SOCIEDAD ESPAÑOLA DE BENEFICENCIA

18-A Chatham House Bldg., 116 Valero cor. V.A. Rufino Sts.
Salcedo Village, 1227 Makati City
Tel. Nos. 843-0742; 889-6724; Tel/Fax 843-0739
e-mail: sociedad_espanola@pldtdsl.net
website: www.sociedadespanoladebeneficencia.com

STRICTLY CONFIDENTIAL – FOR SEB BOARD OF TRUSTEES ONLY.

March 10, 2009

Subject: On the matter of confidentiality

Dear ,

The Board of Trustees has observed that, during the last few board meetings,
certain classified information about details of SEB’s investment portfolio and certain
critical comments expressed by some trustees during the board meetings appear to
have leaked out to other concerned parties, to wit:

1. Certain details of SEB’s investment portfolio managed by ING were the

subject of discussion included in Merill Lynch’s proposal to SEB to take over
the management of some SEB’s funds portfolio with ING (reference: Merill
Lynch letter proposal to SEB dated ).

2. Board discussion and comments exchanged amongst the trustees present

during the board meeting on March 5, 2009 on the topic of SEB’s donation of
P10 million to Siervas de Jesus de la Caridad. More specifically, whether the
P1.7 million that SEB had raised through solicitation from an agency-donor,
for the acquisition of elevator for the new 5-storey building of Siervas de
Jesus de la Caridad, is deemed part of the P10 million donation that had
been previously approved by the Board or to be treated as additional
donation on top of the approved P10 million?

Our SEB staff were surprised to receive a call from Madre Sagrario of Siervas
the following day, March 6, to ask for more details on the above board
discussion and comments. The telephone call received from Madre Sagrario
is obviously motivated by the information she received (according to her
“yesterday”, March 5) from anyone knowledgeable about the discussion and
exchange of comments from the meeting that happened the day before.

The board, through its President, expresses deep concern about how information
and exchange of comments during board meetings are handled and kept.
Needless to say, unauthorized dissemination of classified information cause varied
reaction from concerned parties that result into misunderstanding and discomfort
in relationships.

More board meetings will happen and more classified confidential information will
continue to float in the process. It is on this note that the following reminder is
appropriate to be circulated among the board including key staff of Sociedad
Española de Beneficencia:

1. To observe confidentiality: A member of the Board of Trustee should

observe confidentiality of information acquired by reason of his position as
Trustee. He/she should not disclose any information to any other person
without the authority of the Board. A trustee who has a special allegiance to
a particular stakeholder and any person, natural and/or juridical, shall not
disclose any information to those particular stakeholder and any person
without the authority of the board.

2. To ensure the continuing soundness, effectiveness and adequacy of the

organization’s control environment.

3. The board and the trustees are, therefore, reminded not to ignore ethical
standards in the pursuit of transparency balanced with confidentiality. Core
values must govern how the organization is run.

Thank you.

FRANCISCO A. GOMEZ DE LIAÑO

Presidente

Cc: Corporate Secretary Alberto Guevara, Jr.

Executive Director Rodelio B. Arellano
Finance & Admin Kimmy S. Alegarbes