Notification Anti-corruption Policy
The Company’s Board directors, management and employees shall not demand, practice or accept corrupt practices of all forms, aimed at both direct and indirect benefits for the Company, themselves, families, friends and acquaintances, whether as recipients, givers or those offering a bribe, and whether in the form of money or not, covering business transactions in all countries and sections relating to the Company. In addition, they shall strictly comply with the defined anti-corruption policy and constantly verify an implementation of the policy, apart from reviewing a practice guideline and implementation requirements so that they are in conformity with an alteration in business, rules, regulations and requirements of law.
Duties and Responsibilities
- The Company’s Board of Directors has duties and responsibilities for defining and approving an anti-corruption policy and overseeing to ensure that there is an efficient supporting system of anti-corruption to make sure that everyone in the Company understands and realizes the significance and practices it until it becomes the organization’s culture.
- The Audit Committee has duties and responsibilities for following up and overseeing to ensure that there is an adequate internal control, and verifying a report on audit consequences from the Internal Audit Office before presenting it to the Board.
- The President and the Management Committee have duties and responsibilities for providing for a system of, promoting and encouraging an implementation in compliance with the anti-corruption policy, communicating with and training employees and related persons for their acknowledgement, including making a review of the appropriateness and of systems and measures so that they are in accordance with an alteration in business, rules, regulations and requirements of law.
- The Internal Audit Office has duties and responsibilities for auditing and verifying the performance to ensure its accuracy and being in line with the defined policy and guideline to make sure that the Company has an internal control system proper and adequate for a corruption risk which may occur, before reporting it to the Audit Committee.
- The Company’s Board directors, management and employees have duties and responsibilities for strictly complying with and supporting the anti-corruption policy.
- The Company’s business partners shall agree to abide by its anti-corruption policy.
- The Company’s Board directors, management and employees shall practice in compliance with its anti-corruption policy by not being involved in corrupt practices, whether directly or indirectly. If employees have doubts or need suggestions concerning a practice based on the Company’s anti-corruption policy, they may consult their superior directly.
- The Company’s Board directors, management and employees shall not ignore or pay no attention when they find any action tending to be a corrupt practice relating to the Company, and shall report to their superior or persons responsible for acknowledgement through the defined channels, apart from giving cooperation for an examination of facts.
- The Company will provide fairness and protection to its employees rejecting a corrupt practice or reporting on corruption relating to the Company by not demoting, punishing or imposing a negative impact on employees rejecting a corrupt practice though such an action may cause the Company to lose its business opportunity, besides having a protective measure for those making a complaint or giving cooperation in reporting on a corrupt practice based on the whistle-blowing policy defined by the Company.
- The Company will disseminate knowledge and provide understanding to its customers of issues having to be practiced in compliance with its anti-corruption policy, including communicating for acknowledgement of channels for whistle-blowing or complaints.
- A person committing corruption and conspiring to commit or involved in it is subject to disciplinary punishment according to the rules and regulations defined by the Company, and may even be penalized by law if his/her act is illegal.
- The Company has provided for an audit procedure and an internal control system to prevent corruption, covering all work systems within the Company.
- The Company has been determined to generate and maintain the organization’s culture attaching to the concept that corruption is unacceptable for transactions with both the government and the private sectors.
- The Company has required that there be public relations on its anti-corruption policy via both internal and external media, for instance, the Company’s website, Intranet and annual report.
- The anti-corruption policy covers all work systems in the Company, using a guideline defined in the Company’s code of ethics, policy on good corporate governance, regulations and performance manual, including other practice guidelines to be subsequently defined by the Company. All levels of superiors are required to communicate with and provide understanding to employees under their responsibility, including overseeing to ensure an efficient implementation of the policy.
- For the sake of clearness of an implementation of a matter with a high risk of corruption generation, the Company’s Board directors, management and employees shall practice with caution on the following issues.
- 2.1 Giving and taking a bribe
Don’t allow giving or taking a bribe of any form in return for business advantages, besides not allowing assigning other persons to give or take a bribe on one’s behalf.
- 2.2 Gift expense, reception service expense and other expenses
The Company has a policy for its management and employees not to accept or give gifts, reception services or other expenses beyond necessity by attaching to a practice in compliance with the Company’s practice regulations.
- 2.3 Political contributions
Political contributions means giving financial supports, things and/or taking part in activities, apart from encouraging employees to participate in political activities on behalf of the Company, aimed at obtaining commercial and business advantages, but not including an activity in which employees take part out of their personal rights and freedom. Nonetheless, employees shall not pass themselves off as the Company’s employees, or use any of its assets, equipment or instruments to seek an advantage in carrying out any political activity.
The Company is a business organization which is neutral politically and lends its support to democratic government, with the King as head of state. It has no policy of helping or supporting political parties or politicians, whether directly or indirectly.
- 2.4 Donations to a charity or financial support
The Company supports a participation with communities in a social and environmental respect, aimed at the development of the sound quality of life and generation of security for society, or provides a financial support only to activities with a business purpose, or for the Company’s good reputation. The donation to a charity or giving a financial support must be transparent, lawful and not be against morality, or have no hidden intention of a commercial advantage. Furthermore, the Company has to be confident that a donation or financial support is not used as an excuse to pay a bribe, through being in strict compliance with the Company’s practice rules.
- 2.5 Facilitation payment
Facilitation payment means a small amount of expenses informally paid to government officials and given only to ensure that they will perform based on the defined procedure, or as an incentive for them to perform faster, for instance, asking for a license or certificate, receiving public services, etc.
The Company has no policy of making a facilitation payment in whatever form, whether directly or indirectly, and will not make any implementation or accept any act in exchange for the facilitation of business transactions.
- 2.6 Employment of government officials/employees
Government officials/employees means persons who are or used to be government officials/politicians/advisers to government agencies and have come work for private companies, and may use a relationship or insider information to assist the private companies or generate a conflict of interest from the duty performance of government agencies or the regulator and companies under the supervision of the former, of which the consequence is aimed at creating an unfair business advantage, or the formulation of policies benefiting the private companies for which ex-government officials had worked.
Government officials means those holding political office, government officials or local officials having a regular position or salary, employees or persons working in a state enterprise or government agency, local administrators and members of a local council who are not those holding political office, officials appointed by the local administrative law, including committee members (directors), sub-committee members, employees of the government sector, state enterprises or government agencies, and people or a group of people exercising their authority or assigned to exercise the state’s administrative authority for any implementation in accordance with laws, whether established in the bureaucracy, state enterprises or other state affairs.
For an appointment of government officials or ex-government officials, the Company possesses the following practice guideline.
- Have a process of due diligence of the persons the Company will nominate as its Board directors, advisers and management, aimed at an examination of what may become an issue of a conflict of interest prior to an appointment.
- Not disclose the secrets of government agencies to which one is or used to attached.
- Not be assigned to communicate with government agencies to which one is or used to be attached.
- Disclose, in the Company’s annual report, data on names and histories of the persons who are or used to be government officials and are appointed the Company’s Board directors, advisers and management.
- 2.1 Giving and taking a bribe