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Business Ethics

Commitment


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

Materiality


Conducting business ethically with respect for human rights and responsibility for all stakeholders helps enhance business competitiveness, increases credibility with all groups of stakeholders and reduces business risks. By contrast, business conduct that is not in line with business ethics, respect for human rights and responsibility for all stakeholders not only has the potential to destroy stakeholder trust but may also negatively impact business revenue. The Bank has always been committed to conducting business ethically and ensuring that proper practices are in place including: committing to business ethics; adopting international principles on human rights; preventing and managing corruption risks; strictly complying with anti-money laundering, counter-terrorism financing (AML/CFT) and combating weapons of mass destruction regulations; and, engaging in proper market conduct as well as ensuring an effective and fair whistleblowing process and grievance mechanism. Furthermore, we also place importance on training and knowledge sharing for employees to ensure their proper compliance with the Bank’s policies and rules, as well as the laws and regulations of relevant government agencies. This is to enable us to achieve our commitment to being the most trustworthy Bank for all stakeholders.
Code of Conduct for Employees
The Bank issued its Code of Conduct1 to promote and uphold good corporate governance which is an important foundation of sustainable development and to provide clear guidelines for how directors, executives and employees shall perform their work with integrity, honesty and responsibility for all stakeholders. All executives and employees have signed an acknowledgement of the Code of Conduct and Business Ethics and are obliged to comply with it as well as other relevant regulations as stated in their employment contracts. Compliance with the Bank’s rules and regulations and the Code of Conduct and Business Ethics is one of the factors used in evaluating the performance and remuneration of employees at all levels. Employees who are eligible for a bonus payment must not be those who have been disciplined to the point of dismissal or are the perpetrators of corruption. In situations where the employee is under investigation for an offense, the bonuses will be temporarily suspended until the investigation is completed. Once the investigation finds that the employee has not committed any wrongdoing, his/her entitlement to receive a bonus shall resume as usual. In addition, the Bank places importance on raising awareness and understanding of ethical business practices by organizing mandatory training courses on the Code of Conduct and Business Ethics for employees at all levels.

Besides the Code of Conduct and Business Ethics, the Bank has established the Code of Conduct for Employees1 and encourages all directors, executives and employees to strictly abide by it. Moreover, we promote awareness and understanding of the importance of compliance with the Code of Conduct for Employees by introducing it during the orientation of new directors, executives and employees, regularly communicating about the Code of Conduct for Employees within the Bank, and making available a manual for the Code of Conduct for Employees to ensure clear understanding.

Remuneration and Performance Linked the Compliance with Code of Conduct and Business Ethics

To escalate an effectiveness of the Bank’s corporate governance, we have integrated the compliance with our rules and regulations, and the compliance with our code of conduct and business ethics as performance criteria that are linked to remuneration and bonus for all level of employees in a particular year. In addition, the employees who are qualified for bonus must be those who do not misbehave which lead to disciplinary actions such as immediate dismissal or termination and those who do not get involved with fraud. If an employee still remains in the investigation process for high level of disciplinary/ corrective action, or are alleged to get involved with fraud, the employee will be temporarily restrained from bonus payment. In case the employee is proved no guilty or acquitted from any wrongdoings, the employee will be able to receive bonus.

Respect for Human Rights
The matter of human rights is currently considered to be one of the most important issues affecting all sectors. This issue is extremely important, not only to government and society, but also to the business sector. Violations of human rights in business still occur from time to time, causing damage not only to those who are violated but also to the image of the violators and the business sector. Therefore, the Bank recognizes the importance of respecting and managing human rights as this not only ensures that the Bank’s business operations and activities do not directly or indirectly violate human rights but promote a positive image and extend business opportunities for the Bank. We strictly comply with international and local human rights principles and standards, such as the Universal Declaration of Human Rights (UDHR) and the International Labor Organization (ILO) Conventions. In addition, we have adopted the United Nations Guiding Principles on Business and Human Rights (UNGP) to guide our human rights management. Accordingly, we have established a human rights policy and practice2, and have also conducted Human Rights Due Diligence3 (HRDD) to assess human rights risks and impacts that may occur as a result of business activities of the Bank, its suppliers and its customers throughout the business value chain, in order to set appropriate measures to prevent risks and impacts thereof.

