WHISTLEBLOWER POLICY

Ayala Healthcare Holdings, Inc. (“AC Health” or the “Company”) is committed to the highest standards of business conduct and personal ethics. The Company expects all its employees and members of the Board to fulfill their duties and responsibilities with honesty, integrity and comply with all applicable laws and regulations. In line with this, AC Health adopts this Whistleblower Policy (the “Policy”) to encourage employees and all suppliers, business partners, contractors, sub-contractors to come forward and raise serious concern about a perceived malpractice, impropriety, wrongdoing, or a risk involving the Company.

This Policy provides a formal mechanism and an avenue for directors, officers, employees, suppliers, business partners, contractors and sub-contractors and other third parties to raise such concerns. This Policy provides an assurance that a person who will raise a concern (the “Whistleblower”) will be protected from reprisals, harassment or disciplinary action or victimization for whistleblowing.

Reporting Channels:

• Face-to-face meetings: Any member of the Whistleblower Committee (the “Committee”) composed of Chief Finance Officer, Head of Finance and Administration, Human Resources or Internal Audit.

• E-mail: whistleblower@achealth.com.ph

• Mail:

  Head of Human Resources

  Ayala Healthcare Holdings, Inc.

  3F Makati Stock Exchange Building

  6767 Ayala Avenue Makati City 1226 Philippines

• Telephone: +632 7745 2508