Insider ownership - Insider trading

The Bank has an Insider Trading Policy which covers the Board and senior management as well as other BPI employees who have access or who are made aware of undisclosed material information, including the Board, officers and employees of BPI’s subsidiaries. This policy also covers consultants and advisers of BPI in possession or with knowledge of material non-public information about BPI and its clients, as well as spouses and members of the immediate families (children and parents) of the covered persons living in the same homes of the covered persons.

Covered persons are strictly prohibited from trading during periods of structured and non-structured disclosure. This prohibition includes passing on material, non-public information relating to BPI or its clients to anybody who may buy or sell securities.

• Five (5) trading days before and two (2) trading days after the disclosure of quarterly and annual financial results

• From date of disclosure of material non-public information and until two (2) trading days after the disclosure of any material information other than quarterly and annual financial results

• Office bulletins for special blackout periods pertaining to the above will be issued by the Compliance Officer

The exercise of vested stock options (i.e., acquiring shares) may be done at any time, even during blackout periods. However, the liquidation, (i.e., the sale of shares acquired from options) is subject to blackout periods.

Covered persons include officers of BPI with the rank of Senior Vice Presidents and up and other officers or employees who are or may be in possession or knowledge of material non-public information about Bank of the Philippine Islands or companies/institutions BPI deals with either as lender, trustee, investment advisor, consultant or simply as client because of their position, privity to information or responsibilities. The above-described Officers and/or employees include the Officers and employees of BPI’s subsidiaries.

All covered persons should consult the Office of the Compliance Officer, prior to transacting securities of BPI and its clients, regardless of when they would like to perform such transactions, in order to determine if the trade violates this policy.

Without prejudice to the normal, regular reportorial requirements of the Securities and Exchange Commission and the Philippine Stock Exchange for purchase and sale of BPI shares by Directors and officers, all covered persons are required to report their trades to the Office of the Compliance Officer on a quarterly basis.

All covered persons shall report their trades to the Office of the Compliance Officer within three to five business days from dealing in such securities.

All other officers and employees shall likewise report their trades in BPI securities to the Office of the Compliance Officer within 10 days from the end of each quarter when the trades were made. In compliance with an SEC directive, the bank also requires all directors and senior management to file within three business days the required SEC Form 23-A and B.

Violation of the policy shall be subject to disciplinary action as may be determined by management or the Board of Directors, without prejudice to any civil or criminal proceedings which BPI or the regulators may file. Under the law, insider trading may be subject to penalty for damages or fine and/or imprisonment.