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

Maintain the standard of anti-corruption operations evaluated by the CAC.
Communicate knowledge and evaluate the knowledge of anti-corruption measures to 100% of the personnel in the Company and its subsidiaries.
Communicate and express the Company’s stance against corruption to 100% of all business partners.
Continue being a contributor of Thai Private Sector Collective Action Against Corruption (CAC) and invite at least ten companies to join.

Manage corruption-related risks and review operational procedures to ensure transparency, accountability, and the prevention of corruption in the following processes:

  1. Customs procedures for importing raw materials from ports.
  2. Procurement of raw materials for production from suppliers.

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:

  1. In accordance with GRI Standard 205-2 regarding communication and training about anti-corruption policies and procedures.
  2. 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:

  1. AP (Thailand) Public Company Limited
  2. Bangkok Commercial Asset Management Public Company Limited
  3. Blue Solution Public Company Limited
  4. Central Plaza Hotel Public Company Limited
  5. Charoen Pokphand Foods Public Company Limited
  6. CP All Public Company Limited
  7. Ichitan Group Public Company Limited
  8. KCE Electronics Public Company Limited
  9. Mitr Phol Sugar Corporation Limited
  10. Sabina Public Company Limited
  11. Siemens Energy Limited
  12. Sri Trang Agro-Industry Public Company Limited
  13. Starflex Public Company Limited
  14. Supalai Public Company Limited
  15. 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

Ensure compliance with business ethics and codes of conduct within the organization.
Communicate and promote business ethics and codes of conduct to all employees within the organization to achieve 100% awareness.
Ensure that employees understand business ethics and codes of conduct by measuring their knowledge through a test with a minimum score 80%.
Conduct surveys with stakeholders, including customers, partners/creditors, society, and the environment, aiming for a combined rating of “very good” and “good” at 90% or higher.

Operations to ensure compliance with the Code of Conduct

1. Specify that all board members, executives, and employees must be informed, understand, and comply with the codes of conduct strictly. Anyone who violates the established code of conduct will be subject to strict disciplinary action and may also face legal consequences if the act is unlawful.
2. Establish measures for reporting grievances, complaints, violations of the law, code of conduct, or behavior that may lead to corruption or misconduct of the Company’s personnel, related parties, and stakeholders, and protect whistleblowers by providing channels for filing complaints and suggestions through the internal audit department responsible for receiving complaints and suggestions.
3. The board of directors requires an annual review of the code of conduct manual, and requires a report on compliance with the code of conduct to be submitted to the audit committee and the board of directors.
4. Conduct training and publicizes the business ethics and the code of conduct of the Company to ensure that employees in the organization are aware of and understand, through bulletin boards and the creation of brochures/posters for public dissemination.
5. Review the knowledge and understanding of business ethics and the code of conduct among all employees in the organization through a test for all employees

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.

which is
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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%.

Scored
0 %
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%.

Scored
0 %
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%.

Scored
0 %

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

Conduct ESG assessments in the supply chain for the top 100 suppliers based on raw material purchase value

  • Onsite audit for strategic suppliers: >50% of the top 20 raw material purchase suppliers.
  • Questionnaire audit for key suppliers: >50% of the next 80 raw material purchase suppliers.
Achieve ESG assessment results in the supply chain at levels >80%.

Guideline

1. Select new suppliers based on supplier qualifications and ESG performance evaluation, with the following assessment criteria:

  1. Environment

    Waste management, adoption of sustainable materials, procurement of renewable energy, water sourcing and wastewater treatment, and air pollution control.

  2. Social

    Compliance with general/labor laws, child labor usage, forced labor usage, and human rights.

  3. 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:

Strategic Supplier

The top 20 suppliers with the highest raw material purchase value will undergo onsite ESG audits.

Key Supplier

The next 80 suppliers with the highest raw material purchase value will undergo ESG evaluations through questionnaires (Questionnaire ESG Audit).

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.

Performance Results for 2024

Conduct ESG assessments in the supply chain for the top 100 suppliers based on raw material purchase value.

  • Onsite audit for strategic suppliers: Achieved 11 out of the top 20 raw material purchase suppliers in 2024, meeting the target.
  • Questionnaire audit for key suppliers: Achieved 41 out of the next 80 raw material purchase suppliers in 2024, meeting the target.
ESG assessment results in the supply chain: Achieved an average score of 81% for 41 suppliers, meeting the target.