The Company conducts its business with transparency and aware on anti-corruption of all forms through abiding by laws and promoting social interest as well as encouraging employees to have moral values in performing their duties and adhere to good citizenship. Besides, given its commitment to anti-corruption, the Company signed a joint declaration with the Thai Private Sector’s Collective Action Coalition for Anti-Corruptions as approved by the Board of Directors on 25 February 2019. This project is operated under collaboration of 8 leading organizations which are Thai Institute of Directors, Thai Chamber of Commerce, International Chamber of Commerce, The Thai Bankers Association, Thai Listed Company Association, The Federation of Thai Capital Market Organizations, The Federation of Thai Industries and The Thailand Tourism Council.
To serve this purpose, the Company has stipulated an anti-corruption policy as a clear guideline to prevent and tackle corruption problems in the Company through making an organization culture that is fully aware of dangers from corruption and creating right values and building trust among all stakeholders to enhance effectiveness of anti-corruption actions. In case of incompliance, disciplinary actions and legal actions will be taken on a case-by-case basis. Details are summarized below:
- Directors, executives, employees at all levels are prohibited from acting, omitting to perform their duties or wrongfully using authority to violate laws or ethical codes including any activity or participation in all forms of corruption, directly and indirectly. They are forbidden to seek unlawful benefits in any form such as a provision, a promise, a solicitation of benefits or assets, an offer of benefits or assets including any other interest to government officials or other persons doing business with the Company, a persuasion to an illegal action or trust destruction or any corruption activity including a solicitation, an acceptance or an offering assets or any other interest to government officials or other persons doing business with the Company.
- Procedures on offering and acceptance of gifts or entertainment are stipulated as a part of the Code of Conduct and Business Ethics of the Company. Employees must refrain from offering, soliciting, accepting or agreeing to money, items, treats, entertainment or any other interest that are subject to doubts regarding bribery or fraud. Gift acceptance should be reasonable, not lead to any business obligation and not be in a form of cash or cash equivalents. Employees must be fully aware that all actions or inactions are transparent and accountable.
- The Company stipulated procurement practices, objectives of transactions, reimbursement, and any contract making/entering. In every step in the procurement process, supporting documents or evidences must be enclosed while approval authority at each step is properly set with transparency in compliance with laws, practices, and processes that the Company imposed. Procurement shall also be audited on a regular basis.
- The Company ensures communications on the anticorruption policy to all units at all levels in the Company through various channels such as employee trainings and internal communication with the purpose to educate related persons and enforce implementation and compliance. Employees can report misconducts, file complaints and make suggestions to the Company so that investigation will be carried out to find facts according to the procedures and the results can be used to solve or improve related matters.
- The Company set up a human resources management system to promote right values and build anticorruption culture. Employees are informed and communicated of the anti-corruption policy as well as the Code of Conduct and Business Ethics.
- The Company notifies its subsidiaries, affiliates, other companies that the Company has the controlling power as well as business representatives to adopt anti-corruption measures and disclose the anti-corruption policy and measures to both employees and the general public.
- The Company provides multiple communication channels for employees and related persons to file complaints and report dubious activities. Whistleblower protection measures are in place and identities of whistleblowers and people who deny to involve in corrupted activities shall be kept strictly confidential in order that they are protected from any impact from their actions as well as unfair punishment or transfer. Responsible persons shall be appointed to examine and follow up on all whistleblowing or reported information.
- Anti-corruption measures are developed in accordance with related laws and moral codes. The Company conducts risk assessment for related activities that are prone to corruption, prepares proper protective measures and communicates internally in the organization on a regular basis.
- The Company ensures adequate and appropriate internal control systems to prevent corruption and any action that are not in compliance with good corporate governance principles.
- The Company set forth a policy on related party transactions to prudently consider suitability before engaging in every related party transaction as well as determine prices and conditions on those related party tractions which are comparable with doing with external parties as arm’s length basis.
- In case that directors, executives and employees involve in any action that violates the anti-corruption policy, directly or indirectly, disciplinary or legal actions will be taken to those persons according to the Company’s practices or related laws.
In addition, the Company recognized on the prevention of corruption or acquisition of illicit benefits for personal interest or interest of others using power or position. A practical guideline is established as follows:
- Charitable Donation and Financial Support
The guideline on charitable donation or financial aid of the Company is based on the table of authority approved by the Board of Directors. Donation can be in forms of money or other non-monetary items such as scholarships, educational aids, books, and computers offered to students, schools or donation of goods e.g. supplies for victims of natural disasters, medical expenses or supplies for destitute patients. The donation must not be used as an excuse for any kind of corruption.
