The Company is committed to operate its business in accordance with the principles of good corporate governance and compliance with the Code of Conduct on the basis of honesty, transparency and accountability. The Company realizes the importance of all forms of Anti-Corruption Policy. This will be the cornerstone of building confidence and trust among all stakeholders. Therefore, the Company has determined an Anti-Corruption Policy for the Board of Directors, executives, employees, and related persons of the Company to uphold and use as a guideline.
The Board of Directors, executives, employees, and related persons of the Company must strictly follow the anti-corruption policy. Without being involved in corruption in any form, type, method, directly or indirectly. The guidelines are as follows:
1. Don’t do any behavior which represents the intent the corruption. Giving or accepting bribes whether they are money, gift, gratuity, property, thing, entertainment, other benefits, having a conflict of interest, and concealing the facts or any other benefits which are contrary to morals and good ethics with government officials, government agency, private agency, or those who are directly or indirectly related. In order for such person to act or refrain from performing duties that are correct in accordance with the prescribed practice to obtain or maintain any other improper business interests or competitive advantages or for the benefit of oneself and those involved.
2. Do not neglect or ignore when seeing an action that is considered corruption related to the Company. It is the duty to notify supervisor or responsible person, and cooperate in the investigation of various facts.
3. The Company realizes the importance of promoting, disseminating, and providing knowledge and understanding to the persons who have to perform duties related to the Company or may affect the Company in matters that must be complied with the anti-corruption policy.
4. The Company will provide fairness and protection the persons who reject corruption or notify the company about corruption. By using measures to protect complainants or those who cooperate in reporting corruption.
5. Those who commit corruption are violations of regulations or business ethics, they must be considered for disciplinary action in accordance with the Company’s rules and regulation. And they may be subject to legal penalties if the act is illegal.
6. The Company provides an appropriate and efficient audit process and internal control system to prevent corruption.
7. The Company provides an assessment of the Company’s corruption risks, and establish operational measures that are consistent with that risk.
8. The Company establish rules and regulations for the approval authority in the administration that are clear, concise, appropriate, efficient, transparent and verifiable.
9. To clarify the operation in matters that have a high risk of corruption, the Board of Directors, executives, employees and related persons of the Company must perform duties with caution in the following matters:
- 9.1 Political Contributions
- 9.2 Donation and Sponsorship
- 9.3 Gift and Entertainment
- 9.4 Business Relationship and Dealings with Government Sectors
Communication and Training
The Company provides communication channels for whistle blowing or complaints about corruption or behaviors that may imply corruption of the Board of Directors, executives, and employees of the Company and related persons of the Company. The whistleblower or complainant must specify the details of the whistle blowing or complaint together with name, address, and telephone number where can be contacted; and send to the channels as specified by the Company as follows:
- Postal Channel
To Chairman of the Board of Directors or Chairman of Audit Committee
SLM Corporation Public Company Limited
No 165, The Racquet Club, Building 4, 4th Floor, Unit 401, Sukhumvit 49 (Klang) Alley, Klongton Nua Subdistrict, Wattana District Bangkok
Whistle Blowing Channel
Protection and Confidentiality Measures
To protect the rights of whistleblowers or complainants who act in good faith, the Company will conceal names, addresses or any information that can identify the whistleblower or the complainant and keep information confidential. It will be limited to those who are responsible for the investigation of complaints that can access the information only.
In the case of complaints about corruption of the directors of the company, audit committee or executive; the Board of Directors appoint an intermediary. The directors who are involved will not have the right to receive information. The company will protect the whistleblowers or complainants, witnesses and persons who provide information in investigation of facts; not to suffer any harm or injustice arising from whistle blowing, complaints, witnessing or providing information.
Investigation procedures and penalties
When receiving a whistle blowing, the Audit Committee will assign internal auditors or appoint a committee to investigate facts and report the results of the investigation to the whistleblower or the complainant periodically.
If the fact investigation found that information or evidence available, there is reason to believe that the accused actually committed corruption. The Company will give the accused person the right to be informed of the allegation and to prove himself. By seeking additional information or evidence demonstrating that they are not involved in the corruption.
If the accused has actually committed such corruption, the perpetrators of corruption are subject to disciplinary action according to the regulations set by the Company.