The Bank conducts human rights due diligence covering all groups of stakeholders including vulnerable groups such as female employees, child workers, migrant workers, daily wage workers, minorities, people with disabilities, LGBT people, etc. The human rights due diligence process involves identifying human rights risks in business operations across the Bank’s value chain, considering those who may be affected by human rights violations by the Bank and related parties, assessing human rights risks, identifying human rights risk mitigation measures, and developing remediation actions for those affected by human rights violations. The Bank conducts and reviews its human rights due diligence process every three years, or when the review is necessary due to a significant event, so that the Bank can manage human rights in a timely manner given changing situations.




Respect for Employee Rights

The Bank respects the rights of employees and treats all employees equally without discrimination on the grounds of gender, race, religion, education, skin color, sexual orientation or any other reasons. We strictly comply with labor laws and internal rules and regulations including those relating to employment, compensation, welfare, working conditions and occupational health and safety in the workplace. Meanwhile, if the Bank is obliged to terminate a contract with an employee due to a cause other than misconduct or retirement, the Bank will ensure compliance with regulations regarding termination of employment by paying severance as required by law and a family allowance according to the Bank’s policy.

In 2023 the Bank announced its Non-discrimination and Anti-harassment Policy1 to declare our stand and zero tolerance approach against any kind of discrimination or harassment. The policy is used as a guideline to prevent discrimination and harassment in the organization including physical, verbal or sexual harassment and to provide guidance when there is a case of discrimination or harassment. Accordingly, the Bank began offering an online training course on “Human Rights, Non-discrimination and Anti-harassment” to raise awareness and promote understanding among all employees.

The Bank respects the rights of our employees to exercise freedom of association and engage in collective bargaining activities for labor rights in accordance with the law. We allow all employees to join the Bank’s two labor unions, namely the Bangkok Bank Workers Union and the Bangkok Bank Managerial Officers Union. Both unions negotiate in the interests of their members and have successfully negotiated terms and conditions that likewise apply to non-member employees. In addition, the Bank offers opportunities for union’ representatives to raise significant issues for discussion with the Bank to find solutions and prevent labor relations problems that may arise in the future. The unions’ requests and suggestions have been duly accommodated by the Bank. In 2023, the two unions had a total of 9,121 members, representing 49 percent of the total employees.
Anti-corruption
The Bank has established an Anti-corruption Policy1 as an operational framework for compliance by directors, executives and employees and to foster a corporate culture in this respect. The policy includes comprehensive corruption risk assessment and management and whistleblowing and complaint channels. We also annually conduct a performance assessment in compliance with the policy, as well as regularly raise awareness of the policy to employees at all levels through training and internal communication to ensure concrete outcomes. In the case of violation or non-compliance by any employee, the Bank will conduct an investigation according to the disciplinary procedures and impose appropriate penalties ranging from a verbal warning to employment termination or legal action.

The Bank has been recognized by various external agencies as a financial institution that plays an important role in fostering anti-corruption and has been a certified member of the Thai Private Sector Collective Action Against Corruption (CAC) since 2015 (with certified membership extended since 2021). We also invite suppliers and business partners to become members of the Thai Private Sector Collective Action Against Corruption (CAC) which reflects our unwavering support for anti-corruption in the private sector.



Corruption Risk Management

To prevent and control the risk of corruption, we have established an effective corruption risk management process that is aligned with our business context as follows:

1. Identification of any corruption risk we may be exposed to through our operations or business activities.

2. Assessment of the corruption risk and severity of the impact.

3. Adoption of preventative and control measures specific to the corruption risk that is applicable to the situation and business context of each unit. Executives or supervisors involved with each risk issue will oversee the risk assessment and determine risk prevention and control measures on an annual basis. All assessment results and related information will be collected and stored in a corruption risk database for further analysis and reference.

