The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How GT Capital promotes ethical business behaviour

GT Capital Holdings, Inc. is a Philippine conglomerate with a strategic business portfolio and a heritage of leadership in financial services, insurance, property development, infrastructure and utilities, and automotive assembly and distribution. Above everything else, GT Capital practices consistent adherence to ethical and moral values under all circumstances, both from an institutional and individual basis. 

This case study is based on the 2018 Sustainability Report by GT Capital published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Ethical business practices and integrity are embedded in GT Capital’s corporate culture  Tweet This!, which has earned for GT Capital the trust and confidence of its clients, investors, and business partners. In order to promote ethical business behaviour GT Capital took action to:
  • implement a Code of Ethics
  • apply a Code of Discipline
  • implement a Whistleblowing Policy

What are the material issues the company has identified?

In its 2018 Sustainability Report GT Capital identified a range of material issues, such as economic performance, environmental compliance, labour/management relations, customer privacy, marketing and labelling. Among these, promoting ethical business behaviour stands out as a key material issue for GT Capital.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups GT Capital engages with:

Stakeholder Group
Capital Fund Providers
Senior Executives
Component Companies

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics GT Capital distributed an online survey among its stakeholders, structuring the questionnaire in such a way that the respondents were able to conveniently express their expectations from GT Capital.

What actions were taken by GT Capital to promote ethical business behaviour?

In its 2018 Sustainability Report GT Capital reports that it took the following actions for promoting ethical business behaviour:

  • Implementing a Code of Ethics
  • The Code of Ethics exemplifies GT Capital’s culture of good governance and serves as a guide to make sure that GT Capital’s directors, officers, and employees adhere to the highest ethical standards in the conduct of its business, keeping in mind GT Capital’s corporate core values of integrity, excellence, respect, entrepreneurial spirit, and commitment to value creation. The Code of Ethics is implemented through the CG Manual, Whistleblowing Policy, Code of Discipline of Employees, and the Policies and Procedures Manual of each department. The Whistleblowing Policy and Code of Discipline of Employees are distributed to all directors, officers and employees while the Policies and Procedures Manuals (“PPM”) of each department are disseminated to all departments’ employees. All these documents are also readily available for access of all directors, officers, and employees through GT Capital’s website, by request from the Legal and Compliance Department, and through the Human Resources (“HR”) and Administration Department, and are reviewed on an annual basis in the context of evolving best practices and changing regulations. GT Capital’s HR and Administration Department, in coordination with the relevant heads of other departments, is tasked with implementing and ensuring compliance with the provisions of the Code of Ethics as well as the policies and codes implementing the Code. Its responsibilities include, among others, making sure that the contents of the Code are communicated to all existing and new officers and employees. This is done by providing officers and employees with a copy of GT Capital’s employee handbook, requiring each officer and employee to sign annually a “Code of Conduct Acknowledgment Form”, and conducting an annual orientation on the Corporation’s policies. Its activities also include investigating reported violations of the Code and, if necessary, imposing the appropriate disciplinary action. In addition, each department is audited by GT Capital’s Internal Audit Department to further verify observance of the relevant policies.
  • Applying a Code of Discipline
  • The Code of Discipline, which has been distributed to all employees of GT Capital and is available on GT Capital’s website, ensures that employees of GT Capital conduct themselves in a manner befitting their respective positions in the Company by espousing the general principles of professionalism, high ethical standards, discipline, integrity, and honesty. It also promotes efficient, orderly and safe conduct of the Corporation’s operations, as well as fairness and uniformity in the implementation of any disciplinary action on its employees. GT Capital’s anti-corruption programme is also integrated in the Code of Discipline, and considers bribery and offering or accepting anything of value for personal gain in the conduct of official business a serious offense, with a penalty of dismissal. The HR and Administration Department is responsible for monitoring and implementing the Code of Discipline. It regularly carries out seminars for employees, including an onboarding seminar for new employees, tackling the policies and procedures of GT Capital including the Code of Discipline and the Anti-Corruption Programme. Since its adoption in 2013, there have been no major violations of the Code of Discipline.
  • Implementing a Whistleblowing Policy
  • GT Capital’s Whistleblowing Policy was adopted to further strengthen GT Capital’s Corporate Governance framework. It reflects GT Capital’s commitment to maintain the highest standards of transparency, probity, and accountability, consistent with its stature as a PLC. The Whistleblowing Policy strictly prohibits fraudulent practices and unethical conduct by any of its board members, officers and employees. It defines who qualifies as a whistleblower and provides the procedure to be followed by such whistleblower to report in good faith acts or omissions which he or she reasonably believes violate a law, rule or regulation or constitute unethical conduct or fraudulent accounting practice. Whistleblowers are protected by the confidentiality and non-retaliation provisions in the Whistleblowing Policy. The former makes sure that the Corporation maintains the anonymity of the whistleblower during the review and investigation process, and provides sanctions to be imposed on any party who reveals the identity of the whistleblower without his consent. The non-retaliation policy prohibits retaliation or reprisal tactics against employee whistleblowers, such as punitive transfers, withholding of professional promotion or training, loss of seniority rights or benefits, among others, and provides that disciplinary action shall be taken against an officer or employee who engages in such conduct. The Whistleblowing Policy is accessible through the GT Capital website, and is also attached to GT Capital’s CG Manual. Reports by stakeholders, including employees, may be submitted by e-mail or directly in writing to the Chief Audit Executive (“CAE”). The CAE may then investigate the report, appoint an investigating officer, create a special Task Force (internal or outsourced) to investigate the matter independently, or elevate the report to the Discipline, Ethics, and Values Committee composed of the CAE and the respective heads of the Human Resources and Administration Department and Legal and Compliance Department. Investigations shall be completed within sixty calendar days from receipt of the report by the CAE.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption


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1) This case study is based on published information by GT Capital, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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