Anti Corruption Policy
Sky Tower Public Company Limited has participated and announced intentions of Private Sector Collective Action, Coalition against Corruption (CAC) and set up a policy of Anti-Corruption date since 17 December 2015, tougher with other activities in order for applying certification. In 2019, UWC has received a certificate at CAC National Conference Day 2019.
Duties and Responsibilities
- All executives have duties and responsibility to ensure that its own subordinate realizes and understand the Anti-Corruption and Fraud Policy and already be trained sufficiently and regularly.
- Employee will perform to be in line with Anti-Corruption and Fraud Policy. In case of any query or find any violation to Anti-Corruption and Fraud Policy shall immediate report to superior or through the Company’s reporting channel specified according to policy for misconduct and fraud, investigation, and protection the whistle blowers.
Policy and Practice
- Company has Zero-Tolerance Policy and conduct in compliance with related legal requirement to Ant-Corruption and Anti-Bribery in Thailand.
- Company will not involve in the bribery and corruption both indirect and direct and determines to implement effective system to anti-bribery and anti-corruption.
- Employee of the Company will not involve in the bribery and corruption to government officer and private officer such as personnel from various companies which
have transaction with Company both direct and indirect in order to receive or maintain the business or competitive advantage.
Company will not contribute for money, items and/or joining activities, as well as encourage employees to participate in the political activities on behalf of Company in order to gain advantage of competitive trade business. Therefore, not including employees who participate the activities as per personal right. Company has policy to conduct business as neutral, nonaligned to any politic or professional politician of any political party, and not use capital or other assistances to support politics as per above meaning by aiming to business advantage.
- Shall prove that the activities according to the charitable contribution project is real, and shall conduct to support to achieve objective of the project and to create real benefit to society.
- Shall prove that that Charitable Contribution is not involve in reciprocal benefit to someone or some authorities, except the commemorative certificate announcement as general practice such as Logo attachment, name list announcement at the event or media in order for publication, etc.
- For Charitable Contribution shall fill in the form of Charitable Contribution and others (Enclosure 1), specifies do nee and objective of contribution with supporting document to propose to authorized person for Company to consider and approval according to the authorities table of Company.
- Shall follow up for thank you letter or acknowledgement or receipt in order to submit to Accounting & Finance Department.
Objectives for business to promote brand or Company’s reputation which might be risk due to it’s the payment for services or benefit which is difficult to evaluate and follow up for sponsorship which might connect to bribery. Company has set up policy and criteria of sponsorship, review process, and detail of control including the assessment the received benefit as follows:
- Shall prove that the done really conducts that project and to perform in order to achieve objectives of the project and to create real benefit to society.
- Shall prove that sponsorship or other benefit can calculate as cash basis such as offering accommodation and food, etc., not related to reciprocal benefit to someone or some authorities, except the commemorative certificate announcement as general practice.
- For Sponsorship shall fill in the form of Charitable Contribution and others (Enclosure 1), specifies donee and objective of contribution with supporting document to propose to authorized person for Company to consider and approval according to the authorities table of Company.
- Shall follow up for thank you letter or acknowledgment of receipt in order to submit to Accounting & Finance Department.
Providing and Receiving Gifts, Entertainment, and Hospitality or Else
- Company realizes that building good relationship with business alliance is important to continually bring achievement to Company.
- Employees can provide/receive gifts to/from others if it falls into the following condition.
- Business Entertainment and other expenses related to conduct business contract which can perform but with reason, able to inspect, and proceed according the working expenses procedure.
- No action to intent to dominate, to lead or to compensate anyone in order to take the benefit from misconduct, or clearly exchange or hidden in order to receive assistance or To provide on behalf of Company, not on behalf of that employee.
- Not offering gifts in cash or equivalent to cash (such as gift card or complementary card).
- Appropriate to situation such as little gift during Song Kran Festival, Chinese New Year or New Year as normal custom.
- To disclose, no hidden.
- Employee can receive gift which value not more than 5,000 Baht. In case of cannot deny and shall receive the gift which value more than 5,000 Baht, shall inform superior and use Receiving Gift Form (Enclosure 2) and send that gift to Human Resources Department in order to be prize for employee or contribute to charity as appropriate.
Company and Personnel Related to Business
- Subsidiary and affiliate that Company has control power, Company will inform and support subsidiary and affiliate to conduct business in compliance with Anti-Bribery and Anti-Corruption Policy.
- Representative and business media.
Not Allow for employee to hire representative or business media which having objectives to corrupt or bribe.
- Product supplier/Service Provider/Contractor.
