Corruption means any acts which include an offer or promise for bribery, an agreement to bribe, a request or acceptance of the assets or any other benefits to the governmental officer, governmental agency or private agency or the respective person whether directly or indirectly in order that they will act or refrain from performing certain duty, to obtain or maintain inappropriate benefits in business, excluding the case where permitted by law, regulation, rules, local customs of tradition or business norms.

Bribery means giving or offering assets or any other benefits, for example, cash, gift or expensive goods, tourism and entertainment, to a certain person in order to encourage him/her to act or omit the act as intended by the person.

Charity contribution is a form of giving money or assets to someone without expecting any return or business benefits.

Sponsorship is the giving of money to an activity that promotes a product's brand, company's reputation, without any hidden agenda or expectation of return.

Gifts or any other benefit means any items of monetary value or the item which can be exchanged for goods or services, for example, reward coupons or discount coupons.

Entertaining and hospitality means the expenses for food, beverages, service charge, and expenses rising out of the banquet arranged to welcome a related person or group of persons without expecting any return or business advantages.

A political contribution is a form of support, whether direct or indirect, that is used to support political activities, political parties, politicians, or the person having political roles with an intention to provide benefits, privileges, or business advantages.

Facilitation payments are expenses of minor value that are informally paid to governmental officers to ensure that the said person will proceed in accordance with the procedure or to accelerate the progress without discretion from the respective governmental officer. Furthermore, such an act is within the scope of duty of the said officer, and also the right of which the juristic person may exercise under the law, for example, applying for a license, applying for a certificate, and receiving public service.

The term 'conflict of interest' refers to a conflict between personal interest and corporate interest, whether direct or indirect. A situation or an act involves personal interest of a director, executive, employee or staff, and such situation can affect their decision or respective execution. Example: Nepotisk ad Cronyism, i.e., awarding a contract to a specific individual or group that provides support, hiring former governmental officer to exploit from data, influence, or relationship of such officer (revolving door).

A revolving door means having a government personnel working in a private entity or a private personnel working for policy in the governmental sector, which could cause a conflict of interest between the person and the government. A government officer may not provide fair supervision, or private personnel may attempt to establish a state policy that gives advantages to their own entity.

A governmental officer/employee means a person who is or was a governmental officer/politician/consultant for a government agency working in a private entity and may exploit the relationship or internal data to provide benefit to a private entity or may cause a conflict of interest in execution of the state agency or business governance entity of the company under its supervision. The result of such an act causes unfair business advantages or creates a policy in favor of the private entity for which the former governmental officer used to work.

Local tradition or trade usage refers to a festival or important day in which a gift may be given. An occasion to congratulate, welcome, show condolence, or help in a social manner shall be provided.

The Company means AP (Thailand) Public Company Limited

Affiliated company means a subsidiary company or joint venture of AP (Thailand) Public Company Limited.

Director means a director of the company

Executive means the Company executives from assistant managing director and higher.

Employees means full-time employees, daily staff, contracted staff who receive wages from the Company.

Directors, executives and employees of the Company and affiliated company must not claim, commit or accept all forms of fraud and corruption whether directly or indirectly for benefit of oneself, his family, friend, acquaintance, whether by offering, promising, soliciting, demanding, giving or accepting bribes or any behavior implying fraud or corruption.

• The Board of Directors is responsible for preparing policy and supervising to ensure the effective system that supports the anti-corruption movement, to raise awareness and address the importance of the anti-corruption concept among all employees.
• It is the responsibility of the Audit Committee to audit the system and report financial and accounting information, internal control system, internal audit, risk management to meet international standards. It is also responsible for providing consultation and monitoring to ensure compliance with the Anti-Corruption Act.
• The Corporate Governance and Risk Management Committee is responsible for supervising the Anti-Corruption policy, including its suitability to business operations, context, and corporate culture. It also considers the risk assessment results concerning corruption, as well as the corruption risk management plan's acceptable level.
• Chief Executive Officer, Managing Director and executives are responsible in implementing the Anti-Corruption policy, by promoting and supporting and communicating to all employees, reviewing operational procedures and measures to be up-to-dated and consistent with the volatility of situation.
• Company policies, rules, regulations, and orders regarding anti-corruption, including employee morality and code of conduct, must be adhered to. The Board of Directors, executives and employees should report any suspicious behavior, which may cause corruption. This includes external persons such as business partners, customers, and related persons, in accordance with the internal procedures established.

