Compliance with Anti-Corruption Policy

Mission and Objectives
The Company and its subsidiaries have a policy to conduct business with integrity and transparency, prioritizing the benefits of the organization, and not supporting any operations that involve intellectual property infringement or political affiliations. The policy emphasizes the participation of everyone in the organization, raising awareness of the negative consequences of corruption, operating business with transparency and against corruption in any forms (gifts and money), and promoting good values without risking harm to the Company. All personnel of the Company and its subsidiaries are required to strictly follow this policy. Additionally, employees are also sent to participate in various courses organized by institutions to prevent corruption, for the purpose of studying, reviewing, and developing information disclosure about anti-corruption efforts.
Level 1: Committed
Having policies as guidelines or commitments to work together towards the common goal of combating corruption.
Level 2: Declared
announcing to external parties and collaborators the intention to act on this matter.
Sabina Public Company Limited has joined Thai Private Sector Collective Action Against Corruption (CAC) on September 1st, 2011
Level 3: Established
Implementing various measures to prevent possible corruption, as setting norms for acknowledgement.
Level 4: Certified
Sabina Public Company Limited has been certified anticorruption by Thai Private Sector Collective Action Against Corruption (CAC) on July 10th, 2015, renewing on three-year basis. In the present time, Sabina is also represented as Change Agent with three stars sign.


Goals For 2024
Guideline
Our company has implemented the policy into practice and makes sure that all departments are involved in order that we can ensure that all operations are processed appropriately. Our company makes sure all departments’ goals are in alignment and suitable for each department.
1. The Anti-Corruption Committee will develop materials, training, and activities
to educate executives and employees at all levels of the company about corruption, anti-corruption policies, and measures. Knowledge and understanding will be concretely assessed, with all employees required to achieve a passing score of 80% or 8 out of 10 on the test.
Anti-Corruption Policy, which covers the following areas:
- Giving or receiving gifts, hospitality, and entertainment
- Sponsorship
- Donations
- Political Contributions
- Conflict of Interest
- Bribery and Facilitation Payment
- Hiring of government officials (Revolving Door)
- Whistleblowing, complaints, consultation, and protection of whistleblowers
2. To ensure transparency, equality, and fairness for all stakeholders
and to prevent business favoritism and future incentives, the Anti-Corruption Committee has established a "No Gift Policy." This policy requests cooperation in refraining from giving or receiving gifts of any kind on any occasion. The company communicates this policy to partners via electronic mail, creates banners for promotion, and conveys the message to external parties and company personnel to foster understanding. The policy also sets guidelines for the acceptance and giving of gifts, assets, or other benefits, as well as entertainment.Note: This is in accordance with GRI Standard 205-2 regarding communication and training about anti-corruption policies and procedures.
3. CAC with Suppliers to Promote Transparency in Business Operations
In 2024, the company organized activities to invite partners to participate in meetings and understand the importance of joining the anti-corruption alliance with Sabina. There were three activities in total:
- The "Moving Towards CAC with Sabina 2024" project via MS Teams, held on June 7, 2024. T he company invited 10 partners to attend the sessionhonored by Ms. Wachirawan Yamsri, Chief Operating Officer, who presided over the event and shared her experience about Sabina Public Company Limited joining the Thai Private Sector Collective Action Against Corruption (CAC). The aim was to raise awareness of the CAC project among attendees and provide information to help them decide to declare their commitment to becoming part of the Thai CAC.3.2 Supplier Conference Project "Sustainable Business Practices (ESG)"On November 13, 2024, from 1:30 PM to 4:00 PM, at Conference Room 702, Sabina Public Company Limited, Pin Klao Office.The company had the honor of hosting 44 partner companies, totaling 78 attendees. The event was graced by Ms. Duangdao Mahanaowanont, Chief Executive Officer, who presided over the event, alongside Ms. Wachirawan Yamsri, Chief Operating Officer, to meet and share experiences with the distinguished guests.
- Supplier Conference Project "Sustainable Business Practices (ESG)"On November 13, 2024, from 1:30 PM to 4:00 PM, at Conference Room 702, Sabina Public Company Limited, Pin Klao Office.
- Online Supplier Conference Project via MS TeamsOn December 2, 2024, from 10:00 AM to 12:00 PM, the company invited 42 partner companies to attend the session.
4. Maintain the standards of anti-corruption
operations as assessed by the Thai Private Sector Collective Action Against Corruption (CAC). This includes reviewing the implementation of anti-corruption policies and measures, as well as regularly conducting self-assessments using self-evaluation forms to continuously develop the anti-corruption system, overseen by the Internal Audit Office and the Anti-Corruption Committee.
5. The management, Internal Audit Office, and Anti-Corruption Committee
are responsible for continuously testing and assessing corruption risks. They must be vigilant of these risk points and strictly adhere to regulations. The assessment results are presented to the Audit Committee and reported to the Board of Directors every quarter. Additionally, efforts must be made to promote and raise awareness within the organization to ensure unified cooperation and further organizational development.
6. The Company and its subsidiaries have implemented measures
Reporting and Addressing Grievances, Complaints, and Violations
For reporting and addressing grievances, complaints, violations of regulations, laws, ethics, or behaviors that may lead to corruption or misconduct by employees, related persons, and stakeholders. The channels for reporting complaints and suggestions are as follows:
- Email to the Internal Audit Department:
GRP_AUDIT_HO@sabina.co.th - Letter sent by post to the Internal Audit Department:
Head office No.12 Arun-Amarin Rd., Arun-Amarin, Bangkoknoi, Bangkok 10700 - Line: @SABINA AUDIT 191
- Directly report to the Internal Audit Department staff in person or via telephone at 02-422-9400 to have the complaint recorded as evidence.
7. The Company has established measures to protect complainants
Measures to Protect Complainants
- In order to protect the rights of complainants and informants who act in good faith, the Company will not disclose any information that may identify the complainant or informant, including their name, address, or any other information that may reveal their identity. The Company will also keep the information of complainants and informants confidential, which will be protected from retaliation, such as position change, job description, workplace relocation, suspension, threats, harassment, termination, or any other unfair treatment related to the complaint. Such information will be limited to the internal audit department only, which is responsible for investigating and accessing such information.
- In cases of complaints regarding wrongdoing by high-level executives, the audit committee will be responsible for protecting the whistleblower, complainant, witnesses, and individuals providing information in the investigation, from any harm or retaliation that may arise from reporting the complaint. The complaint should be submitted directly to the audit committee and will be recorded by the committee secretary for direct reporting to the committee.
8. The Company will disseminate anti-corruption policies
Dissemination of Information to Personnel, Relevant Parties, and Stakeholders
The dissemination will be carried out through the following channels:
Internal Departments:
- Announcements through the Company’s electronic media.
- Posting announcements of the Company and its subsidiaries in prominent locations.
- Spreading the news through the communication channel.
- LINE@ account of the Company
- Conducting orientation programs for new employees.
- Providing training or communication to disseminate anti-corruption policies, business ethics, and the code of conduct, as well as annual risk management training to personnel of the Company and its subsidiaries to ensure that everyone is aware and emphasizes compliance with the measures mentioned above.
External Departments:
- Announcement through the Company’s website
- Email notifications to business partners
- Annual reports of the Company (56-1 One Report)
9. The board of directors and subsidiaries have come up with guidelines on evaluation procedures for anticorruption conduct for the company.
In addition, it is a requirement to have an internal control policy and make recommendations or complaints to the evaluation on an annual basis with tangible / reasonable reasons or proof to help improve internal control.
Performance in 2024


