Policy, objectives, and overall coverage
- The code declares NAPOLCOM policy to administer and control the PNP effectively and efficiently through a corps of officials and employees who are exemplars in selfless public service—accountable to the public, responsible, honest, competent, efficient, morally upright, with simple but dignified lifestyle, and with judicious utilization of financial and logistical resources (Section 2).
- The code declares a further policy to fortify commitment to public service and uphold the primacy of public interest over personal interest in performing duties and responsibilities (Section 2).
- The code’s objectives include establishing standards of behavior and conduct for NAPOLCOM officials and employees, including:
- promoting ethical behavior, professionalism, and excellence;
- fostering responsible stewardship over NAPOLCOM assets and ensuring strict adherence to accounting and auditing rules;
- ensuring effective and responsive systems that promote accountability, transparency, and efficiency;
- establishing incentives, rewards, and grants for exemplary conduct; and
- specifying the applicable administrative penalty for any violation of the code (Section 3).
- The code applies to all officials and employees of NAPOLCOM, regardless of appointment nature or status (permanent, temporary, contractual, on-the-job training, or on detailed service from other government agencies or consultant), when they report within NAPOLCOM as regular working hours (Section 4).
Definitions and core values
- The code provides definitions including:
- “Conflict of Interest” as institutional and personal interests that interfere with duty performance or affect objectivity/independence of judgment (Section 5(b));
- “Deputized Official” as local government executives (mayors/governors) automatically deputized pursuant to Section 6 of R.A. 8551 (Section 5(c));
- “Employee” as individuals occupying 1st and 2nd level positions in NAPOLCOM (Section 5(d));
- “Official” as personnel occupying 3rd level positions (Section 5(g));
- “Personnel” as both officials and employees (Section 5(h));
- “Nepotism” as appointments made in favor of a relative within the 3rd degree of either consanguinity or affinity of the recommending/appointing authority or immediate supervision (Section 5(f));
- “Sanction” as the commensurate administrative penalty imposed upon an exercising official (Section 5(i));
- “Violation/Offense” as any act or omission contravening rules embodied in the code (Section 5(k));
- “Whistleblower” as a person who reveals wrongdoing or malpractices within the organization (Section 5(l));
- “Grievance” as a complaint in writing ignored, overridden, or dropped without due consideration based on the employee’s opinion (Section 5(e));
- “Token” as a nominal item given to visitors/lecturers/guests or things received by NAPOLCOM personnel from other institutions for services rendered as lecturer/speaker or similar acts (Section 5(j)).
- NAPOLCOM officials and employees must uphold the core values of Honesty, Integrity, and Dedication (Section 6).
- The code includes a pledge to be solemnly sworn, emphasizing excellence and professionalism, honesty/integrity and esprit da corps, efficient service, obedience and respect for the rule of law, listening to client concerns, transparency and accountability, oversight of Commission policies and programs for the PNP, and holding a civilian police organization promoting community welfare (Section 6).
General conduct norms and office rules
- Personnel must avoid conduct that causes breach of public trust and confidence; in case of conflict, public interest shall prevail (Section 7(a)).
- Personnel must treat clients, stakeholders, co-employees, and officials with utmost honesty, impartiality, and fairness, and respect their rights and obligations; officials must hear complaints of staff fairly and reasonably (Section 7(a)(1)-(2)).
- Officials and supervisors must demonstrate and promote leadership by example; personnel must notify or disclose violations of laws and breaches of ethical standards to the appropriate authority, and employees must bring matters directly to the appropriate body rather than through media or unprofessional means (Section 7(a)(4)).
- The Commission (or appropriate authority) shall entertain written and duly signed complaints only for impartiality; unsigned grievances in the form of a white paper or any document may be entertained only after review if sufficient ground exists to conduct an investigation (Section 7(a)(5)).
- Personnel must exercise transparency in official and personal transactions and contracts and must make known office policies and procedures in clear and understandable language, ensure openness of information, conduct public consultation when appropriate, and encourage suggestions/feedback (Section 7(b)(1)-(2)).
- Personnel must, upon written request, make available public documents for inspection within reasonable working hours, provided no confidentiality rule under existing laws is violated; requests from third parties or media must be in writing and duly approved by the Vice-Chairman and Executive Officer (VCEO) or the appropriate authority (Section 7(b)(3)).
- Personnel must maintain confidentiality by prohibiting altering, falsifying, concealing, destroying, or mutilating public or official records; confidential information must not be released without approval of the immediate supervisor, and confidential documents must be transmitted directly to concerned officials or authorized representatives without discreet discussions (Section 7(c)).
