Code of Conduct

Commitment


To reinforce the highest ethical business practices by focusing on cultivating an ethical culture, building employee awareness and understanding, and implementing an effective internal control system to gain stakeholder trust

Materiality


We attach great significance to conducting business in accordance with ethics and responsibility for all stakeholders. This will help maintain our longstanding reputation and mitigate risks in doing business while helping our stakeholders gain confidence in the Bank. We encourage all employees to observe high standards of ethics and comply with the Code of Conduct, the Code of Conduct for Employees, and other related policies and practices of the Bank and applicable laws. We have defined clear guidelines, communicated and provided online training to all employees to raise their awareness and gain strict observance, which will help reduce risk and promote confidence by stakeholders in the long run.

With regard to governance, units responsible for compliance are required to ensure that our operations are in accordance with all laws, rules, regulations and regulatory requirements, as well as policies and practices stipulated by the Bank. These units must perform their duties independently from the Bank’s business units and are allocated adequate manpower and other resources. Furthermore, we have put in place policies and practices on whistleblowing and complaint filing in cases of fraud and breaches of laws or related regulations as well as violation of, or non-compliance with, ethical standards, the Code of Conduct and policies and practices of the Bank. Additionally, we ensure proper whistleblower protection and fair investigation while taking disciplinary actions according to the severity of the case.
Management Approach
Code of Conduct and Business Ethics

It is our firm belief that a strong code of conduct and business ethics are the foundation of good corporate governance and the sustainability of an organization, and thus we encourage all employees to have a good understanding of the Bank’s Code of Conduct and business ethics and related policies and to adhere diligently to them. We also require all of our subsidiaries to adopt the Code of Conduct and business ethics and adapt it as appropriate to fit the context of each company. All employees have signed acknowledgement of the Code of Conduct and business ethics in their employment contract. Furthermore, a training program on the Code of Conduct and business ethics is mandatory for all employees to ensure their awareness, understanding and strict observance to the Code of Conduct and business ethics.

Code of Conduct for Employees

We require all staff, executives and directors to understand and strictly perform in compliance with the Code of Conduct for Employees, which is described in detail during the orientation for new directors, executives and staff. Moreover, we have published an employee handbook and conduct internal communications on a regular basis.

Market Conduct

Realizing that the right to receive impartial and unbiased services is a basic right of customers, we have formulated market conduct guidelines based on the nine following principles.

  1. Corporate Culture and Roles and Responsibilities of the Board of Directors and Senior Management
    The Board of Directors and senior management are responsible for fostering ethical market conduct as part of the organizational culture.
  2. Product/Service Channels Development and Client Segmentation
    We develop products and service channels that are suitable for the needs, financial ability and comprehension of each target group of customers, with due consideration of the selling capabilities of employees, work systems and quality control systems related to sale so that customers receive suitable quality products. We recognize that in determining product terms such as benefits, prices and fees, we must consider fairness and actual costs while avoiding joining with other providers to require a bundle of products unless it is justified on the ground of risk protection of the main product.
  3. Remuneration Scheme
    Remuneration and penalties are determined after taking into consideration compliance with market conduct by employees who provide services to customers as well as executives who are responsible for monitoring compliance with market conduct. KPI must be properly defined to prevent sale propositions and recommendations that are of poor quality and ensure that staff do not offer irresponsible advice to customers (mis-selling).
  4. Sale Process
    Products and services offered to customers must not invade their privacy. Key information must be provided without misrepresentation or distortion so that customers receive products and services that meet their needs and financial ability. Call backs, welcome calls and mystery shopping are subject to quality controls. In addition, sales and service offerings to vulnerable customers must be prudent and well considered. Employees must understand the requirements and financial resources of customers as well as their ability to understand the service so they can provide sufficient information and knowledge about potential risks.
  5. Communication and Training
    We communicate regularly with employees to raise awareness, and organize training programs to provide knowledge about market conduct. This includes providing informative content around new products or services, sale approaches using simple language and customer rights as well as customer protection guidelines so that employees can properly follow the market conduct practices.
  6. Data Privacy
    We protect the privacy of customer data in accordance with applicable laws. Work systems are designed, developed and tested to ensure data security while the scope of authority of employees who are responsible for data security under the “three lines of defense” principle is clearly defined.
  7. Problem and Complaint Handling
    We have established processes for problem solving, complaint handling and whistleblowing, and put in place remedies to ensure clarity, speed, effectiveness and fairness during the resolution process.
  8. Three Lines of Defense
    We have adopted the three lines of defense concept for controlling, monitoring and auditing compliance with market conduct. This is used to detect risks and anomalies and has a self-monitoring process to ensure that sales and services are in line with practices stipulated by the Bank.
  9. Operation and Business Continuity
    We have established operating systems and business continuity plans that cover operations in both normal circumstances and during emergencies to ensure that customer requirements are met correctly, completely and on time. We have also prepared a manual and checklist for employees to use as well as ongoing training programs to prevent operational mistakes.

