“Corruption” means fraudulent action by giving, offering to give, or promising to give assets or benefits to officers of government, officers of foreign government, officers of international organizations, organizations, institutes, or other persons as for convincing them to act, not to act or delay act unlawfully in order to acquire any benefits or maintain any benefits for oneself or others.
It shall include any forms of fraudulent actions by requesting, receiving, or promising to receive assets or any benefits for oneself or others unlawfully in order to act or not to act lawfully or unlawfully.
It shall also include any actions that might indicate such fraud.
1. Board of Directors
• Approve the Anti-Corruption Policy and procedures to be in line with the Anti-Corruption Policy
• Establish confidence to the Company that the Management is aware of and focuses on anti-corruption and fosters the organization culture
•Review the Anti-Corruption Policy and procedures annually
2. Audit Committee
• Review financial and accounting report system, internal control system, internal audit system, and compliance system to ensure that they are in line with international standard, sufficient, appropriate, up-to-date, and effective
• Determine procedures to mitigate risks, give advice to executives, and report audit results as well as corruption measures to the Board of Directors
3. President and executives
• Adhere to the Anti-Corruption Policy as operation procedures
• Manage to have every department and all employees apply the Anti-Corruption Policy strictly
• Appoint the anti-corruption working team to monitor the compliance with the Anti-Corruption Policy
• Supervise to have a system supporting the compliance with the Anti-Corruption Policy
4. Anti-corruption working team
• Evaluate risks which might cause corruption
• Formulate guidelines to ensure that the control system of the Company is appropriate and sufficient for any possible corruption risk
• Supervise and support risk management related to the Anti-Corruption Policy
• Conduct an inspection to comply with the laws, and regulations of the regulators
• Inspect and review performance to be in line with the Policy
5. Employees of the Company
• All employees must comply with the Anti-Corruption Policy and must not neglect or ignore once seeing any act which might breach the Anti-Corruption Policy. The Company has formulated a whistleblowing channel and channels to give advice and protect a whistleblower for their safety and confidence in providing information to the Company. If employees have inquires, they can discuss with supervisors, executives, or designated persons responsible for monitoring the compliance with the good corporate governance through any channels specified by the Company.
Anti-Corruption Measure is formulated to combat risks and corruption. Directors, executives and all employees must comply with Compliance Policy, Anti-Corruption Policy, No Gift Policy, Conflict of Interest Prevention and Management Policy, relevant rules and operation manuals and other guidelines specified by the Company.
1. Political assistance
To comply with the Code of Conduct and Business Ethics and the Company's Anti-Corruption Policy, guidelines for political assistance are set as follows:
2. Charitable donations, grants, gifts, entertainment and other expenses
Employees are required to check charitable organizations, foundations, companies, and stores to which the Company will make donations and/or provide financial support. It must be ensured that donations and support will not be used as pretext for bribery and must act transparently by specifying the name of donor and/or sponsor. It must be able to prove that such activities bring real benefits to society and/or in accordance with the objectives of the operations of the Company and the guidelines for charitable contributions, sponsorship, gifts, hospitality, and expenses. Employees are prohibited to receive gifts from partners or business partners in order to show integrity, transparency, confidence and trust from all sectors. If it is not possible to refuse, follow No Gift Policy.
3. Human resources management
The Company has taken steps to support the Anti-corruption Policy, starting from the process of recruiting or selecting personnel who have no record of offense or being punished for corruption to work with the Company, including promotion, performance evaluation and compensation. In addition, the Company also provides training for employees regarding anti-corruption measures by providing orientation to new employees and regularly testing the employees to create knowledge, understanding and raise awareness about anti-corruption culture in the organization.
4. Corruption risk assessment
A corruption risk assessment form must be made available for departments that are at risk of giving bribes to government officers, officers of foreign government, officers of international organizations or third parties. Therefore, anti-corruption measures can be defined to effectively prevent corruption and risks. Risks must be regularly reviewed and reported to Operational Risk Management Committee every year.
5. Internal control management
The Company has set internal controls in order to check the preparation of financial reports, accounting process, and storage of documents, financial evidence and other information as planned and in accordance with laws and the Anti-Corruption Policy.
6. Communication of policy and data reporting
The Company emphasizes the importance of communicating Anti-Corruption Policy and Anti-Corruption Measure. Therefore, both internal and external communication to employees of the Company, shareholders, customers, agents, partners, all stakeholders and related persons must be carried out via letter, public relation media, video, intranet and Company websites.