Corporate Governance Policy | Octagon Interactive

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Fair Operating Practices Policy

Octagon Interactive Co., Ltd. is committed to developing products and providing services with a strong awareness of safety for life, property, and the environment. We uphold honesty, fairness, care, and responsibility while delivering high-quality products and services based on professional ethics, standards, and legal requirements from the initial stages through to delivery.

Guidelines for Practice

Conduct business under fair and transparent competition without exploitation.
Value free trade competition within the framework of fair competition rules, following clear, transparent, and just procedures.
Do not distort information or use any tactics to attack competitors.
Avoid dishonest practices, defamation, or spreading false news.
Do not enter into agreements with competitors or any parties that reduce or restrict competition.
Company personnel must be cautious when interacting with competitors and their staff, ensuring that company secrets are not disclosed or negligently exposed to competitors.
Provide advice, product recommendations, services, and tools suitable for the customer’s or partner’s business, adhering to established standards, and clearly specifying details in contracts as agreed.
Maintain the confidentiality of customer and partner information.

Anti-Corruption Policy

The company is committed to conducting business with honesty, fairness, and responsibility toward society and all stakeholders. It adheres to good corporate governance principles, ethics, business codes of conduct, and the company’s work regulations, as well as strictly complying with both governmental and private sector regulations. The company oversees the establishment of anti-corruption policies and practices, including training, promoting, and instilling knowledge among employees about the company’s anti-corruption policies and procedures. This includes fostering a culture that prohibits bribery for business gains and emphasizes performing duties with integrity. The company also regularly monitors the implementation to prevent risks of corruption.

“No directors, executives, employees, or staff of the company shall use their authority, directly or indirectly, to seek benefits for themselves or others, including offering unlawful incentives to others for the company’s business advantage. The company conducts regular monitoring, audits, and corruption risk assessments at least once a year, as well as reviews procedures and operational requirements to ensure alignment with changes in business, regulations, rules, and legal requirements.”

Furthermore, the company communicates and provides knowledge to all personnel through information technology systems, announcements, and training to build understanding of regulations, practices, and responsibilities, ensuring everyone in the organization and relevant parties is informed and acts under the same policy.

Guidelines for Practice

Directors, executives, and employees at all levels must comply with the anti-corruption policy, ethics, and business conduct codes, including policies and practices related to various stakeholder groups, relevant company regulations and manuals, as well as any other guidelines the company may establish in the future. They must not be involved in any corruption, whether directly or indirectly.
Employees must not neglect, ignore, or be indifferent when witnessing acts that may constitute corruption related to the company. They must immediately report to their supervisors or responsible persons and cooperate in any investigations. In case of doubts or questions, employees should consult their supervisors or designated persons responsible for monitoring compliance with business ethics through the channels specified by the company.
This anti-corruption policy covers human resource management processes including recruitment, training, performance evaluation, promotion, and compensation. Supervisors at all levels must communicate and ensure understanding among their subordinates, oversee effective compliance, and serve as role models in honesty, integrity, ethics, and professional conduct.
In matters that may pose a risk of corruption, directors, executives, and employees at all levels must act with caution regarding issues such as accepting or giving gifts, hospitality, donations, business relationships, procurement, etc., in accordance with criteria set forth in the business code of conduct.
The company prioritizes training, dissemination, and understanding of the policy through orientation for new employees, announcements, emails, the company website, or other appropriate methods for all employees and any other persons involved with the company, ensuring continuous awareness of the anti-corruption policy and practices.
The company is committed to fostering employee awareness and maintaining an organizational culture of honesty, ethics, professionalism, and opposition to corruption in all operations.
The company monitors and reviews compliance with the policy, conducts risk assessments at least once a year, and reviews practices and procedures to align with changes in business, regulations, and legal requirements.
This anti-corruption policy covers all activities related to the company’s operations.

Conflict of Interest Policy

The company conducts its business with transparency and accountability, prioritizing the best interests of all stakeholders while adhering to legal and ethical standards. It avoids actions that may cause conflicts of interest which could affect any decision-making. Accordingly, guidelines have been established for directors, executives, employees, and related parties to follow and comply with.

