ATN Holdings Inc.

ATN Holdings Inc. encourages and welcomes whistleblowers. The company will handle said complaints of whistleblowers with utmost confidentiality and fairness.

ATN Holdings Inc. recognizes the need for all material information to be disclosed in full and in a timely manner to the SEC and PSE particularly information for the investing public. Our policy on insider trading prohibits directors, officers, consultants, advisers and employees who are considered to have knowledge of material facts which have not yet publicly disclosed to directly or indirectly engage in any financial transaction as a result of or relying upon “insider information".

CONFLICT OF INTEREST POLICY

Manual on Corporate Governance

ATN Holdings Inc. has adopted the Revised Corporate Governance Manual and has aligned their reportorial disclosures on Related Party Transaction (RPT) in accordance with the Revised Code of Corporate Governance and Securities Regulation Code issued by SEC.

RELATED PARTY TRANSACTION POLICY

Manual on Corporate Governance

ATN Holdings Inc. recognizes the need for all material information to be disclosed in full and in a timely manner to the SEC and PSE particularly information for the investing public. Our policy on insider trading prohibits directors, officers, consultants, advisers and employees who are considered to have knowledge of material facts which have not yet publicly disclosed to directly or indirectly engage in any financial transaction as a result of or relying upon “insider information".

INSIDER TRADING POLICY

Manual on Corporate Governance

Health, Safety and Welfare of our Employees are very important to ATN Holdings Inc. Any accident or incident must be reported immediately to supervisor or officer-in-charge. We give our employees access to our partner clinic to address their individual needs. In-house training is also given to them to further hone their skills and talents.

POLICY AND DATA RELATING TO HEALTH, SAFETY, AND WELFARE OF EMPLOYEES INCLUDING SPONSORED TRAININGS

Manual on Corporate Governance

GROUPWIDE POLICY

Manual on Corporate Governance

INTERNAL CONTROL SYSTEM POLICY

Manual on Corporate Governance

STRATEGY EXECUTION PROCESS

Manual on Corporate Governance

RETIREMENT POLICY

Manual on Corporate Governance

SUCCESSION PLANNING POLICY

Manual on Corporate Governance

ENVIRONMENTAL SOCIAL AND
NON-FINANCIAL GOVERNANCE POLICY

Manual on Corporate Governance

BOARD DIVERSITY POLICY

Manual on Corporate Governance

ENVIRONMENTAL, SOCIAL AND GOVERNANCE POLICY