- The VCEO must designate an Official Spokesperson responsible for releasing information on NAPOLCOM programs, activities, or issues (Section 7(d)(1)).
- Personnel must conduct themselves with dignity and respect toward the public, maintain impartiality, propriety, and probity, and avoid comments and personal opinions that may be construed as the Commission’s official position (Section 7(d)(2)-(4)).
- Personnel must maintain an environment free of discrimination and harassment and must perform duties without expecting material gain or favor; they must not demand or insinuate financial consideration for past, present/pending, or future services or transactions with a client (Section 7(d)(5)-(6)).
- Office decorum rules include:
- wearing prescribed uniforms during work days except wash days (Friday), with appropriate and modest dress (Section 8(a)(1)(a));
- wearing the Identification Card (ID) as part of the uniform whenever inside NAPOLCOM premises and when representing NAPOLCOM for official business (Section 8(a)(1)(b));
- pregnant women and those in mourning are not required to wear the prescribed uniform during pregnancy and mourning (Section 8(a)(1)(c));
- prohibiting slippers/step-ins of any brand/cost inside NAPOLCOM premises (Section 8(a)(1)(d));
- marking absent by the HRMD of PAS persons not in prescribed uniform or not observing the dress code during office hours (Section 8(a)(1)(e));
- exempting on-the-job trainees and those on detail service from other government agencies from wearing NAPOLCOM uniform but requiring identification cards from their mother agency inside premises (Section 8(a)(1)(f)).
- Attendance rules require all personnel to attend the Flag Raising Ceremony every Monday at 8:00AM and Flag Retreat every Friday at 4:30PM (Section 8(a)(2)).
- Working hours rules require personnel to render daily eight hour duty on work days; they must log in and out via biometric scanner or bundy clock and logbook, and appointees to third level career positions must log in and out using a logbook (Section 8(a)(3)(a)).
- Personnel must not queue before biometric/bundy clock earlier than authorized dismissal time; flexible time must follow civil service law and rules (Section 8(a)(3)(b)).
- Overtime may be allowed only when urgently needed and failure to do so will negatively affect completion of projects/activities; personnel must secure an Official Business (OB) pass from immediate supervisor or a Letter Order for future reference (Section 8(a)(3)(c)).
- Personnel are prohibited from loitering around office premises (Section 8(a)(3)(d)).
- Officials and immediate supervisors must always be in their post to closely monitor staff and daily activities (Section 8(a)(3)(e)).
- Central office overtime requests must originate from the Staff Service Chief and be endorsed to the VCEO for consideration and approval; regional office overtime requests must be submitted to the regional director by the concerned division chief (Section 8(a)(3)(f)).
- The code adopts:
- a no-smoking policy within NAPOLCOM premises pursuant to Republic Act No. 9211, Civil Service Memorandum Circular No. 17, series of 2009, and NAPOLCOM Office Order No. 2003-01 (Section 8(a)(4));
- a drug-free workplace policy (Section 8(a)(5));
- an anti-violence policy, prohibiting threats or violent activities; possession of firearms by authorized personnel is governed by NAPOLCOM Office Order No. 2003-005 and existing laws; drinking alcoholic beverages during office hours is prohibited (Section 8(a)(6));
- a zero tolerance sexual harassment policy, where violation constitutes grave misconduct and may lead to disciplinary action including suspension or termination subject to administrative disciplinary rules of R.A. 7877 (Section 8(a)(7));
- telephone etiquette guidelines for the Information-Communication Program where office telephone is FOR OFFICIAL USE ONLY, allowing personal calls only for emergency calls of utmost necessity limited to three (3) minutes (Section 8(a)(8));
- a prohibition on use of computers for online games and social networking (Section 8(a)(9));
- cleanliness and orderliness through daily and weekly cleaning schedules (Section 8(a)(10)).
Nepotism and conflict-of-interest bans
- Nepotism is prohibited under existing civil service laws, and the code imposes these guidelines:
- No relative within the prohibited 3rd civil degree of affinity and consanguinity shall be employed in the same office/unit whether or not the authority exercises supervision or control over the appointee, covered by nepotism rules under civil service law and rules (Section 9).
- If more than one relative within the 3rd degree is already employed in the same office/unit, the resulting vacancy after separation by resignation, retirement, or death must be filled by a qualified person not related to the remaining family member within the prohibited degree (Section 10).
