ETHICS

I. STATEMENT ON ETHICAL STANDARDS

Mabuhay Vinyl Corporation adheres to the highest ideals of ethics in conducting its
business. To this end, the company and its employees shall ensure commitment
through words and deeds, to conform to the basic tenets of service, integrity,
teamwork, excellence and social responsibility consistent with the value of God-
centeredness.

II. INTRODUCTION
Mabuhay ´s long years of operations is grounded in maintaining high ethical standards
in the conduct of its business. It has published a Code of Business Conduct that
summarizes its Ethical Principles and Core Values. This Code describes acceptable
behaviors and how it treats its customers, its employees, and all the company's
stakeholders (suppliers, government, etc.)

The company expects its employees to support a work environment that fosters
respect, fairness and integrity, the ultimate objective of which is to preserve is
untarnished reputation as a reliable and ethical company.

Every MVC employee is expected to faithfully comply with and perform his jobs and
tasks. He/she shall not allow himself/herself to be placed in a situation that will cast
doubt upon his/her company loyalty or invite any opportunity to compromise his/her
fidelity. Utmost dedication and zeal in work performance and execution are highly
expected.

III. ETHICAL STANDARDS FOR SPECIFIC RELATIONAL DOMAINS

(PARTIAL LIST)
• A. CUSTOMERS

MVC shall at all times, seek to attain customer satisfaction and loyalty by
delivering only quality products and services, stressing value and safety to the
user while affirming the company's reliability.

To enhance and maintain customer confidence, an MVC employee is expected to

attend to customers, in ethical behavior and with utmost competency knowing
that the customers are the reason for the company's existence.

• B. SHAREHOLDERS
 Being the very source of MVC´s lifeblood, shareholders deserve no less than fair
and full disclosure of information on the company's operations and finances. MVC
shall never resort to fraud or machinations in order to overvalue or undervalue
the company's worth. Transparency shall forever be espoused.

• C. COMPETITORS

MVC undertakes to promote and market its products by abiding by the rules of
free competition and fair play. It shall not resort to blackmail, negative publicity
and similar unfair practices aimed at securing undue advantage over its
competitors.

