[To be prepared on the entity’s letterhead]

May 28, 2021

SyCip Gorres Velayo & Co.

2F Elan 3 Building, Roxas Avenue
General Santos City, 9500

Attention: Jose Rao’ul J. Balisalisa

Partner in charge

This representation letter is provided in connection with your audits of the financial statements
of Richmond Land Innovations, Inc. (a subsidiary of RD Corporation) (the Company) for the years
ended December 31, 2020 and 2019. We recognize that obtaining representations from us concerning
the information contained in this letter is a significant procedure in enabling you to form an opinion as
to whether the financial statements present fairly, in all material respects, the financial position of the
Company as of December 31, 2020 and 2019 and of its financial performance and its cash flows for
the years then ended in accordance with Philippine Financial Reporting Standards (PFRSs).

We understand that the purpose of your audits of our financial statements is to express an opinion
thereon and that your audit was conducted in accordance with Philippine Standards on Auditing,
which involves an examination of the accounting system, internal control and related data to the
extent you considered necessary in the circumstances, and is not designed to identify - nor necessarily
be expected to disclose - fraud, shortages, errors and other irregularities, should any exist.

Accordingly, we make the following representations, which are true to the best of our knowledge and
belief, having made such inquiries as we considered necessary for the purpose of appropriately
informing ourselves:

A. Financial Statements and Financial Records

1. We have fulfilled our responsibilities, as set out in the terms of the audit engagement letter
dated October 30, 2020 for the preparation of the financial statements in accordance with
PFRSs.

2. We acknowledge, as members of the Board of Directors (BOD) of the Company, our

responsibility for the fair presentation of the Company’s financial statements. We believe the
financial statements referred to above present fairly, in all material respects, the financial
position, financial performance and cash flows of the Company in compliance with PFRSs,
and are free of material misstatements, including omissions. We have approved and
authorized the issuance of the Company’s financial statements on May 28, 2021.

3. The significant accounting policies adopted in the preparation of the financial statements are
appropriately described in the notes to the financial statements. The significant accounting
policies adopted in the preparation of the Company’s financial statements are appropriately
disclosed in Note 2 to the financial statements. Additional disclosures are also made in
various notes to financial statements to explain significant information related to the balances
reflected in the face of the financial statements.
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4. Each element of the financial statements is properly classified, described and disclosed in
compliance with PFRSs.

5. As members of management of the Company, we believe that the Company has a system of
internal controls adequate to enable the preparation of accurate financial statements in
accordance with PFRSs that are free from material misstatement, whether due to fraud or
error. In addition, we have informed you of the significant information about all changes in
procedures and controls arising as a result of the COVID-19 pandemic. The Company
properly considered the impact of the pandemic and believe that it does not pose any
deficiencies on the Company’s internal controls.

6. There are no material weaknesses in internal control, including any of which we believe the
cost of corrective actions exceed the benefit. There have been no significant changes in
internal control from January 1, 2021 to May 28, 2021, which is the date of your report.

7. We acknowledge that the Company’s loose-leaf books of accounts and accounting records
registered with the Bureau of Internal Revenue (BIR) should at all times agree with the
audited financial statements/balances filed with the BIR and other regulatory authorities.

8. There are no unadjusted audit differences identified during the current year under audit.

9. The financial records of the Company have been kept so as to be sufficient to enable the
financial statements to be prepared and audited, and other records and registers required by
the Bureau of Internal Revenue (BIR) Revenue Regulation (R.R.) 15-2010 has been properly
kept and is up-to-date.

B. Non-compliance with laws and regulations, including fraud

1. We acknowledge that we are responsible to determine that the Company’s business activities
are conducted in accordance with laws and regulations and that we are responsible to identify
and address any non-compliance with applicable laws or regulations, including fraud.

2. We acknowledge that we are responsible for the design, implementation and maintenance of
internal controls to prevent and detect fraud.

3. We have disclosed to you the results of our assessment of the risk that the Company’s
financial statements may be materially misstated as a result of fraud.

4. We have no knowledge of any identified or suspected non-compliance with laws or

regulations including fraud that may have affected the Company (regardless of the source or
form and including without limitation, any allegations by “whistleblowers”), including non-
compliance matters:

 Involving financial improprieties

 Related to laws or regulations that have a direct effect on the determination of

material amounts and disclosures in the Company’s financial statements

 Related to laws or regulations that have an indirect effect on amounts and

disclosures in the financial statements, but compliance with which may be
fundamental to the operations of the Company’s business, its ability to continue in
business, or to avoid material penalties

 Involving management, or employees who have significant roles in internal control,

or others
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 In relation to any allegations of fraud, suspected fraud or other non-compliance with

laws and regulations communicated by employees, former employees, analysts,
regulators or others.

