Anti-Corruption and Anti-Bribery Policy
GC Maintenance and Engineering Company Limited (the “Company”) prioritizes anti-corruption and is committed to complying with all laws regarding the prevention and countering of fraud, corruption, and bribery involving both domestic and foreign government officials, as well as private sector personnel. Furthermore, the Company encourages and promotes anti-corruption awareness among personnel at all levels in every form.
The Board of Directors has therefore established this policy to ensure that directors, executives, staff, employees, and any persons acting on behalf of the Company uphold this policy as a standard for their conduct. Any action that fails to comply with the Company’s policy shall be subject to disciplinary action as well as relevant legal penalties.
Definitions
Fraud refers to any act performed to seek unlawful benefits for oneself or others, which includes embezzlement, accounting manipulation, and corruption.
Corruption refers to any act—whether offering, promising, requesting, demanding, giving, or receiving assets or any other benefits—involving government officials or any other persons doing business with the Company, whether directly or indirectly, to induce such persons to perform or refrain from performing their duties, or to obtain or retain any other improper business advantages. Exceptions apply only where permitted by law, regulations, rules, local customs, or commercial traditions.
Giving or Receiving Gifts refers to the giving or receiving of money, objects, remuneration, or any other benefits.
Hospitality and Business Entertainment refers to expenditures on business entertainment, such as food and beverages, sporting activities, and other expenses directly related to business operations or commercial traditions, including the provision of business knowledge and insights.
Donations and Sponsorships refer to the provision of financial support, products, or services to recipients of such support or donations for the purpose of public benefit or to promote the business and corporate image of the Company.
Political Contributions refer to the provision of assets, money, items, rights, or any other benefits to assist, support, or benefit political parties, politicians, or persons involved in politics, as well as political activities, whether directly or indirectly.
Conflict of Interest refers to any action in which an individual has a personal interest that conflicts with the interests of the Company, whether arising from dealings with the Company’s business associates, or from exploiting opportunities or information gained through their employment for personal gain. This includes engaging in business that competes with the Company or undertaking outside work beyond Company duties that adversely impacts their official responsibilities.
Facilitation Payments refer to unofficial payments made to government officials solely to ensure that they perform routine administrative actions or to expedite processes that are within their legal duties. Such processes must not involve the discretionary power of the official and must be actions to which the legal entity is already entitled by law, such as applying for permits, requesting certificates, or receiving public services, etc.
Government Official refers to persons holding political office, civil servants or local government employees holding positions or receiving regular salaries, employees or personnel working in state enterprises or government agencies, local executives and members of local councils who are not political office holders, officials under the Local Administration Act, and shall include directors, sub-committee members, employees of government agencies, state enterprises, or state agencies, as well as any individuals or groups of individuals exercising state administrative power or assigned to exercise such power under the law to perform any action, whether established within the bureaucracy, state enterprises, or other state affairs.
The Company refers to GC Maintenance and Engineering Company Limited.
Related Persons refer to spouses, children, parents, siblings, close relatives, friends, and acquaintances of the Company’s directors, executives, and employees at all levels.
Policy
Board of Directors, executives, staffs, employees, and any persons acting on behalf of the Company have a duty to comply with the laws, rules, and regulations concerning anti-corruption, as well as the Corporate Governance and Business Code of Conduct, policies, regulations, and guidelines established by the Company. All duties must be performed with transparency, without any intent to engage in fraud or corruption. Soliciting, facilitating, or accepting corruption for the benefit of oneself or related persons, including friends and acquaintances, is strictly prohibited. Furthermore, personnel must be always prepared for the auditing of their performance by authorized auditors or relevant agencies.
Guidelines and Implementation Measures
- The Company maintains a process to review, audit, and improve anti-corruption measures, reporting to the Board of Directors annually to evaluate effectiveness and update measures in alignment with evolving corruption risks.
- The Company conducts corruption risk assessments and implements risk prevention measures across Operational Control, Environmental Control, Financial and Accounting Control, and document retention.
- The Company maintains internal control audit processes regarding financial reporting, accounting procedures, and data retention, including procedures for the expedited reporting of internal audit findings to senior management and the Board of Directors.
- The Company maintains political neutrality and has no policy to provide financial support, resources, or other assets, directly or indirectly, to politicians, political parties, or political groups for their benefit.
- The Company prohibits facilitation payments in any form, whether direct or indirect, and will not take any action or accept any acts in exchange for business facilitation.
- The Company does not hire current or former government officials, politicians, or government advisors to mitigate risks of “quid pro quo” or reciprocal benefits.
- The Company’s human resources management—including recruitment, selection, performance evaluation, compensation, and promotion—reflects its commitment to anti-corruption.
- The Company will not demote, penalize, or adversely affect personnel who refuse to participate in fraud or corruption, even if such refusal results in a loss of business opportunity. This commitment is clearly communicated to all employees.
- Personnel must avoid any actions that conflict with the Company’s interests. All actions must be reasonable, prioritize the Company’s benefit, and comply with relevant laws and regulations. Any potential conflict of interest must be reported through the Company’s designated channels.
- The Company continuously communicates anti-corruption measures to personnel and related stakeholders, such as business agents and partners.
- The Company provides continuous anti-corruption training and education to its personnel.
- Implementation of this policy shall follow the guidelines stipulated in the Corporate Governance and Business Code of Conduct, as well as the Company’s rules, policies, and regulations.
- The Company regularly reviews this policy to ensure compliance with legal and regulatory changes, submitting updates to the Board of Directors for approval.
In case of inquiries regarding this policy, guidelines, or measures, please contact the Office of the Managing Director at 038-977800 ext. 78915.
Penalties
- The Company shall impose disciplinary actions against directors, executives, and employees who fail to comply with anti-corruption measures. Such penalties include removal from office for directors or termination of employment for executives and employees, as deemed necessary by the Company.
- In the event that related parties fail to adhere to the Anti-Corruption measures, the Company reserves the right to terminate the legal relationship. This is due to the fact that any involvement in corruption may severely compromise the Company’s reputation and corporate image.
Announced on 11 May 2022
(Mr. Wiboon Chuchepchunkamon)
Chairman