Thai Wah Public Company Limited (“the Company”) has established and adhered firmly and consistently
to our business operation guidelines in accordance with good corporate governance in exercising
corporate social responsibility (CSR) and giving importance to promoting anti-fraud and
anti-corruption practices. The Board of Directors’ Meeting no. 1/2017 on February 21, 2017, had
approved the Company to join the Private Sector Collective Action Coalition Against Corruption.
The Company has established Anti-corruption Policy to promote anti-fraud and anti-corruption
practices as well as to enhance the efficiency, integrity, honesty and transparency of the
anti-fraud and anti-corruption business practices to be in-line with the Company’s core values and
to serve as clear guidelines for Directors, Executives and staff.
||an intentional act committed to secure unfair or unlawful gains for one’s self or others.
Fraud can be broken down into three types: corruption, asset misappropriation and fraudulent
reporting, for example, fraudulent financial statements.
||the misuse of position or power of influence for inappropriate gains for the organization,
one’s self or others. Corruption includes any types of bribery; an offering, giving,
promising or agreeing to give, demanding or accepting money, assets, or other inappropriate
benefits from the government officers, government sectors, private sectors, or responsible
person either in direct or indirect action so that such person could proceed or disregard
his/her function in order to acquire, retain the business, recommend specific company to the
entity, or achieve any improper benefits in business transaction. Exception shall be applied
in case of laws, regulation, statement, standard, custom, or business traditions enable to
||the act of paying, offering, promising to pay, receiving, requesting or soliciting anything
of value, such as assets, money, things, rights or other advantages that are against good
ethics, conduct, rules, regulations or laws with government officials, government
organization, private organizations or other individual(s) - directly or indirectly - in
order for that person to wrongfully act or wrongly refrain from performing their duties to
receive or retain benefits that are inappropriate for the business.
||monetary or non-monetary support provided to a political party, representative of a
political party, politician or candidate for election. As such, non-monetary political
contributions include lending or donating any equipment for free of charge.
||receptions, provision of food and drinks, and recreational activities, such as
entertainments, sports event, etc.
|Gift, tokens, assets, or any other benefits
||anything of mental values, cash or non-cash, that are courteously given on important
occasions according to common customs and culture, to award, honor, support, or to be given
out of kindness. They could be privileges to service, entertainments, recreations, or
coverage of expenses related to traveling, accommodations, meals, or any other similar
expenses, such as tickets, lotteries, etc. It also includes tokens given out of courtesy, or
in accordance with local traditions, such as New Year gifts, birthday presents, or
congratulatory new job gifts, etc.
Scope of the Policy
This Policy is applicable to all levels of employees including Directors, Executives, employees in
the head office or working abroad, the factory workers, trainees, contract-based employees, or any
other relevant persons. All must strictly comply with the Anti-corruption Policy as well as the
additional guideline (if any).
This Policy is also applicable to the employees of the subsidiaries companies.
Directors, Executives and the Company’s staff are prohibited from operating or accepting any type of
corruptions either direct or indirect manner, in all businesses or from any concerned parties. The
anti-corruption practices are required to be consistently counter checked as well as the
Anti-corruption policy and business operation guidelines are to be reviewed regularly to reflect the
changes in business, regulations and applicable laws.
- Executives, the Company’s staff or persons acting on behalf of the Company, shall not request,
provide, persuade or promise to provide or accept bribery or any forms of inappropriate payments
including facilitation payments.
- The Company’s staff shall not be negligent in any corruption conditions involved directly with
the Company. All staff must notify such act to supervisors or responsible person, as well as
provide cooperation in the investigation process.
- The Company shall provide fairness and safeguard staff who informs corruption cases relating to
the Company by applying Protection Policy for appellant, witness or persons who incorporate with
Anti-corruption information as stated in the Whistleblowing Policy.
- A person who commits the corruption is to be considered disciplinary action followed by the
Company’s standard. Besides, possible legal penalty may be applied, if such act violates the
- The Company shall disseminate, share the knowledge and establish a common understanding with
other people who are involved or affect the Company, especially on matters involving
- This Anti-corruption Policy covers to Human Resource Management process starting from
recruitment, selection, promotion, training, evaluation, compensation and benefits provided to
staff. All supervisors at all levels must communicate and establish common understanding of the
policy with staff to apply in the business activities under their responsibility and to monitor
the effectiveness of implementation.
- Charitable contributions and sponsorships to individuals or organizations, to both government or
private sectors, must be transparent for charity purposes, and not be made with the expectation
for favorable treatment in return that may be considered as fraud or corruption. The request and
approval processes must be performed in accordance with the Company’s guideline on charitable
contributions and sponsorships.
