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Anti-Bribery and Corruption

Anti-Corruption of Interlink Telecom Public Company Limited

Interlink Telecom Public Company Limited was certified as a member of Thailand’s Private Sector Collective Action Coalition Against Corruption: (CAC) and was certified on 12 November 2019. Which the certificate will valid for 3 years from the date of approval. Which reinforces that the company have taken important steps and principles of the guideline of anti-bribery and corruption policy as a guideline for business operations. Such as setting guidelines for charitable donations and sponsorships Human Resources Management, without any action within the scope of a bribe or corruption by directly or indirectly. Which the company has added intention to the corporate.

Definition

Corruption means bribery of any form by offering a promise, commitment, or commitment of money, property, or any benefit that is not appropriate for a government official, government agency, and stakeholders with direct or indirect duties. In order that, for the person to act or omit to perform the duty which is to obtain or maintain any other improper business benefits of anti-corruption policy.

Anti-Corruption Policy of Interlink Telecom Public Company Limited

Interlink Telecom Company Limited and affiliates dedicated to conducting business in accordance good corporate governance and corporate governance principles, with a focus on anti-corruption. Including adhering to the principles of morality, morality, ethics, code of conduct and good governance. Transparent management and responsible to all stake holders. In this regard, the company has specified guidelines for the proper conduct of the advisory committee, executive subcommittee, employees of the company in business ethics and employee ethics. Which is a part of the corporate governance of the company. For ensure that the company has a policy to specify guidelines, regulations, and channels of complaint to prevent corruption. Including decisions and conducting business that may be risk with corruption has been considered and implement by carefully. Therefore, has established a “Anti-Corruption Policy” in writing so as to be guideline for business operations. Directors, executives, and employees will not commit or accept any form of corruption either directly or indirectly. Which covers every business of the company in all categories and all related departments by the company. As well as providing reviews and regularly review the implementation of the anti-corruption policy.

Responsibility

  1. 1.Board of Directors

    Board of Directors have duties and responsibilities in determining policy and supervise to have an efficient system to support anti-corruption and instill it into the culture of the organization. Board of directors responsible for giving advice recommendations for penalties and jointly find solutions to problem for the chief executive officer and executive committee.

  2. 2.The audit committee’s duties and responsibilities as follows

    2.1 To review the anti-corruption policy received from the executive committee to be suitable for the business model, its environment, its culture and present to the board of directors for the approval.

    2.2 To review whether the change of the anti-corruption received from the executive committee is appropriate or not. Then it needs to be presented to the board of directors for approval.

    2.3 To review and ensure that the financial report, the internal system control, the internal audit and the risk management system correspond appropriately with international standard, modern including with efficiency.

    2.4 To perform the duties of reporting any clue in association with the corruption in the organization involved by it’s officers and ensure any information received then propose to the board of directors for the punishment or revision.

  3. 3.The internal audit department’s duties and responsibilities as follows

    3.1 To review and consider the performance according to the internal audit plan goes correctly along with its policy to ensure that the control system is appropriate and enough to resist the fraud and corruption that may occur and report directly to the audit committee.

  4. 4.Chief executive and the executive committee’s duties and responsibilities as follows

    4.1 To establish the system as well as the policy according to the anti-corruption issue including the policy’s support.

    4.2 To communicate with the personnel in the organization and the relevant people to be aware of the anti-corruption policy.

    4.3 To review the suitability of the systems and measures including the anti-corruption policy to be appropriate according to the business changes and the legal requirements.

    4.4 To corporate with the audit committee to investigate the fact as notified or any assignments received from the audit committee relating to the corruption by assigning the tasks to the management team that could help to figure out the fact.

Practice Guidelines According to Anti-Corruption Policy

  1. 1.Gifts, souvenirs or other benefits

    1.1 Offering gifts or souvenirs by any occasion must be by the employee’s code of ethics. For example, the limit price for Thailand is not more than 3,000 baht per person ruled by (NACC) The National Counter Corruption Commission and it should be provided in a form that helps to promote the company’s image as follows:

    • Calendar or diary

    • Products used as public relations media

    • Royal project products, community products, charity or public interest products or products that support sustainable development.

    1.2 Offering gifts or souvenirs should be applied by the same standard to prevent discrimination.

    1.3 Avoid giving gifts, souvenirs, fees or other advantages to spouses, children, related persons of government officials, customers, business partners and the persons who are considered as a substitute.

    1.4 Offering souvenirs as important business events such as the establishment day, the business contract signing day could be accepted if the gift’s value does not exceed 3,000 baht and it must be approved by the chief executive or according to with the company’s regulation.

  2. 2.Entertainment The expense of the business

    Entertainment The expense of the business receptions including food and beverages and other sports receptions related to the business or business practices. Proving business knowledge is included but it must be a reasonable expense and it does not affect the decision to cause any conflicts of interest.

  3. 3.Carry out CSR activities with government organizations or government officials.

    3.1 Organizing CSR with government organizations or government officials could be done appropriately on behalf of the company. Its objective must be corresponding with the company’s CSR policy. Furthermore, there should be a process, clear evaluation proceeding through the company’s regulations.

