We have developed the Program and Procedures covering the activities vulnerable to bribery and corruption, do communication and promoting compliance with the Policy and Program for Anti- Bribery and Corruption in the risky activities, setup the whistleblowing channels, do accuracy on the accounting records and document retention and also determining the appropriated internal control for activities vulnerable to bribery or corruption, as followings;
The giving or receiving of gifts, entertainment, and other expenses must be appropriated and in line with the local traditions and conventions as well as comply with applicable laws including the laws of the counterparty country. Gifts, entertainment, and other expenses above certain value thresholds or high risk activities, require the approval before proceed the transaction. In addition, the Company has asked for cooperation from executives and employees to comply with “No Gift Policy” during any festivals and occasions, every year, as well as, communicate “No Gift Policy” to related parties for their acknowledgment.
No donations or sponsorships can be made to any individuals or juristic persons if such activity may create bribery risk and are prohibited if they are intended or could reasonably appear as intended to improperly obtain or retain business or other business advantages.
In making donations or sponsorships, the due diligence must be conducted on the individuals or entities receiving the donations or sponsorships. Any donations and sponsorships must be approved by authorized person assigned by the Company. In case such requests are above certain value thresholds or deviated from the determined condition, must require additional measurements on the risk assessment and approval from the authorized person before proceed the donations or sponsorships.
It is never permissible to provide a political contribution, personally or on behalf of the Company, to improperly influence any external party in connection with the Company’s business, or in exchange for any improper business advantage. Employees are not permitted to make political contributions with the Company’s funds or on behalf of the Company, other than pursuant to applicable the Company’s policies related to political contributions. In case where political contributions are legal, it requires pre-approval by the Board of Directors or assigned persons.
Speaker fees or honoraria paid to Public Officials may create the appearance that such payments are intended or appear intended to improperly influence the recipient so that such activity shall be avoided in principle. Invitation of Public Official as speaker or the speaker fees / honoraria paid to the Public Official if above certain value thresholds, requires approval from authorized person before proceed the transaction..
Extending an offer of employment or work experience (paid or unpaid) to a candidate with the expectation that, the Company will obtain or retain an improper business benefit or advantage, as a result, is prohibited.
Before approach the high-risk candidates (i.e. candidates who are known to be Public Officials, clients or prospective clients, were referred by Public Officials, clients or prospective clients, or who have a close personal or familial relationship to Public Officials, clients or prospective clients) for any employment or work experience,, the Company shall treat such candidates in the same manner as any other candidates (they must not receive any preferential treatment), and subject to additional measurement to conduct the risk assessment and approval from the authorized person before the offer of employment or work experience.
TPIs present heightened bribery and corruption risk because they may provide Anything of Value to Public Official, client, or prospective client to obtain the benefit for the Company. A bribe paid by a TPI in connection with the Company’s business can be just as damaging as a bribe paid by the Company employee.
The due diligence must be conducted on TPIs and relevant documents must be keeping for examination. Before creating any relationship with TPIs, the commitment and accountability clauses must be included in writing in the contracts. The Compliance Pre-approval must be established whereby factors such as profile, experience, reputation, etc. must be taken into consideration. Also, TPIs must be acknowledged for comply with the Policy and Program for Anti-bribery and corruption policy and measures.
Relationship with TPIs, breaching any anti-bribery and corruption measures, shall not be established or shall be cancelled. This shall be applicable to transactions executed with the local or foreign governments as well as public and private entities. There must be control over payment made or benefits given to TPIs. Details of transactions, records and relevant documents must be available, as well as, the approval must be obtained from the authorized persons assigned by the Company.
Before entering into mergers, acquisitions, or joint ventures, the Company must conducted the appropriate examination to determine whether the entities to be merged or acquired or to enter into a joint venture have any bribery and corruption records or any involvements in bribery and corruptions in order to prevent and check any corrupt payments.
Assessment must be conducted to measure the adequacy of their anti-bribery and corruption measures, internal control, and compliance with relevant laws and regulations as appropriate and practicable. Also, anti-bribery representations and warranties must be stated on the merger contracts or joint venture contracts.
The Company has been certified as the member of the Thai Private Sector Collective Action Coalition against Corruption which confirms the Company intention to put the high important on preventing the bribery and corruption in any forms as stated in the Policy and Program for Anti-Bribery and Corruption, in writing, and supportive to the sustainable business operating. Directors, Executives and Employees are subjected and must explicitly agree and sign the clause for complying with the Policy and Program for Anti-Corruption and subject to the Disciplinary action if violate.
Whistleblowing Program is the tool which the Company manipulates to stimulate the Good Corporate Governance Principles. The Whistleblowing program is open to all employee or any relevant person to raise any clues or complaints when happens to know or in doubt whether there is any violation against the Company policies and/ or Procedures. The clues and complaints will be followed up and investigated further to verify the truths and must be taking any appropriated actions and report to Executive Management and related Board. Those will be kept as confidential and the employee who raise any clues or complaints and who corporate in the investigation, shall be protected from retaliation, bullying, intimidation, while who are not cooperating or hinder the inspection, will be imposed with the highest disciplinary actions. .
Whistleblowing Channels for Stakeholders
- Vice President of Employee Relations Section, Happy People Department Ngern Tid Lor Public Company Limited 428 Ari Hills 9th – 15th floor, Phaholyothin road Samsennai, Phayathai, Bangkok, 10400, Tel: 02-792-1860 or;
- Head of Fraud Management Department Ngern Tid Lor Public Company Limited 428 Ari Hills 9th – 15th floor, Phaholyothin road Samsennai, Phayathai, Bangkok 10400, Tel: 02-792-1888 # 5200
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