- In case of marriage between personnel in the same office/unit—especially where the official is the direct supervisor—the Director of Personnel and Administrative Service may recommend to the VCEO a change of assignment, reassignment, or transfer to maintain objectivity, fairness, and impartiality (Section 11).
- This nepotism policy applies to NAPOLCOM Central and Regional Office personnel except those in coterminus, highly technical and confidential positions (Section 12).
- Conflict-of-interest prohibitions require that no official or employee engage directly or indirectly in specified acts (Section 13), including:
- entering any contract with NAPOLCOM and any private entity with existing contracts with NAPOLCOM for procurement, services, or lease/sale of property (Section 13(a));
- participating in any official action where the person or a relative is applying for possible employment (Section 13(b));
- recommending for employment in the same office any relatives (Section 13(c));
- recommending any person for employment to any supplier or other person doing business with NAPOLCOM (Section 13(d));
- giving due advantage/preference to further personal/private interests and the benefited party (Section 13(e)).
Gifts, donations, sponsorships, and related limits
- NAPOLCOM maintains a “no gift policy,” defining gift as a thing or right disposed of gratuitously or any act of liberality, including simulated sale or ostensibly onerous disposition, and excluding unsolicited gifts of nominal or insignificant value not given in anticipation of or in exchange for a favor from a public official or employee (Section 13, paragraph beginning “Generally”).
- Officials and employees are prohibited from soliciting gifts, donations in cash or in kind, and sponsorship for themselves or others, regardless of amount, unless approved by the Head of the Agency (Section 14).
- Officials and employees are prohibited from accepting/receiving directly or indirectly any gift, donation, and/or sponsorship, regardless of amount, when it may influence or may reasonably be seen to influence past, present, or future performance of official functions, from any:
- bidder, supplier, contractor, or entity with contract/s with NAPOLCOM (including agents) (Section 15(a));
- individuals applying for official forms/documents such as clearances, certificate of ratings, etc. (Section 15(b));
- individuals, counsel, witnesses, or their agents undergoing fact-finding/formal investigation (Section 15(c));
- respondents, counsel, witnesses, or their agents in any case before NAPOLCOM (Section 15(d));
- persons or companies transacting official business with NAPOLCOM (Section 15(e)).
- No official or employee may accept any fee or remuneration beyond what the law legally entitles them to receive in the course of official functions (Section 16).
- Officials and employees may receive plaques, awards, certificates, souvenirs, or tokens of gratitude/benefits appropriate to invitations as guest speaker or lecturer, including acceptance of transportation and accommodation provided during the occasion/ceremony (Section 17).
- Officials and employees may receive gifts or cash awards given by NAPOLCOM during Anniversary and Christmas celebrations (Section 18).
- Officials and employees may receive performance-based cash rewards, scholarship grants, and similar benefits granted by appropriate government agencies, NGOs, and peoples organizations (Section 19).
Operational norms for investigations and transactions
- Personnel must follow operational conduct rules, including:
- Inspection Team must refrain from informing in advance PNP officials/personnel in subject police offices about impending NAPOLCOM inspection (Section 20(1)(a)).
- Familiarity with respondents or complainants is strictly prohibited (Section 20(1)(b)).
- Hearings/investigation involving victims of rape or sexual harassment by police personnel must be conducted in a separate room away from public view (Section 20(1)(c)).
- Impartiality and fairness must be observed in all stages of investigation or hearings (Section 20(1)(d)).
- Decisions and investigation reports may not be divulged unless authorized (Section 20(1)(e)).
- After each inspection, an after inspection report must be submitted to the VCEO within three (3) days (Section 20(1)(f)).
- The Chief PNP must be furnished a copy of the inspection report for implementation/appropriate action (Section 20(1)(g)).
- The Commission through IMIS must monitor regular implementation of recommendations/findings (Section 20(1)(h)).
- Examination rules require:
- prohibition on unauthorized personnel entering the quarantine room (Section 20(2)(a));
- confidentiality in preparation of test materials for PNP entrance, promotional examinations, and the Police Executive Service Examination (Section 20(2)(b));
- prohibition on releasing premature information on police examination results to further personal interest (Section 20(2)(c)).
- Purchase rules require:
- items for purchase must be included in the Annual Procurement Program (Section 20(3)(a));
- purchases must comply with Republic Act No. 9184 (Section 20(3)(b));
- clearance-required purchases must follow clearance requirements (Section 20(3)(c));
- government contracts must follow Republic Act No. 9184 (Section 20(3)(d));
- supply officers must monitor distribution of supplies, materials, and equipment (Section 20(3)(e)).
