Bangkok Insurance Public Company Limited has been strongly determined to conduct its business transactions transparently, accurately and fairly based on the principle of good corporate governance, generating confidence and trust among all groups of stakeholders. The Company realizes and gives priority to opposing giving a bribe, and anti-corruption of all forms, both directly and indirectly since, besides benefiting the Company, this also promotes the development of society and the country’s economy. As a consequence, the Company has displayed its determination to take part in the Collective Anti-Corruption  (CAC) and has complied with Thailand’s anti-corruption law, including defining, in writing, an anti-corruption policy as an obvious practice guideline, aimed at development toward a sustainable organization. In this connection, the Company stipulates that its Board directors, management, employees and business partners shall strictly abide by the defined policy as the following:

Corruption means an exploitation of one’s authority, whether directly or indirectly, to seek any advantage for oneself or others, or giving a bribe of whatever form by offering, promising, presenting, giving one’s word for, demanding or accepting money, assets or other benefits which are inappropriate for government officials, government agencies, private agencies or those in charge so that such persons perform or refrain from performing their duties, which brings about or maintains any advantage improper for business.

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

1. 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.
2. 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.
3. 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.
4. 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.
5. The Company’s Board directors, management and employees have duties and responsibilities for strictly complying with and supporting the anti-corruption policy.
6. The Company’s business partners shall agree to abide by its anti-corruption policy.

A Practice Guidelines

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. The Company has provided for an audit procedure and an internal control system to prevent corruption, covering all work systems within the Company.
7. 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.
8. 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.

Implementation Requirements

1. 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.
2. 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.
   1. 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. 2.2 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.
   
   
   3. 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.
   
   
   4. 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.
   
   
   5. 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.
   
   
   6. 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.

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.