Anti-Corruption Policy

       “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(1), 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) Organic Law on Anti-Corruption B.E. 2561, Section 176

1) Board of Directors

• Approve the AntiCorruption Policy and procedures to be in line with the AntiCorruption Policy
• Establish confidence to the Company that the Management is aware of and focuses on anticorruption and fosters the organization culture
• Review the AntiCorruption 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, uptodate, 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 AntiCorruption Policy as operation procedures
• Manage to have every department and all employees apply the AntiCorruption Policy strictly
• Appoint the anticorruption working team to monitor the compliance with the AntiCorruption Policy
• Supervise to have a system supporting the compliance with the AntiCorruption 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 AntiCorruption Policy
• Conduct an inspection tocomply 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 AntiCorruption Policy and must not neglect or ignore once seeing any act which might breach the AntiCorruption 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

1) Directors, executives, all employees, including individuals and juristic persons who work on behalf of or act on behalf of the Company must comply with the Anti-Corruption Policy and must not get involved in corruption either directly or indirectly, including all businesses and transactions in every country such as any kinds of giving/accepting bribes.

2) The Company is aware of the importance in publicizing, giving knowledge and establishing understanding with other people or other agencies that are required to comply with the Anti-Corruption Policy, including notifying of whistleblowing channels.

3) The Company intends to build and preserve the organization culture of zero tolerance of corruption on making transactions with public and private sectors.

4) The Company shall give justice and protect personnel who deny or report the corruption relevant to the Company by applying a protection measure to a whistleblower or collaborator in reporting the corruption as specified by the Company.

5) A person who commits corruption will be regarded as breaching the good corporate governance of the Company and must receive disciplinary punishment according to the Company’s rules.

       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 (2) are set as follows:

• The Company has guidelines not to give financial support or any items for political parties, politicians, candidates or carry out any actions which concentrate on specific politician and/or political party for the Company’s benefits
• Employees are prohibited from participating in all types of political activities and using the facilities or resources of the Company in political campaigns or political fundraising for any particular political party unless the support is permitted by law

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. (3)

       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. (4)  

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

(2) The Company’s order No. 93/2559 (93/2016) Re: Political Assistance Guidelines

(3) The Company’s order No. 47/2562 (47/2019) Re: Guidelines for Charitable Contributions, Sponsorship, Gifts, Hospitality, and Expenses

(4) The Company’s order No. 46/2562 (46/2019) Re: No Gift Policy

Human Resources Management Department

1. Inform Internal Audit Department, or 
2. Inform via Tel. 02-290-2744, 02-274-9400 ext. 2744, or
3. Inform via e-mail: CGhotline@muangthai.co.th

1. Details of whistleblowing or complaints must be true, clear, or sufficient to find facts and proceed further. 
2. Whistleblower needs not to disclose his/her name, address, and contact number if he/she views that the disclosure might cause vulnerability and damages to himself/herself (based on the whistleblower’s discretion).
3. The whistleblower, whether he/she is an employee or outsider, shall be protected.

1) The Company shall treat the information and identity of whistleblower and reported person confidential.

2) The Company shall reveal the information as deemed necessary only and take into account the safety and damage of whistleblower, source of information, or relevant parties.

3) The person who receives damage from the compliance with Anti-Corruption Policy shall receive the suitable and fair damage remediation. 

4) In case whistleblowers or persons who cooperate in inspecting facts feel that they may not be safe or receive any damages, they can request the Company to establish appropriate protection measure; or the Company may establish the protection measure without any request from such persons if the Company deems that it is likely to cause damage, or to be unsafe.

5) The Company shall not perform any unfair actions whether by rotation from current position, change of job description, relocation, suspension from work, intimidation, disturbance in his/her work, termination of employment, or any other unfair actions to the whistleblowers or persons who cooperate in inspecting facts.

       This Policy is considered as a main policy which authorizes the anti-corruption working team to issue related manuals or guidelines and to review and update the Policy. 

       The Company established the investigation measure and deemed that compliance with the Anti–Corruption Policy is considered as a discipline, which the directors, executives, and all employees shall apply strictly. The employee who does not comply with the Anti–Corruption Policy shall be punished according to the Company’s rules or laws.