This printed article is located at

Anti-Corruption Policy and Guidelines


Anti-Corruption Policy

“The Company’s directors, executives and staff members are prohibited from supporting corruption or accepting corruption of all sorts, for one’s own direct or indirect benefits, or for one’s family members, friends, acquaintances, regardless whether one is the receiver, giver or offer of the bribes; monetary or non-monetary, to individuals, government officers, government bodies or private sector organizations that deal businesses with the Company. This includes businesses of subsidiaries, associates or other companies with the authority, and the anti-corruption protocols must be strictly observed. The responsible party structure and risk management system should be established, as well as the internal control and internal audit systems to prevent and suppress dishonest acts or organizational corruption, as well as to review the practices and operational regulations to align with changes in the business, regulations and the laws.”

Anti-Corruption Guidelines

  1. Directors, Management and Employees at all levels must follow The Anti-Corruption Policy and The Code of Conduct by not involving with any courses of corruption both direct or indirect manner and not performing any act in the manner that may cause others to believe that they hold position or duty while actually they do not hold such position or duty.
  2. Employees are not supposed to neglect upon witnesses of corruption-prone behaviors relevant to the Company but instead inform supervisors or assigned individuals to obtain cooperation in the scrutiny process. In case of doubts or questions, one can consult with one’s direct supervisor or assigned individual regarding the Company’s Business Code of Conduct via different channels available.
  3. The Company will ensure justice and protection for employees denying or reporting acts of corruption relevant to the Company. Protection measures will be imposed upon those who file complaints and cooperate in reporting acts of corruption as specified in the Company’s measures. No acts of demotion, punishment, or negative consequences will be executed upon employees denying acts of corruption even such doing might lose business opportunities for the Company. With this, the Company has identified work procedures for each department, including roles, duties and responsibilities, with monitoring and verification protocols in place.
  4. Directors, executives, and staff members of all levels known to commit acts of corruption are considered breaching the Company’s Code of Conduct and will be subject to disciplinary considerations specified by the Company, with no limitations to legal proceedings if such acts are illegal.
  5. The anti-corruption measurement is a part of the business operation and it is the duty and responsibility of the Company’s Board of Directors, The Management, supervisors, and employees at all levels including suppliers or sub-contractors to express their opinions regarding the practice on the implementation of the anti-corruption actions to ensure achievement of compliance with the policy set.
  6. The Company shall formulate and continuing develops its anti-corruption measurement in accordance with the related laws and the principles of moral. Risk assessment shall conduct on activities that are related or at risk for corruption and the results are to use in preparing the operating guidelines or manual for all related parties.
  7. The Company shall provide knowledge of anti-corruption to The Board of Directors, The Management and employees to promote integrity, honesty and the responsibility in fulfilling their duties, and to show The Company’s commitment.
  8. The Company shall has in place the mechanisms for its transparency and accuracy of financial report and realized its importance in distribution the knowledge and to make clear understanding to others whose duties are related to The Company or may have impact to The Company.
  9. The Company shall provide variety of communication channels for employees and stakeholders to raise concerns and report of suspicious circumstances with confidence of being protected from punishment, unfair transfer or harassment in any ways, and appointed person(s) to investigate and monitor the complaints.

Corruption Prevention Protocols

1. Risk Management

The Company has devised the corruption risk management initiative, starting from risk evaluation plan, identification of objectives, duties and responsibilities of relevant staff members, as well as the identification of risk evaluation criteria in writing, with reference to the “Corruption Risk Management Manual”. In this regard, the Company has evaluated potential risks that may cause financial and non-financial impact, with consideration of internal and external factors, as well as chances of incurring risks, in order to cover potential risks exposed to the Company, while at the same time devising the protocols to minimize the risks in case the existing internal control measures are insufficient.

2. Anti-Corruption Policy and Practices

The Company’s staff members must perform their duties with care, transparency and in accordance with the laws, to ensure clarity in the operations, especially for matters that involve high risks for corruption in different formats. So, the policy and practices have been identified as follows:

“The Company has devised the political support policy or Political Assistance and regards it as the Code of Business Conduct, with respect to the democratic system, and an emphasis on political neutrality, encouraging staff members to exercise their political rights as a good citizen. Financial support or offers in the form of assets, privileges or any other benefits as political support either directly or indirectly to politicians or political parties, as well as politicians’ representatives, shall be omitted, if it is for the Company’s interests, unless it is part of the democratic procedure executable by law.”

“The Company has devised the Conflicts of Interest Prevention Policy, which is regarded as the Business Code of Conduct that prevents directors, executives and staff members from taking opportunities by using one’s position to seek personal interests both direct and indirectly. Directors are prohibited from operating the business that competes with the Company and they should avoid inter-related transactions that may lead to conflicts of interest with the Company. In case of necessity, the Board of Directors should ensure that such transactions are transparent and fair, as if they are the transactions made with external parties. Directors or staff members who have potential losses or benefits in such transactions are prohibited from making consideration and approval”.

In case the inter-related transactions are under the announcement of the Securities and Exchange Office and the Stock Exchange of Thailand, the Board of Directors shall ensure and monitor that the criteria, procedures and disclosure of inter-related information of listed companies are strictly abided by.

The Board of Directors have devised the policy and executional procedures, with reference to the “Conflicts of Interest Practical Guidelines”.

“The Company has devised the Convenience Fees Policy that prohibits directors, executives, staff members and any employees from paying convenience fees to government officers in all cases, as this poses high risk for bribery, increasing business costs, defamation and violation of the anti-corruption policy”.

“The Company has devised the Government Officer Hiring Policy that the government officers to assume the director, executive and staff member positions or the Company’s consultants must go through the selection process, compensation package approval and control procedures to ensure that hiring government officers do not serve the purpose of returning any acquired benefits, as it may damage the credibility and honesty in performing duties, which may expose the Company to corruption risks.”

