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Anti-Corruption Policy

Anti-Corruption Policy

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 are all prohibited. 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.

“Corruption” means
Any kinds of fraud by giving, requesting to give, or promising to give assets or benefits to officers, members of National Legislative Assembly, members of provincial council, members of city council or officers of other government agencies, 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

Any kinds of fraud 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

Any actions that might indicate such fraud

Duties and responsibilities

1. The 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 foster 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, compliance system to ensure that they are in line with international standard, sufficient, appropriate, up-to-date, and effective. Determine procedures to mitigate risk, give advice to executives, and report audit results as well as any measures regarding corruption 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 which affects to the Anti-Corruption Policy
    Conduct an inspection to comply with the laws, regulations of the regulator
    Inspect and review performances to be in line with the Policy

5. Employees of the Company

All employees must comply with 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 channel to report complaints, clues as well as 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 person responsible for monitoring the compliance with the good corporate governance through any channels specified by the Company.

Procedure

    Directors, executives, all employees must not relate to corruption either directly or indirectly including all businesses and transactions in every country such as any kinds of giving/accepting bribes. The Company is aware of the importance in publicizing, giving knowledge and establishing understanding with other persons or other agencies that are required to comply with the Anti-Corruption Policy. The Company intends to build and preserve the organization culture stating that we cannot accept any corruption from making transactions with public and private sectors. The Company shall give justice and protect a personnel who denies or reports the corruption to the Company by applying a protection measure to a whistleblower or cooperates in reporting the corruption as the Company specified. A person who conducts corruption will be regarded as breaching the good corporate governance of the Company and must be punished according to the Company’s rules

Operation Guideline

    The Anti-Corruption Policy covers human resources management process from recruitment or selection of personnel, promotion, training, employee performance evaluation, to reward. Supervisors and executives in every level are required to communicate with and establish an understanding for their subordinates in order to apply this with their responsible business activities, control and monitor the operation to be effective. Any actions under the Anti-Corruption Policy shall apply according to the guideline prescribed in Corporate Governance Policy, Management or Prevention of Conflicts of Interest policy, relevant guideline and work manual, and other guidelines to be prescribed by the Company. In order to be clear in complying with the Anti-Corruption Policy, the employees of the Company shall carry out the following actions with prudence.
      Offering welcome dinner and expense
      Giving or receiving gifts and welcome dinner shall be subject to the Company’s provisions. Charitable donations or sponsorship
      Giving or receiving charitable donations or sponsorships shall be transparent, legal, and subject to the Company’s provisions. The company shall ensure that the charitable donations or sponsorship is not a pretext for bribes. Business Relationship and procurement with public sector
      Giving or receiving bribes related to business operation are prohibited. The operations and contact with public sector shall be conducted with transparent and honest manner, subject to the relevant laws.

Channel to provide recommendation regarding the compliance with Anti-Corruption Measure

    Human Resources Management Department

Channel to report complaints or clues when there is a corruption in the Company

    Inform Internal Audit Department or
    Inform via the Telephone 02-290-2744 (ext. 2744) or
    Inform via the below CGhotline@muangthai.co.th

Conditions to consider clues or complaints

    Details of clues or complaints must be true, clear, or sufficient to find facts and proceed further. Whistleblower can keep his/her name, address, and contact phone number anonymous if he/she views that the disclosure might cause vulnerability and damages to himself/herself (based on the whistleblower’s discretion). The whistleblower will receive protection of rights whether he/she is an employee or outsider.

Whistleblower Protection Policy

    The Company shall treat the information and identity of whistleblower and reported person confidential. 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. The person who receives damage from the compliance with the Policy shall receive the suitable and fair damage relief process. In case a whistleblower or a person who cooperates in inspecting facts feels that they may not be safe or receive any damages, a whistleblower or a person who cooperates in inspecting facts can request the Company to establish appropriate protection measure; or the Company might be able to establish the protection measure without any requirement from such persons if the Company deems that it is likely to cause damage, or to be unsafe. The Company shall not perform any unfair actions toward whistleblower whether by rotation from current position, job description, work location, suspension from work, intimidation, disturbance in his/her work, termination of employment, or any other unfair actions to the whistleblower or a person who cooperates in inspecting facts.

Monitoring and Evaluation

This Policy is considered as a main policy which authorizes the Anti-Corruption working team to issue a related manual or guidelines and to review and update the Policy.

Punishment

The Company established the investigation measure and deemed that compliance with the Anti–Corruption Policy is the one of the Company 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 might be punished by laws.