Operating business
Conduct Business While Maintaining Standards According to the 71 Requirements of the Thai Private Sector Collective Action Against Corruption (CAC).These standards are reviewed by the Audit Committee through the Internal Audit Office. In 2024, the company successfully passed the third renewal of its certification


Conduct training
For personnel of the Company and its subsidiaries on anti-corruption measures, business ethics and the code of conduct, including risk management. In 2024, the following training has been organized:
- Pin Klao Office: October 8, 2024
- Sales Employees (PC): October 8, 2024
- Phutthamonthon Sai 5 Factory: December 5, 2024
- Tha Phra Factory: October 8, 2024
- Chainat Factory: November 29, 2024
- Yasothon Factory: November 27, 2024
In this regard, 100% of the total number of personnel has been trained. The details of operations in previous years are as follows:
Plant | 2020 | 2021 | 2022 | 2023 | 2024 | |||||
---|---|---|---|---|---|---|---|---|---|---|
Employees | % | Employees | % | Employees | % | Employees | % | Employees | % | |
Pinklao office | 353 | 100% | 336 | 100% | 352 | 100% | 356 | 100% | 367 | 100% |
Sale staff (PC) | 1,078 | 100% | 866 | 100% | 843 | 100% | 841 | 100% | 816 | 100% |
Sai 5 | 645 | 100% | 468 | 100% | 573 | 100% | 596 | 100% | 552 | 100% |
Ta Phra | 309 | 100% | 238 | 100% | 229 | 100% | 227 | 100% | 168 | 100% |
Chainat | 411 | 100% | 336 | 100% | 349 | 100% | 344 | 100% | 256 | 100% |
Yasothon | 1,008 | 100% | 859 | 100% | 899 | 100% | 886 | 100% | 701 | 100% |
Buriram | 25 | 100% | 166 | 100% | 179 | 100% | 195 | 100% | - | - |
Total | 4,059 | 3,269 | 3,424 | 3,445 | 2,860 |
Note:
- In accordance with GRI Standard 205-2 regarding communication and training about anti-corruption policies and procedures.
- Closed the Buriram Factory in 2024.