- Financial transaction rules require:
- NAPOLCOM personnel must not follow up claims of police personnel or beneficiaries (Section 20(4)(a));
- NAPOLCOM personnel must not accompany claimants during encashment of checks (Section 20(4)(b));
- recommendations relative to financial claim must not be divulged or withheld for personal gain (Section 20(4)(c));
- financial transactions must comply with the General Appropriations Act and related rules of the Department of Budget and Management and Commission on Audit (Section 20(4)(d));
- Special Disbursing Officers must liquidate cash advances immediately after disbursement as required by COA rules and regulations (Section 20(4)(e)).
Grievances, complaints, and complaint handling
- A grievance machinery is established to address grievances/complaints filed by NAPOLCOM officials and employees (Article VII title; Section 22).
- A grievance covers work-related issues causing dissatisfaction including:
- non-implementation of economic/financial policies and employment terms fixed by law (including salaries, incentives, working hours, leave benefits, and related terms);
- non-implementation of policies affecting employees from recruitment to promotion, detail, transfer, retirement, termination, lay-offs, and other issues;
- physical working conditions;
- interpersonal relationship and linkages;
- protest on appointment; and
- other analogous circumstances (Section 23).
- For grievances:
- oral complaints must be discussed first with the immediate supervisor, who must inform the aggrieved party within three (3) days of presentation (Section 24);
- if the immediate supervisor is the subject, the grievance must be presented to the next higher supervisor (Section 24);
- if unsatisfied, the complainant may submit a written grievance through the immediate supervisor to the next higher official, who must decide within five (5) days from receipt and inform the complainant in writing through the immediate supervisor (Section 25);
- if unsatisfied, the complainant may file a written grievance to the VCEO, who refers it to the Grievance Committee (Section 26).
- The Grievance Committee includes:
- a Service/Office Director assigned as Chairman;
- Director II of PAS or the Chief, Administrative Division of the Regional Office as member; and
- a rank-and-file employee designated by NAPEMA as member (Section 26).
- Grievance Committee procedure requires:
- within five (5) days from referral, the Chairman notifies parties of the hearing schedule;
- investigation and hearing must be completed within ten (10) days from receipt of the grievance;
- findings and recommendations must be prepared within five (5) working days after investigation and submitted to the VCEO, who must render a written decision within three (3) days from receipt (Section 27).
- Civil Service appeal:
- an appeal on the VCEO decision must be filed with the Civil Service Commission within fifteen (15) working days from receipt of the decision (Section 27).
- Special grievance routing:
- if the object of the grievance is the Grievance Committee, the aggrieved party may submit to top management (Section 27);
- if the object is top management, the aggrieved party may bring directly to the Civil Service Commission (Section 27).
- A complaint is a disclosure/report disciplinary or non-disciplinary under the Uniform Rules on Administrative Cases in the Civil Service (URACC) and handled by assigned NAPOLCOM committees (Section 28).
- Disciplinary complaint finality and decision limits:
- disciplinary complaints are acted and decided with finality if the penalty imposed is suspension for not more than thirty (30) days or fine not exceeding thirty (30) days salary (Section 28(a)).
- decisions imposing dismissal are executory only after confirmation by the Commission En Banc (Section 28(a)).
- Non-disciplinary complaints include:
- protest against appointment/s;
- complaints on personnel actions and other non-disciplinary actions (Section 28(b)(1)-(2)).
- Form and oath requirements:
- a complaint against a civil service official/employee must be written and subscribed and sworn by the complainant;
- complaints initiated by the proper disciplining authority need not be under oath (Section 28).
- Anonymous complaints:
- anonymous complaints are not entertained unless they have obvious truth or merit supported by documentary or direct evidence, and the person complained of may be required to comment (Section 28).
- Definitions for graft and corruption-related complaints:
- Graft is unlawful acquisition of public money through questionable/improper transactions, personal gain/advantage not part of official pay, usually implying theft/corruption/fraud/lack of integrity in transactions involving a public official (Section 29(a)).
- Corruption is abuse of public power for personal gain or benefit of a group to which one owes allegiance, including bribery, extortion, cronyism, nepotism, patronage, graft, and embezzlement (Section 29(b)).
- Internal Audit Service intake:
- graft and corruption-related complaints must initially be received by the Internal Audit Service for recording before referral to a specific committee (Section 30).
