Code of Business Conduct and Ethics

ATI is committed to ensuring that all company business is conducted according to rigorous ethical, professional and legal standards.

The Company provides for a code of conduct and ethics that provide standards which cover everything from potential conflicts of interest and fraudulent activity, to gifts policy and share dealing that are intended as a general framework for personal behavior.

Every employee, director and officer of ATI is expected to comply with these standards and to behave in a mature, professional and responsible manner.

Conflict of Interest

Employees, officers and directors are expected to put ATI’s interests ahead of their own personal interests in executing the Company’s business. All business conducted on behalf of ATI must be performed in a diligent and loyal manner.

All employees are mandated to avoid situations where personal interests could conflict, or appear to conflict, with the interests of ATI. Employees must ensure that his/her conduct does not provide or give the appearance of providing him/her with personal gain at the expense of the company or external business contract. Employees are likewise prohibited from holding any interest or position, direct or indirect, financial or otherwise, in any Restricted Company. A “Restricted Company” includes any competitor, customer, supplier, distributor, dealer, agent of the Company and/or any of its related companies, government official or employee or any other family business, professional or non-business enterprise or association, where an interest or position may be or could be detrimental to the interest of the company and companies affiliated with it or its agents.

Directors and key officers of the Company must act fairly in their business transactions and must not be engaged in any business which competes with or antagonistic to that of the Company as set forth in the Company Corporate Governance Manual.

Compliance with Laws, Rules and Regulations

ATI commits to observance and compliance with laws, rules and regulations, including but not limited to applicable labor laws, law on data privacy, Securities Regulations Code and other relevant issuances and circulars of regulatory agencies.


The company has zero tolerance policy on any form of bribery and corruption. A violation of said policy warrants termination from work.

Relationships with Customers and Suppliers

Every employee of the company has the responsibility to ensure that there are no compromises in delivering the highest standard of services and products, and that every aspect of our operations which impacts upon quality promotes and reflects these standards.


The Company is committed to conducting its business with honesty and integrity, and expects all staff to maintain high standards in accordance with its code of conduct policy and procedure. In line with this, the Company encourages staff to report suspected wrongdoing or dangers at work as soon as possible, including criminal activity, miscarriage of justice, danger to health, safety & environment, failure to comply with any legal, professional obligation or regulatory requirement, bribery, etc., with guidance as to how to raise such concerns and an assurance that such genuine concerns in good faith may be raised without fear of reprisals, even if they turn out to be mistaken. The aim is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace while maintaining procedural and substantive due process at all times.

Related Party Transactions

Transactions with subsidiary, substantial stockholders, officers and directors, including their spouses, children and dependent siblings and parents and of interlocking director relationships of members of the Board are on arm’s length basis in a manner similar to transactions with non-related parties. Any probable related party transaction is submitted for review and approval of the Board and/or the stockholders, as applicable pursuant to the provisions of the Corporation Code on interlocking directors. The ratification and monitoring of any related party transaction is being monitored by the Board, Audit Committee and checked by the company’s independent external auditor. Directors concerned do not participate in the voting and approval or evaluation of the transaction.

Insider Trading

Any confidential information or those that are not generally disclosed to the public which would likely affect the market price of the securities of the Company after being disseminated or any such information that would be reasonably considered by any person as important in making a decision to invest on securities of ATI are “inside information”, regardless whether such information is positive or negative. Any person within the Company in possession or with knowledge of inside information as stated above, is considered as an “insider”. Insiders may include directors, key officers, members of management team, consultants, and employees, including the relatives of such persons.

As a listed company, ATI is subject to the provisions of the Securities Regulation Code of the Philippines and foreign securities laws. Said laws prohibit and penalizes "insiders" from trading the Company's securities, or those of other companies while in the possession of material, non-public information regarding the Company or such other company, including the sharing thereof.