• The Anti-Corruption policy requires directors, executives, and employees to refrain from any corruption matter, whether directly or indirectly.
• Directors, executives and employees of the Company must not neglect or ignore any act that commits to corruption which involves the Company business. In such a case, the person must report to his respective supervisor or via the provided channels. In addition, they must cooperate with the investigation process, including related documents and evidence.
• The following are operational procedures and substantial regulations implemented for employee compliance as a single standard:
  1. The regulations and procedures for requesting an expense withdrawal request are strict. Balance, authority, and objectives are clearly defined. The recipient must provide accurate and correct supporting evidence.
  2. As a practice guideline, our sales and marketing procedures are precise for compliance and adherence. There are significant controls and risk mitigation measures, with a regular audit and monitoring process.
  3. The Company has prepared procedures for procurement management, such as tender, contract covenant, supplier selection, and an updated assessment of supplier's potentiality risk as a supporting factor in a decision that will ensure maximum benefit to the Company. The operation must comply with the Company's procurement regulations, with adequate audit and review.
  4. The Company's work procedures in personnel resource management are transparent and fair, preventing corruption. They cover personnel management from nomination or recruitment process, promotion, training, and performance assessment. The Company has no policy in place to demote or punish an employee who refuses to commit a corruption, despite the Company's intention to lose business opportunities.
  5. To ensure the effectiveness of the business operation under their responsibility, supervisors of all levels must communicate the Anti-Corruption policy and measure to employees, as well as monitor the implementation outcome.
  6. The Company emphasizes strict compliance with the Anti-Corruption policy and measures among its employees. Any negligence, omission, or intentional breach is considered a disciplinary offense and is subject to disciplinary penalties and possibly legal offenses in case such act is against the law regarding the nomination process or personnel recruitment, training, performance assessment, or incentive. The Company doesn't demote or punish an employee who reports or sees corruption.
• The transaction which is at risk of corruption and the Anti-Corruption measure are reviewed in a written form under the annual audit plan to ensure that those measures are effective and consistent to potential changes.
• There are procedures for keeping documents and records available for review in order to verify the accuracy and suitability of financial reporting. Operation procedures are determined in order to ensure that all transactions will be recorded with correct explanations and no false transactions.

• Guideline for Gift and Hospitality

  With well awareness, that the good relationship with business partners is a part that contributes to our continual growth, the Company, hence, has established the policy to guide the receiving/giving of gifts or any other benefits, hospitality and welcome service in a written form for compliance among our employees (Announcement No. AP-IARM-078/2565). Followings are the summarized guideline.

  Taking gifts or any other benefits, banquet and hospitality service
  1. No directors, executives, or employees shall be entitled to receive gifts or benefits, hospitality from customers, suppliers, or relevant persons under any circumstances. Performing this duty may cause bias or difficulty, or may cause a conflict of interest. No, person should assign any other person to take the briber for oneself.
  2. Taking gifts or any other benefits, hospitality service occasionally or season which is under local custom or tradition or trade usage where the two parties should do to each other and/or it is necessary to maintain the good relation between persons or organizations are allowed to the extent that the value of the gift must not exceed 3,000 bahts per each time.
  3. In case the person is under situation where he/she cannot refuse the gift, or it is necessary to take the gift or any other benefits, the person should report to the respective supervisor of director level and higher and forward the matter to the human resources - administration department within 7 days from the date of receipt for record and proceed as considered appropriate.
  Giving gift or any other benefits, banquet and hospitality
  1. No directors, executives and employees shall give a gift or any other benefits, banquet, hospitality or assign any other person to act on his/her behalf for bribery or provide improper business benefits.
  2. Taking gifts or any other benefits, banquet and hospitality during local season or tradition or trade usage where the two parties should do to each other, without causing a conflict of interest or being against the law are allowed to the extent that the value must not exceed 3,000 baht or the matter must be approved by the power of authority as determined by the Company.

  Further details on the policy for giving gift or any other benefits, banquet and hospitality can be reviewed from the Announcement No. AP-IARM-078/2565

• Guideline for Donations and Sponsorship

  The Company has in place the business operation policy that adheres to the good corporate governance, responsibility for society, environment and groups of stakeholders, to ensure the transparency and traceability. The financial support from the Company should be for business purpose only. There is no hidden agenda or disguise for the brands, trademark or reputation of the company. However, the donation made with intention for society or contribution as a part of return to society, for instance, donation for education, religion, arts and cultures, hospital with no intention to gain business return should follow the following guideline.