Guidelines for Practice

Actions that conflict with the interests of the company or compete with the company’s business, or any work outside the company’s business, should be avoided.
One must adhere to doing what is right and lawful, not performing duties improperly or neglecting duties to gain undue benefits for oneself or others, nor intend to cause harm to others.
Avoid seeking personal gain from information obtained through one’s position, duties, work, or responsibilities, as this constitutes taking advantage of the company’s stakeholders.
Personnel involved in procurement operations and approval of budgets/projects must immediately disclose any personal interests or related parties involved when transactions arise, so the company can review transactions that may involve conflicts of interest. The management and the executive board shall acknowledge and regularly review such interests annually.
Avoid conducting transactions with persons who may have conflicting interests with the company. If necessary, such transactions may be conducted only with prior report and approval from the company’s board of directors. The approval must consider the benefits, fairness, reasonableness, normal business practices (fair and at arms’ length transactions), and market prices for procurement, which can be compared with prices from external parties.
Employees should avoid holding shares in competing businesses if such ownership causes them to act or neglect to act according to their duties or negatively affects their work responsibilities.
Employees must disclose to the company if they or their family members hold shares in any business that could cause conflicts of interest or business conflicts with the company, regardless of whether the shares were acquired before employment or inherited.
Employees should avoid using work time to search for information, contact, or trade securities or assets for personal benefit or for others, unless it benefits the company.
The company disseminates knowledge and understanding from the time personnel begin their duties and regularly reviews and audits policies to prevent misuse of inside information for personal or others’ improper gain.

Human Rights and Labor Practices

The Company recognizes and acknowledges the importance of respecting human rights with equality and fairness, taking into consideration human dignity and individual freedom. The Company does not discriminate based on origin, race, nationality, skin color, gender, age, language, religion, culture, class, disability, marital status, physical or health condition, personal status, economic or social standing, social beliefs, education, political opinions, or any other differences, in accordance with the fundamental principles of international human rights law, which must be strictly adhered to in the Company’s policies.

Guidelines for Practice

Provide equal opportunities for all executives and employees, including employees of subsidiaries, in their work under the same lawful rules, regulations, announcements, and orders of the Company.
Emphasize labor rights by treating employees fairly in accordance with labor laws and related regulations.

Ensure equality in all aspects of employment processes, including recruitment, compensation, working hours and holidays, task assignments, performance evaluations, training and development, career planning, and more, without discrimination.
Refrain from any form of violation or harassment, whether verbal or physical, and do not engage in discriminatory or exclusionary practices.
Promote awareness and a sense of rights, duties, and responsibilities among all personnel toward others and society.
The Company does not employ forced labor or illegal child labor and prohibits punishment involving threats, harassment, or any form of physical or psychological violence toward personnel.
Provide fair, appropriate, and equal compensation and benefits based on individual abilities.
Maintain a good working environment, including providing necessary equipment to prevent work-related hazards.
Encourage and support employees to receive regular training, both internal and external, to learn new techniques, build professional expertise, and enhance work potential and efficiency, contributing to comprehensive and sufficient customer service in all processes.
Provide safety systems and equipment as required by law for employees, customers, and the community to prevent harm that may arise from operations or impact lives, property, the environment, and customer reputation.
Support employees in using their capabilities in research and development to invent tools, equipment, and modern innovations that meet international standards and are practical, helping reduce service costs for both the organization and its customers.
Offer channels and opportunities for employees to file complaints or submit suggestions regarding their work via central email, company website, postal mail, online forms, or the Company’s Human Resources Department, while ensuring the confidentiality of the complainant.

Employee Management Policy

Principle

Octagon Interactive Co., Ltd. recognizes that employees are valuable assets and the core driving force behind the organization’s success and sustainable growth. Therefore, the Company places great importance on treating employees fairly and respectfully, based on human rights principles. We emphasizes the promotion of participation and appreciation of individual differences to create value for employees and inspire them to reach their full potential.

The Company’s employment and labor management policy is aligned with human rights standards under the labor laws of the countries in which it operates, international standards upheld by the Company, its management policies, and the Company’s Code of Conduct.

Scope

This policy applies to the business operations of Octagon Interactive Co., Ltd. It is also communicated to the Company’s business partners for adaptation and implementation in their own operations, promoting the participation of all stakeholders in the supply chain to respect human rights.