4. Controlling, monitoring and auditing are undertaken under the “three lines of defense” principle. Business unit heads and business unit compliance officers, as the first line of defense, manage risks pertaining to their units. The Risk Management Division and Compliance Unit, the second line of defense, oversees and monitors corruption risk management. The third line of defense, the Audit and Control Division, independently audits matters related to corruption and reports to responsible persons according to the line of command.

In 2023, the Bank had no corruption and bribery allegation or complaint against it from the Bank of Thailand, the Office of Securities and Exchange Commission, and the Office of the National Anti-Corruption Commission or the Anti-Money Laundering Office. We were not directly or indirectly involved in any activity related to lobbyists, political support, political parties, political candidates, or political influencers.

Anti-money Laundering and Counter Terrorism and Proliferation of Weapons of Mass Destruction Financing (AML/CTPF)

We have formulated a policy on anti-money laundering and combating the financing of terrorism (AML/CFT)1 as well as financing the proliferation of weapons of mass destruction as a framework for our conduct in order to prevent or mitigate the risk of the Bank being used as a channel or a tool for related offences. The Board of Directors, executives and all employees have the duty and responsibility to strictly comply with the policy. We also place importance on Know Your Customer (KYC) and Customer Due Diligence (CDD) in accordance with the risk level of customers. For high-risk customers, including Politically Exposed Persons (PEP), the Bank requires Enhanced Due Diligence (EDD) which requires a more in-depth examination to find factual information about the customer and monitors financial account movements in greater detail than usual. We have also developed an internal work system to check customer names against the databases for the designated person, the sanctioned person and the high-risk person as specified by the relevant authorities to accommodate and provide convenience for the Bank’s staff to examine and assess the risks of each customer in an effective and efficient manner. An AML Monitoring System is also in place to review and monitor dubious and irregular financial movements and transactions, thereby reducing the risk of the Bank being used as a channel for money laundering or supporting terrorism. Furthermore, we have set up risk management systems in accordance with the three lines of defense principle and conduct regular communication and training for all employees. All related documents are properly filed and kept for a period of 10 years to ensure that our anti-money laundering and counter terrorism practice is effective and in accordance with the laws and regulations.
Market Conduct

We realize that receiving fair service is a basic right of customers and is key to quality service. Therefore, we have formulated a market conduct policy and guidelines as follows:

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 Bank’s corporate culture.

2. Product and Service Channel 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 our employees’ selling capabilities and knowledge, our work systems and ability to assure quality of sales so that customers receive suitable products with good quality. We recognize that in determining product terms such as benefits, prices and fees, we must consider fairness to customers and associated actual costs, while not joining with other providers to specify terms that are against customers’ interests nor offering bundled products unless it is justified on the grounds of risk protection of the main product.

3. Remuneration Scheme

Remuneration and penalties are determined for employees who provide services to customers as well as executives who are responsible for monitoring compliance with market conduct. KPI are also properly defined to prevent irresponsible sales propositions and recommendations to customers (Mis-selling).

4. Sales Process

Selling products and services to customers must not invade their privacy. Information provided to customers must be complete, not misrepresented or distorted so that customers receive products or services that are suitable for their needs and affordability. A system to regularly check selling and service quality is in place, such as call backs, welcome calls and mystery shopping.

5. Communication and Training

We regularly communicate with employees to raise awareness and organize training programs to provide knowledge about market conduct. This includes providing detailed information of new products or services, guidance on sales approaches using simple language, customer rights and market conduct guidelines.

6. Data Privacy

We protect the privacy of personal customer data by strictly complying with applicable laws.

7. Problem and Complaint Handling

We have established effective processes for problem solving, complaint handling, whistleblowing, as well as remedies.

8. Three Lines of Defense

We have adopted the three lines of defense principle for controlling, monitoring and auditing compliance with market conduct requirements to detect risks and anomalies while a self-monitoring system is in place for after-sales service to ensure compliance with the Bank’s guidelines.

