Corruption refers to the misuse of authority and duties for the benefit of oneself or others or any form of bribery through offering, agreeing to, giving, promising, seeking, or receiving funds, assets, or other benefits in an inappropriate manner with government officials, government authorities, private entities, or persons with the duty, whether direct or indirect, to persuade such parties to perform or refrain from performing duties in order to acquire or maintain inappropriate business benefits.
The Company’s directors, executives, and employees shall not solicit, execute or receive all forms of corruption for the direct or indirect benefit of oneself, family members, friends, and associates, whether they are in the capacity of persons receiving, giving, or offering bribes in monetary and non-monetary terms. This shall cover all kinds of businesses in all countries and all entities relating to the Company. The Anti-corruption Policy shall be strictly complied with and the compliance with the policy shall be reviewed on a regular basis. Related practices and requirements shall be revised to ensure alignment with changing business circumstances, regulations, rules, and provisions of laws.
Duties and Responsibilities
- The Board of Directors shall be responsible for determining and approving the Anti-corruption Policy as well as overseeing and ensuring an efficient system to support the policy implementation so that all people at the Company can understand and realize the importance of the policy and apply it to their operations in fostering an anti-corruption corporate culture.
- The Audit Committee shall be responsible for monitoring and ensuring adequate internal controls and reviewing audit reports prepared by the Internal Audit Office for submission to the Board of Directors.
- The President and the Management Committee shall be responsible for arranging a system to promote and support the implementation of the Anti-Corruption Policy. The policy shall be communicated and trainings shall be provided for employees and relevant parties. Appropriateness of the system and measures shall be reviewed to ensure alignment with changes of business circumstances, regulations, rules, and laws.
- The Internal Audit Office shall be responsible for auditing and reviewing compliance with the policy and guidelines to ensure that the internal control system is appropriate and adequate for mitigating possible corruption risks; and sending audit reports to the Audit Committee.
- The Board of Directors, executives, and employees shall be responsible for strictly complying with and supporting the Anti-corruption Policy.
- The trading partners must agree to comply with the Company’s Anti-corruption Policy.
- The Board of Directors, executives, and employees shall comply with the Anti-corruption Policy and shall not involve in any forms of corruption, director or indirect. If the employees have any questions or need any advice regarding the compliance with the Anti-corruption Policy; they shall directly consult their supervisors.
- The Board of Directors, executives, and employees shall not neglect or disregard any actions considered as corrupt practices relating to the Company. In such cases, they shall inform their supervisors or responsible parties through the provided channels and shall provide collaboration in information corroboration.
- The Company shall treat and protect employees who deny corruption or those who file complaints about corruption with the Company with fairness. The Company shall not demote, punish, or cause any negative impact on the employees who deny corruption even though such actions will lead the Company to lose business opportunities. The Company shall have measures to protect complainants or persons who collaborate in reporting corruption incidents according to the Company’s Whistleblowing Policy.
- The Company shall educate the trading partners about the compliance with the Anti-corruption Policy as well as inform them of the whistleblowing or complaint filing channels.
- Corrupt persons and those being conspirators or involved in the corruption shall be subject to disciplinary actions according to the Company’s regulations. Furthermore, the said persons may also be punished by laws if such wrongdoing is considered an illegal offense.
- The Company shall arrange to have an audit process and an internal control system to prevent corruption across all work systems of the organization.
- The Company strives to create and maintain the culture of zero-tolerance for corruption when conducting transactions with the government and the private sectors.
- The Company requires that there shall be public relations activities for the Anti-corruption Policy through internal and external media channels such as the Company’s website, intranet, and annual reports.
- The Anti-Corruption Policy shall cover all work systems of the Company based on the guidelines stipulated in the Business Code of Conduct, the Corporate Governance Policy, regulations, and operating manuals of the Company as well as other practices to be determined in the future. Supervisors at all levels shall inform their employees under responsibility and monitor their compliance to ensure efficiency.
- To ensure clarity, when undertaking transactions with high risks of corruption, the directors, executives, and employees of the Company shall exercise prudence in the following matters:
- Giving or accepting bribes: It is prohibited to give or accept any forms of bribes in exchange for business benefits. Also, it is prohibited to assign others to give or accept bribes on one’s behalf.
- Gifts, entertainment, and other expenses: According to the Company’s policy, the executives and employees shall not receive or provide gifts, entertainment, or other expenses excessively. The Company’s operating procedures shall be complied with.
- Political contributions: Political contributions refer to the provision of financial support or objects and/or participation in activities as well as promotion of employee’s participation in activities relating to politics on behalf of the Company in order to gain business advantages. An exception applies to the case where the employees would like to join the activities according to their personal rights. However, they shall not use their employee status or assets, equipment, or tools of the Company to seek benefits from any political actions. The Company shall remain politically neutral and provide support for the democracy regime where the king serves as head of state. The Company does not have the policy to aid or support political parties or politicians directly or indirectly.
- Financial donation or support: The Company supports participation in social and environmental activities with local communities for improved well-being and social stability. The Company also provides financial support for activities that help improve its business or reputation. Financial donation or support must be conducted transparently, legally, morally, and without hidden agenda to gain business advantages. It shall be ensured that such financial donation or support shall not be misused for bribery and shall comply with the Company’s operating procedures.