Definitions

Company means Octagon Interactive Co., Ltd.
Employee means all employees of Octagon Interactive Co., Ltd. who perform duties under an employment contract in any position.
Business Partner means suppliers of goods/products and services, including labor and service contractors.
Child Labor means labor performed by individuals under 18 years old but above the minimum legal working age.
Forced Labor means work performed involuntarily by a person through methods or reasons involving punishment, coercion, threats, or intimidation, resulting in the person working unwillingly or being unable to resist.

Guidelines for Practice

To promote a good quality of life and foster employee loyalty to the company based on fair treatment and mutual respect, the company has established the following guidelines:

Child Labor
The company will comply with laws regarding the minimum employment age and will not allow underage workers to perform work that is hazardous to their health, development, or compulsory education.
Forced Labor
The company will not engage in or support any form of forced labor and will not charge fees or withhold employees’ personal identification documents unless done legally.
Non-Discrimination
The company respects diversity and treats employees equally without unfairly benefiting or depriving rights based on race, nationality, ethnicity, skin color, ancestry, religion, social status, gender, age, disability, political beliefs, marital status, or other factors. Measures will be established to prevent and address sexual harassment.
Employment and Recruitment
The company hires and appoints employees according to job necessity and suitability. Recruited employees must have qualifications, experience, and competencies appropriate to the position and meet company regulations. When vacancies arise, current employees will be given priority for selection before hiring externally.
Compensation
The company pays wages, allowances, and benefits in accordance with labor laws and on time. Salary deductions occur only as legally permitted. Compensation is managed fairly considering qualifications, experience, position, responsibilities, local market wage comparisons, and company needs. The company follows equal pay principles for equal work regardless of gender.
Benefits
The company ensures employees have good health to work efficiently, providing welfare benefits comparable to similar industries or as required by law.
Working Hours
Normal working hours do not exceed legal limits. Overtime is managed according to legal requirements.
Freedom of Association and Collective Bargaining
The company respects employees’ rights to freely associate or form groups legally and to participate in bargaining processes according to law.
Safety, Occupational Health, Environment, and Facilities
The company continuously promotes and maintains a safe work environment that protects employee health and minimizes environmental impacts from its activities in compliance with laws. It provides clean and hygienic toilets, drinking water, first aid supplies, dining areas, and proper food storage facilities.
Protection of Pregnant Workers
Pregnant employees will be assigned safe work during appropriate periods, avoiding risks to themselves or their unborn children. The company will not dismiss, demote, or reduce benefits due to pregnancy.
Discipline and Punishment
The company prohibits inappropriate verbal punishment, physical punishment, coercion, intimidation, or physical harm to employees.

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Safety, Occupational Health and Working Environment Policy

The company upholds safety, occupational health, and the working environment as fundamental responsibilities and key factors for the organization’s sustainable growth. Therefore, it has established policies that promote a safe working environment, particularly for employees, in compliance with relevant legal requirements. The company is committed to operating efficiently and continuously improving (Continual Improvement) toward excellence by adhering to the principles of good corporate governance, earning the trust and acceptance of stakeholders.

Overall Policy on Safety, Occupational Health, and Working Environment

1. All employees must strictly follow the 5S principles for workplace safety to prevent accidents and work-related illnesses:

Sort (Seiri): Separate necessary and unnecessary items; remove unnecessary ones.
Set in Order (Seiton): Store tools and equipment in accessible and safe locations.
Shine (Seiso): Maintain cleanliness and organize the workplace.
Standardize (Seiketsu): Keep the workplace orderly and hygienic at all times.
Sustain (Shitsuke): Practice and instill the 5S principles until they become habitual.

2. The company sets it as policy that all supervisors must act as role models and are responsible for ensuring the safety, occupational health, and working environment of their subordinates in strict compliance with company rules and regulations.

3. All employees are responsible for performing their duties in a way that ensures the safety of themselves and their colleagues, by strictly following the company’s safety, hygiene, and environmental regulations.

4. The company recognizes that every employee plays a role in accident prevention and environmental maintenance. It welcomes suggestions and feedback from employees and will consider them to make improvements and correct deficiencies as appropriate to ensure the highest level of safety for everyone.

