Governance / Economic

And to prevent business interests and motivations from affecting the right to receive benefits and advantages in the future, the anti-corruption committee has collaborated to develop No Gift Policy. This involves sending emails to our business partners to prepare banners to business partners and communicating with company personnel to create understanding and establish guidelines for receiving and giving gifts, assets, or any other benefits, as well as for hosting events.

Information disclosure according to GRI 205-2 Communication and training on anti-corruption policies and procedures

The details are as follows:

• The Company and its subsidiaries establish policies regarding the receiving of gifts, assets, benefits, or welcoming parties to minimize the impact on decision-making and to avoid conflicts of interest.
• Personnel of the Company and its subsidiaries strictly adhere to policies related to anti-corruption, including the refusal of gifts, assets, benefits, or welcoming parties. The Company and its subsidiaries prohibit the receiving of gifts or assets bearing the Company’s logo or as a means to maintain business relationships or follow traditions and morals. Gifts, assets, or benefits must not be in cash or cash equivalent and must not violate any laws.
• Welcoming parties must not have any commitments or create a sense of obligation to reciprocate in a corruptive manner, and must not violate rules, regulations, and laws.
• In the case of selection, negotiation of prices, procurement, supply of goods, raw materials, sales areas, or any other benefits provided to the Company and its subsidiaries, no demands for gifts, assets, benefits, and welcoming parties should be made to obtain special privileges that should not be granted, or to enter into agreements that result in non-compliance with established standards, regulations, and rules.
• The Company and its subsidiaries have communicated and publicized to its employees and individuals involved in the operations to create understanding and practices regarding the receiving of gifts, assets, benefits, and welcoming parties for the Company and its subsidiaries.
• Personnel of the Company and its subsidiaries are prohibited from giving or accepting any form of bribes or conveniences in conducting the business of the Company, except for transparent, honest, and lawful dealings with government agencies.
• Personnel of the Company and its subsidiaries must not engage in any business that may create conflicts of interest with the Company, directly or indirectly, and must not use their position for personal gain. They must avoid any business that may create conflicts of interest that could affect decision-making, as well as any transactions or dealings, whether on their behalf or as legal entities in which they have an interest.
• The Company and its subsidiaries have a policy against hiring or appointing government officials who are still in office to work within the company.

They must be vigilant of the aforementioned risks and strictly comply with regulations, presenting assessment results to the audit committee and reporting to the company’s board of directors every quarter. Additionally, they must promote and instill a sense of consciousness within the organization to work together to develop the company further.

Starting from 2019, our company has been inviting 48 business partners to attend meetings organized by CAC for SME with Mr. Phana Rattanabanangkun represented as a master of ceremony.

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.

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.

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)

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.