C. Compliance with Laws and Regulations

1. We have provided you with:

 Access to all information of which we are aware that is relevant to the preparation of
the financial statements such as records, documentation and other matters;

 Additional information that you have requested from us for the purpose of the audit;
and;

 Unrestricted access to persons within the Company from whom you determined it
necessary to obtain audit evidence.

We confirm that the scanned copies of the hardcopy documents provided to you represent the
true and genuine copies of the original documents. We also confirm that the electronic copies
of forms and other similar documents with electronic signature provided to you are authentic
in accordance with applicable laws, rules and regulations and have not been altered.

2. All material transactions have been recorded in the accounting records and are reflected in the
financial statements.

3. We have made available to you all minutes of the meetings of shareholders, directors and
committees of directors (or summaries of actions of recent meetings for which minutes have
not yet been prepared) held from January 1, 2020 to the most recent meeting on
May 28, 2021, which is the date of your audit report.

4. We confirm the completeness of information provided regarding the identification of related

parties. We have disclosed to you the identity of the Company’s related parties and all related
parties and related party transactions of which we are aware, including sales, purchases,
information relating to remuneration of directors and other key management personnel, loans,
transfers of assets and liabilities and other transactions for the year ended, as well as related
balances due to or from such parties as at December 31, 2020. These transactions have been
appropriately accounted for and disclosed in notes to the financial statements. All
transactions with related parties were entered into at arm’s length.

5. We believe that the methods, significant assumptions and the data we used in making
accounting estimates and related disclosures are appropriate and consistently applied to
achieve recognition, measurement and disclosure that is in accordance with PFRSs.

6. We have disclosed to you, and the Company has complied with, all aspects of contractual
agreements that could have a material effect on the financial statements in the event of
noncompliance, including all covenants, conditions or other requirements of all outstanding
debt.

7. We have made available to you all signed contracts and related documents pertaining to
activities and engagements that were transacted during the year and of the previous years
which affected your current year audit.
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8. We have properly disclosed in the notes to the financial statements of the Company’s risk
management objectives and policies as well as capital management policies.

9. From June 10, 2020 through the date of this letter, we have disclosed to you any unauthorized
access to our information technology systems that either occurred or to the best of our
knowledge is reasonably likely to have occurred based on our investigation, including of
reports submitted to us by third parties (including regulatory agencies, law enforcement
agencies and security consultants), to the extent that such unauthorized access to our
information technology systems is reasonably likely to have a material impact to the financial
statements, in each case or in the aggregate.

D. Independence and Conflict of Interest

1. We are not aware of any act or omission on the part of the Company that does or may impact
on your ability to comply with your independence obligations as auditor of the Company. We
have brought to your attention any items which we consider may affect your ability to remain
independent of the Company and we will continue to work with you to maintain the
independence of the audit relationship.

2. We are not aware of any instances where an officer or director of the Company, or any
member of his or her immediate family (i.e., spouse, spousal equivalent, and dependents), has
a direct or material indirect business relationship with SGV & Co. or any of its affiliates, or
has an ownership interest of five percent or more in, or serves as an officer or director of, any
Company (public or private) that has a direct or material indirect business relationship with
SGV & Co. or any of its affiliates.

3. We are not aware of any reason SGV & Co. would not be considered to be independent for
the purposes of the Company’s audit. There are no instances where any officer or employee
of the Company has an interest in a company with which the Company does business that
would be considered a “conflict of interest”. Such an interest would be contrary to Company
policy.

4. We are not aware of any capital lease, material cooperative arrangement, or any business
relationship between the Company and SGV & Co. or any of its affiliates.

E. Comparative Information - Comparative Financial Statements

In connection with your audit of the comparative financial statements for the year ended
December 31, 2020, we represent, to the best of our knowledge and belief, that there have been no
significant errors or misstatements, or changes in accounting policies that would require a
restatement of the amounts from the financial statements for the year ended December 31, 2019
which are shown as comparative amounts in the financial statements for the year ended December
31, 2020. Any differences in the comparative amounts from the amounts in the financial
statements for the year ended December 31, 2019 are solely the result of reclassifications for
comparative purposes.

F. Recognition, Measurement and Disclosure

1. Items included in the financial statements are measured using the Company’s functional
currency that best reflects the economic substance of the underlying events and circumstances
relevant to the Company. The financial statements are presented in Philippine peso, which is
the functional currency of the Company.
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2. The management has considered the statement of financial position values of non-current
assets and are satisfied that no provision are required either due to impairment in values of
these assets or for any other reason. The assumptions used in estimating the recoverable
amounts of these assets for determining whether there has been any impairment are
reasonable.