- The provision and acceptance of gifts are permitted according to local tradition. However, the
Company does not encourage its staff to accept gifts from business partners beyond reasonable
amounts. The provision and acceptance of gifts must not be made for influence to impair the
- The Company prohibits the provision or acceptance of gifts that include advantages in exchange
for the business treatment/agreement in return.
- The Company’s staff shall avoid providing or accepting gifts or other advantages that may
constitute bribery or raise suspicions about integrity issues or conflicts of interest which may
impact the Company’s reputation.
- The Company prohibits providing or accepting money, services, gifts, or anything of values
to/from government officials or the private sector in exchange for benefits or inappropriate
- The request and approval process for gifts must be performed in accordance with the Company’s
Announcement or guideline on gifts.
- The Company’s staff shall create and sustain organization’s culture representing that corruption
is unacceptable in every business transaction dealing with both public and private sectors. All
stuff shall raise awareness by working honesty, ethically and transparency without engaging in
fraud and corruption.
- The Company adopts a political neutrality policy and will not participate or make a political
contribution to any activities of political parties, political groups, or politicians, whether
directly or indirectly. The Company shall not allow political supporters to use the Company’s
resources or premises for political activities.
- The Company has no policy to demote or punish or mistreat any employee who denies corruption
even though it may cause the Company to lose business opportunity.
The Additional Guideline
The Chief Executive Officer has the authority to order or establish the additional guideline to align
with the Anti-corruption Policy.
Roles, Duties and Responsibilities
- The Board of Directors is responsible for establishing policies, monitoring, and forming an
effective system or guideline supporting Anti-corruption practices in order to affirm that the
Management or the Executives intensively emphasize Anti-corruption.
- The Audit, Risk and Corporate Governance Committee is responsible for revision of financial and
accounting reports, internal audit, risk management process, anti-corruption policies and
measures including reviewing the guidelines for monitoring and implementing the Anti-Corruption
Policy to ensure the appropriateness and efficiency of the internal controls.
- The Chief Executive Officer and the Executives are responsible for establishing guidelines or
implementing methods to support the Anti-corruption Policy, as well as for setting communication
channels and organizing training program relating to the Anti-corruption Policy, regulations and
implementation methods/procedures for staff, personnel and all related persons. They also are
responsible for reviewing the appropriateness of related procedures to align with any changes in
business, procedures, regulations and applicable laws.
- The Company’s staff are responsible for complying with the Anti-corruption guidelines and all
related announcements. The Company’s staff must report to their supervisor or to a designated
reporting channel, when they have any queries or encounter any suspicions of fraud or breach of
the Company’s regulations.
Procedures for monitoring risks from fraud and corruption
- Put in place the audit process, internal control and risk management systems covering key
operating systems, such as, purchasing, account recording and payment systems, etc., aiming to
prevent and monitor fraud and corruption risk.
- Set forth a risk management system suitable to the Company's business nature by identifying
risks level from fraud and corruption that may arise and establishing appropriate preventive
measures, measurement methods and resources required to mitigate the risks and evaluating the
performance under the established risk management plan.
Guidelines for Monitoring and Evaluating the Implementation of the Anti-Corruption Policy
- Internal Audit Unit is set up to oversee the internal control system, corporate governance and
to provide recommendations continuously by conducting audit in accordance with the annual audit
plan including reporting significant results with recommendations to the Audit, Risk and
Corporate Governance Committee.
- Risk Management Department is responsible for evaluating the fraud and corruption risk on a
regular basis to ensure that the Anti-Corruption Policy is implemented effectively, including
monitoring, reviewing and improving the guidelines on a continuous basis, with the assessment
results being presented to the Risk Committee and reported to the Audit, Risk and Corporate
- If there is an action that may have a significant impact on the Company’s financial position or
operations, including an offense or breach of laws or the Company’s Code of Business Conduct or
guidelines for the Anti-Corruption Policy, the Audit, Risk and Corporate Governance Committee
will report such matters to the Board of Directors.
This Policy is communicated to all levels of the employees. In addition, channels are provided for
internal whistleblowing, complaints, or suggestions as well as trainings and taking the tests to
ensure that they have sufficient understanding for complying with the Policy.
Policies and guidelines on anti-corruption are parts of the work disciplines for the Company’s
directors, executives, and employees. Negligence and ignorance to comply with the Company’s policies
and guidelines is considered breaches of discipline. Punishment will be in accordance with the
Company’s rules. However, if the act is also against the law, the Company will consider to proceed
This Anti-corruption Policy has been reviewed by the Audit, Risk and Corporate Governance Committee’s
Meeting No. 4/2020 and approved by the Board of Directors’ Meeting No. 4/2020 held on November 4,
2020 and November 11, 2020 respectively.