  1. The donation or sponsorship must be transparent, in line with the law, not in the contrary with the good morals, and not include any act that may cause damage to overall society. The donation should not be made as a reason to bribe.
  2. A donation or sponsorship must be approved by the power of authority as established by the Company. The information should include the donee, purpose of donation, date and value of the donation, as well as supporting documents related to the donee.
  3. A donation or sponsorship must have evidence of receipt or a receipt or other evidence showing receipt of money as a proof of recipient, for instance, thank you letter, donation receipt, pictures of the activity.
• Political Contribution Guideline

  It is the Company's policy to remain neutral in politics, neither supporting any particular party nor providing financial support to a political party, political group, political influencer or political candidates whether directly or indirectly, whether in local, regional or national level.

  With due respect to the political right of all employees as a good citizen under the constitution, regarding voting or becoming a political party member, the Company recognizes employee's right and freedom in politics under the law. Regardless, the employee should be aware that any political act must not cause damage to the Company, whether directly or indirectly. The Company's resources should not be used for political activities or illegal purposes, or lead to bribery. Followings are the practice guidelines:

  1. All employees should exercise their political rights with caution and avoid misleading the third party into believing that such an act is on behalf of the company.
  2. To participate in any political activities, an employee should avoid any act or omit any act which may mislead the others as the Company's support to any particular political party or contribute to political group, political influencer, or political candidate.
  3. The employee who participates in a political activity must not wear the company uniform or use any symbol that misguides the Company's support for a certain political party, political action, political group, political influencer, or political candidates.

     The support to political action, political group, political influencer or political candidates

• Facilitation Payment

  AP Thai has no policy to grant a facilitation payment in any form, whether directly or indirectly. The Company will either proceed nor accept any act in exchange for the business convenience.

• Guideline for Revolving Door

  TIt is the Company's policy to hire a governmental officer or employee who remains in the governmental agency since it may cause a conflict of interest, or to hire such person in exchange for business benefits which could lead to corruption.If however, it is necessary to hire a governmental officer or employee, the Company has established a preventive guideline to avoid potential risks, as follows:

  1. The cooling-off period established by the Company requires that a governmental officer or employee must resign from the position for 2 years or for the duration as stipulated by specific law.
  2. The background of a candidate can be investigated to determine whether they are a government officer or an employee. The procedures are listed as one of the conditions in the personnel recruitment process for the executive position and higher, to identify matters that may contain a conflict of interest.
  3. Name and background of the governmental officer or employee being appointed for high-rank executive, director or advisor position, and the reason of such appointment must be provided in the Company's annual report.
• Preventive guideline for a conflict of interest

  The AP Thai business practices adhere to the good corporate governance, in accordance with the corporate ethics. Our employees are oriented towards morality, honesty, integrity, transparency, and accountability in their work. Followings are the practice guideline established to prevent potential conflict of interest.

  1. Directors, executives, or employees who wish to undertake the directorship or advisorship of the Company, organization, or business association having the same business as the Company must notify the Board of Directors in advance.
  2. Directors must notify the Board of Directors through Chairman of the Board about the cause of conflict of interest immediately and refrain from attending the discussion, giving opinions or vote in the agenda where she/she related or to express any intention to participate in deciding over such matter.
  3. To ensure the transparent and accountable operation, list of major shareholders, related transactions are disclosed to the public. Directors and executives must report the changes in their securities holding to related agencies as stipulated by law. The minutes of the meeting should be stored accurately for retro investigation purposes.
  4. In case of a merger, acquisition or taking over, the Board of Directors will appoint an independent agency to investigate the fair value of operational cost and the transparency of procedures thereof.
  5. Employees, including their family members, must notify the Managing Directors or executive of the Human Resource Department in a written form when they take part or become shareholders in any business that may involve interest or cause a conflict of interest to the Company.

• AP Thai recognizes the importance of disseminating the policy and measures related to the anti-corruption to directors, executives, and employees of all levels, in particular, to employees who involve with the transaction that is at risk of corruption. The training of the matter is arranged on regular basis through specified channel, for instance, setting as one of the courses in the orientation session, webinars, intranet, internal emails, announcement board to ensure everyone in the organization achieve the correct understanding and comply with.
• The Anti-Corruption policy, including the whistleblowing policy, will be disseminated to all stakeholders via various channels, for example, the Company website, Annual Report, and the meeting related to business operation.
• If any personnel have questions about this Anti-Corruption policy and measure, they can contact their respective supervisor, Corporate Secretary or the Compliance Department

The Company has provided channels for reporting and practice guideline for consideration. The whistleblowers are protected by a systematic approach that is transparent and fair, in order to ensure that our approach is integrity and consistent with the whistleblowing policy. Our channels for whistleblowing are provided as follows:

In case there is question about the whistleblowing, the person may seek for advice or consultant from a respective supervisor or the Internal Audit or Human Resource.