Company will provide the procurement for product/service with fairness and transparency, including will carefully evaluate the Product supplier/Service Provider/Contractor. Moreover, Company will inform Product supplier/Service Provider/Contractor for this policy and Company will reserve the right to cancel order and service. If it’s found out that Product supplier/Service Provider/Contractor corrupt or bribe.
Training and Communication
All employees will receive copy of Anti-Corruption and Fraud Policy in order to ensure that they receive and understand for Anti-Corruption, Fraud and Bribery Policy. Moreover, still could see the policy from the updated information from Company’s website: www.skytower.co.th. Company will keep employees inform when having updated major information.
Training for Anti-Corruption and Fraud Policy will be part of orientation or before taking the position of all new employee of Company
Reporting When Find the Bribery and Corruption
If employee suspects or finds evidence that some employee or persons performing on behalf of Company entered into the bribery or corruption, shall report to superior immediate or report though whistle blowing channel. When Company receives that reporting, shall conduct seriously, and will not punish to that employee who inform with integrity.
- Company assures employee that no any employee will be demoted or penalty or receives any impact when denying for bribery. Even though that deny will cause Company to loss business or miss the new business opportunities. The Company believes that Policy of Anti-Corruption and Anti-Bribery and Zero-Tolerance Policy will create value to Company. Moreover, Company does not allow anyone to threaten or hold the willingness of employee to perform in accordance with this policy.
- If employee believes that he is threaten or hold, shall report directly to subordinate or head of Human Resources Department immediately. If it is still not receiving any correction, shall report to the whistle blowing channel of Company
Company will have discipline punishment to employee who violates the conduct according to this policy, including direct superior who ignore for misconduct or know for wrong actions but not try to correct. The discipline penalty has until dismiss. Not knowing this policy and/or related legal requirement cannot use as reference for un-perform.
Review and Monitoring
Internal Audit Office will audit internal control system and other processes regularly in order to ensure that internal control process is effective against bribery and corruption, by discussing finding of audit with related person in order to find appropriate correction and will further report to executive and Audit Committee.
Channels for Receiving Clues or Corruption Complaints
The Board of Directors assigned the Chief Executive Officer and/or the Company Secretary to consider clues, complaints about any suspicious acts that may directly or indirectly cause corruption within the company. In 2019, the Board of Directors agreed to increase channels to receive clues. Any suspicious clues can be submitted to the Audit Committee’s and the Secretary of the Audit Committee’s emails.
A complainer must specify details of a matter to be reported or complaint including name, address and telephone number and send it to the following channels.
1. Inform through e-mail channel of
- Chief Executive Officer Email: firstname.lastname@example.org
- Company Secretary Email: email@example.com
- Chairman of Audit Committee Email: firstname.lastname@example.org
- Audit Committee Email: email@example.com
- Audit Committee Email: firstname.lastname@example.org
- Audit Committee Secretary Email: email@example.com
2. Send to post office and sealed to
- Mr. Theerachai Leenabanchong Chief Executive Officer
- Mr. Onchulee Lawsmithikul Company Secretary
- Ms. Wanna Maluengnon Chairman of Audit Committee
- Dr. Nathee Naktnasukanjn Audit Committee
- Mr. Pianchai Thawornrat Audit Committee
- Mr. Komwut Pornnaradon Audit Committee Secretary
Sky Tower Public Company Limited
247 Romklao Road, Saen Saeb Sub-District, Minburi District, Bangkok 10510.
Measures for Complainers Protection or Whistle Blowers for Corruption and Confidentially
- Company will keep information and conceal name, address and other information which could identify the complainers or whistle blower and keep confidentially, especially the person who has responsibility to investigate complaint only that can access to that information.
- The person who receives information regarding complaints has duties to keep information, complaints, and evidence of complainers as confidence, do not disclose to others who does not involve, except the disclosure in accordance with legal requirement.
- Company will disclose when it’s necessary by considering the safety and damage of whistle blower or concern.
- Victims will be rescue for damage with the appropriate and fair process.
Publication of Anti-Corruption and Fraud Policy
- Company will post Anti-Corruption and Fraud Policy at every bulletin board of the Company.
- Company will publicize Anti-Corruption and Fraud Policy through Company’s communication channel such as Electronic Mail (e-mail), Company’s web site, Disclosure Report for Annual Data (56-1), Annual Report (56-2) and leaflet, etc.
- Company will provide training for Anti-Corruption and Fraud Policy to new employee and also add in the employee manual.
- Company will review Anti-Corruption and Fraud Policy every year.
*** This is effective from 10 November 2017 onwards.
Collective Action Coalition of the Private Sector Against Corruption