Objective
To demonstrate the intent and firm commitment to opposing all forms of corruption, and to ensure consistency with the Corporate Governance Policy and the Anti-Corruption and Anti-Bribery Policy, GC Maintenance and Engineering Company Limited (the “Company”) has established the Gifts, Hospitality, Charitable Contributions, and Sponsorships Policy. All executives and employees at all levels are required to strictly adhere to this policy as a fundamental standard of conduct. This is to ensure that the Company’s business operations are transparent, accountable, and maintained under clear and appropriate operating standards in compliance with relevant laws and regulations. This policy shall be deemed an integral part of the Company’s Corporate Governance and Business Code of Conduct.
Principles
GC Maintenance and Engineering Company Limited (the “Company”) is committed to conducting its business ethically under the principles of Corporate Governance and Business Code of Conduct. The Company treats all stakeholders with equity and transparency, strictly avoiding any actions that may lead to discrimination or Conflict of Interest and to ensure alignment with the Anti-Corruption and Anti-Bribery Policy.
The Company has therefore established the Gifts, Hospitality, Donation, and Sponsorship Policy. This policy is intended for personnel at all levels (directors, executives, and employees) to utilize as a guideline for the giving and receiving of gift, hospitality, donation, and sponsorship. This ensures alignment with the principles of Corporate Governance and Business Code of Conduct, thereby establishing high standards for transparent and efficient operations conducive to sustainable growth.
Definitions
Gift refers to the giving or receiving of money, items, compensation, or any other benefits to or from others, in the name of the Company or as a representative of the Company.
Hospitality refers to expenditures on business entertainment, such as food and beverages, sporting events, and other expenses directly related to business practices or commercial customs, including the provision of business knowledge and understanding.
Donation and Sponsorship refer to the provision of financial support, products, or services to recipients of such support or donations, with the objective of providing public benefit to society or promoting the business and corporate image of the Company.
Guidelines
- Giving Gifts, Souvenirs, Assets, or Any Other Benefits
1.1 The giving of gifts, souvenirs, or any other benefits in accordance with traditional customs is permissible, provided that it does not violate relevant domestic and international laws and regulations. For instance, in Thailand, the provision of assets or any other benefits to government officials must not exceed a value of 3,000 Baht per person, per occasion. Furthermore, any gifts, souvenirs, assets, or other benefits provided to external parties must be for the purpose of promoting the Company’s corporate image.
1.1.1 Calendars, diaries, or the Company’s products.
1.1.2 Products used as the Company’s public relations and promotional media.
1.1.3. Products from Royal Projects, Royally-initiated projects, community products within the Company’s operational areas, or products for charitable and public interest purposes, or products that support sustainable development.
1.2 The giving of gifts, souvenirs, assets, or any other benefits on significant business occasions—such as company anniversaries or the signing of business contracts—is permissible. If the value is less than 3,000 Baht, it must be reviewed and approved by an executive (Vice President Level or equivalent). If the value is 3,000 Baht or more, it must be reviewed and approved by Deputy Managing Director or Managing Director.
1.3 The giving of gifts or souvenirs should be conducted in a standardized manner to avoid discrimination. No gifts, souvenirs, assets, or any other benefits shall be given to the spouses, children, adopted children, or related persons of government officials, customers, business partners, or any individuals with whom the Company conducts business, as such circumstances are considered as receiving on their behalf.
1.4 Monitoring and audits shall be conducted to ensure that the giving of gifts, souvenirs, assets, or any other benefits strictly complies with the Gifts, Hospitality, Donations, and Sponsorship Policy - Acceptance of gifts, souvenirs, assets, or any other benefits
2.1 The Company’s personnel must refrain from accepting gifts, souvenirs, assets, or any other benefits in all circumstances. The Company shall communicate this no-gift policy to its personnel and external parties, such as business representatives and business partners, through appropriate communication channels.
2.2 In cases where it is not possible to refuse the acceptance of gifts, souvenirs, assets, or any other benefits, and such items cannot be returned, the recipient shall prepare a report on the receipt of such gifts, assets, or benefits and submit both the report and the received items to their supervisors in the line of command for consideration and appropriate action.
If the supervisors in the line of command determine that the items should not be accepted, they shall collect such items and donate them to external individuals or organizations, or submit them to the Corporate Strategy and Corporate Affairs Department for further donation to charitable or public benefit purposes, except where otherwise specified.2.2.1 In the case of consumable items with an expiration date of less than one month, the management of such gifts shall be at the discretion of the Division Manager who received them.
