SG Capital Public Company Limited is committed to conducting business under ethical code, transparency and awareness of the importance of anti-corruption practices for fraud and corruption of all forms, directly or indirectly, monetary or non-monetary. Anti-corruption is considered a principle and a responsibility of employees and executives at all levels so that they perform their duties with morals, good citizenship and anti-corruption mindset to prevent corruption at work including bribery. The Company also places importance on supporting efforts in fostering strong mindset, values, morals and ethics and cultivating organization culture that everyone realizes the danger of corruption. Therefore, the Company has issued this Anti-Corruption Policy to effectively combat corruption which will help elevate Thailand’s image on transparency to meet international standards.
1. Set policies and practices to fight against corruption of all forms both inside and outside organization by complying with related laws and regulations such as disclosure and reporting of key events of the Company and accurate, transparent and timely financial statements.
2. Prepare a clear work manual based on internal control systems and ensure a proper audit by the Internal Audit Unit on a regular basis while financial statements are audited by external auditors who are independent and certified by the Securities and Exchange Commission to prevent and eliminate corruption issues in the organization.
3. Supervise business operations of the Company and group of companies to ensure no involvement in corruption without paying money to gain business unfairly while bribery is not tolerated.
4. Review practices and related rules to be consistent with changes in business, rules, regulations and legal requirements.
1) Corruption
2) Policy
3) Definitions
4) Duties and Responsibilities
5) Practical Measures
6) Communication of Anti-Corruption Policy
7) Political Contributions
8) Charitable contributions, Donations and Aid Grants
9) Sponsorships
10) Whistleblowing
11) Whistleblowing Channels
12) Penalties
An action or inaction in performing duties or abuse of entrusted authority of a position including a violation of law, ethics, rules or the Company’s policies to seek undeserved benefits in various forms such as solicitation, acceptance, proposal or offering of assets and any other benefit to government officials or any other person doing business with the Company.
4.1 The Board of Directors is in charge of formulating, supervising and approving the Anti-Corruption Policy for all forms of corruption, directly and indirectly, to ensure that the Management prioritizes anti-corruption and enforce the Anti-Corruption Policy as a part of the organization culture, The Board also delegates the Management to adopt anti-corruption measures as internal guidelines to perform duties efficiently.
4.2 The Audit Committee has a duty to audit and review financial reporting systems, internal control systems and internal audit systems to ensure that they meet international standards and are precise, appropriate, up-to-date and efficient so that the Company has adequate corporate governance consistent with its related policies, rules and legal requirements.
4.3 In case that the Audit Committee finds out or has doubts about a transaction or an action that may significantly impact financial status and operating performance of the Company including corruption, the Audit Committee will report to the Board of Directors for corrective actions.
4.4 CEO and the Management have a duty to put in place a system to enforce and support the Anti-Corruption Policy and to communicate with employees and all related units including reviewing suitability of systems and measures to be in line with changes in business, rules, regulations and legal requirements.
4.5 Internal Audit Unit is responsible for auditing and reviewing operations of all business units in the organization to be in compliance with policies, practices, authorities, regulations, laws and rules of each unit to ensure effective internal control systems and evaluation properly and adequately under corporate governance principles to be able to control potential corruption risks and report to the Audit Committee.
4.6 Employees at all levels are required to comply with anti-corruption policies, practices and measures.
5.1 Directors, executives and employees have a duty to comply with the Anti-Corruption Policy while the Board of Directors assigned the Management to enforce and communicate anti-corruption measures
5.2 Directors, executives and employees who violate or fail to comply with the Corporate Governance Policy and the Anti-Corruption Policy are considered undertaking a misconduct related to work rules on human resources management. They are subject to disciplinary penalties as stipulated in the rules and may receive a legal punishment in case of unlawful actions. Note that the Company will not demote, punish or cause negative impacts to those who deny to engage in corruption even that action caused the Company to lose business opportunities.
5.3 The Company set out requisition procedures covering limit, approval authority, objectives, and recipients which require clear supporting documents and evidence to prevent corruption while audit processes are undertaken by the Internal Audit Unit.
5.4 The Company arranged an audit process for sales and marketing work including procurement and contracting to regularly monitor risks that may arise from corruption to comply with the requisition and procurement procedures while the Internal Audit Unit will provide comments and suitable solutions.
5.5 The Company ensures that human resources management processes are in place which reflect the Company’s commitment to anti-corruption measures from selection, training, performance evaluation, rewards to promotion.
