Anti-Corruption Policy
The Bank has established this anti-corruption policy to indicate a direction and framework for its anti-corruption undertaking in accordance with principles and best practices generally accepted as being relevant to the country’s economic and social environment as well as the financial institution business. This policy was approved by the Board of Directors and will be reviewed annually.
The Bank encourages companies in its financial business group to adopt and implement this anti-corruption policy in a manner that is appropriate to its specific circumstances.
Directors, executives, employees, and relevant parties are required to adhere to and comply with this anti-corruption policy in conducting their business operations.
“Corruption” means any form of bribery, whether in the form of giving, demanding, or agreeing to give, or any action of offering, giving, promising, granting, or committing to give any valuables or benefits to a public official, government agency, private entity, or responsible individual, whether directly or indirectly, to induce favorable actions or to restrain the person or entity from performing their duties or to commit illegitimate actions. Corruption also includes demanding, obtaining, or agreeing to obtain any illegitimate valuables or benefits for oneself or others to induce favorable actions or to restrain the person from performing either legitimate or illegitimate duties.
Operational Guidelines
Bribery
Rationale
The Bank promotes the values of integrity, fair practices, and compliance with laws and regulations, while ensuring accountability in the performance of duties. It is committed to operating as a transparent and corruption-free organization.
Guideline
The Bank prohibits directors, executives and employers from engaging in any form of corruption or bribery.
Political Contribution
Rationale
Political contribution refers to financial contribution, non-financial contribution, and any other form of contribution made for any political purpose. Financial contribution includes monetary gifts and loans. In-kind contribution includes offers of goods or services, advertising or promotional activities endorsing a political party, purchase of tickets to fundraising events or donation of money to an organization with a close relationship with a political party. Allowing employees to take leave without pay or to act as the company’s representative to participate in any political cause or campaign is included in the scope of political contribution.
Political contribution to support democracy in the form of monetary or non-monetary support is permitted by law. If the company uses political contributions to help it gain a contract or to draft a bill to facilitate business deals, this political contribution action is considered illegal.
Guideline
The Bank has a policy to not make political contributions to gain contracts or business advantages, including not making contributions to any political campaigns or the activities of any politicians or political parties. An exception to the previous statement exists only if the Bank decides to make a contribution to support democracy that is proper and permitted by law.
Charitable Contribution
Rationale
Charitable contributions can be a part of activities that represent corporate, but it can also be a channel for bribery. This is because such activities involve spending money without tangible returns and may be used as an excuse or channel for corruption.
Guideline
The Bank has a policy of making charitable contributions on appropriate occasions as a socially responsible business in accordance with laws and good practice, and will not use charitable contributions as an excuse or channel for corruption.
Sponsorship
Rationale
Sponsorship has an objective for promoting the business, brand, or good reputation of the company, which can constitute a corruption risk. Sponsorship is considered as the expenditure for services or benefits that cannot be measured for business outcomes and is not traceable, and may be linked to corruption.
Guideline
The Bank has a policy to consider sponsorship of projects, transactions or matters to be carried out that use funding carefully, prudently, and appropriately within reasons, as well as in accordance with laws and best practices, and not to use it as an excuse or channel for corruption.
Gifts and Hospitality Expenditures
Rationale
Gifts and hospitality expenditures are expenses associated with the Bank’s business operations to build or maintain a good relationship or, on some occasions, paid as part of social etiquette. However, gifts and hospitality expenditures could be considered as bribes if they are paid to induce a public official to wrongfully perform his duty.
Guideline
The person responsible for the receiving or giving of gifts, hospitality/reception, or other expenses shall review the relevant rules, regulations and laws, including those of the parties with whom the Bank has a business relationship. Such activities must not be undertaken during any ongoing bidding or procurement process.
- Accepting Gifts
Do not accept any gifts that impact decision making, or accept service or make purchases at a price unreasonably below the market value.
- Providing Gifts
The value of gifts provided to public officials should not exceed THB 3,000 or equivalent per person per year and must not exceed those stipulated in the laws of the applicable country or the regulations of the organization.
Training
The Bank provides learning courses for Directors, Executives, and employees to promote an understanding of corruption methodology and its negative impacts, as well as the Bank’s Anti-corruption policy and guidelines. In addition, the Bank encourages Directors, Executives and employees to attend external training related to anti-corruption as appropriate.
Risk Management
The Bank established a risk management process to identify corruption risks, assess their potential impacts, design mitigating and preventive measures, and to monitor and control those risks.
Raising Concerns and Whistleblowing
Raising Concerns and Seeking Guidance, or Whistleblowing
The Bank provides appropriate channels to report suspicious matters and for seeking guidance, and actively encourages whistleblowing. The bank recognizes that such actions are good and takes steps to protect individuals who disclose such information, with the expectation that all employees will cooperate in ensuring compliance with anti-corruption measures by seeking guidance or consultation when in doubt, when suspicions arise, or when reporting concerns. Employees are expected to act as whistleblowers when discovering inappropriate behavior or any case that may violate anti-corruption measures.
Corruption Management Procedures
Whistleblowing and Whistleblower Protection Measure
The Bank provides open channels for whistleblowing or filing complaints related to corruption and treats all parties equally on the basis of transparency and fairness while ensuring an appropriate investigation period. Measures are in place to protect those whistleblowers and those who cooperate in the investigation from being violated or harassed. Information about whistleblowers and those who cooperate during the investigation will be kept confidential with access restricted to responsible parties unless the disclosure is required by law or becomes necessary. Note that bona fide whistleblowers and those who cooperate during the investigation will not be punished or treated negatively by the Bank.
Whistleblowing Management
The Audit Committee, and the Customer’s Complaint and Fraud Cases, Compliance Unit, oversee and deliberate on whistleblowing or complaint cases with prudence and fairness by ensuring that the investigation process is transparent and fair. For severe or complex cases, the Customer’s Complaint and Fraud Cases, Compliance Unit, may refer the case to an ad hoc committee or the Audit Committee for consideration as deemed necessary and appropriate.
Governance of Whistleblowing Procedures
The Audit Committee and the Customer’s Complaint and Fraud Cases, Compliance Unit, supervise whistleblowing or complaint procedures from accepting whistleblowing or complaint cases to closing those cases, as well as notifying and reporting progress updates and results to relevant parties. Moreover, they also ensure that the Bank has preventive and corrective measures in place, treats employees fairly, enforces disciplinary actions against employees who are involved in corruption or violate anti-corruption measures. These disciplinary actions include warnings, remuneration reduction, dismissal and termination.
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