Code of Business Conduct and Ethics

Conflicts of Interest

The Company/(University) does not permit conflict of interest. All Directors, Senior Management and employees have an obligation to act in the best interests of the Company/(University). Any activity, interest, or association outside the Company/(University) that could impair ability to perform the work objectively and effectively or that could give the appearance of interfering with the responsibilities on behalf of the Company/(University) or its clients is avoided.

It is not possible to describe every situation in which a conflict of interest may arise. The following, however, are examples of situations that may raise a conflict of interest (unless permitted by law and Company/(University) policies): Accepting special favors as a result of a position with the Company/(University) from any person or organization on which the Company/(University) has a current or potential business relationship.

a. Competing with the Company/(University) for the purchase or sale of property, services, or other interests.

b. Acquiring an interest in a transaction involving the Company/(University), a client, or supplier (not including routine investments in publicly traded companies).

c. Receiving a personal loan or guarantee of an obligation as a result of a position with the Company/(University).

d. Working for a competitor while being a Director/Senior Management an employee of the Company/(University).

e. Directing business to a supplier owned or managed by, or which employs, a relative or friend.

Any potential relationships, actions or transactions (including those involving family members) that reasonably could be expected to give rise to a conflict of interest is promptly reported to Administrative Department.

Involvement in certain outside activities of licensed employees requires prior approval of the Company/(University

Directors also disclose any actual or potential conflicts of interest to the Chairman of the Board, who shall determine the appropriate resolution. All directors refuse themselves from any Board discussion or decision affecting their personal, business or professional interests.

Conduct of Business and Fair Dealings

The Company adheres to the principle of fairness in the conduct of its business and dealings. No one should take unfair advantage of anyone through manipulation, abuse of privileged information, misrepresentation of facts or any other unfair dealing practice.

Receipt of gifts from third parties

The Company requires disclosure and regulates the receipt of gifts from third parties. Gifts and entertainment may create an inappropriate expectation or feeling of obligation. Any Directors, Senior Management and employees and members of their family does not accept gifts or special favors (other than an occasional non-cash gift of nominal value) from any person or organization with which the Company has a current or potential business relationship. Further, the company (university) considers business gifts to, and entertainment of, non-government employees in connection with business discussions or the development of business relationships are only appropriate if they are in the ordinary course of business and their value is modest.

Compliance with Laws & Regulations

The Company requires compliance with applicable laws and regulations. As a publicly-listed company, The Centro Escolar University is subject to numerous laws and regulations. It is the responsibility of the Directors, Senior Management and employees to know and understand the laws applicable to their job responsibilities and to comply with both the letter and the spirit of these laws. This requires that their avoid not only actual misconduct but also even the appearance of impropriety. The Company/(University) assumes that any action taken could ultimately could be publicized, and considered how the Company would be perceived. Respect for Trade Secrets/Use of Non- public Information The Company treats as confidential trade secrets and regulates use of non- public information. The Company never, under any circumstances, trades, encourages others to trades, or recommends securities or other financial instruments based on (and in some circumstances, while in the possession of) inside information.

Use of Company Funds, Assets and Information

The Company/University policies regulate use of the Company’s systems, including telephones, computer networks, electronic mail and remote access capabilities only for legitimate Company business.

Employment & Labor Laws & Policies

The Company requires compliance with laws, rules and policies on employment and labor. The Company is also committed to conducting its business in compliance with all applicable environmental and workplace health and safety laws and regulations

Disciplinary action

The Company enforces its rules and regulations in accordance with the company employees manual on employment and discipline.

Whistle-Blowing Policy

The University's open door policy makes it conducive to all stakeholders to raise their concern with management

 

Conflicts Resolution

Conflicts Resolution are undertaken by the Board of Directors and/or by the Administration. All officers and employees are expected to cooperate in internal investigation of any allegation which may subject them to disciplinary action.