Communicate and show intentions to business partners
Communicating Anti-Corruption Commitment to Partners In mid-December 2024, the company sent electronic letters to 1,197 partners (100% of all partners), informing them of the "No Gift Policy," which requests cooperation in refraining from giving or receiving gifts of any kind on any occasion.


Thai Private Sector Collective Action Against Corruption (CAC)
The company received the CAC Change Agent Award 2024 at the CAC Certification Ceremony 2/2024 "Navigating ESG: The Power of Integrity" on Monday, November 11, 2024, from 9:00 AM to 12:30 PM at the Siam Kempinski Hotel Bangkok. A total of 15 companies received the award, including:
- AP (Thailand) Public Company Limited
- Bangkok Commercial Asset Management Public Company Limited
- Blue Solution Public Company Limited
- Central Plaza Hotel Public Company Limited
- Charoen Pokphand Foods Public Company Limited
- CP All Public Company Limited
- Ichitan Group Public Company Limited
- KCE Electronics Public Company Limited
- Mitr Phol Sugar Corporation Limited
- Sabina Public Company Limited
- Siemens Energy Limited
- Sri Trang Agro-Industry Public Company Limited
- Starflex Public Company Limited
- Supalai Public Company Limited
- Thanachart Insurance Public Company Limited


To ensure transparency, equality, and fairness for all stakeholders and to prevent business favoritism and future incentives, the Anti-Corruption Committee has established a "No Gift Policy." This policy requests cooperation in refraining from giving or receiving gifts of any kind on any occasion. The company communicates this policy to partners via electronic mail, creates banners for promotion, and conveys the message to external parties and company personnel to foster understanding. The policy also sets guidelines for the acceptance and giving of gifts, assets, or other benefits, as well as entertainment.
GRI Standards Universal Standards
Disclosure | Page(Annual Report 2023) |
---|---|
GRI 205-2 Communication and training about anti-corruption policies and procedures | 199,204 |
GRI 301-1 Materials used by weight or volume | 102,107 |
GRI 302-1 Energy consumption within the organization | 65 |
GRI 302-4 Reduction of energy consumption | 58,60,63 |
GRI 302-5 Reductions in energy requirements of products and services | 64 |
GRI 303-2 Management of water discharge-related impacts | 74 |
GRI 303-4 Water discharge | 76 |
GRI 303-5 Water consumption | 75,76 |
GRI 305-1 Direct (Scope 1) GHG emissions | 37,43,52,53,54 |
GRI 305-2 Energy indirect (Scope 2) GHG emissions | 40,43 |
GRI 305-3 Other indirect (Scope 3) GHG emissions | 42,43,87 |
GRI 305-5 Reduction of GHG emissions | 37,44 |
GRI 306-2 Waste by type and disposal method | 83,85,86,88 |
GRI 401-1 New employee hires and employee turnover | 190 |
GRI 401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees | 186 |
GRI 401-3 Parental leave | 190 |
GRI 402-1 Minimum notice periods regarding operational changes | 189 |
GRI 403-1 Occupational health and safety management system | - |
GRI 403-2 Hazard identification, risk assessment, and incident investigation | 150 |
GRI 403-3 Occupational health services | 156 |
GRI 403-5 Worker training on occupational health and safety | 151 |
GRI 403-6 Promotion of worker health | 156 |
GRI 403-9 Work-related injuries | 154 |
GRI 403-10 Work-related ill health | 155 |
GRI 404-1 Average hours of training per year per employee | 181 |
GRI 404-2 Programs for upgrading employee skills and transition assistance programs | 180 |
GRI 404-3 Percentage of employees receiving regular performance and career development reviews | 182 |
GRI 405-1 Diversity of governance bodies and employees | 190 |
GRI 406-1 Incidents of discrimination and corrective actions taken | 173 |
GRI 407-1 Operations and suppliers in which the right to freedom of association and collective bargaining may be at risk | 171 |
GRI 410-1 Security personnel trained in human rights policies or procedures | 160 |
GRI 412-2 Employee training on human rights policies or procedures | 160 |
GRI 413-1 Operations with local community engagement, impact assessments, and development programs | 169 |
GRI 418-1 Substantiated complaints concerning breaches of customer privacy and losses of customer data | 18 |
Code of Conduct
Mission and Objectives
Sabina Public Company Limited, a manufacturer and distributor of women’s lingerie, is committed to conducting business with integrity and transparency towards all stakeholders, including shareholders, employees, customers, business partners, and/or creditors, as well as society and the environment. The Company has established its codes of conduct for responsibilities towards each stakeholder and has communicated these principles of responsibility to all levels of the Company’s employees and related parties to serve as guidelines for ethical business conduct. This also serves as a guide for the board of directors, executives, and employees to uphold appropriate and ethical practices in the future.