2.2.2 In the case of calendars, diaries, or items featuring the other company’s logo used for public relations purposes, employees are permitted to accept them as personal gifts.
2.3 In the case of receiving gifts or souvenirs on an organization-to-organization basis—such as during the signing of a business contract-such actions are permissible. However, all such gifts and souvenirs must be considered the property of the Company.2.4 Monitoring and audits shall be conducted to ensure that the acceptance of gifts, souvenirs, assets, or any other benefits strictly adheres to the Company’s regulations and procedures.
- Hospitality and reception arrangements
3.1 Expenses for business hospitality—such as food and beverages, sports-related hospitality, and other expenses directly related to business operations, commercial customs, or business educational purposes—are permissible. However, such expenses must be reasonable, have clearly defined pricing, and must not influence operational decision-making or lead to a conflict of interest.
3.2 Monitoring and audits shall be conducted to ensure that business hospitality is utilized strictly in accordance with the Company’s objectives, and that the Gifts, Hospitality, Donations, and Sponsorship Policy is strictly adhered to.
Conducting CSR activities in collaboration with government agencies or government officials.
4.1 Conducting CSR activities in collaboration with government agencies or government officials is permissible as appropriate. Such activities must be carried out in the Company’s name and align with the Company’s CSR policy. Furthermore, there must be clear criteria, work plans, and performance measurements in place, and all actions must strictly follow the Company’s established procedures.
4.2 The organization of CSR activities or any other activities in the Company’s name must not involve any activities related to the support of political parties.
4.3 Monitoring and audits shall be conducted to ensure that CSR activities are carried out appropriately and genuinely meet the Company’s objectives, and that the Gifts, Hospitality, Donations, and Sponsorship Policy is strictly adhered to.Accepting proposals for meetings, training, seminars, and site visits funded by business partners.
5.1 Acceptance of proposals for meetings, training, seminars, and site visits is permissible, provided that they are explicitly specified in the contractual agreement and do not involve any hidden tourism or leisure activities.
5.2 In cases where it is not specified in the contractual agreement, the acceptance of proposals for meetings, training, seminars, and site visits is permissible provided that it serves the best interests of the Company. Such acceptance is subject to prior approval from the relevant supervisor and must strictly comply with the Company’s regulations.
5.3 Proposals for training or seminars that involve hidden tourism, without a genuine intent to transfer knowledge, shall not be accepted.- Sponsorship of travel expenses and other costs for government officials.
6.1 The Company has no policy to provide direct payment for travel expenses or any other costs to government officials under any circumstances.
- Donations and sponsorships provided to government agencies, government officials, or charitable organizations.
7.1 Donations and sponsorships provided to any organization must be conducted under the following conditions:
7.1.1 The organization must be a reputable entity and/or legally established.
7.1.2 The procedures must be carried out in the Company’s name with transparency, in compliance with the law, and in accordance with the criteria established by the Company.
7.1.3 Direct payments shall not be made to government officials or any individuals in their personal capacity, unless clearly specified in a formal request for sponsorship and supported by written evidence of receipt.
7.1.4 Such actions must not be for the purpose of providing political assistance and must strictly adhere to the Gifts, Hospitality, Donations, and Sponsorship Policy.
7.1.5 Monitoring and audits shall be conducted to ensure that donations and/or sponsorships are utilized for public benefit and/or genuinely meet the intended objectives of such contributions, and are not used as a pretext for bribery.
Announced on November [ ], 2024
(Mr. Sarawuth Nuntavadeepisarn)
Managing Director
Precautions
- Company personnel should study and understand the guidelines and strictly adhere to the Good Corporate Governance and Business Code of Conduct Manual, as well as the Anti-Corruption and Anti-Bribery Policy.
- Any violation or failure to comply with the relevant policies, guidelines, or regulations will result in disciplinary action in accordance with the Company’s Work Rules and Regulations. In cases where such actions may involve corruption or constitute a legal offense, personnel at all levels who witness such conduct are obligated to report the matter through the Company’s Whistleblowing channels.
- Should you have any inquiries or require further information, please contact the Corporate Strategy and Corporate Affairs Department, GC Maintenance and Engineering Co., Ltd., at Tel. 038 977 800 ext. 78915.