5.6 The Company put in place proper internal audit to ensure that existing internal control systems help the Company achieve goals as well as being in charge of conducing audit of all business units to be in compliance with rules and regulations. Internal audit also involves finding defects and weaknesses and providing suggestions to enhance operational systems to achieve higher efficiency and effectiveness according to good corporate governance guidelines.
5.7 Internal Audit Unit reports findings promptly to the Audit Committee to directly report to the Board of Directors.
To ensure awareness and understanding of employees at all levels on the Anti-Corruption Policy, the Board of Directors conducts policy communication through multiple channels listed below.
6.1 The Company posts the announcement of the Anti-Corruption Policy on the Company’s PR bulletins.
6.2 The Company disseminates the Anti-Corruption Policy through the Company’s communication channels such as intranet, website, annual registration statements (Form 56-1) and annual reports (Form 56-2).
6.3 The Company incorporates the Anti-Corruption Policy in the employee handbook.
6.4 the Company organizes training on Anti-Corruption Policy during the orientation of new employees.
6.5 All employees must sign the form and acknowledge the content of the Code of Conduct and Business Ethics and the Anti-Corruption Policy to confirm their understanding and agreement to comply with the policies. Note that employees cannot use an excuse that they have not read or signed the form to acknowledge for their reasons for non-compliance.
6.6 The Company conducts a revision of the Anti-Corruption Policy regularly on a yearly basis. In case that one of the rules in the Code of Conduct and Business Ethics and the Anti-Corruption Policy is revoked, it must be approved by the Board of Directors and the revoked rule must be diclosed immediately.
Political contributions mean support of money or in-kind and/or participation in activities including encouragement of employees to participate in political activities on behalf of the Company with the purpose to gain business advantage. Note that this excludes the case that employees join activities according to their personal liberty and rights on the condition that they do not claim their statuses as employees or use any asset, equipment and tool of the Company for a political cause.
The Company refrains from supporting political parties, politicians or political candidates neither in forms of money nor in-kind that can be considered political contributions according to the previous paragraph with the objective to offer business benefits to the Company.
For charitable contributions, donations and aid grants, the Company has formulated related policies and rules including a review process and control details per below.
8.1 The donation must be proven that activities of charitable projects are real for the purpose of ensuring that projects achieve objectives and truly benefit the society according to the corporate social responsibility (CSR).
8.2 The donation must be proven to be solely for the charity without involvement with or any mutual benefit with a particular person or agency.
Given that sponsorships are for business, brands or the Company’s reputation which are subject to risks as they are considered payments for services or benefits that are hard to measure and monitor and the fact that sponsorships can also be linked to bribery, the Company has clearly defined rules related to sponsorships, review process and control details per following.
9.1 It is proven for that persons who request a sponsorship carry out activities according to projects to ensure that projects achieve objectives and truly benefit the society according to the corporate social responsibility (CSR).
9.2 It is proven that sponsorships or any other benefit can be calculable to monetary values such as accommodation and food.
9.3 To be a sponsor, sponsorship request form must be prepared with details of the sponsorship including objectives, enclosed with all supporting documents to be proposed to authorized persons of the Company to approve according to the Company’s approval authority.
The Board of Directors gives importance to receiving complaints. and reporting clues by giving employees an opportunity and stakeholders have channels to make complaints Leave a comment and report clues to legal violations, corruption, and accuracy of financial reports. internal control system violation of human rights Unequal treatment actions without due diligence and lack of caution Including receiving complaints regarding corporate governance and the company's business ethics. as well as the behavior of those that may indicate corruption.
Whistleblowing channels
Registered Mail :
Chairman of Audit Committee
SG CAPITAL PUBLIC COMPANY LIMITED.
72 NT Bangrak Tower, Floor 20, Charoen Krung Road,Bangrak, Bangkok 10500
E-mail address : SgcAmnesty@sgcapitl.co.th
Violators of law, rules, regulations and polices including any other codes of the Company will receive disciplinary actions after considering their intentions, contexts, impacts from the misconduct, cooperation during investigation and other actions of violators. This is to correct or prevent the same incident from reoccurring. Violators may receive disciplinary penalties from a written warning to highest disciplinary penalty which is a removal from position or termination of employment.
This Anti-Corruption Policy was considered and approved by the Board of Directors according to the resolution of the meeting of the Board of Directors No.43/2021, effective from 8 November 2021 onward with a regular revision on an annual basis.
