Bangkok Insurance Public Company Limited is committed to conducting business with transparency, righteousness, and fairness according to the principles of good corporate governance in order to secure confidence of all groups of stakeholders. The Company recognizes the importance of fighting against bribery and all forms of corruption, direct and indirect, since it will give a favorable impact not only on the Company but also on the country’s social and economic development as a whole. Thus, the Company has expressed its intention to join in Thailand's Private Sector Collective Action against Corruption (CAC) and to comply with Thailand’s anti-corruption laws. The Company has also determined the Anti-corruption Policy in writing for use as clear guidelines to drive the Company’s sustainable development. In this connection, the Company requires that its directors, executives, and employees as well as trading partners shall strictly adhere to the policy as follows:

Definition

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.

Anti-corruption Policy

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

1. 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.
2. 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.
3. 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.
4. 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.
5. The Board of Directors, executives, and employees shall be responsible for strictly complying with and supporting the Anti-corruption Policy.
6. The trading partners must agree to comply with the Company’s Anti-corruption Policy.

Guidelines

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. The Company shall arrange to have an audit process and an internal control system to prevent corruption across all work systems of the organization.
7. The Company strives to create and maintain the culture of zero-tolerance for corruption when conducting transactions with the government and the private sectors.
8. 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.

Operating Requirements

1. 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.
2. 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:
   1. 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.
   
   
   2. 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.
   
   
   3. 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.
   
   
   4. 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.
   
   

Objective: To encourage all employees, customers, or outside parties to comply with the laws, rules, regulations, policies, and the Articles of Association; and also to encourage such persons who witness any corrupt practices relating to the Company to report such incidents to the ombudsperson.

Scope of Whistleblowing:
Any violations of laws, rules, regulations, the Articles of Association, the Business Code of Conduct, and all forms of corruption.

Ombudspersons:

1. Audit Committee
2. Company Secretary
3. Internal Audit Office
4. Quality Control Center

Complaint Filing Procedures
The complainant or the whistleblower shall lodge a complaint to one of the ombudspersons by one of the following means:

1. Verbal or written complaints
2. Letters to ombudspersons according to the Company’s mailing address
3. The Company’s website
4. The Company’s e-mail at anti-corruption@bangkokinsurance.com

All complaints shall be treated in strict confidentiality. The complainants may file complaints through more than one channel. Their identities are not required to be disclosed. However, with the disclosed identities, the Company will be able to reach back to the complainants and inform them of the results and additional details about the complaints.

Fact Corroboration Procedures

1. In the case where the Audit Committee and/or the Company Secretary receives a complaint; they shall submit the relevant information and documentary evidence to the Internal Audit Office for further actions.
2. If the complaint is made through the Quality Control Center; the complaint shall be considered as follows:
   1. In the case of service delivery quality, rectification actions shall be taken according to the operating procedures.
   2. In the case of corruption, relevant information and documentary evidence shall be submitted to the Internal Audit Office.
3. The assigned person may invite any employee to provide information or request the employee to send any related documents for fact corroboration.
4. If, after corroboration, the complaint details are true, the Company shall take the following actions:
   1. In the case where the complaint is about the Company’s violation of laws, rules, regulations, or the Articles of Association, details of the complaint, supporting opinion, and recommended solutions shall be proposed to the President for consideration and actions. If the matter affects the Company’s reputation, image, or financial position; or is related to high-level executives, for instance; the matter shall be submitted to the Audit Committee or the Board of Directors for consideration.
   2. In the case where the complaint is about internal corruption, relevant actions shall be undertaken according to the operating procedures regarding criteria for consideration of wrongdoings and authority to punish the wrongdoers.

Protection of Complainants or Whistleblowers

1. The complainant or whistleblower may choose not to reveal one’s identity if such revelation may cause damage to oneself. However, the said person must identify facts or evidence enough to constitute a reasonable ground to believe that there is a violation of laws, rules, regulations, the Articles of Association, or the Business Code of Conduct; or a corrupt practice. However, if the complainant or whistleblower chooses to reveal one’s identity, relevant actions may be expedited.
2. Information relevant to the Company shall be treated as confidential and disclosed on a need-to-know basis. The safety of or possible damage to complainants, whistleblowers, sources of information, or relevant parties shall be taken into consideration. The responsible party shall, at all steps, treat the received information in strict confidentiality and shall not disclose it to irrelevant parties. Any violation shall be deemed as a disciplinary offense and shall be subject to disciplinary actions according to the Company’s procedures.
3. In the case where the complainant or whistleblower deems that it may be unsafe or there may be a trouble, the person may request the Company to determine appropriate protective measures or the Company may proactively determine protective measures without the request by the complainant or whistleblower should there be a tendency that the matter may incur damage or result in comprised safety.
4. The Company shall take actions fairly for the complainant. In the case where the complainant is an employee; his/her position, job or workplace shall not be changed; he/she shall not be suspended from his/her job nor shall be threatened or terminated from employment; and he/she shall not be treated with unfair practices. In the case where the complainant is an external party; the Company shall consider the case and conduct investigation with transparency and treat all involved persons fairly and equally. This is to give assurance to the complainant that the investigation process is fair.
5. If the complainant or whistleblower has an ill will in reporting and/or if later it is proved that such person intends to cause damage or file a false report; in the case of an employee, he/she shall be subject to disciplinary actions according to the Company’s work rules; and in the case of an outside party where the Company suffered damage, legal actions shall be taken against such person.