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Anti-Corruption Policy

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 are all prohibited. 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.

“Corruption” means
Any kinds of fraud by giving, requesting to give, or promising to give assets or benefits to officers, members of National Legislative Assembly, members of provincial council, members of city council or officers of other government agencies, 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

Any kinds of fraud 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

Any actions that might indicate such fraud

Duties and responsibilities

1. The 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 foster 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, compliance system to ensure that they are in line with international standard, sufficient, appropriate, up-to-date, and effective. Determine procedures to mitigate risk, give advice to executives, and report audit results as well as any measures regarding corruption 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 which affects to the Anti-Corruption Policy
    Conduct an inspection to comply with the laws, regulations of the regulator
    Inspect and review performances to be in line with the Policy

5. Employees of the Company

All employees must comply with 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 channel to report complaints, clues as well as 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 person responsible for monitoring the compliance with the good corporate governance through any channels specified by the Company.

Procedure

    Directors, executives, all employees must not relate to corruption either directly or indirectly including all businesses and transactions in every country such as any kinds of giving/accepting bribes. The Company is aware of the importance in publicizing, giving knowledge and establishing understanding with other persons or other agencies that are required to comply with the Anti-Corruption Policy. The Company intends to build and preserve the organization culture stating that we cannot accept any corruption from making transactions with public and private sectors. The Company shall give justice and protect a personnel who denies or reports the corruption to the Company by applying a protection measure to a whistleblower or cooperates in reporting the corruption as the Company specified. A person who conducts corruption will be regarded as breaching the good corporate governance of the Company and must be punished according to the Company’s rules

Operation Guideline

    The Anti-Corruption Policy covers human resources management process from recruitment or selection of personnel, promotion, training, employee performance evaluation, to reward. Supervisors and executives in every level are required to communicate with and establish an understanding for their subordinates in order to apply this with their responsible business activities, control and monitor the operation to be effective. Any actions under the Anti-Corruption Policy shall apply according to the guideline prescribed in Corporate Governance Policy, Management or Prevention of Conflicts of Interest policy, relevant guideline and work manual, and other guidelines to be prescribed by the Company. In order to be clear in complying with the Anti-Corruption Policy, the employees of the Company shall carry out the following actions with prudence.
      Offering welcome dinner and expense
      Giving or receiving gifts and welcome dinner shall be subject to the Company’s provisions. Charitable donations or sponsorship
      Giving or receiving charitable donations or sponsorships shall be transparent, legal, and subject to the Company’s provisions. The company shall ensure that the charitable donations or sponsorship is not a pretext for bribes. Business Relationship and procurement with public sector
      Giving or receiving bribes related to business operation are prohibited. The operations and contact with public sector shall be conducted with transparent and honest manner, subject to the relevant laws.

Channel to provide recommendation regarding the compliance with Anti-Corruption Measure

    Human Resources Management Department

Channel to report complaints or clues when there is a corruption in the Company

    Inform Internal Audit Department or
    Inform via the Telephone 02-290-2744 (ext. 2744) or
    Inform via the below e-mail CGhotline@muangthai.co.th

Conditions to consider clues or complaints

    Details of clues or complaints must be true, clear, or sufficient to find facts and proceed further. Whistleblower can keep his/her name, address, and contact phone number anonymous if he/she views that the disclosure might cause vulnerability and damages to himself/herself (based on the whistleblower’s discretion). The whistleblower will receive protection of rights whether he/she is an employee or outsider.

Whistleblower Protection Policy

    The Company shall treat the information and identity of whistleblower and reported person confidential. 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. The person who receives damage from the compliance with the Policy shall receive the suitable and fair damage relief process. In case a whistleblower or a person who cooperates in inspecting facts feels that they may not be safe or receive any damages, a whistleblower or a person who cooperates in inspecting facts can request the Company to establish appropriate protection measure; or the Company might be able to establish the protection measure without any requirement from such persons if the Company deems that it is likely to cause damage, or to be unsafe. The Company shall not perform any unfair actions toward whistleblower whether by rotation from current position, job description, work location, suspension from work, intimidation, disturbance in his/her work, termination of employment, or any other unfair actions to the whistleblower or a person who cooperates in inspecting facts.

Monitoring and Evaluation

This Policy is considered as a main policy which authorizes the Anti-Corruption working team to issue a related manual or guidelines and to review and update the Policy.

Punishment

The Company established the investigation measure and deemed that compliance with the Anti–Corruption Policy is the one of the Company 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 might be punished by laws.

Corporate Governance

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