1. Principles and reasons
Muang Thai Life Assurance Public Company Limited is aware of the importance of business operation and management which need to be conducted based on an integrity, transparency, and responsibilities to society and all stakeholders according to the good corporate governance. Therefore, the Company has formulated this Anti-Corruption Policy with a purpose of prohibition on any kinds of corruption. Directors, executives, employees as well as a third party relating to the Company, either for benefits of the Company or oneself, family, friends, or acquaintances, must not commit corruption. The Company does not allow any kinds of corruption including the corruption in businesses and responsible work units, and all transactions in every country. At the same time, the Company has formulated procedures for anti-corruption in detail. In order to comply with this Policy, the Company shall review the procedures regularly to be suitable with the business operation and comply with the laws. In this regard, directors, executives, and employees are all required to comply with this 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.
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.