Objectives for 2024
Operations to ensure compliance with the Code of Conduct
Performance in 2024


Business ethics and code of conduct operations
From the business ethics and code of conduct operations in 2024, it was found that the goal of ensuring that every board member, executive, and employee adheres to the specified business ethics was achieved.


Business ethics
Directors, executives, and employees in the organization receive communication about business ethics, 100% of the total number of directors, executives, and employees in the organization.


Code of conduct test
Participation in the Ethics and Business Code of Conduct Test: A total of 3,041 individuals out of 3,048 participated in the ethics and business code of conduct test, accounting for 99.8%. The test results showed that 100% of participants passed, with an average score of 9.7 out of 10.


The test results
The test results for business ethics and code of conduct showed that 100% of participants passed the test, and the average score was 9.7 out of 10.
In the past year, none of the directors, executives, and employees violated or acted against the company's ethics and business ethics.
Results of questionnaire responses to stakeholders
The company conducted a survey with stakeholders, including customers, partners/creditors, society, and the environment, regarding the company’s business code of ethics. The summary is as follows:
Results of ethics assessment towards trading partners and/or creditors
According to the evaluation results from partners and/or creditors, they believe that the company conducts business with integrity and strictly adheres to laws and regulations as outlined in the code of ethics for partners and/or creditors, achieving an overall rating of "very good" and "good" at 99.7%.
Results of customer ethics assessment
According to the evaluation results from customers, they believe that the company conducts business with integrity and considers the best interests of customers as outlined in the code of ethics for customers, achieving an overall rating of "very good" and "good" at 97.5%.
Results of the social and environmental ethics assessment
According to the evaluation results from the community regarding social and environmental aspects, the community believes that the company is concerned about social safety, the environment, and the quality of life of the public. The company places importance on nature and environmental conservation as outlined in the code of ethics for society and the environment, achieving an overall rating of "very good" and "good" at 100%.
ESG in Supply chain
Commitment and Goals
The company supports the SDGs by building a sustainable and responsible supply chain, addressing environmental, social, and governance (ESG) aspects. This approach mitigates business risks, such as violations of environmental and labor laws, climate change impacts, and governance issues. A responsible ESG supply chain enhances the company's image, increases customer trust, meets stakeholder expectations, and creates long-term value for the organization.


Objectives for 2024
Guideline
1. Select new suppliers based on supplier qualifications and ESG performance evaluation, with the following assessment criteria:
Environment
Waste management, adoption of sustainable materials, procurement of renewable energy, water sourcing and wastewater treatment, and air pollution control.
Social
Compliance with general/labor laws, child labor usage, forced labor usage, and human rights.
Governance
Business Code of Conduct, Anti-Corruption policies.
In 2024, 6 new suppliers passed the performance evaluation as follows:
Supplier | Type of Raw Material | Supplier Qualification Score | ESG Score | Overall Score |
---|---|---|---|---|
New Supplier 1 | Fabric | 58% | 75% | 72% |
New Supplier 2 | Fabric | 58% | 75% | 72% |
New Supplier 3 | Fabric | 75% | 75% | 75% |
New Supplier 4 | Printed Fabric | 92% | 100% | 98% |
New Supplier 5 | Label | 75% | 75% | 75% |
New Supplier 6 | Label | 75% | 79% | 78% |
Evaluation Summary | 72% | 80% | 78% |


2. A conference to communicate the company's policies and business guidelines to suppliers was held on November 13, 2024, with 46 suppliers participating, totaling 79 attendees.
3. To educate and encourage suppliers on the importance and necessity of conducting business based on ESG responsibility, including the trend of the Climate Change Act. The conference will explain the updated ESG guidelines and assessment criteria. Held on December 2, 2024, with 42 suppliers participating, totaling 68 attendees.



4. Rank the top 100 suppliers based on the highest raw material purchase value to monitor and evaluate ESG performance, divided into:
The supplier evaluation results will affect future business relationships. The company will summarize and inform suppliers of their evaluation results. If a supplier's score falls below the set criteria, the company will notify the supplier with improvement guidelines. If the supplier's score remains below the criteria for three consecutive evaluations, the company will terminate the business relationship.