Employees must adhere to the anti-corruption policy when dealing business with customers, suppliers, trade partners or third parties in relevant to the Company’s business.
7.1. Employees must comply with laws, rules, business traditions and manners when interacts with relevant business-related third parties. Employees who didn’t comply with to Anti-corruption Policy will face disciplinary punishment, related legal penalties and may also be legally prosecuted.
7.2. Employees must not seek any benefit from their positions in the Company in receiving or soliciting any business-related third party or relevant individual to provide service that has no connection to the Company’s business.
7.3. When employees or management recommend an individual to the Company, such action must not induce conflict of interests or interfere with the company’s recruitment process and must not be unlawful act towards personal gain.
7.4. The bribery with money or other benefits
1. Employees must not accept or solicit, both directly and indirectly, for money, gift voucher, check, stock, present, any bribe, special compensation or incentives of any value from relevant business-related third parties and employees in the Company such as the public sector and the private sector.
2. Employees must not bribe authorities or government officials by offering money, gift vouchers, check, stock, present, or any bribe, special compensation or valuable incentives.
7.5. Procurement Process
1. For the purchase and hire process must be conducted by the Company’s working procedures, from the beginning of biding, price comparisons, selected suppliers and/or contractors by prohibiting employees accept the bidding that enclose hidden benefits with suppliers and/or contractors. However, the Company have an active internal control system that monitor and involved by related manager departments, and all the procurements were approved by Managing Director only.
2. The action of business relationship, negotiation and purchasing between public or private sectors must be carried out with transparency, integrity and strictly abide by the law.
7.6. Donate to charity, public interest and Sponsorships
There are restrictions on donations to charity, public interest, and funding as follow;
1. Charitable contributions and sponsorships to individuals or organizations, both for government or private sector, must be transparent and with objectives for charity, and not made with the expectation of favorable treatment in return that may give the appearance as being for fraud or corruption. Thus, the request and approval processes must be in accordance with the Charitable Contributions and Sponsorships Procedures.
2. To approve the donation is subject to the Company’s approval authority but if donations and sponsorships in any form is worth not more than THB 10,000 must be approved by Human Resources Manager if more than THB 10,000 must be approved by Managing Director.
3. The donation must be under ‘the Company’s name’ only with reliable evidences and follow the Company’s procedures. The Company shall not claim on the donation to other purpose.
4. The sponsorships can be support in the way of asset or financial support to the project or activities that are made for business objectives and usually for brand or reputation management purposes. It must be under ‘the Company’s name’ only with reliable evidences and purposes and follow the Company’s procedures.
5. Charitable contributions and sponsorships must demonstrate that their activities, based on the objective of the project, have taken place and can be traced.
Procedures for charitable contributions and sponsorships as follows:
1. The Requestor prepares the “Requesting Form” that indicates the name of the receiving organization and the objectives with the supporting documents attached. The Requesting Form shall be approved by the authority according to the authority limits as indicated in the table below.
|Less than THB 10,000
||Human Resource Manager
|More than THB 10,000 But not exceeding THB 100,000
|THB100,000 and above
||The Chairman of the Executive Board
2. Human Resource Manager reviews and approves the “Requesting Form” if the objectives for the charitable contributions and sponsorships are aligned with the established procedures.
3. The Requestor provides evidence of the charitable contribution or sponsorship, such as a “Thank You Letter” from the organization receiving the contribution or a picture of the donation, to the Finance Department as supporting documentation after the charitable contribution or sponsorship has been made.
4. The Finance Department reviews evidence relating to the charitable contribution or sponsorship, as well as retains the evidence in a proper manner. In the event of insufficient evidence, additional supporting documentation or clarification shall be requested. If it is proven the charitable contribution or sponsorship provided do not comply with the Company’s policy or has been used as an excuse/method for corruption, the perpetrator will be subject to the highest level of disciplinary action.
5. The Finance Department prepares a “Summary Charitable Contributions and Sponsorships Report” which is submitted to Managing Director on a quarterly basis.
6. The Internal Audit Department evaluates the charitable contribution and sponsorship process annually to ensure the efficiency, effectiveness and appropriateness of the internal controls of the process.
7.7. Political Contributions
The Company adopts a political neutrality policy and establishes independent management and operations, without involvement in political activities. The definition of political contribution is a contribution, financial or in-kind, to support a political cause. Defining what a political contribution is presents some difficulty. Financial contributions can include loans. In-kind contributions can include gifts of property or services, advertising or promotional activities endorsing a political party. The release of employees without pay from the employer to undertake political campaigning or to stand for office could also be included in the definition.
Employees have right and political liberty and have the freedom to participate in political activities under the terms of the Constitution, related laws, and regulations. However, Employees must not participate in any political activities on behalf of The Company or employ any of The Company’s resources as political contributions to political parties or any parties in relation to politics. However, one must not use company’s resources in either directly or indirectly for the political purpose that leads to the loss of company’s neutrality and a potential to damage company’s reputation.
7.8. Gifts, Hospitality and Expensess
Managers and Employees of the Company must not accept any gifts, hospitality and expenses from customers and suppliers. However, the gifts are acceptable if it is intended solely for the reception, greeting or congratulate only, no hidden agendas, such as gift baskets during festive season, snacks, Promotional products in small values such as pens, books, calendars, or mugs with the organization’s logo. The receiving or providing of gifts and entertainment must be transparent and not with the expectation of favorable treatment in return. Receiving or providing gifts and entertainment but be done on behalf of the Company only.
Procedures for receiving and providing Gifts, Hospitality and Expenses
1. The receiving or providing of gifts and entertainment is permitted according to tradition but must not impact The Company’s operations and business decisions. Employees must not ask for gifts and entertainment.
2. Providing Gifts, Hospitality and Expenses during festive season
2.1 The Requestor has to prepare “Requesting Form” that shall be indicated the name of the organization receiving the gifts and hospitality, the details of gifts and entertainment to be provided, the quantity, the amount (Not More Than THB 2,000 per piece), and the objectives as well as the supporting documents attached. The Requestor submits the form to Human Resource Manager to review and approve.
2.2 Human Resource Manager reviews and approves the “Requesting Form” if the objectives for gifts and entertainment align with the established procedures.
2.3 The Requestor provides evidence of gifts and entertainment, such as receipts and a “Thank You Letter” from the organization receiving the gifts or hospitality, as supporting documentation after the gift or entertainment has been provided.
2.4 The Finance Department reviews evidence relating to the gifts or entertainment as well as retains evidence in a proper manner. In the event of insufficient evidence, additional supporting documentation or clarification shall be requested. If it is proven that the gifts and entertainment provided do not comply with the Company’s policy or have been used as an excuse/method for corruption, the perpetrator will be subject to the highest level of disciplinary action.
2.5 The Finance Department prepares a “Summary Gifts and Hospitality Provided Report” which is submitted to the Managing Director on a quarterly basis.
2.6 The gift and hospitality process shall be evaluated by the Internal Audit Department annually to ensure its efficiency, effectiveness and appropriateness.