Good Corporate Governance
Anti-Bribery and Corruption Policy
1. General Requirement
1.1 Purpose
The policy is established to set a framework for directors, Company’s personnel at all levels, its related persons, and its authorized persons. They are expected to carry out their responsibilities and duties in compliance with the policy, which include preventing, supervising, and refraining from any actions that lead or may lead to corruption as well as avoiding involvement with bribery in order to support the Company’s compliance with relevant laws.
1.2 Scope
The policy applies to operations of the Company and its subsidiaries, collectively referred to as “the Company.” The Company’s personnel, related persons, and authorized persons must study and strictly adhere to this policy. Those who violate it may face disciplinary actions, legal penalties, or termination of contracts.
1.3 Effective Date
This policy shall be effective from the date of approval by the Board of Directors.
1.4 Review Frequency and Revision
This policy must be reviewed annually, or when a significant change arises.
Any significant revisions, review, or renewal of this policy must be considered by the Corporate Governance and Sustainability Committee before being submitted to the Board of Directors for approval.
1.5 Responsible Function
The Compliance Office is the responsible function of this policy.
2. Main Requirement
2.1 Definition
| 2.1.1 | “The Company” means Bangkok Life Assurance Public Company Limited. | |
| 2.1.2 | “Subsidiary” means companies in which the Company holds shares directly or indirectly. | |
| 2.1.3 | “Corruption” means giving or offering money, property, or anything of value to government officials or government agencies, either directly or indirectly, to induce them to act or omit to act in their official capacity, or to abuse their power to gain or maintain the Company’s business. | |
| 2.1.4 | “Bribery” means giving, offering, or receiving money, property, or anything of value to or from government officials or private officers to induce them to act or omit to act in their official capacity, regardless of whether such actions are abuse of power or not, in a manner that goes against laws, moral integrity, or social ethics. Bribery inducement can take various forms, including money, gifts, hospitality, prizes, properties, or any other benefits. The objective is to gain or maintain the Company’s business or personal interests. The Company does not set a minimum monetary amount or value as an exception for giving or receiving bribery in any circumstances. | |
| 2.1.5 | “Company’s personnel” means directors, executives, and employees at all levels of Bangkok Life Assurance Public Company Limited and its subsidiaries. | |
| 2.1.6 | “Company’s related persons” means contractors, agents, advisors, or any persons acting for or on behalf of the Company. |
2.2 General Principle
The Company is committed to conducting its business with moral integrity, adhering to responsibilities to all groups of stakeholders with ethics, honesty, transparency, fairness, and verifiability. The Company participates in the Thai Private Sector Collective Action Against Corruption (CAC) to demonstrate its intention and determination to combat all forms of corruption and bribery. To ensure that the Company’s operations comply with laws and align with good corporate governance principles and international standards on anti-corruption, the Board of Directors has established this Anti-Bribery and Corruption Policy.
2.3 Role, Duty, and Responsibility
| 2.3.1 | The Board of Directors (“BoD”) establishes the policy framework and enforces this policy. | |
| 2.3.2 | The Corporate Governance and Sustainability Committee reviews this policy before the responsible function presents it to the Board of Directors. | |
| 2.3.3 | The Management Committee (“MC”) applies this policy to the Company’s business operations. |
2.4 Requirement
2.4.1 Zero-Tolerance Stance towards Bribery and Corruption
The Company does not endorse the giving or receiving of money, property, or anything of value to influence an act or omission of an act for unlawful gains; and will adhere to all anti-bribery and corruption laws.
2.4.2 Types of Transactions with Corruption and Bribery Risks
Corruption and bribery can take various forms, including but not limited to giving gifts, hospitality, charitable donations, sponsorship, facilitation payment, political contributions, and the employment of government officials.
2.4.2.1 Gifts and Hospitality
Gifts and hospitality can pose risks of corruption and bribery. Therefore, the Company has established the No Gift Policy to raise awareness about these risks and provide guidelines for Company’s personnel to refrain from receiving or giving gifts or hospitality. However, receiving or giving gifts or hospitality in accordance with traditions, guidelines, and the Company’s code of conduct is permitted.
2.4.2.2 Charitable Donations and Sponsorship
The Company supports community participation in social and environmental initiatives to enhance quality of life and promote societal stability. Charitable donations or sponsorship reflect the Company's commitment to community and societal responsibilities, enhancing its positive image. To prevent the pursuit of unlawful benefits, the Company has implemented measures regarding consideration of charitable donations and sponsorship. These measures include assessing the recipients and the purpose of their operations making donations or sponsoring activities. This is to prevent the misuse of these channels for corruption, bribery, or unfairly benefiting the Company or any other individuals. Charitable donations and sponsorship must also fall within the scope of and align with the Company’s regulations and policies concerning the business operations.
2.4.2.3 Facilitation Payment
The Company does not allow facilitation payment that could potentially lead to corruption and bribery.
2.4.2.4 Political Contributions
A political contribution is defined as provision of property, money, objects, rights, or anything of value to assist, support, or provide any other benefits to political parties, politicians, or those with responsibilities related to politics as well as political activities, whether directly or indirectly.
The Company maintains political neutrality, not providing political support to political parties, whether directly or indirectly.
2.4.2.5 Employment of Government Officials
The Company considers the employment of government officials based on appropriateness and through its established processes, ensuring that there are no conflicts of interest or opportunities for corruption or bribery. Additionally, the Company assesses the timeframe within which government officials must be discharged from their former positions before applying for a position within the Company.
2.4.3 Corruption and Bribery Prevention Measures
The Company conducts regular assessments of corruption and bribery risks. Company’s personnel must study the nature and types of transactions that may lead to corruption or bribery in order for the Company to be able to appropriately handle potential corruption and bribery incidents that may arise from its operation.
Company’s personnel and those related to the Company must honestly and strictly adhere to the policy, not being involved in or ignoring corruption and bribery incidents. Personnel and related persons who witness corruption, bribery, or incidents that may lead to corruption or bribery must promptly report them to executives, their supervisors, or whistleblowing channels provided by the Company, and cooperate in the investigation.
Company’s personnel, related persons, and authorized persons who refuse to engage in acts that could be deemed as corruption or bribery will not face demotion, punishment, or any negative repercussions, even if the refusal results in loss of business opportunities for the Company.
To establish a concrete process for combatting corruption and promote a transparent corporate culture, the Company has developed an Anti-Bribery and Corruption Guideline under this policy and implemented a regular review schedule.
2.5 Penalty
Violation of this policy is considered violation of the Company’s Code of Conduct for All Personnel and may constitute an offense against the Company's rules, as well as other applicable laws, regulations, rules, or requirements.