- Graft/corruption procedures:
- complaints are filed with the Internal Audit Service at central office or with the Office of the Regional Director (Section 31(a));
- within three (3) working days, the complaint is acted upon (Section 31(b));
- after evaluation, the complaint is numbered/coded and dated, then forwarded based on completeness:
- if complete and with documentary evidence: to NAPOLCOM Legal Affairs Service (Central) or Technical Services Division, Regional Office (Regional) (Section 31(c)(1));
- if insufficiently documented but verifiable: verification must be done within five (5) but not more than ten (10) working days (Section 31(c)(2)).
- validated complaints undergo preliminary investigation completed not more than forty-five (45) days, including submission of the preliminary investigation report by Legal Affairs Service/Regional Technical Services Division (Section 31(d)).
- if there is a prima facie case, the preliminary investigation report and formal charge (including preventive suspension if warranted) are forwarded for approval to:
- NAPOLCOM VCEO for central office officials/employees, or
- NAPOLCOM Regional Director for regional officials/employees (Section 31(e)).
- respondent rights and timeline:
- respondent must receive a copy of formal charge and all evidence;
- respondent must be informed of right to formal investigation and counsel of choice; and
- respondent must submit a sworn answer within five (5) days from receipt (Section 31(f)).
- URACC procedures apply to all proceedings (Section 31(g)).
Protected whistleblowing system and public disclosure
- The code establishes a mechanism to encourage disclosure of malpractices, corruption, illegal or fraudulent acts by co-personnel and to protect whistleblowers from retaliation/reprisal while promoting confidence in reporting (Article VIII preamble).
- Protected disclosure is defined as deliberate and voluntary disclosure of relevant information on actual, suspected, or anticipated wrongdoing by an official/employee or by any NAPOLCOM office/unit (Section 32).
- Persons classified as whistleblowers include those who meet the code’s specified requirements, including regular plantilla or contractual NAPOLCOM personnel at the time of complaint, and those personally involved or benefiting from irregularities with sufficient sworn statement and ability/willingness to assist prosecution; whistleblower status is also tied to not being the most guilty (with exceptions) and not being previously convicted by final judgment involving moral turpitude (Section 33).
- Protected disclosures may cover acts/omissions contrary to laws/rules/regulations; unreasonable, unjust, unfair, oppressive, or discriminatory acts; undue or improper exercise of powers; and matters of public interest or that may prejudice government as a whole (Section 34).
- Whistleblower rights include:
- no criminal, administrative, or civil action shall be entertained against a whistleblower involving a protected disclosure (Section 35(a));
- an absolute defense of privileged communication in actions arising from protected disclosures (Section 35(b));
- no breach of confidentiality duty when confidential information is disclosed as a protected disclosure (Section 35(c)).
- Whistleblower confidentiality is required at all times during and after protected disclosure and any proceedings, including confidentiality of identity, subject matter, and the person to whom disclosure was made (Section 36).
- Whistleblowers may be compelled to testify when testimony is necessary or indispensable to successful prosecution of charges arising from protected disclosure (Section 37).
- Confidential information protection is required, prohibiting identifying the whistleblower or revealing subject matter, except for limited instances: written consent, indispensability for proceedings, or disclosure/referral pursuant to an obligation under the rules (Section 38). The prohibition also binds any official who became privy by any means (Section 38).
- Retaliation protection includes both protection from disciplinary liability and a broad ban on retaliatory actions (including enumerated forms like victimization, reprimand, punitive transfer, adverse personnel file notes, ostracism, public humiliation, denial of work for promotion, and similar retaliatory acts) (Section 39).
- Conditions for entitlement to whistleblower benefits require all listed requisites to concur, including voluntary written disclosure under oath, assisting participation in proceedings, sufficiently detailed information supported as much as possible by other evidence, and conditions regarding whether the disclosure relates to matters already filed/investigated (with limited exception where necessary for successful prosecution or essential evidence acquisition) (Section 40).
- A disclosure is not deemed protected in cases including disclosures made in connection with the whistleblower’s own official investigation, disclosures later found absolutely groundless without basis (allowing investigation decline/discount if made without reasonable grounds), absolutely false/misleading disclosures, or disclosures later retracted by the whistleblower (which then forfeits the right to benefits for that disclosure and affects admissibility for future disclosures) (Section 41).
- A disclosure made by a person who is a party to the disclosed conduct is still deemed protected under the