3. We have no plans or intentions that may materially affect the carrying value or classification
of assets and liabilities reflected in the Company’s financial statements.

4. Other significant judgements and estimates of the Company were properly recognized and
disclosed in Note 3 of the Company’s financial statements.

5. We are not aware of any subsequent events that require adjustment to the accounting
estimates and disclosures included in the financial report.

G. Effects of New Accounting Standards

We are aware of the amendments to the following standards effective January 1, 2020 and these
had no impact on the financial statements of the Company:

 Amendments to PFRS 3, Business Combinations, Definition of a Business

 Amendments to PFRS 7, Financial Instruments: Disclosures and PFRS 9, Financial
Instruments, Interest Rate Benchmark Reform
 Amendments to PAS 1, Presentation of Financial Statements, and PAS 8, Accounting
Policies, Changes in Accounting Estimates and Errors, Definition of Material
 Conceptual Framework for Financial Reporting issued on March 29, 2018
 Amendments to PFRS 16, COVID-19-related Rent Concessions

H. Ownership and Valuation of Assets

1. The Company has satisfactory title to all assets appearing in the balance sheets, and there are
no liens or encumbrances on the Company’s assets, nor has any asset been pledged as
collateral, other than those that are disclosed in the financial statements. All assets to which
the Company has satisfactory title appear in the balance sheets.

2. There are no formal or informal compensating balance arrangements with any of our cash and
investment accounts.

3. Financial and nonfinancial assets to be held and used have been reviewed for impairment
whenever events or changes in circumstances have indicated that their carrying amounts may
not be recoverable.

I. Financial Instruments

Financial risk management objectives and policies and capital management including
analyses presented in the Company’s financial statements are complete and accurate and are
responsibility of the management.

J. Property, Plant and Equipment

1. Property, plant and equipment, except for construction in progress, are carried at revalued
amounts as determined by an independent firm of appraisers, which is the fair value at the
date of the revaluation less any subsequent accumulated depreciation, except land, and
subsequent accumulated impairment losses. The revalued amounts were determined based on
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valuations undertaken by professionally qualified appraisers for all classes of property, plant
and equipment. Subsequent additions are stated at costs. The net appraisal increment
resulting from the revaluation is credited to the “Revaluation increment on property, plant,
and equipment” account shown under the equity section of the statement of financial position.

2. The useful lives, depreciation and amortization methods and carrying values of property,
plant and equipment with regards to their impairment were periodically reviewed. Based on
the periodic review conducted on the foregoing, all assumptions and methods used were
reasonable and appropriately recorded and disclosed on the financial statements.

3. All directly attributable costs capitalized to property and equipment would qualify for
capitalization and in accordance with PFRSs.

4. An item of property and equipment is derecognized upon disposal or when no future

economic benefits are expected from its use or disposal. Any gain or loss arising on de-
recognition of the asset (calculated as the difference between the net disposal proceeds and
the carrying amount of the asset) is included in the statement of comprehensive income in the
year the asset is derecognized. Fully depreciated assets are retained in the accounts until
these are no longer in use.

5. Construction in progress represents structures under construction and is stated at cost.

Construction in progress is not depreciated until such time that the relevant assets are
completed and are available for use.

K. Investment Property

1. We determine whether a property qualifies as an investment property. In making its

judgment, we consider whether the property generates cash flows largely independent of
the other assets held by the entity. Owner-occupied properties generate cash flows that are
attributable not only to the property but also to the other assets used in the production or
supply process.

2. The Company’s investment property pertains to parcels of land held for an undeterminable
future use. To estimate the fair value of investment property, the Company uses an
approach that is primarily based on sales and listings, which are adjusted for the time of
sale, location and general characteristics of comparable lots on the neighborhood where the
subject lot is located. The carrying amounts of the investment properties approximate their
fair values.

L. Liabilities and Contingencies

1. All liabilities and contingencies, including those associated with guarantees, whether written
or oral, have been disclosed to you and are appropriately reflected in the financial statements.

2. We have informed you of all outstanding and possible litigation and claims, whether or not
they have been discussed with our legal counsels.