The Company ensures a supervision on charitable donation and financial aid by requiring a letter or a request record specifying an authorized person according to the table of authority to approve and a receipt and/or a thank you latter and/or an acknowledgment letter and/or a photo as a supporting evidence for every time a donation or a financial aid is made.
- Political Support
The Company is politically independent and is able to conduct its business without engaging in politics in any case. Therefore, the Company has no policy in supporting politics either using money or any asset of the Company directly or indirectly. However, the Company does not forbid directors, executives and employees from participating in political activities undertaken under the constitution, laws and related rules and regulations but the participation must be on personal behalf without any negative association with the Company.
- Acceptance and Offering of Gifts, Hospitality and Entertainment
The Company allows directors, executives and employees to accept and pay money for gifts, services and entertainment that are unambiguous and are considered as a service to customers, trade partners or relevant parties according to ordinary business undertaking or traditions or international festivals without impacting the business conduct or being a potential channel for corruption. The act must be in accordance with the Company’s practices without any violation of related laws and notifications or with the purpose to gain any advantage through a misconduct or to be an outright on hidden exchange to seek benefits in any form. Moreover, type and value of gifts, hospitality and entertainment must be reasonable and appropriate.
- The Company and Parties with Business Relations
The Company encourages its subsidiaries and/or any other party that represents the Company participate in anticorruption efforts and prohibits directors, executives and employees to hire any business representative or intermediary with the purpose of corruption. The Company will inform its subsidiaries and the parties representing the Company of the anti-corruption policy similar to the Company.
- Risk Assessment
The Company’s directors must understand on potential risks from bribery and corruption together with communicate with employees at all levels for their understanding and compliance to ensure the effective risk management. The Company conducts risk assessment for all operational systems especially processes that are prone to bribery and corruption. Overall risk management policy and proper risk management measures to prevent and mitigate risks under acceptable levels must be reviewed regularly on an annual basis
- Internal Control
The Company specified internal control systems that handle corruption covering finance, accounting and data recording including other processes related to anti-corruption measures. Internal control systems are processes that ensure efficiency and credibility of the Company’s operations. The Company shall evaluate the adequacy of its internal control systems that include assessment of control environment, risk management, control activities, information and communication and monitoring activities aimed to report results of the evaluation of internal control system to the Audit Committee.
- Accounting Audit and Data Storage
The Company has an audit process for accounting entries and these entries are approved according to the delegation of authority before being recorded in the accounting system. The transactions will be reviewed by considering the Company’s policies, rules and regulations of government agencies and related agencies, relevant laws, contracts and agreements according to accounting standards and policies.
- Human Resources Management
The Company will adopt the anti-corruption policy as a part of its human resources management and processes such as recruitment, hiring, training, reward and promotion.
- Whistleblowing and Complaint in for Corruption Issues
In case that directors, executives and employees are suspicious of or uncertain of any action that can be considered corruption, they shall seek advice from their direct supervisors or persons that the Company assigned to handle complaints. When there is an evidence that directors, executives, employees and/or any person acting on the Company’s behalf engage in corruption, ones must expose the information or file complaints through the following channels.
- Tel: 02 917 3055 Ext. 307 and 669
- E-mail: firstname.lastname@example.org
- Suggestion and Complaints Box
- Mail: Do Day Dream Public Company Limited “Complaint Handler”
No. 32 Keharomklao Road, Rat Patana, Saphansung, Bangkok 10240
Complaint Handler means Human Resources Director or Company Secretary or the Risk Management Committee or the Audit Committee or the Board of Directors
- Whistleblower Protection
Whistleblowers or complainers can rest assured that their whistleblowing or complaints will be taken seriously and they are protected from any adverse consequence from an honest whistleblowing or complaint. The employees who are whistleblowers must gather information carefully and be mindful of the accuracy of disclosed information.
Whistleblowers are entitled to anonymity and the Company shall treat the information and their identities with confidentiality throughout the investigation. The Company shall not allow any action that can cause damage to the whistleblowers and will take disciplinary actions with the persons who attempt any retaliation to the whistleblowers under a proper process to prevent any impact on the work and/or work relationship of the whistleblowers.
In case that employees release any information with dishonesty such as information disclosure of personal complaints or with an intention to create internal disharmony within the group of companies or the information is not truly factual whether it is a rumor or for personal benefits, the action will be considered a serious offense and the Company will investigate and consider a punishment according to the Company’s practices.