“The Company has devised the Charitable Donation Policy that it must be proven that the donation serves to aid the society and community. The donation must genuinely be for public charity, such donations must not influence business decisions and done with transparency with documented evidence for the donation, and not to serve as the excuse for giving or receiving bribes, or for corruption purposes. The company is no policy to accept donation in all circumstance.”

“The Company has devised the receiving and giving sponsorship Policy and regulates that the provision of sponsorship support must be provable that it serves to facilitate successful completion of the activity or the project, to promote the business, the Company’s brand, or to serve operational objectives, with genuine responsibility to the society in a transparent and lawful manner. It should not serve as the excuse for bribery, whereby approval procedures have been concisely determined, allowing for inspection and verification of the documented evidence.”

“The Company has devised the Gifts Hospitality and Reception Policy, whereby directors, executives, staff members and hired workers must not call for, receive or give gifts hospitality, host a reception, provide service or privileges of any kinds to persuade decisions or cause negligence of duties, or in ways that suggest giving or receiving bribes, either directly or indirectly, to individuals, government officers, government bodies, private sector organizations or related parties, unless as a gesture to express goodwill or relationship in a feasible manner; not too frequent, suitable for the occasion, with appropriate pricing or value and in accordance with the customs, not against the regulations, Code of Conduct, the Company’s rules and relevant laws.”

Reception or hospitality fees must be directly relevant to the activities that serve the Company’s business, for instance, transportation fees, accommodation fees, food and beverage, entertainment fees, sports and recreation fees. They should be related to the business or commercial tradition, or they should serve to provide an understanding on the business. The spending should be reasonable and does not affect decision making in work execution, cause negligence of duties or lead to conflicts of interest.

The Company has devised the policy concerning receiving gifts, complimentary items or other benefits from suppliers or relevant parties that the Company coordinates with on the Company’s behalf, unless receiving gifts is only for personal relationship and does not affect decision making or negligence of one’s duties. The Company is responsible for notifying outsiders of the mentioned gift policy, and staff members should observe the following practical guidelines.

Protocols on Detection of Corruption

Good corruption prevention protocols can minimize the chance of incurring corruption to a certain extent. However, it is necessary for the Company to develop protocols on detection of corruption in order to facilitate the process and report conducts that may induce corruption in a timely manner. Thus, the whistleblowing mechanisms have been devised as well as the reporting system to help the Company detect corruption early on. Moreover, in order to ensure that the corruption detection protocols are appropriate, effective and efficient, the Internal Audit Department will be conducting the audit on the internal control system on a regular basis, as follows:

The Company has arranged for credible and independent channels for filing complaints and whistleblowing in case of legal or ethical misconduct, violation of the anti-corruption policy or behaviors that may suggest dishonesty and inappropriate conduct of organizational members; staff members, executives and stakeholders. Everybody, either the Company’s staff members or outsiders, is allowed opportunities to provide clues, thus they are required to notify of the possibility of corruption via available channels. Punishment shall be exercised upon the person who is aware of the information or incident that may involve corruption but fails to notify the responsible parties. The Company has the measures on protecting whistleblowers, with mechanisms to protect providers of information, and emphasizes on keeping the complaints confidential, in order to build confidence for the complainants. Nevertheless, punishment will be exercised upon those who provide untrue information.

  1. Via email to:
    Board of Directors
    Audit Committee
    Company Secretary
    or via our website:
  2. or via post directly to:
    The Audit Committee through Head of Internal Audit Office
    Phol Dhanya Public Company Limited
    1/11 Moo. 3 Lamlukka Road, Ladsawa, Lamlukka, Pathumthani 12150
    Tel. (662) 791 0111
  • Details concerning such clues or complaints must be true, unambiguous or adequate for further investigation and proceeding.
  • Information received will be regarded as confidential information and the name of the whistle blower or the person filing complaints will not be disclosed to the general public without prior consent.
  • The time it takes to respond to the person filing complaints shall not exceed 3 working days after receipt of complaints.
  • The time it takes to process the matter depends on the complexity, sufficiency of the documents, the evidence received from the person filing complaints, and the subject matter’s counter evidence and clarification. However, the whole process shall not take longer than 30 working days.
  1. Database-Establishment and punishment shall be setup for keeping confidential information of whistleblower or complainant and infringed person and execute such punishment to staff who is responsible for the information when it has been disclosed.
  2. Access to the database shall be limited to Chairman of the Board and Chairman of the Audit Committee only.
  3. The Company shall only disclose the related information of whistleblower, complainant and infringed person when it is necessary by taking into account of the safety and the possibility of damage to them.
  4. It is the duty of supervisor or head of all defendants and infringement person to use his/her discretion giving an appropriate order to protect the complainant; infringed person; witness and person who provides useful information for investigation, from any danger and trouble including any unfair treatment as a result from complaint or infringed person or being as a witness or informant.
  5. The Company shall not treat whistleblower and complainant or infringed person in an unfairly manner including changing their position, work nature, or workplace, suspending his/her work, threatening, interrupting, dismissing, or committing any other unfair acts against whistleblower or complainant or infringed person or any person cooperating in the corruption investigation.

Protocols on Handling Corruption

The Company has developed protocols on handling dishonesty and corruption to tackle the impact and identify methods to prevent dishonesty and corruption from taking place repititively. The protocols are comprised of the investigation, punishment, corrective measures and information disclosure

For more details, could study from the Anti-corruption Policy and Guidelines.

Please read our General Disclaimer & Warning carefully.
Use of this Website constitutes acceptance of the Terms of Website Use.
Copyright © 2024. All Rights Reserved.