The Exchange does not warrant and holds no responsibility for the veracity of the facts and representations contained in all corporate disclosures, including financial reports. All data contained herein are prepared and submitted by the disclosing party to the Exchange, and are disseminated solely for purposes of information. Any questions on the data contained herein should be addressed directly to the Corporate Information Officer of the disclosing party.

PAL Holdings, Inc.PAL

PSE Disclosure Form 17-12-A - List of Top 100 Stockholders (Common Shares) Reference: Section 17.12 of the Revised Disclosure Rules

Type of Securities

Common

For the period ended	Dec 31, 2021

Description of the Disclosure
We are submitting herewith the List of the Top 100 Stockholders (Common Shares) of the Company as of December 31, 2021. Based on the report of our Stock and Transfer Agent, the total of 20,133,236 common shares difference between the cumulative certificated common shares and lodged shares as against the total issued and outstanding shares reflected in the PHI month end report ,represents the total number of common shares still pending with the BIR ,waiting for the issuance of CAR. By way of background, sometime in 2017 – 2018, PAL and PHI undertook a share swap transaction between PAL shareholders and PHI to provide the former an exit mechanism by which they can dispose or unload their shares via the stock exchange. Said transaction have been filed with the BIR and while some of the shareholders have been able to secure their CARS, there is still the balance of 20,133,236 who are waiting for the release of their CARS. Thus their status cannot be reflected in either the certificated or lodged shares. We trust you will take note accordingly. Thank you.

Description of the Disclosure

We are submitting herewith the List of the Top 100 Stockholders (Common Shares) of the Company as of December 31, 2021.

Based on the report of our Stock and Transfer Agent, the total of 20,133,236 common shares difference between the cumulative certificated common shares and lodged shares as against the total issued and outstanding shares reflected in the PHI month end report ,represents the total number of common shares still pending with the BIR ,waiting for the issuance of CAR. By way of background, sometime in 2017 – 2018, PAL and PHI undertook a share swap transaction between PAL shareholders and PHI to provide the former an exit mechanism by which they can dispose or unload their shares via the stock exchange. Said transaction have been filed with the BIR and while some of the shareholders have been able to secure their CARS, there is still the balance of 20,133,236 who are waiting for the release of their CARS. Thus their status cannot be reflected in either the certificated or lodged shares.

We trust you will take note accordingly. Thank you.

Number of Issued and Outstanding Common Shares	11,611,003,257
Number of Treasury Common Shares, if any	25,015
Number of Outstanding Common Shares	11,610,978,242
Number of Listed Common Shares	10,502,320,021
Number of Lodged Common Shares	1,849,276,686
PCD Nominee - Filipino	744,797,333
PCD Nominee - Non-Filipino	1,104,479,353
Number of Certificated Common Shares	9,741,593,335

Change from previous submission
None.

Filed on behalf by:

Name	Ma. Cecilia Pesayco
Designation	Corporate Secretary