 

Retail customer debt collection policy and practice 

The Bank has established policy, principle, procedure including guidelines on debt collection for retail customers in accordance with the Debt Collection Act B.E. 2558, the Debt Collection Supervisory Committee Notices, Debt Collection Guidelines issued by Bank of Thailand (BOT), Personal Data Protection Act B.E. 2562, Credit Data Business Operation Act B.E. 2545, and relevant laws and regulations. These cover details of the Bank’s regulations and procedure, personal identification, information disclosure, location or person, date, time and the amount of contact for debt collection purpose, including fees or expenditures (if any), rights and complaint channels for debtors, penalization for debt collectors or debt collection companies that are appointed by the Bank in case of violations of and non-compliance with the Bank’s policy and relevant laws and regulations. This is to ensure that the Bank has properly and fairly collected the debts.


  •  Appointed debt collection companies for retail customers*
  1. CHALINTHON AND COUNSELLOR CO.,LTD.   
  2. PRACHACHON LAW OFFICE.CO.,LTD.    
  3. DHAMSIRIRAT LAW CO.,LTD.   
  4. NISIT AND PARTNERS CO.,LTD. 
  5. LEADER GROUP CO.,LTD.   
  6. Lawyer Smart Company Limited   
  7. MAXGROUP CORPORATION CO.,LTD.   
  8. NITIRAT LAW & COLLECTION CO.,LTD.
  9. S.S.C.LAW OFFICE   

* Remark: The debt collection companies have been appointed to clarify and provide information for the debt collection purpose only. The recruitment principles are in accordance with the Bank’s outsourcing policy and regulations and BOT announcement. The Bank reserves the right to change the debt collection companies without prior notice.

Anti-corruption Policy

The Bank’s anti-corruption policy is clearly prescribed and employees are expected to strictly adhere to it to build a healthy corporate culture. The anti-corruption policy covers proper practices, risk management, provision of channels for whistleblowing and complaint filing as well as whistleblowing and complaint handling. Violation or non-compliance by employees will result in penalties as stipulated in the policy. At the same time, we have prepared an anti-corruption handbook as a practical guideline for employees, conduct an annual compliance assessment checklist and regularly raise awareness of the policy to employees at all levels through training and internal communication channels.

The Bank has been recognized as a financial institution that plays an important role in fostering anti-corruption awareness, as certified by the Private Sector Collective Action Coalition Against Corruption Council (CAC), of which it has been a member in good standing since 2015. The Bank’s certified membership was also extended for another three years, starting in 2021.

Corruption Risk Management

To prevent the risk of corruption that may negatively affect our image and reputation, we have established an effective corruption risk management process that reflects our business context as follows:

  1. Identification of any risk of corruption we may be exposed to through our operations or business activities
  2. Assessment of the risk and degree of potential impact
  3. Adoption of preventive and control measures specific to the corruption risk that is applicable to the situation and business of each unit
These three steps are carried out by executives and supervisors who are closest to the issues and best suited to manage each corruption risk. All relevant information, which is subject to regular updates, will be collected and stored in a corruption risk database for further analysis and reference.

The Bank conducts its corruption risk management under the three lines of defense principle. First, business unit heads and business unit compliance officers follow up, supervise and examine the units for which they are responsible. Second, the Risk Management Division and Compliance Division track and monitor corruption risk. Third, the Audit and Control Division independently reviews related work.
Key Activities
Learning and Development for Executives and Employees

Building awareness and understanding of the Code of Conduct is a high priority for us and therefore we have developed various curricula for our online platform, BBLearn. All employees can access relevant information and knowledge through smartphones, tablets and computers in a convenient, fast and comprehensive manner so that they can comply with policies and practices imposed by the Bank.

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