Safety Policy

Workplace safety can only be achieved through the collective cooperation and responsibility of all employees across the organization — from executives and managers to operational staff at every level. To ensure that safety management is conducted smoothly and in alignment with company objectives, the company has established the following policy:

1. The company promotes safe working practices, with safety considered a top priority and the primary responsibility of every employee in performing their duties.

2. The company encourages and supports the development of safe work methods, aiming to ensure a safe working environment by providing sufficient safety equipment and tools suited to the nature of the work. Employees are encouraged to recognize potential risks and hazards in their work, and are educated about causes and prevention methods.

3. The company conducts regular inspections around its premises and provides necessary equipment and technology to ensure the safety of lives and property.

4. The company promotes and supports various safety-related activities that help raise employees’ awareness, such as training sessions, seminars, workshops, incentive programs, safety campaigns, and safety competitions.

5. The company regularly reviews and evaluates its safety management system to develop and implement continuous improvements.

Safety Management

Each year, the company implements organizational safety initiatives through planning, activities, and training programs to ensure that employees possess the necessary knowledge and skills to perform their duties safely. The following are key components of the safety management practices:

1. Management of Unused Materials (in accordance with company regulations):

Disposal of electronic equipment
Destruction of documents

2. Basic Firefighting Training: Employees are required to attend basic fire safety training as scheduled and announced by the office building management.

3. Fire Drill and Evacuation Exercise: The company cooperates with the office building management to conduct annual fire drills and evacuation exercises, as required by law, to ensure employees are familiar with proper prevention and emergency response procedures.

4. Business Continuity Plan (BCP)

5. Incident Management Plan

6. Recovery and Disaster Recovery

Occupational Health Policy

1. The company considers the occupational health of its employees a core and vital policy.

2. The company considers the occupational health of its employees a core and vital policy.

3. The company consistently maintains cleanliness throughout the premises to ensure a hygienic and healthy environment, contributing to improved quality of work life and overall employee health.

Occupational Health Management

1. Annual Health Check-Ups
The company conducts annual health check-ups to monitor and assess the health trends of employees, enabling timely treatment or preventive action. After the check-ups, the results are analyzed to identify overall health patterns. These insights are then used to design and implement health-promotion initiatives as part of the company's annual operational plan.

2. Group Life and Health Insurance
Although employees are legally covered under the national social security scheme, the company goes further to ensure their well-being by providing additional group life and health insurance. This enables employees to receive medical treatment at any hospital within the insurance network, without being limited to their registered social security hospital, thus ensuring faster and more convenient access to care.

3. Personal Accident and Specific Disease Insurance
In response to the widespread impact of the COVID-19 pandemic, the company recognizes the seriousness of the outbreak. Beyond facilitating vaccination through the Ministry of Public Health—both via Social Security Office (Section 33) and online registration—the company also provides additional personal accident and disease-specific insurance for both office and operational staff, ensuring enhanced protection during such health crises.

Work Environment Policy

1. The company considers a good working environment for employees to be a key policy.

2. The company promotes and supports the development and improvement of the work environment.

3. The company continuously upgrades, improves, and maintains the internal workplace environment and ensures cleanliness around the company premises at all times.

Work Environment Management

1. Work Environment Measurement
The company recognizes the importance of the work environment as it may affect employees' health. Therefore, the company conducts measurements and analyzes the work environment concerning heat, lighting, and noise to comply with the Ministerial Regulations on standards for managing occupational safety, health, and work environment regarding heat, lighting, and noise (B.E. 2549). This also serves as data to improve the working conditions to ensure safety and meet legal standards. The lighting condition assessment results meet the criteria and legal standards.

2. Inspection and Maintenance of Equipment and Electrical Appliances
The company regularly inspects, repairs, and maintains equipment and electrical appliances to ensure they are always ready for use. This includes safety checks of electrical systems and appliances, which are vital for managing a safe workplace, preventing electrical accidents, and ensuring the safety of employees and the workplace.