    3.2 Organizing CSR or any activities on behalf of the company is forbidden if it involves supporting politics.

  4. 4.Accepting gifts, souvenirs or other benefits

    4.1The company’s employees are banned from accepting gifts, souvenirs or other benefits and it’s their responsibility to inform the outsiders about the policy too.

    4.2If it’s in the necessary case to accept the gift that can not be returned, the company must appoint the responsible department to collect and donate them to others or the external organization for charity or public benefit or perform by the company’s regulations except.

    • In case it is food with a less than the 1-month expiration date, this shall be up to the discretion of the supervisor who receives the gift.

    • In case it is a calendar or diary published for public relation purposes, the employee could own it.

    • In case you receive the gifts or souvenirs in the name of the organization to an organization such as signing a business contract could be accepted. So, these gifts and souvenirs must belong to the company.

  5. 5.Accepting meeting proposals, meetings, training and business visits using business partner’s budget

    5.1 Accepting meeting proposals, meetings, training and business visits using the business partner’s budget can proceed if it follows the contract but it must not have another hidden tourism purpose.

    5.2 Accepting meeting proposals, meetings, training and business visits using the business partner’s budget if it’s appropriate and beneficial for the company. It must be approved by the supervisor and the company’s regulation. The company will not accept the proposal relating to the meetings or seminars for traveling without the knowledge transfer purpose.

  6. 6.Supporting traveling

    Supporting traveling and other expenses for the government officials can proceed appropriately along with the company’s regulation.

  7. 7.Donating and supporting the government organization

    Donating and supporting the government organization or government officials including the non-profit organization, the charity, and other supports must be proceeded by the followed conditions

    7.1 It’s a reliable organization and/or it’s established legally.

    7.2 All processes must be done on behalf of the company in a legal manner and according to the company’s regulations.

    7.3 Do not pay directly to the government officials or any person unless there is a clear description of the request of the support and there is written evidence.

    7.4 There should be the monitoring step to ensure that the donation or the supports have been used for donation purposes or the company’s personnel support. There should also understand the gifts and entertainment policy or other benefits. If there is any doubt, contact the company secretary or the responsible department.

Practice Guide to Complaint and Clue Handling

The company provides channels for complaints, comments or suggestions from those who are affected from the company or from the performance of the management crew or the officers involving the illegal acts or failure to comply the company’s rules and the acts considered fraud or corruption, please notify the company to conduct further investigation.

Complaints and Whistleblowing

When witnessing some acts that violate and do not comply with the code of conduct including corruption acts that may represent corruption or illegal. The questions and complaints should be sent to the following people.

  1. Managing Director

  2. Supervisors that they trust at all levels

  3. Vice President of Internal Audit

  4. The Board of Directors

Where to Contact to Report Clues and Complaints

  1. Company secretary
    E-mail : secretary@interlinktelecom.co.th
    Tel : 0 2666 2222 ext. 200
    Fax : 0 2666 2299

  2. The chief of the audit committee
    Mrs. Kesara Manchusree
    E-mail : m.kesara@interlinktelecom.co.th

  3. Website : www.interlinktelecom.co.th

  4. E-mail : info@interlinktelecom.co.th

  5. Mailing : 48/66 Soi Rung-Reung Ratchadapisek Road, Samsennok, Huay Khwang, Bangkok 10310

Process for Receiving Complaints

The company has the following practices when receiving complaints

  1. Complaints received by the company, the recipient will appoint the responsible people appropriately and will screen, investigate and consider the offenses related to violation or non-compliance with the code of ethics. In the case of the accused is the executive director of the company, the person who complains must file a complaint about the audit committee.

  2. Propose to the president to consider the appointment of an investigation consisting of skilled and fair experts to investigate complaints.

  3. The investigation committee proceeds to gather the information through interviews and document verification.

  4. The investigation committee processes and judges the facts to consider appropriate management procedures and methods.

  5. The investigating committee establishes the measures to alleviate the damage of those affected and report the result to the president to report to the board of directors.

  6. The investigating committee reports the result to the complainants if they disclose themselves.

Security and Confidentiality Measures

Security and confidentiality measures to the reporters or the complainants who cooperate in reporting violations of the code of ethics. Both will be protected and fair by providing information or useful clues to the company relating to the corruption, non-compliance with the laws and regulations issued by the company.

  1. Reporters or complainants could choose not to disclose their names if it leads to insecurity or any damages. But if they are willing to disclose themselves, the company will conveniently and quickly report the result or relieve the damages.

  2. The company will keep the data confidentially and it will disclose in case of it is necessary for those who are responsible by considering the safety and damage of the reporters or the relevant people.

  3. In case of the complainants consider about the unsafe situation or it may cause damage, they can ask for the company to apply the appropriate protection measure. Determine appropriate protection or the company may specify protection for the complainant without requested if it’s matter likely to cause of damage or insecure. The person who suffered from damage will be alleviated with appropriate and fair procedures.

Dissemination of Anti-Corruption Policy

Employee in the company must be aware of the anti-corruption policy, the company has taken the following actions.

  1. The company announces the anti-corruption policy prominently in the office building.

  2. The company disseminate the anti-corruption policy through the company’s channels such as website, e-mail, annual report, sustainability report, forms 56-1

  3. The company will hold the anti-corruption policy training to the new officers.

  4. The company will revise the anti-corruption policy continuously.