9. Operation and Business Continuity

We have established operating systems and business continuity plans that cover operations in both normal circumstances and emergencies. We have also prepared a manual and checklist for employees to prevent operational mistakes.

The Bank pays special attention to vulnerable groups such as the elderly (over 60 years), customers with limited financial knowledge or no experience in using products and services, and customers with visual impairments. Therefore, we have specifically established guidelines for selling products and giving services to vulnerable groups ,as well as provide trainings to service staff to prevent aggressive sales techniques, forced selling and disrespectful treatment to these groups. For example, we take into account customer’s needs and objectives, financial knowledge, risk appetite and tolerance level, and ability to understand when we offer products and services to them. In addition, an explanation of details, conditions, rights and exceptions of the products and services must be clear and easy to understand, as well as highlighting and emphasizing the key messages. If customers have questions, service staff must explain or clarify to them until they truly have a complete understanding without doubts or further questions. This is aimed to ensure that customers receive sufficient important information to make a reasonable decision. Service staff must also give as much time as necessary for vulnerable groups to digest and understand the information provided and not rush them to make decisions.

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. Dharmsirirat Law Co.,Ltd.
  4. Nisit and Partners Co.,Ltd.
  5. Leader Group Co.,Ltd.
  6. Lawyer Smart Group Company Limited
  7. Max Group corporation Company Limited
  8. Nitirat Law and 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.
Whistleblowing
According to the Bank’s Whistleblowing Policy1, all stakeholders can send information or file complaints related to the actions of the Bank and related parties including directors, executives, employees and contractors that are suspected to be frauds or be in violation of laws, regulations, the Code of Conduct and Business Ethics, policies and practices of the Bank, or represent inaccurate financial reports or instances of failure of internal control systems according to the guidelines and via the channels stated below:

Whistleblowing and Whistleblower Protection Measures

The Bank provides open channels for whistleblowers and treats all parties equally based on 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 with regard to safety and potential damage to whistleblowers and those who cooperate during the investigation. 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 Complaint and Fraud Unit, under the Compliance Unit, oversee and deliberate on whistleblowing cases with prudence and fairness by ensuring that the investigation process is transparent and fair. For severe or complex cases and fraud cases, the Customer Complaint and Fraud 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 Complaint and Fraud Unit supervise whistleblowing or complaints 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, these responsible parties also ensure that reventive and corrective measures are in place and wrongdoers punished according to the Bank’s stipulated disciplinary actions ranging from an official warning in writing, remuneration reduction, to employment termination.

Complaint Management

The Bank provides channels for complaints related to working conditions, unfair discrimination at work, and other forms of intimidation or harassment, whether it is verbal, physical, or sexual harassment. An employee can raise issues about another employee to stop an action immediately or, if the person still continues to behave in such a way, the former can report or consult with his supervisor to find a solution or a mitigation. If the issue is not resolved satisfactorily, a complaint can be filed in writing to the Employee Relations Unit under the Human Resources Department, which then submits it to a Disciplinary and Petition Committee which is assigned to investigate complaints and which rules on whether the alleged wrongdoing has indeed occurred. If it is found that there is unfair treatment or intimidation which is against the Bank’s rules or the law, the case will be referred to the Audit and Control Division and the division /department in which the violator works to consider appropriate disciplinary action and punishment. The penalty for wrongdoers is based on the severity of the case, ranging from verbal warnings, pay cuts, to termination of employment and legal action. The Bank ensures that all parties are treated fairly through a transparent and equitable investigation process with regard to keeping of confidentiality and protection of the plaintiff while affected persons are remedied properly and fairly.

Total number of breaches

Reporting areas

Number of breaches in FY 2023

Corruption or Bribery

0

Discrimination or Harassment

2

Customer Privacy Data

0

Conflicts of Interest

0

Money Laundering or Insider trading

0
Training Courses
The Bank focuses on encouraging all employees to adhere to the Code of Conduct and Business Ethics Practice including related polices and guidelines through the following courses:


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