P H I L I P P I N E S , I N C .

DRUGBUSTERS: War Against Drugs Policy

Republic Act 9165, known as the Comprehensive Dangerous Drugs Act of 2002,
declares the State Policy against Drugs:

“Section 2. It is the policy of the State to safeguard the integrity of its

territory and the well being of its citizenry particularly the youth, from the
harmful effects of dangerous drugs on their physical and mental well-being, and
to defend the same against acts of omissions detrimental to their development
and preservation. In view of the foregoing, the State needs to enhance further
the efficacy of the law against dangerous drugs, it being one of today’s more
serious social ills.

Toward this end, the government will pursue an intensive and unrelenting
campaign against the trafficking and use of dangerous drugs and other similar
substances through an integrated system of planning, implementation and
enforcement of anti-drug abuse policies, programs, and projects. The
government however aims to achieve a balance in the national drug control
program so that people with legitimate medical needs are not prevented from
being treated with adequate amounts of appropriate medications, which
includes the use of dangerous drugs.”

Department Order No. 53-03 of the Department of Labor and Employment provides
for the mandatory adoption of an internal Company Policy for the purpose of ensuring a
safe, healthy and drug free workplace:

“Section B. 1. It will be mandatory for all private establishments employing ten

(10) or more workers to formulate and implement drug abuse prevention and
control programs in the workplace, including the formulation and adoption of
company policies against dangerous drug use.

Section D. (b) Drug Testing for Officers and Employees

1. Employees will require their officials and employees to undergo a random
drug test in accordance with the company’s work rules and regulations for
purposes of reducing the risk in the workplace. Strict confidentiality will be
observed with regard to screening and the screening results.”

INFONXX Philippines, Inc. (“the Company”) strongly supports this State Policy.
Accordingly, Management hereby incorporates, as part of the Company Rules and
Regulations, the “War Against Drugs” Policy, in compliance with the directive of
Department of Labor and Employment.

DRUGBUSTERS
War Against Drugs

A. Policy

1. Possession, Selling, Trading, Offering for Sale or Use of Prohibited or

Regulated Drugs and/or Reporting to Work under the Influence of Prohibited
or Regulated Drugs is violation of the Company’s Policy “ War Against
Drugs”.

2. Violation of the Company’s Policy “ War Against Drugs” shall be penalized

with termination of employment. Please refer to INFONXX Employee Manual,
page 22.

Drugbusters: War Against Drugs Policy 1

 3. Pursuant to the requirement of RA 9165 and DOLE DO-53, the Company shall
implement a Random Drug Testing Program. Refusal to submit to drug test
will be considered an act of insubordination and shall be penalized with
termination of employment. (INFONXX Employee Manual, page 22).

4. Any employee who voluntarily discloses his/ her drug-related problem(s) to

the Human Resources Director or Manager shall immediately be put under
preventive suspension and required to undergo drug testing within twenty-
four (24) hours.

Voluntary admission of drug-related problem is considered a mitigating

factor, for which reason the penalty of Dismissal may be suspended and/or
lowered provided the following conditions are met:

4.1 The employee must undergo rehabilitation in a medical center

accredited by the Department of Health and jointly selected by the
Company and the concerned employee. The cost of the rehabilitation
will be 100% shouldered by the employee.

4.2 After undergoing rehabilitation, with the employee being

certified drug free and fit to work, the Human Resource Director shall
evaluate the employees culpability and impose the appropriate
penalty, as may be warranted by the situation.

4.3 It must be stressed that the feasibility of reinstatement, in the

event that the penalty of Dismissal is lowered, is conditioned on the
premise that the position vacated is still available.

5. Instances for Compulsory Drug Testing. The company, in addition to the

random drug testing program, may require the compulsory submission of
employees to drug testing on the following instances:

i. Violation of any Company Policy that may be related to drug use

ii. Involvement in any violent or physical altercation; and
iii. Other similar incidences that may indicate drug abuse problem.

5. Two Testing Methods. The drug-testing program will conform to the

requirement of the Department of Health. The program will employ two (2)
testing methods namely: the Screening and Confirmatory Test of urine
sample. The company will secure the services of a DOH-Accredited Class A
Laboratory to perform these procedures.

6. Right of Employee to Challenge Test Result. The concerned employee may

challenge the result of the Confirmatory Test within ten (10) days after
release of drug test results. Failure on the part of the employee to challenge
the Confirmatory Test within the period shall constitute as an admission of
Drug use.

