you may have about the Bank’s preparedness in the event of an outage or other disaster. We are committed to safeguarding your assets and, while some disasters may be unavoidable, a rigorous contingency plan can often reduce the financial risk. To that end, we recognize that contingency planning demands not only consistency, but also a continued willingness to listen and improve. As such, the recovery and business continuity plans of EastWest are subject to modification without notice. The Bank does not guarantee that for every event or business disruption: (i) such plans will be successfully implemented; or (ii) such plans, if implemented will be sufficient and appropriate to avoid, deter, or mitigate the event or business disruption. In addition, given that the Bank is likewise dependent upon various infrastructures (e.g., transportation, telecommunications, exchanges, and industry utilities), the Bank’s ability to implement its plans may be impacted by issues with these infrastructures. To help mitigate such risks, the Bank’s agreements with third parties have business continuity provisions to ensure the continued and efficient delivery of services to customers.