Anti-Bribery and Corruption Policy

Thai Union Group Public Company Limited has been certified by the Thai Private Sector Collective Action Against Corruption (CAC) since 2018. On 31 March 2024, the company received its second renewal certification which is continuously certified. This certification demonstrates that the company has comprehensive anti-bribery and corruption policy, guideline and governance measure for preventing corruption and strictly complies with the policy, guideline and measure as mentioned.

Intent

Thai Union Group Public Company Limited (“the Company”) is committed to conducting our business in a transparent, ethical and lawful manner. With this commitment, the Company has prepared this Anti-Bribery and Corruption Policy (the “Policy”) to compliance with laws of Thailand as well as line with international standard, along with the prevention guidelines related to against bribery and corruption which are generally acceptable in order to ensure that the Company, Board members, Management or Employees are comply with related anti-bribery and corruption laws rules and regulations.

The Company shall take all necessary actions against bribery and corruption in whatsoever forms, covering all of our business transactions at in any related business levels and business units worldwide. Hence, the Company has adopted the Anti-Bribery and Corruption Policy and its guidelines which provides strict guidelines. Additionally, the process of reviewing our policies and procedures is regularly implemented by the Company on a periodic basis to ensure that our guidelines shall be kept up to date and aligned with current business conducts as well as changing laws, rules and regulations to which the Company is subject, and to ensure that our integrity and ethical business conduct is upheld. All of the board members, management and employees shall strictly comply with this Policy and shall communicate in respect of the policy to external stakeholders to prevent any bribery and corruption-related risks.

Any corrupt activities of the Company’s personnel shall be considered as serious violation of the Company’s disciplinary rules and anyone who violates this Policy and Code of Conduct shall be subject to disciplinary action in accordance with the company’s rules and regulations.

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

Definition

Bribery means offering, promising, giving or accepting money, property or anything value to person either direct or indirect, with intention of persuading that person to wrongfully perform or not perform to avoid an action violating laws, rules, regulations or immoral which is illegal and affecting the trust towards the company.

Corruption means any action, omission of duty or wrongful misconduct of entrusted power of any forms as employees, representatives, or other relationships acting on the behalf of the Company in order to gain illegal advantage for themselves, organizations and/or the others including the Company’s rules and regulations and guidelines.

Bribery and corruption can take many forms, including the provision or acceptance of:

  1. A. Political Contributions
  2. B. Charitable Contributions and Sponsorships
  3. C. Facilitation Payments
  4. D. Gifts and Hospitality
  5. E. Cash or cash equivalent
  6. F. Travel expense for leisure that are not related to business matter

Facilitation Payments means small payment made to Public Officials to expedite routine or necessary actions which they are already required to perform as usual.

Political Contributions means to provide monetary or any support for political parties, individual politicians or political candidates i.e. giving things or advertising in order to support political parties or the person who works related to political included donating or borrowing equipment included the Employees donating their time during working hours.

Embezzlement means to take money and other property that belongs to the Company by a person with responsible to take care of or manage for the Company’s work for personal own use or for other persons or other unauthorized purposes.

Public Official means state official, government official, foreign public official or official of a public international organization as stipulate in Section 4 of the Act supplementing the Constitution Relating to the Prevention and Suppression of Corruption, B.E. 2561.

Third Parties means agents, advisors, joint venture partners or other intermediaries, whether individuals or entities, who deals with the Public Official on the Company’s behalf.

Policy Statement
  1. The Company has adopted a zero-tolerance policy towards bribery and corruption and comply with the anti-bribery and corruption laws everywhere it does business. The Company will not be a party to any illegal practices or unethical behavior, either directly or indirectly and committed to implementing with enforcing effective system to counter bribery and corruption.
  2. Employees are prohibited from engaging in acts of corruption, paying bribes to or accepting bribes from Public Officials or private individual either directly or indirectly.

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