Anti-Corruption Policy

2.1 Corruption means fraudulent action by giving, or promising to give bribes or requesting or accepting to receive either gifts, gratuities or services, cash or cash voucher, assets or any benefits as well as any actions that are deemed corruption to officers of government, officers of foreign government, officers of international organizations, organizations, institutes, or other persons who do business with the Company either directly or indirectly as for requiring them to use power illegally, 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, unless the laws, the regulations, local culture or trade usage allow to do so.

2.2 Gifts, gratuities mean things or any benefits which have financial value, cash voucher for exchanging for goods or traditional services which are given as gratuities or change as influence for the Company to receive privileges for businesses which may link to bribery.

2.3 Bribes, inducements, change or hospitality mean cash, assets, reception for hospitality or any benefits which are given to act or omit to act as a payer requires as well as any actions deemed as offering a promise, giving, accepting, requesting that create benefits in any forms which are considered as convincing to act illegally or against duties and responsibilities.

2.4 Facilitation payment means expenses unofficially paid to officers of government as to ensure that they will proceed according to process, or motivate them to proceed quicker which such process does not require discretion of officers of government and it is lawful act of such officers; moreover, it is the right that a juristic person is entitled to have according to the laws such as request of a license, request of a certificate and public service.

2.5 Donation means giving or receiving cash, things, goods, services or any benefits without expectation for returns by a person or a juristic person or through organizations for either charity or aid.

2.6 Sponsorship means money paid or received, things given or received, or returns given or received which may be financially calculated, from customers, partners, business associates with objectives for business, brand or reputation of the Company, and advantages to build credibility and enhance business connection, which is given in appropriate occasion.

2.7 Government officer recruitment means employing a person who is or was a government officer that means a person holding a political office, a government official or a local officer who holds a position or has regular salary, an officer or a person who performs duties in a state enterprise or a government agency, a local administrator and a local council member who does not hold a political office, and an official under the local administrative laws. It shall also include committees, subcommittees, employees of the government or state enterprises, and a person or a group of people who exercises authority or is authorized to exercise the administrative authority of the government to perform any act in accordance with the law whether it has been established in the government system, state enterprises or other state affairs.

2.8 Political support means giving assets, money, things or any privileges to aid or support or provide any benefits to political parties, politicians or persons related to politics as well as supporting political activities either directly or indirectly.

3.1 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

3.2 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
• Oversee risks and internal control related to anti-corruption, and report audit results to the Board of Directors regularly
• Give recommendations to the management to oversee operations, and report to the Board of Directors in case a suspicion of the following transactions or actions occurs
     (1) Conflict of interest transactions
     (2) Corruption, malpractice or significant defect in the internal control system
     (3) Violation of laws related to the Company’s businesses
     (4) Fraud or any actions that severely impact the financial position, performance or reputation of the Company 

3.3 Chief Executive Officer, 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

3.4 Anti-corruption working team
• Oversee the committees, executives, employees, agents and brokers to comply with the Anti-Corruption Policy
• Communicate to the Company’s related persons to acknowledge that the Company has the Anti-Corruption Policy and is a member of the Private Sector Collective Action against Corruption
• Assess corruption risk of the Company, oversee risk management and internal control related to corruption adequately and appropriately as well as 
• Establishing anti-corruption guidelines 


3.5 Employees of the Company
• All employees must comply with the Anti-Corruption Policy and must not neglect or ignore once seeing any acts which might breach the Anti-Corruption Policy. The Company has formulated the Information or Complaint Handling Policy for employees to inform any violations or complaints with good faith through multiple channels specified by the Company. Names of sources are kept confidentially and protected for safety during investigation and after completion. If employees have inquiries, 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.

4.1 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.

4.2 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 Whistle-Blowing Policy.

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

4.4 The Company shall uphold justice and protect personnel who refuse or inform about corruption related to the Company by implementing protection measures for sources or whistleblowers, witnesses and individuals who provide information for investigations as specified by the Company.

4.5 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, Whistle-Blowing Policy, Conflict of Interest Prevention and Management Policy, relevant rules and operation manuals and other guidelines specified by the Company.

5.1 Gifts, gratuities, hospitality, reception and other expenses
• Employees can provide gifts, gratuities, hospitality, reception and other expenses by tradition or general practice of the society. Employees must perform the action with transparency and comply with the Code of Conduct and the laws.
• Employees must not request gifts, gratuities, hospitality, reception and other expenses from normal duties, and must comply with No Gift Policy. In case employees cannot reject gifts, gratuities, hospitality or reception, they must notify executives and keep a record and collect information.

5.2 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.

5.3 Facilitation payment
The Company does not have a policy to make facilitation payment for its businesses in form of assets or any benefits either directly and indirectly to officers of government, officers of foreign government, or officers of international organizations because the facilitation payment is a high risk payment item that can be considered as illegal expense.

5.4 Political support
• The Company has a policy to have political neutrality by not performing any actions to side with any parties or not supporting political parties, political alliance, political authorities or political candidates with finance or resources of the Company either directly or indirectly, locally, regionally or nationally.
• The Company has respect for political rights of employees as good citizens according to the constitution. Moreover, it formulated guidelines for its employees where they are prohibited from supplying political activities with facilities or resources of the Company. Furthermore, all employees regardless of positions are prohibited from ordering or convincing employees and subordinates through any methods to participate any political activities.

5.5 Government officer recruitment
• Recruitment of government officers is based on appropriateness according to the Company’s process by considering on preventing conflict of interest or corruption.
• For the recruitment of government officers, such officers must be no longer in such status for a specific period before submitting applications to the Company.

5.6 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.

5.7 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.

5.8 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.

In case executives and employees wish to give comments and recommendations or request advice and suggestions regarding the Anti-Corruption measure, please contact Human Resources Management Department.

7.1 Postal mail:
       Internal Audit Department of Muang Thai Life Assurance Public Company Limited (Headquarters)
       250 Rachadaphisek Rd., Huaykwang, Bangkok 10310
7.2 Telephone No. 02-290-2744, 02-290-2547, 02-274-9400 press 2744 or 2547
7.3 E-mail: CGhotline@muangthai.co.th or HR_SOS@muangthai.co.th
7.4 Intranet for employees: Muangthailink (Comments & Suggestion)

The Company appointed a committee that considers the information or complaints about corruption to be in charge of consideration on information or complaints related to corruption of the Company. Investigation, root cause analysis and preventive guidelines must be conducted to prevent repetitive cases in the future. Moreover, guidelines of solution and punishment are formulated. Report of complaint consideration results and proposal of punishment will be presented to the Chief Executive Officer for further actions.

The measures are formulated to protect the rights of sources and whistleblowers who give information with good faith, and employees who refuse corruption.

9.1 The Company shall conceal name, address or any information that can identify sources or whistleblowers, and confidentially maintain information of sources or whistleblowers. Only persons in charge of complaint investigations are allowed to access the information.

9.2 In case of corruption related complaints are made, the committees shall protect sources or whistleblowers, witnesses and individuals who provide information for investigations from any harm, danger, injustice resulted from reporting information or complaints, being witnesses or sources.

9.3 The Company shall not perform any unfair actions such as changing position, job description, workplace, suspending, threatening, disturbing, dismissing or any actions deemed as unfair treatment towards sources or whistleblowers or participants of investigations and employees who refuse corruption, even the Company will lose business opportunity.

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 working team is required to review this Policy at least once a year which must be presented to the Board of Directors for consideration and approval.

The Company established that compliance with the Anti–Corruption Policy is considered as a discipline, which the directors, executives, employees, agents, brokers 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 if such actions are prohibited by laws.