Corporate Governance Policy

Anti-Fraud and Anti-corruption

The Company has an anti-corruption policy and prohibits the payment of any bribes. By stipulating principles in the Code of Business Conduct that prohibiting any employees from demanding benefits or avoiding receiving any assets that incentivize them to act or neglect to act in a wrong way or may cause the Company to lose its legitimate interests or do not take any actions that may cause the conflicts of interest to the organization for commercial benefits for themselves or their partners or refrain from any illegal or unlawful actions against their position. The Company has disseminated the business ethics to employees thoroughly and was aware of the performance of duties on a regular basis.

Guidelines for supervision and control of the risk of corruption and performance monitoring and evaluation are as follows :

  1. Preventive measures through organization structure to be appropriate for management and control. The Company’s structure strengthens the organization’s transparency and effective, in line with the goal, nature of business, by using the principle of segregation of duties. There is an appropriate balance of power and separation of duties. Establish a clear working process and chain of command in each department. The structure of organization which has an organizational culture emphasizing morality and ethics. By having a mechanism for regular monitoring and evaluation of performance including the adequate communication and training for employees. The guidelines are communicated through various channels such as Company’s intranet and on the Company’s website.
  2. Prepare the Code of Conduct for Executives and employees as a written policy, enhance compliance with the code of conduct, provide the communication through various channels including the Company’s intranet and website, including planning for proper follow up and assessment of the Code of Conduct properly.
  3. The process for assessing the risks associated with the corruption within the Company and assess the implementation of the policy through the internal control according to COSO form at the Board level, the internal control assessment at the department level and the working mechanism of the Risk Management and Sustainable Development Committee and the Company’s internal control Division.
  4. Supervision at the department level, the Head of the department shall evaluate the internal control, risk from corruption at the department level and set up the effective and efficient internal control system to cover any loopholes that may cause corruption. Review the suitability of the system and continually improve the system, control and monitor the operations of their units and assign supervisors at each level to control and investigate fraudulent actions and errors arising from operations.
  5. The internal Audit Department performs audits for compliance with the work systems’ rules and regulations. Compliance with the Code of Conduct, assess the risks of corruption including the early warning signs, assess the adequacy of the internal control system in preventing, monitoring and detecting the risks of corruption by reporting the results of the audit at least once a quarter.
  6. Through the working mechanism of the Risk Management and Sustainable Development Committee to continuously test and assess the risks of fraud and corruption and present the results of the assessment report to the Board of Directors.
  7. Provide the channels for reporting any violations or witnessing fraud and corruption and provide measures to protect and mitigate damage to the reporters, complainants or those who corporate in such reporting. Details are shown under the topic “Whistleblowing”.
  8. In the event of an incident of wrongdoing, information from audit, complaint and there are evidence that should be believed that there is a real transaction of wrongdoing, to investigate the fraud and corruption, the Company will establish a temporary special investigation team to provide justice to the accused and provide appropriate protection to the whistleblower.
  9. Use the case of an offense found as a case study to find a preventative approach and methods of checking to find the cause of actions including educating employees at supervisor level to prevent corruption occurring in the organization.

New employees are informed of guidelines for good behavior standards and employee code of conduct on their first day of work and through the orientation of new employees. The Company also provide an inhouse training for Assistant Managing Directors, Executives (Operations), Executives (Supports), Senior Managers and Department Managers about the tools and how to use such tools to track risks so that all the executives and management can use them effectively to monitor and assess risks.

In the year 2021, the Company has no legal disputes related to corruption cases whether in the process of being investigated, prosecuted or judged by the Court.