3. Annual Big Cleaning Day Activity
All employees participate in cleaning and improving the landscape, as well as organizing their own workstations by discarding unused items or materials. This not only ensures cleanliness and orderliness but also allows employees to inspect the environment to make improvements. Additionally, it promotes teamwork among employees.

This policy applies to all departments within the company. Executives, managers, and supervisors must lead by example and take responsibility to ensure that the implementation aligns with the organization’s intentions. All employees must be informed, understand, and comply with this policy.

Whistleblowing / Complaints / Comments or Suggestions and Prevention Policy

The company values the participation of employees and all stakeholder groups. Therefore, it has established channels for reporting tips, complaints, feedback, or suggestions that benefit the company’s business operations, as well as for reporting violations of the business code of conduct or legal infringements.

Guidelines for Practice

1. Complaints / Whistleblowing Submission: Complainants or whistleblowers must provide clear contact information including their name and address. Submissions can be sent via the following channels:

Website: www.octagoninteractive.co.th
E-mail: complaint@8interactive.co.th
Mail: Octagon Interactive Co., Ltd. 919/541B Jewelry Trade Center, 49th Floor, Silom Road, Silom Subdistrict, Bangrak District, Bangkok 10500, Thailand
Phone: 02-104-9044
Online Form: https://airtable.com/appl32kmLAjOA3PKG/shrZa41uAPUJLRuCW

2. Handling of Complaints: All complaint information will be forwarded directly to the Chairman of the Executive Committee, who will consolidate and coordinate with the responsible departments to conduct fact-finding investigations. The findings will then be presented to the relevant management and executive committees for further consideration.

3. Protection Measures for Whistleblowers and Complainants: The company has measures in place to protect those who report, complain, provide feedback, or make suggestions. Whistleblowers may choose one of the following:

To remain anonymous if revealing their identity may cause insecurity or harm.
To disclose their identity, in which case the company will keep their personal information confidential and proceed with addressing the issue.

The Chairman of the Executive Committee will receive the complaint or report, conduct investigations, and report significant findings to management and the executive committee. Appropriate recommendations, remedial actions, or legal proceedings will be implemented as necessary.

Business Partner Conduct & Ethics Policy

The company has established policies and procedures for sourcing and selecting suppliers, which are disclosed transparently. Recognizing the importance of suppliers, the company purchases goods/products and services only from suppliers who comply with commercial terms and conditions, adhere to laws, regulations, and contracts fairly and transparently, and place importance on timely payment for goods/products and services.

This is to ensure that the company conducts supplier selection systematically, fairly, and transparently, while supporting suppliers who operate ethically, responsibly toward society and the environment. The company will not engage in transactions with individuals or legal entities involved in illegal activities, corruption, or behavior that indicates fraudulent conduct.

Definitions

Procurement means purchasing, contracting for goods, contracting for services, transportation contracting, leasing, and hire-purchase.

Supplier means sellers, distributors, contractors, service providers, lessors, or hire-purchase providers who deliver goods/products or services to the company, whether they are legal entities or natural persons.

Guidelines for Practice

The company shall conduct procurement in a systematic manner, following the company’s procurement regulations and controlled procedures. It will consider requirements regarding quality, price, quantity, timing, service, delivery, after-sales service, warranty, and other conditions, without conducting transactions with individuals or legal entities involved in illegal activities, corruption, or suspected corrupt behavior.

The company shall neither request nor accept or pay any commercial benefits to or from suppliers dishonestly. It will strictly comply with contracts, agreements, and conditions with suppliers. In cases where compliance is not possible, the company will promptly notify the supplier in advance to jointly consider solutions reasonably.
The company will appropriately manage or prevent conflicts of interest related to its business operations and will not seek any unlawful benefits or violate governmental regulations.
The company shall not engage in any acts infringing intellectual property rights and will promote executives and employees to use company resources and assets efficiently. It will use legitimate licensed products and services and will not support the use of goods or services that violate intellectual property rights.
The company strictly adheres to commercial agreement terms to ensure transactions meet standards.
Payments to suppliers shall be made on time according to the agreed payment conditions.

Supplier Selection Criteria

1. Background Verification: The supplier must be a manufacturer, operator, distributor, dealer, service provider, or contractor with verifiable business premises. The supplier must not be listed as prohibited from conducting business due to fraudulent activities.

