Anti-Corruption Policy

Intent

It is a policy of Thai Union Group Public Company Limited (hereafter referred as “the Company”) to take a firm stand against any acts of corruption, in all of our business dealings at all levels. Hence, the Company has issued the Anti-Corruption Policy and Code of Conduct for Anti-Corruption, which details strict guidelines to prevent and/or deal with any corrupt activities. Further, the process of reviewing our policies and procedures are implemented on a periodic basis, in order to make sure our guidelines are up-to-date and responsive to new developments in the current business conducts as well as changing laws, rules and regulations to which the Company is subject, and to make sure that our integrity and ethical business conduct is upheld; and by which all board members, management and employees must abide. Board members, management and employees shall perform their duty in compliance with this policy and communicate the policy to external stakeholders for corruption-related risk prevention.

Anyone who violates this Policy and Code of Conduct shall be subject to disciplinary action in accordance with the company’s rules and regulations.

In 2015, Thai Union joined “Thailand’s Private Sector Collective Action Coalition against Corruption” in order to corroborate the Company’s standpoint and emphasize on every Anti-corruption case.

More information

The Company shall provide a protection to board members, management and employees who act against corruption in accordance with this Policy and respective Code of Conduct.

Definition

Corruption is defined as

  1. Any behavior that violates one’s terms of employment through an improper use of one’s position as employee, representative, or other title acting for/on the behalf of the Company to gain a personal or other undue advantage; or,
  2. Any act of bribing* government officials and extorting and soliciting** a bribe from business partners or other parties with intent to induce a person or party to violate the laws or avoid complying with any regular legal or ethical conduct and rules and regulations that the Company promote; or,
  3. Any act of embezzling*** financial and/or other assets with which one have been entrusted by the Company, including the working hours used for a personal or other undue advantage.
* Bribery or to bribe means to offer, give, or promise a financial or other advantage with intent to induce a person or party to commit a criminal act and to avoid and/or violate any regular legal or ethical conduct and rules and regulations.
** Extortion and Solicitation means any type of threat, abuse of authority, persuasion or intimidation or any approach that is coercive in this nature to seek financial and other assets in exchange of / for a personal or other undue advantage.
*** Embezzlement means to use/withhold financial and other assets of the Company including the working hours used for a personal or other undue advantage.
Role and Responsibility
  1. Board of Directors are responsible make sure that the business conduct is transparent, accountable, and strictly in accordance with Anti-Corruption policy, respective code of conducts and procedures. The Audit Committee is responsible for
    • Overseeing internal controls both financial and operational of accounting and documenting procedures including all other anti-corruption related procedures,
    • Providing channel(s) for complaint or report of corrupt activities,
    • Providing advices on the implementations per Anti-Corruption Policy and Code of Conduct, and
    • Reporting finding(s) to Board of Directors on a regular basis.
  2. Management is responsible for implementing this Anti-Corruption Policy, including communication and awareness raising among internal and external stakeholders. Proper management systems and measures must be put in place and periodically reviewed to ensure effective governance and implementation in alignment with the intent and new developments in the current business conducts as well as changing laws, rules and regulations.
  3. Management and employees at all levels are responsible for mitigating and preventing corruption-associated risks in their assigned duties, and are responsible for reporting of corrupt activities.

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