7. Right of Company to Inspect Employees or Visitors. The Company reserves

the right to inspect, search or examine all persons entering the Company
premises for possible possession of prohibited or regulated drugs. Any person
who refuses to submit for inspection or examination will be denied access to
the company premises and administratively dealt with. Lockers, pedestals
and tables are deemed company properties and may be inspected upon order,
provided that it is done in the presence of the employee involved.

8. Prosecution of Drug-Related Cases. As a responsible Corporate Entity, the

Company will pro-actively support prosecution of criminal cases involving
illegal drugs regardless whether the accused is an employee or not. As long
as the incident is committed within the company premises. Any dangerous
drugs, instrument, apparatus, materials or appliances intended or designed

Drugbusters: War Against Drugs Policy 2

 for use, manufacture or production of dangerous drugs seized or confiscated
from any person within the Company premises will be turned over to the
proper authority.

OFFENSE PENALTY
1st Offense 2nd Offense 3rd Offense

a. Possession of illegal Termination from

drugs or drug-related employment and
paraphernalia referral of case to
government agency

b. Sale, distribution or Termination and

buying, accepting of illegal referral of case to
drugs government agency

c. Reporting for duty while Termination and

under the influence of drugs referral of case to a
government agency

d. Reporting for work while Suspension for five Suspension for ten Termination
under medication of (5) working days, (10) working days,
therapeutic drugs, without without pay without pay
clearance from company-
accredited HMO doctor/
physician.

e. Refusal to submit to drug Termination

testing

f. Voluntarily admission of Endorsement for Termination

employee to his/her proven Rehabilitation.
drug dependency

g. Proven drug dependency Termination

(after random testing)

B. Guidelines for Drug Testing in the Office

9. All employees, including expatriates, of the Company will be subject to

random drug testing.

10. Drug testing via urine specimen collection will be conducted by a Department
of Health (DOH) accredited laboratory. The collection will be done within
the company premises to ensure that employees are not exposed to hazards
or inconvenience beyond what is needed to complete the drug testing
session. However, the Company may at any time, require an employee
classified under A.5, to undergo drug testing in a nearby laboratory or
hospital.

11. Drug testing may be administered at any time during the year. Only the HR
Director/Managers will set and know the schedule of the drug testing
session/s. The HR Director/ Managers, with the assistance of the Facilities
Manager, will determine the logistics in the conduct of the drug testing
sessions.

12. Depending on the drug-testing schedule, the Company may require all
employees present in a given shift to undergo the urine specimen collection

Drugbusters: War Against Drugs Policy 3

 at one particular schedule. Or the Company may do random selection of
employees to be drug-tested.

13. Once an employee is required or selected to be drug tested, the employee

will be pulled out from work and escorted to the drug testing area set up
within the office premises. The employee will not be allowed to leave the
office premises until he/she has provided his/her urine specimen to the duly
authorized collectors.

14. If the employee randomly selected is out of the office due to a leave,
absence, day off, etc. another name will be drawn. The employee initially
selected, but not present, will still be required to undergo drug testing, but
on another schedule.

15. An employee who refuses to undergo drug testing at a prescribed time and
date will be subject for termination as stipulated in Republic Act 9165 and
the INFONXX Employee Manual.

16. If an employee is found positive on the initial screening, there is a need for a
confirmatory testing. Confirmatory testing will be done on the same sample
provided by the employee. If after the 2 nd testing the employee is found
positive, the employee may be legally separated from the company, as
stipulated in the INFONXX Employee Manual.

17. Results of the drug test will be given to employees concerned in individually
sealed envelopes.

18. INFONXX Philippines, Inc. will maintain the confidentiality of all information
relating to drug tests or to the identification of drug users in the work place.
Exceptions may be made as required by legal authorities.

C. INFONXX Employee Information Program

Objective: To create and maintain a drug-free work environment, INFONXX

Phils. Inc. will establish an Employee Information Program to address drug abuse
problems. To this end, the Human Resources Department and Health & Safety
Committee will undertake a program that will provide assistance and awareness
related to drug-related issues. The program will include the following:

a. Orientation and seminars for employees about RA 9165

and D.O. 53-03;
b. Orientation for employees about Drugbusters: War
Against Drugs Policy pertaining to drug-related problems;
and
c. Education concerning the physical, social and
psychological effects of dangerous drugs

D. Investigation Process

When applicable, violations of this Policy will be investigated, in accordance with

the INFONXX Code of Discipline.

E. Effectivity: War Against Drugs Policy

This policy will be effective on April 15, 2004.

Drugbusters: War Against Drugs Policy 4