3. No claims in connection with litigation have been or are expected to be received.

4. We are unaware of any known or probable instances of noncompliance with the requirements
of regulatory or governmental authorities, including their financial reporting requirements,
and there have been no communications from regulatory agencies or government
representatives concerning investigations or allegations of noncompliance, except as follows:
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a. Matters of routine, normal, recurring nature (e.g., examinations by bank and insurance
examiners, examinations by taxing authorities), none of which involves any allegations of
noncompliance with laws or regulations that should be considered for disclosure in the
financial statements or as a basis for recording a loss contingency; and,

b. Matters referred to in the letters issued to you by the Company’s legal counsels.

M. Retirement Benefits

1. We have disclosed to you all significant retirement benefits promised and have made
available to you all significant summary plan descriptions, benefit communications, and
all other relevant information, including plan changes that constitute the plan.

2. The actuarial assumptions and methods used to measure retirement liabilities and costs for
financial accounting purposes are appropriate in the circumstances.

N. Operating Leases

We have properly recorded or disclosed in the financial statements the various lease
agreements entered by the Company as a lessor. We have determined that the lessor
retains all significant risks and rewards of ownership of the properties which are leased out
on operating lease.

O. Equity

1. We have properly recorded or disclosed in the face of the financial statements the Company’s
capital stock and retained earnings, along with other related information.

2. There are no share repurchase options and agreements and no person has an option to
subscribe for shares in the Company.

3. The list of stockholders provided by our Corporate Secretary as at December 31, 2020 reflects
the current owners of the Company.

4. There are no significant restrictions on our ability to distribute the retained profits of the
Company because of statutory, contractual, exchange of control or other restrictions.

P. Revenue

1. We have adequately disclosed a description of the service agreements/arrangements and a

description of the related revenue recognition policy.

2. We have disclosed to you all terms and made available to you all contracts, communications
(either written or oral), and other relevant information pertaining to arrangements with our
customers. These agreements represent the entire arrangements and are not supplemented by
other agreements either written or oral.

Q. Related Parties

1. Parties are considered to be related if one party has the ability to directly or indirectly, control
or exercise significant influence over the other party in making financial and operating
decisions. Parties are also considered to be related if they are subject to common control.
Related parties may be individuals (being members of key management personnel, significant
stakeholders and/or their close family members) or other entities and include entities which
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are under the significant influence of related parties of the Company where those parties are
individuals or any entity that is a related party of the Company. Except as otherwise
indicated, the outstanding accounts with related parties shall be settled in cash. The
transactions are made at terms and prices agreed upon by the parties.

2. We have disclosed to you all transactions and balances with all stockholders and related
companies in Note 15 to the financial statements including key management personnel
compensation of the Company.

3. We confirm the completeness of information provided regarding the identification of related

parties. We have disclosed to you the identity of the Company’s related parties and all related
parties transactions of which we are aware, including liabilities and services, non-monetary
transactions and transactions for no consideration for the period ended, as well as related
balances due to or from such parties at December 31, 2020 and 2019. These transactions
have been appropriately accounted for and disclosed in the financial statements.

4. In 2020, the Company made reclassifications of related party balances from one affiliate to
another as a result of its reconciliation process. The same reclassifications were also made in
the 2019 balances to conform with the 2020 presentation. These reclassifications did not
affect the Company's statements of comprehensive income in both 2020 and 2019.

R. Profit and Loss Accounts

1. The results for the year were not materially affected by transaction of a sort not usually
undertaken and circumstances of an exceptional or nonrecurring nature.

2. In particular, all income earned by the Company have been accounted for in the financial
statements. Likewise, all expenditure has been taken into the financial statements and they
are in the normal course of business of the company.

3. All expenses included in the financial statements have been disbursed in connection with the
business of the Company and do not include any personal expenses of directors and/or
shareholders.

S. Purchase and Sales Commitments and Sales Term

1. As at December 31, 2020 and 2019, the Company had no unusual commitments or
contractual obligations of any sort which were not in the ordinary course of business and
which might have an adverse effect upon the Company (e.g., contracts or purchase
agreements above market price; repurchase or other agreements not in the ordinary course of
business; material commitments for the purchase of property and equipment; significant
foreign exchange commitments; open balances on letters of credit; purchase commitments for
inventory quantities in excess of normal requirements or at prices in excess of the prevailing
market prices; losses from fulfillment of, or inability to fulfill, sales commitments, etc.).

2. We have provided you with all contracts and agreements where the Company is a contracting
party. These agreements represent the entire arrangements and are not supplemented by other
agreements either written or oral.

T. Income and Indirect Taxes

3. We acknowledge our responsibility for the tax accounting methods adopted by the Company,
which have been consistently applied in the current period, and for the current year income
tax provision calculation. Required disclosures on income taxes are adequately made in
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Note 20 to the financial statements.