2. Past Performance Evaluation: The supplier should have qualified personnel, machinery, equipment, products/services, warehouse facilities, and sound financial standing. The supplier’s track record must be reliable with satisfactory past performance. The company will evaluate based on product/service quality, timely delivery, after-sales service, warranty, and other transaction conditions.

3. The supplier must not have any conflicting interests with the company’s business.

4. Fair Employment and Labor Management: The supplier shall employ labor fairly without using workers under the age of 18 or illegal foreign labor. Basic human rights must be respected.

5. The supplier must adhere to anti-corruption policies and refrain from any corrupt practices.

6. The supplier should have an established environmental management system in place.

7. The supplier must provide training related to safety, occupational health, and environmental aspects relevant to the nature of their work.

All suppliers of Octagon Interactive Co., Ltd. must agree to comply with the company’s Supplier Code of Conduct.

Supplier Code of Conduct

Octagon Interactive Co., Ltd. is committed to conducting business with transparency, integrity, in compliance with the law, good corporate governance principles, and sustainable development guidelines. The company focuses on fostering a strong awareness of responsibility towards the economy, society, and the environment. Therefore, it has established the Supplier Code of Conduct as a guideline for business operations that align with legal requirements, the company’s code of ethics, and international standards. The company places great importance on and supports its suppliers to conduct business transparently, respect human rights, treat labor fairly, comply with safety, occupational health, and environmental standards, and strictly monitor compliance with this code of conduct.

Definitions

Company means Octagon Interactive Co., Ltd.

Supplier means a seller, distributor, contractor, service provider, lessor, or hire-purchaser who delivers goods/products or services, whether as a legal entity or an individual, to the company.

Scope and Practices

Integrity and Ethics
Suppliers must not engage in or tolerate any form of corruption. They must not offer gifts, money, bribes, fees, services, discounts, special privileges, or any benefits to the company’s employees or their families to gain special favors. Giving modest gifts or hospitality during appropriate occasions or festivals is allowed only if it does not create any obligation or be perceived as a burden.
Respect for Human Rights and Labor
Suppliers must not discriminate or exclude workers based on race, skin color, religion, gender, age, nationality, citizenship, sexual orientation, disability, or any other factor. They must not engage in or support forced labor, harassment, or intimidation in any form. If employing pregnant women or foreign workers, suppliers must comply fully with labor laws. Working hours must not exceed legal limits; overtime must be voluntary, with proper holidays and leave as per law. Wages, overtime pay, holiday pay, and other benefits must be fairly and timely paid, at rates not below legal requirements. Employment standards must be clear and compliant with legal and regulatory requirements.
Conflict of Interest
Suppliers must avoid any business, financial, or other relationships with company employees that could be perceived as a conflict of interest. Company employees are prohibited from holding managerial, director, employee, agent, or consultant positions at suppliers unless approved by the board of Octagon Interactive Co., Ltd. Suppliers must disclose and resolve any current or potential conflicts of interest.
Confidentiality
Suppliers must not disclose or use any commercial, financial, or other confidential information related to the company or its customers for personal gain or third parties without explicit permission. Any breach causing damage is the sole responsibility of the supplier.
Respect for Intellectual Property Rights
Suppliers must respect the company’s intellectual property rights, avoiding misuse or misappropriation unless properly authorized. They must implement appropriate measures to prevent unauthorized disclosure or use of such intellectual property.
Compliance with Laws and Safety Standards
Suppliers must provide a safe, hygienic working environment that supports effective work and comply with all relevant laws and regulations. They must ensure safe operating procedures to prevent accidents and health impacts arising from work.
Environmental Responsibility
Suppliers must conduct business with environmental responsibility, complying with all related laws, regulations, and standards. They should operate in an environmentally friendly manner, minimizing pollution and resource waste, and promote sustainable use of natural resources.

The Company expects all suppliers to uphold and strictly adhere to the Business Code of Conduct, with a strong commitment to ethical, transparent, and auditable business operations, including zero tolerance for all forms of corruption. Suppliers must also promote fair competition, ensure occupational health and safety, and contribute to sustainable mutual growth.