CODE OF ETHICSINTRODUCTIONAs a good corporate

citizen, Fil-Estate (the Company) has always endeavored to
conductits business in a manner conforming to the
highest ethical standards. The company'sreputation for
unquestionable integrity is its most valuable asset in its
relationships withits customers, employees, shareholders, and
the communities in which its branches andprojects are
located.The following statement of business principles has
been prepared to guide the futureconduct of company
activities in an ethical and legal manner. It is not intended to
supplyanswers for every business activity; rather, it is an
effort to reiterate the continuingpolicies of the corporation
on ethical business behavior, which must be observed by
allFil-Estate employees and representatives throughout the
world. It is essential that allemployees and representative
conform to these principles as they perform their activitieson
behalf of Fil-Estate.COVERAGEThese Rules shall cover all
Executives, Officers, Staff and employees of Fil-
Estate,employed,permanent or temporary and receiving
compensation regardless of amount.VISIONFil-Estate shall be
recognized as:The leader in the real estate industry for
product quality, innovation and superiorcustomer
satisfaction.An active partner in nation building, andA
committed citizen for world ecological balanceMISSIONFil-
Estate provide high quality products and services for the total
delight and satisfactionof customers by:Conducting
our business with the highest standards of professionalism
andintegrity;Creating and marketing real estate products and
services of superior quality anddesign;Providing our
customers the best value for their money, improvement in
theirquality of life, and responsiveness to every related need
and expectation;Ensuring that our investors and shareholders
get a reasonable return for theirinvestments;Providing our
salesmen unlimited opportunity for career advancement
andpersonal growth;
Affording our employees with opportunity for career
advancement and personalgrowth, leading to the
improvement of their quality of life;Supporting an optimum
environment for planet Earth.QUALITY POLICYFil-Estate is
committed to be the recognized leader in real estate industry
for ProductQuality, Innovation and Customer Satisfaction. In
active pursuit of this commitment, we— the Executive
Committee, Officers, Managers and Staff of Fil-Estate shall at
all times:Be Quality Driven — ensuring that every Fil-Estate
product and service thatreaches our customers will bear our
distinct mark of Excellence. Every member ofFil-estae shall
be involved in the continuous improvement of processes,
systemand procedures for the satisfaction of our
customers.Be Customer Focused — placing premium value
in knowing the needs andrequirements of our customers and
doing what is necessary to meet and exceedtheir
expectations. Customer satisfactions shall be the rule at all
times. Ourcustomers shall equate Fil-etate with quality,
excellent performance, reliabilityand service.Recognized,
Support and Reward team and individual efforts that are
contributoryto the fulfillment of the Corporate Vision and
Mission, and the attainment of TotalQuality Management
objectives. Quality shall be important criterion forindividual
and team performance measurement, promotion and career
movement.Towards this end, Management shall ensure an
environment where the pursuit ofquality is a fulfilling as well
as a never-ending process.Pursue Quality as a mean to
Corporate Viability and Profitability —knowing very well
that only Quality will differentiate the Corporation from therest
and guarantee it's competitive edge and leadership in the real
estate industry.Fil-Estate and its EmployeesEmployees are
the corporation's greatest asset, and it is a Fil-Estate policy to
treat themfairly in all matters and to pay them competitively.
Fil-Estate and its subsidiaries areengaged in a program of full
compliance with all national and local laws applicable tohiring
and promoting people on the basis of demonstrated ability,
experience, andtraining without regard to race, religion, sex,
age, national origin, or other factorsrequiring affirmative
action. The corporation requires continuous management
attentionat all corporate levels to assure compliance with the
spirit and letter of this policy.
With this in mind, it is the intent of Fil-Estate to:Choose its
employees on the basis of their ability to perform the work for
whichthey are hired without regard to race, religion, sex, age,
national, origin, or otherfactors requiring affirmative
actionOffer employees a safe, healthy, and clean work
environmentOffer work that challenges the employees and
gives them a feeling of satisfactionPay employees fairly in
relation to their contributions to the company's efforts,within
the boundaries of current standards.Fil-Estate and the
CommunityThe corporation shall conduct its business in a
manner that is socially responsible. Inaddition to developing
and selling real estate products, it shall protect the quality of
theenvironment and endeavor to conserve energy and other
valuable resources.Each of the corporation's offices is
expected to make every effort to be an integral part ofthe
community in which it operates, and to participate in its
activities as a concerned andresponsible citizen. Like
individual citizens, it benefits from such activities as
health,welfare, character - building, education, and culture.
And like individuals, it has theresponsibility to support and
develop these social and civic activities.The company
recognizes that employee participation in cultural, social, or
volunteerorganizations can be public service of a higher
order, and all Fil-Estate employees areencourage to
participate in public activities of their individual choice.Fil-
Estate and its CustomersThe corporation shall endeavor to
provide its customers with quality real estate productsand
services and sold at a fair price. Fil-Estate real estate
products will be developed tothe company's superior
quality standards and design providing our customers the
bestvalue for their money, improvement in their quality of life
and responsiveness to everyrelated need and expectation.Fil-
Estate and the LawIt is the policy of Fil-Estate to comply with
all valid laws and regulations that govern itsoperations in the
various cities and municipalities in which it operates and
conduct itsaffairs in keeping with the highest moral, legal,
and ethical standards.There is an obligation, both corporate
and individual, to fulfill the intent of the abovestatement. It is
not expected that every employee will have full knowledge of
the lawsaffecting his or her responsibilities. The company
does, however, expect that employeeswith significant
responsibilities will have a general knowledge of prohibited