4. We have disclosed to you all tax opinions, correspondence with tax authorities, or other
appropriate information that served as support for the accounting for potentially material
matters.

5. Deferred tax has been accounted for in compliance with PFRS.

6. We have communicated to you all nontaxable income and nondeductible expenses whether
your audit procedures have discovered them or not. In addition, we represent the validity of
all nontaxable income and deductible expenses that we reflected in our tax computation for
the year ended December 31, 2020. In the event that the BIR questions these reconciling
items, management would be able to properly explain its treatment of these items.

7. The income tax return of the Company, including all information contained therein, is the
responsibility of the management. Accordingly, management is responsible for its
completeness, accuracy and compliance with applicable tax laws and regulations.

8. We have acknowledged our responsibility for the implications of Corporate Recovery and
Tax Incentives for Enterprises (CREATE) Act. On March 26, 2021, the President of the
Philippines signed into law the proposed CREATE. Effective July 1, 2020, regular corporate
income tax (RCIT) rate is reduced from 30% to 25% for domestic and resident foreign
corporations. For domestic corporations with net taxable income not exceeding = P5.0 million
and with total assets not exceeding =P100.0 million (excluding land on which the business
entity’s office, plant and equipment are situated) during the taxable year, the RCIT rate is
reduced to 20%. As clarified by the Philippine Financial Reporting Standards Council in its
Philippine Interpretations Committee Q&A No. 2020-07, the CREATE Act was not
considered substantively enacted as of December 31, 2020 even though some of the
provisions have retroactive effect to July 1, 2020. The passage of the CREATE Act into law
on March 26, 2021 is considered as a non-adjusting subsequent event. Accordingly, current
and deferred taxes as of and for the year ended December 31, 2020 continued to be computed
and measured using the applicable income tax rates as of December 31, 2020 (i.e., 30% RCIT
/ 2% MCIT) for financial reporting purposes.

U. Additional disclosures required by the Bureau of Internal revenue (BIR) per Revenue
Regulation (RR) No. 15-2010

1. We acknowledge, as members of management of the Company, our responsibility for the

presentation of the supplementary information on taxes, duties and license fees paid or
accrued during the taxable year, and other information required by the BIR.

2. We believe that the supplementary tax information referred to above is fairly presented in
accordance with R.R. No. 15-2010. Further, we represent that this disclosure is complete and
the amounts presented therein are properly measured and classified into the proper tax items.

3. We believe that the significant assumptions or interpretations underlying the measurement or

presentation of the supplementary information are reasonable and appropriate in the
circumstances.

V. Submission of BIR Form No. 1709 required by R.R. No. 34-2020

We are responsible to present and disclose the nature of intercompany transactions and
comply with the guidelines and procedures set forth by the new regulation in relation to the
submission of BIR Form No. 1709 (RPT Form), Transfer Pricing (TP) Documentation and
other supporting documents by providing safe harbors and materiality thresholds.
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W. Additional Supplementary Schedule Required by the Securities and Exchange Commission

(SEC) per Revised Securities Regulation Code (SRC) Rule 68

1. We acknowledge, as members of management of the Company, our responsibility for the

presentation of the supplementary schedule on reconciliation of retained earnings available
for dividend distribution.

2. We believe that the supplementary schedule referred to above fairly state, in all material
respects, the information required to be set forth therein in relation to the basic financial
statements taken as a whole.

X. Use of the Work of an Expert

We agree with the findings of the experts engaged to do actuarial valuation of the retirement
benefits of employees and have adequately considered the qualifications of the experts in
determining the amounts and disclosure included in the financial statements and the underlying
accounting records. We did not give or cause any instruction to be given to the experts with
respect to the values or amounts derived in an attempt to bias their work, and we are not otherwise
aware of any matters that have had an effect on the independence or objectivity of the experts.

Y. Subsequent Events

Other than the passage of the CREATE Act into law on March 26, 2021, there have been no
events or transactions that have occurred subsequent to the reporting date and through the date of
this letter or are pending that would have a material effect on the financial statements at that date
of for the period then ended, or that are of such significance in relation to the Company’s affairs to
require adjustment or mention in a note to the financial statements in order to make them not
misleading regarding the financial position, financial performance, or cash flows of the Company.

Z. Going concern

The management of the Company believes that there exists no circumstance or event that would
cast significant doubt or material uncertainty on the Company’s ability to continue as a going
concern within 12 months from December 31, 2020.

Very truly yours,

Elizabeth T. Bergundo
Accounting Manager

Chloe Joie B. Torres

Finance and Accounting Head