Arahant Anti-Fraud Procurement Policy

Policy and Guidelines for Prevention of Fraud in Procurement

Arahant (Thailand) Co., Ltd. is committed to conducting business with integrity, adhering to social responsibility and responsibility toward all stakeholder groups in accordance with good corporate governance. The Company manages its business on the basis of transparency and ethics, upholds the principles of good corporate governance, and complies with laws related to the prevention and opposition of fraud and corruption.

To ensure that the Company has policies, responsibilities, practices, and operating requirements that are appropriate for preventing fraud and corruption in all business activities, and to ensure that business decisions and operations that may involve anti-corruption risks are considered and carried out carefully, the Company has prepared this Anti-Corruption Policy in writing as a clear guideline for business conduct.

Definitions

Fraud means seeking an improper benefit, unlawfully or wrongfully, for oneself or another person.

Corruption means giving, promising to give, receiving, or demanding assets, whether in the form of documents, information, money, or any other improper benefit, in order to induce a person to act or refrain from acting so as to obtain or retain business or any improper benefit for oneself, associates, or the Company, whether directly or indirectly. It also includes any act that conflicts with or is contrary to the Company’s Code of Conduct. Such acts include the following:

1. Giving and receiving gifts, entertainment, hospitality, and other forms of service means expenses paid for items, entertainment, hospitality, and related expenses that have monetary value, including things that can be exchanged for goods or services. Waiving the right to receive items or services to which the Company is entitled means waiving a benefit that the Company should receive from customers, business partners, and/or business-related persons, whether or not it has monetary value.
2. Unlawful political assistance means financial assistance or services in any form that are unlawful.
3. Charitable donations and sponsorships mean donating or supporting money, goods, or any other benefit to any person or juristic person with an unlawful hidden purpose, or sponsorship intended for the business, brand, or reputation of the donor.

Operating Guidelines

1. The Board of Directors is responsible for establishing the policy and supervising the anti-corruption policy so that it is efficient and effective, and to ensure that management recognizes and gives great importance to the policy. If any report of fraud or corruption occurs within the organization, management is responsible for giving consultation and recommendations and for determining penalties according to the submitted report.
2. Executives and assigned persons shall review the business lines or departments under their supervision by assessing risks that could give rise to fraud and corruption, in order to ensure that the responsible business lines have the lowest possible risk, or no risk, of fraud and corruption, and shall jointly determine measures to close such risks if they exist in the organization.
3. Executives, supervisors, or assigned persons shall perform duties in accordance with the policy and the audit plan, and shall submit reports on assessments of fraud and corruption risks that may arise in their responsible departments or functions to the Audit Committee.
4. Executives and supervisors shall communicate with personnel in the organization, or persons involved with the organization, so that they are thoroughly informed and understand the anti-corruption policy.
5. Executives, supervisors, employees, and persons involved with the Company shall strictly comply with the anti-corruption policy and shall uphold the Code of Conduct in their work. They must not become involved in fraud or corruption in any form, whether directly or indirectly. They shall not be penalized, whether by demotion or any adverse consequence, for refusing corruption, even if such refusal causes the Company to lose a business opportunity.
6. Do not give or receive items, gifts, entertainment, services, assets, or any other benefits from persons with whom one contacts or coordinates, including government agencies, private organizations, or any other agencies, in a manner that induces an omission or dereliction of one’s own duties or the duties of others.
7. Do not act as an intermediary in offering any benefit, whether money, goods, or assets, to any person involved in the business in exchange for an improper privilege.
8. Executives and employees shall not ignore or neglect any act that may constitute corruption involving the Company. They shall notify their supervisor or the responsible person and cooperate in fact-finding investigations.
9. Procurement activities shall strictly comply with the procurement procedures in order to ensure transparency and auditability at every step.
10. Executives and employees shall not take any action that may cause the Company to be perceived as politically biased. The Company is an organization that upholds political neutrality, supports compliance with the law, and supports democratic governance with the King as Head of State. The Company does not support any political party, whether directly or indirectly.
11. Expenses for business entertainment and other expenses related to the performance of business contracts may be incurred, but they must be reasonable, must not suggest corruption, and must be auditable.
12. Donations or sponsorships of various projects may be made, but only in the name of the Company. Whether made to a project or charitable organization, such donations must be made to credible and verifiable projects or organizations. Disbursements must have a clear objective and must follow the Company’s proper disbursement procedures.
13. The Board of Directors shall regularly review the operating guidelines and measures to ensure that they remain consistent with changes in law and business conditions.

Corporate Communication

To ensure that everyone in the organization is informed of the policy and guidelines for the prevention of fraud in procurement, the Company shall communicate the anti-corruption policy through the Company’s communication channels, such as electronic mail (E-mail) and internal Company announcements.

Whistleblowing or Complaint Channels

Complaints may be made regarding any act that may raise suspicion of fraud or corruption involving the Company, whether directly or indirectly, through the channels specified in this policy. The complainant shall provide details of the whistleblowing matter or complaint, together with evidence or information sufficient for investigation, and shall provide a name, address, and telephone number where the complainant can be contacted. Reports may be submitted through the following channel:

Penalties

Any employee or business-related person who violates or fails to comply with the policy and guidelines for the prevention of fraud in procurement or bribery shall be subject to severe disciplinary action, including dismissal or termination of the employment contract, as the case may be. In addition, such person may be prosecuted under the applicable anti-corruption laws. The Company shall determine the penalty as appropriate.

Arahant (Thailand) Co., Ltd.
(Ms. Rassarin Rungsiriworasak)
Managing Director
Date: 4 January 2022