Whistleblowing and Complaint Filing Mechanisms

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.

Doubts of Corruption

In case that directors, executives, or employees are doubtful of actions that might involve corruption, or have any questions or uncertainty, one is advised to seek consultation with one’s direct supervisor or Please contact:

Please contact: Management and Organization Development Office

• Company Secretary
  Tel. (662) 7910111 ext. 151
  Email: cs@pdgth.com
• Head of Internal Audit Office
  Tel. (662) 7910111 ext. 114
  Email: ia@pdgth.com

Or one can also submit clues or file complaints via specified channels.

Channels to send Whistle Blowing, Notice of Complaint

1. Via email to:
   

   Board of Directors	Email: board@pdgth.com
   Audit Committee	Email: ind_dir@pdgth.com
   Company Secretary:	Email: cs@pdgth.com
   or via our website:	www.pdgth.com/ir_index.php

2. or via post directly to:
   The Audit Committee through Audit Committee’s secretary
   Phol Dhanya Public Company Limited
   1/11 Moo. 3 Lamlukka Road, Ladsawa, Lamlukka, Pathumthani 12150
   Tel. (662) 791 0111

Conditions and Consideration of Clues or Complaints

• 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.

In this regard, the conditions and procedures related to whistleblowing and consideration of complaints are specified in the whistleblowing manual, which has been announced to the Company's and subsidiaries' staff members. However, the Internal Audit Division is responsible for reviewing and improving the whistleblowing procedures to ensure they are up to date, communicating relevant information to the Company's and subsidiaries' staff members, as well as providing training programs for staff members responsible for receiving complaints, including the operational procedures, confidentiality, ethical practices and other relevant policies.

Protection Mechanisms to the Whistleblower or Complainant or Infringed person(s).

• 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.
• Access to the database shall be limited to Chairman of the Board and Chairman of the Audit Committee only.
• 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.
• 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.
• 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.