Anti-Corruption Policy
Sivarom Real Estate Public Company Limited (“the Company”) is committed to conducting its business with honesty, transparency, fairness, and in accordance with the principles of good corporate governance. Therefore, the Company has established this Anti-Corruption Policy as a guideline for Company Personnel to adhere to and apply in their work practices.
1. Definition
“Corruption” refers to bribery in any form, including:
1. Giving, offering, promising, or agreeing to give; and
2. Receiving or demanding;
money, assets, or any other improper benefits to or from government officials, private entities, or persons responsible for related matters, whether directly or indirectly, in order to induce such persons to perform or refrain from performing their duties, thereby obtaining or retaining business or any other improper business benefits. This excludes cases permitted by applicable laws, regulations, notifications, rules, local customs, traditions, or accepted business practices.
“Company Personnel” refers to directors, executives, and employees at all levels of the Company.
2. Policy
The Company does not accept any form of corruption, whether directly or indirectly, and requires all Company Personnel to strictly comply with the Anti-Corruption Policy as follows:
2.1 Company Personnel shall not engage in or participate in any form of corruption, whether directly or indirectly.
2.2 Company Personnel shall exercise caution regarding the giving or receiving of gifts, assets, or any other benefits. The giving or receiving of gifts and hospitality shall be solely for business purposes, be of reasonable value, and shall not materially influence decision-making.
2.3 Promote an organizational culture based on honesty and fairness.
2.4 Provide training programs for employees to promote honesty and integrity in the performance of their duties and encourage them to strictly apply the principles and code of conduct under the Corporate Governance Policy as guidelines for operations throughout the organization.
2.5 Establish effective and appropriate internal control systems and risk assessment processes on a regular basis to prevent corruption, and review and assess operational risks that may lead to corruption at least once a year.
2.6 Establish transparent and accurate financial reporting mechanisms in accordance with internationally accepted accounting standards.
2.7 Implement human resource management processes that reflect a commitment to anti-corruption measures, including recruitment, training, performance evaluation, compensation, and promotion.
2.8 Provide communication channels through which Company Personnel may report information, suggestions, and complaints relating to corruption, together with measures to protect whistleblowers.
2.9 Conduct operations in compliance with laws relating to anti-corruption.
2.10 Cooperate with government authorities in requiring all entities contracting with the public sector to disclose statements of income and expenditure to the National Anti-Corruption Commission (NACC).
2.11 Any act that violates or fails to comply with this Policy, whether directly or indirectly, shall be subject to disciplinary action in accordance with the Company’s regulations or may be subject to legal penalties.
Company Personnel are required to understand and comply with the Anti-Corruption Policy at every stage of their work. If any act that may be considered contrary to this Policy is identified, it shall be reported to the employee’s supervisor or the responsible department/person designated by the Company.