activitiesinvolved in their work and will seek guidance on any
matter on which there is a question,either directly from the
corporation's legal department or through their supervisors.
General Employee ConductFil-Estate expects its employees
to conduct themselves in a businesslike manner.Drinking,
gambling, fighting, swearing, and similar unprofessional
activities are strictlyprohibited while on the job.Employees
must not engage in sexual harassment, or conduct
themselves in a way thatcould be construed as such, for
example, by using inappropriate language, keeping orposting
inappropriate materials in their work area, or accessing
inappropriate materials ontheir computer.Conflict of
InterestFil-Estate expects that employees will perform their
duties conscientiously, honestly, andin accordance with the
best interests of the company. Employees must not use
theirposition or the knowledge gained as a result of their
position for private or personaladvantage. Regardless of the
circumstances, if employees sense that a course of actionthey
have pursued, are presently pursuing, or are contemplating
pursuing may involvethem in a conflict of interest with their
employers, they should immediately communicateall the fact
to their superior.Relationship with Clients and
SuppliersEmployees should avoid investing in or acquiring a
financial interest for their ownaccounts in
any business organization that has a contractual relationship
with theCompany, or that provides goods or services or both
to the Company, if such investmentor interest could influence
or create the impression of influencing their decisions in
theperformance of their duties on behalf of the
Company.Gifts, Entertainment and FavorsEmployees must
not accept entertainment, gifts, or personal favors that could,
in any wayinfluence, or appear to
influence, business decisions in favor of any person
ororganization with whom or with which the Company has, or
is likely to have, businessdealings.Similarly, employees must
not accept any other preferential treatment under
thesecircumstances because their position with the Company
might be inclined to, or beperceived to, place them under
obligation.Kickbacks and Secret CommissionRegarding the
Company's business activities, employees may not receive
payment orcompensation of any kind, except as authorized
under the Company's remunerationpolicies. In particular, the
Company strictly prohibits the acceptance of kickbacks
andsecret commissions from suppliers or others. Any breach
of this rule will result inimmediate termination and prosecution
to the fullest extent of the law.
Organization funds and Other AssetsEmployees who have
access to Company funds in any form must follow the
prescribedprocedures for recording, handling, and protecting
money as detailed in the Company'sinstructional manuals or
other explanatory materials, or both. The Company
imposesstrict standards to prevent fraud and dishonesty. If
employees become aware of anyevidence 'of fraud and
dishonesty, they should immediately advise their superior or
theInternal Audit department so that the Company can
promptly investigate further.When an employee's position
requires spending Company funds or incurring
anyreimbursable personal expenses, that individual must use
good judgment on theCompany's behalf to ensure that good
value is received for every expenditure.Company funds and
all other assets of Fil-Estate are for the Company's purposes
onlyand not for personal benefit. This includes the personal
use of organizational assets suchas
computers.Organizational Records and
CommunicationsAccurate and reliable records of any kinds
are necessary to meet the Company's legal andfinancial
obligations and to manage the affairs of the Company. The
Company's booksand records must reflect in an accurate and
timely manner all business transactions. Theemployees
responsible for accounting and record keeping must fully
disclose and recordall assets, liabilities, or both, and must
exercise diligence in enforcing these requirements.Employees
must not make or engage in any false record or
communication of any kind,whether internal or external,
including but not limited to:False expense, attendance,
production, financial, or similar reports and statementsFalse
advertising, deceptive marketing practices, or other
misleadingrepresentationsDealing with Outside People and
OrganizationsEmployees must take care to separate their
personal roles from their Organizationpositions when
communicating on matters not involving Company business.
Employeesmust not use organization's identification,
stationery, supplies, and equipment forpersonal or political
matters.When communicating publicly on matters that involve
Organization business, employeesmust not presume to
speak for the Organization on any topic, unless they are
certain thatthe views they express are those of the Company,
and it is the Company's desire thatsuch views be publicly
disseminated.
When dealing with anyone outside the Company, including
public officials, employeesmust take care not to compromise
the integrity or damage the reputation of either theCompany,
or any outside individual, business, or government
body.Prompt CommunicationsIn all matters relevant to
customers, suppliers, government authorities, the public
andothers in the Company, all employees must make every
effort to achieve complete,accurate, and timely
communications — responding promptly and courteously to
allproper requests for information and to all
complaints.Privacy and ConfidentialityWhen handling
 financial and personal information about customers or others
with whomthe Company has dealings, observe the following
principles:1. Collect, use, and retain only the personal
information necessary for theCompany's business.
Whenever possible, obtain any relevant information
directlyfrom the person's concerned. Use only reputable and
reliable sources tosupplement this information.2. Retain
information only for as long as necessary or as required by
law. Protect thephysical security of this information.3. Limit
internal access to personal information to those with a
legitimate businessreason for seeking that information. Use
only personal information for thepurposes for which it was
originally obtained. Obtain the consent of the
personconcerned before externally disclosing any personal
information, unless legalprocess or contractual obligation
provides otherwise.
AMENDMENTThe Management of Fil-Estate may amend or
modify these rules as may be necessary.EFFECTIVITYThese
Rules shall take effect effective days following the completion
of the publicationin the Company's official newsletter or as
may be announced by the management of Fil-
Estate._______________________________Chief Executive
Officer_______________________________Chairman of the
BoardJuly 07, 2003

Code of Ethics