The supplier hereby confirms that they have thoroughly read, understood, and agreed to comply strictly with all terms outlined in this Code of Conduct. As evidence of this commitment, the undersigned has duly signed and affixed the company seal below.

Gifts and Benefits Policy

The Company operates under the principles of good corporate governance and business ethics, emphasizing transparency and equal treatment of all stakeholders. The Company avoids any actions that may lead to discrimination or conflicts of interest. In alignment with its anti-corruption policy, the Company has established a No Gift Policy regarding the giving and receiving of gifts, entertainment, or any other benefits. This policy aims to uphold a high standard of transparent and efficient business practices, contributing to sustainable and dignified growth.

Principle

All personnel of the Company must strictly uphold the commitment not to give or accept bribes or any other form of benefits to or from Company personnel or external parties, especially government officials. If it is proven that such actions have occurred, the personnel involved will be considered in violation of both the Company's regulations and applicable laws.

Guidelines for Practice

1. Giving of Gifts, Souvenirs, or Other Benefits

1.1. Giving gifts or souvenirs in accordance with customary practices (i.e., special occasions such as festivals, important days, or social etiquette such as congratulations, appreciation, welcoming, condolences, or assistance) may be carried out if not in violation of any applicable laws or local customs. In Thailand, the value should not exceed 3,000 THB per person per occasion, according to the announcement by the NACC (National Anti-Corruption Commission). The gift should help enhance the Company's image and may include:

1.1.1.) Calendars, cards, diaries, notebooks, pens, stationery

1.1.2.) Promotional products bearing the Company’s logo, products, or brand identity

1.1.3.) Royal project products, community products, charity items, or items supporting sustainability
1.2. Gifts or souvenirs should be handled consistently across all cases to prevent discrimination.
1.3. Gifts, souvenirs, properties, or other benefits must not be given to spouses, children, or associates of government officials, clients, partners, or business contacts, as it may be deemed as indirect receipt.
1.4. For significant business events (e.g., company establishment day or contract signings), the Company may send cards or flowers as congratulations on its behalf, without additional gifts. If a souvenir is necessary, any gift over 3,000 THB must receive approval from the top executive of the Company or as per Company regulations.
1.5. For hospital visits, a health-oriented fruit or vegetable basket not exceeding 1,000 THB may be given on behalf of the Company.
1.6. For expressions of condolences, wreaths or flower arrangements may be sent based on the religious ceremony, not exceeding 1,000 THB on behalf of the Company.

2. Business Hospitality

Reasonable business hospitality, such as meals, beverages, sporting events, or other business-related activities that foster understanding or support business operations, may be accepted. However, such activities must be reasonable and must not influence decision-making or create a conflict of interest.

3. CSR Activities with Government Agencies or Officials

3.1. CSR activities in collaboration with government agencies or officials may be conducted under the Company's name and must align with the Company's CSR policy. There should be clear criteria, planning, and measurable objectives, following Company procedures.

3.2. CSR or any Company-sponsored activity must not involve political support.

4. Receiving Gifts, Souvenirs, or Other Benefits

4.1. Company personnel must refrain from accepting any gifts, souvenirs, or benefits and are responsible for clearly communicating the No Gift Policy to external parties.
4.2. Personnel involved in procurement must reject all forms of gifts in all situations.
4.3. Employees must politely decline gifts without causing offense or damaging relationships, and clearly explain the Company's firm intention to uphold good governance.
4.4. If it is absolutely necessary to receive gifts or benefits that cannot be returned, the Company will assign a responsible unit to collect the items for donation or use in line with Company policy, except:
4.4.1. For consumables with a shelf life of less than one month, department heads may use discretion in handling them.

4.4.2. Company-branded calendars, cards, diaries, notebooks, pens, or stationery may be accepted as personal gifts.

4.4.3. Gifts or souvenirs received on behalf of the organization (e.g., during business contract signings) are considered Company property.

5. Invitations for Meetings, Training, Seminars, or Site Visits Sponsored by Business Partners

5.1. Acceptance is allowed if part of a contractual agreement and not disguised as leisure travel.
5.2. If not contractually specified, such offers may be accepted if beneficial and appropriate for the Company, with prior approval from supervisors and in accordance with Company policies.
5.3. Training or seminars with hidden tourism agendas and lacking genuine educational intent must not be accepted.

6. Sponsorship of Travel and Other Expenses for Government Officials

The Company may sponsor such expenses when appropriate and in line with applicable internal regulations.

7. Donations and Sponsorships to Government Agencies, Officials, or Charities

7.1. Donations or sponsorships must meet the following conditions:
7.1.1. Made to credible and legally established organizations.

7.1.2. Conducted under the Company's name, transparently and legally, and in accordance with Company policies.

7.1.3. Payments should not be made directly to government officials or individuals unless explicitly stated in a formal request with written proof of receipt.

7.1.4. There should be monitoring and verification to ensure that donations or sponsorships are used for public benefit and align with the intended objectives.

Company personnel must understand and comply with the policy on giving and receiving gifts, hospitality, or any other benefits. If there are any questions or concerns, please contact the Company’s Human Resources Manager.

Employees and Practice to Other Employees

The Company promotes and encourages employees to conduct themselves within the framework of ethics and good moral principles, upholding professional ethics as a priority and serving as a good role model for others. This includes treating colleagues with courteous and respectful manners, kindness, good interpersonal relationships, and mutual support. Employees are expected to collaborate in building and developing the Company towards progress and prosperity for the collective benefit.

Guidelines for Practice

Employees should perform their duties with dedication, honesty, integrity, transparency, and be trustworthy.
Employees should conduct themselves with ethics and professional integrity, with consideration for the safety of themselves and their colleagues.
Employees should respect the rights and responsibilities of their colleagues, subordinates, and supervisors.
Employees should be disciplined and comply with the organization's rules and regulations, as well as good traditions, whether formally documented or not.
Supervisors should conduct themselves in a manner that earns respect and serve as good role models for employees, and employees should refrain from any actions that show disrespect towards their supervisors.
Employees should foster and maintain an atmosphere of unity and harmony among colleagues, and avoid any actions that may impact the company’s reputation or potentially cause issues for the company in the future.
Avoid disclosing or criticizing information or stories about other employees, whether work-related or personal, in a manner that could cause harm to the employee or the company’s overall image.

Treatment of Employees Policy

The company establishes policies and regulations in accordance with the basic rights that employees are entitled to receive, including other rights that the company should provide assistance for, and compensation that aligns with the company’s performance both in the short and long term, appropriately and fairly. In addition, the company promotes and instills in all employees strict compliance with rules, regulations, standards, and relevant laws concerning anti-corruption.

Guidelines for Practice

The company sets appropriate and fair compensation and benefits based on each employee’s ability, responsibility, and job performance, and ensures timely payment. In addition, special compensation is provided according to the company’s performance, both short-term and long-term, such as annual performance evaluations and development of knowledge and skills in line with the company’s strategic plan.
The company grants the basic rights to employees as stipulated in company regulations and relevant laws. The company treats employees with respect for their personal rights and dignity, does not violate human rights, and does not discriminate based on gender, age, ethnicity, religion, social status, or illness.
The company provides a good working environment, including rest areas and knowledge corners, as well as safety systems and equipment according to regulations and laws to protect employees from workplace hazards.
The company encourages and supports employees to receive regular and comprehensive training both internally and externally to learn new techniques and build professional expertise, thereby enhancing their work efficiency and capabilities. Opportunities are also provided for employees to develop various work skills for growth in their specialized career paths.
The company supports employees’ ability to research and develop to invent, create tools, equipment, and new innovations that meet international standards and are practically usable.
The company appoints, transfers, rewards, and disciplines employees fairly and equally, based on knowledge, ability, suitability, and the employee’s conduct.
The company promotes employees’ understanding of ethics and roles to foster behavior that adheres to ethical standards throughout the organization.
The company encourages employees to participate in setting work directions and solving departmental problems jointly with the company. Every employee must perform their duties responsibly with honesty, integrity, ethics, and professionalism, not shirking tasks or delegating duties to others unless necessary or for efficiency in specialized work.
The company provides opportunities for employees at all levels to file complaints or offer suggestions related to their work via email, mail, or the Human Resources department, maintaining confidentiality of complainants and giving attention to all suggestions that benefit the organization.