Anti Corruption and Bribery

Target 2029
• Member of Thai Private Sector Collective Action Against Corruption
• 100% of employees have been trained and assessed on corporate governance, anti-corruption, and the Code of Conduct.
Target 2024
• Member of Thai Private Sector Collective Action Against Corruption
• 100% of employees have been trained and assessed on corporate governance, anti-corruption, and the Code of Conduct.
Target 2024 Performance
• Certified Member of the Thai Private Sector Collective Action Against Corruption (CAC) since 2013
• 100% the Board of Directors, management and employees surpassed training and assessment on Corporate Governance Policy, Code of Conduct, and Anti-Corruption Policy
Challenges and Opportunities

KTC is committed to the highest standards of integrity and ethical conduct. The Company is aware that misconduct can impact its relationships with internal and external stakeholders. Corruption and bribery present substantial risks, including legal exposure, financial penalties, reputational damage, and the erosion of stakeholder trust. Conversely, by adhering to strict ethical guidelines and implementing a robust anti-corruption program – the Company can ensure a transparent and auditable business that reinforces the confidence of employees, customers, partners, and other relevant stakeholders. The Company’s dedication to preventing corruption and bribery is an essential fundamental component of KTC’s sustainability strategy that enables transparent, accountable, and responsible business operations.

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1.Anti-Corruption and Bribery

Joining the Network Against Fraud and Corruption

The Company has been renewed its certification as a member of the Thai Private Sector Collective Action Coalition Against Corruption or CAC on 30 June 2022.

The Board of Directors approves anti-corruption policy, which forms part of the Company’s corporate governance policy, including anti-corruption measures with an objective to refrain directors, managements, and employees of the Company and its subsidiaries from engaging or accepting any forms of corruption for benefits of their own, friends, or acquaintances or using authority improperly. Anti-corruption policy specifies roles, guidelines, and penalties in the event of corruption, along with processes and channels for whistleblowing or complaints reporting, to ensure that managements and employees at all levels can perform their tasks accurately and appropriately.

As a member of the CAC, the Company operates as follows:

Review the anti-corruption policy and regulations annually.
Evaluate risk controls in work processes.
Establish a framework to prevent corruption.
Provide channels for reporting potential incidents and implement measures to prevent recurrence as well as provide protection for the whistleblower.
Establish anti-corruption definition and practice guidelines in anti-corruption measures which consist of:
1. Corruption
2. Bribery
3. Gifts and Entertainment
4. Political support
5. Donation and Charity
6. Accommodating Fee
7. Conflict of Interest
8. Government Officer
For additional information, please Summary of the Anti-Corruption Procedure refer here “Summary of the Anti-Corruption Procedure”)
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2.Joining the Thai Private Sector Collective Action Against Corruption

Joining the Network Against Fraud and Corruption

The Company has been renewed its certification as a member of the Thai Private Sector Collective Action Coalition Against Corruption or CAC on 30 June 2022.

The Company has received certification as a member of the Thai Private Sector Collective Action Against Corruption (CAC) since 2013, and KTC has consistently maintained its certification renewal till present.

In addition, the Company urges its suppliers to join a network against corruption by sending letters notifying corporate governance policy, which includes anti-corruption policy. The Company also asks its suppliers to comply with KTC Supplier Code of Conduct and invites them to join as member of the CAC.In 2024, the Company sends invitation letters to a total of 209 suppliers.

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3.Code of Conduct

The Company’s Code of Conduct covers policy and operational measures in the following topics:

  • Code of Conduct
  • Message from the Chairman
  • Guidelines for Business Conduct
  • Code of Behavior
    • Protection of Property and the Interests of the Company and Customers
    • Conflict of Interest
    • Confidentiality of Information
    • Gifts, Entertainment, and Other Benefits
    • Rights and Equitable Treatment of Shareholders
    • Disclosure and Investor Relations
    • Anti-Money Laundering and Counter-Terrorism and Proliferation of Weapon of Mass Destruction Financing
    • Treatment of Stakeholders
    • Social Responsibility and Environmental Conservation
    • Occupational Health and Safety Environment
    • Respect for Human Rights
  • Promoting and Monitoring Compliance Code of Behavior
(Please refer to additional details in “Code of Conduct”)

Engagement with Stakeholders

Directors, Management, and Employees
KTC encourages the directors, management, and employees to comply with corporate governance policy, anti-corruption policy, and code of conduct as follows:
  • Require the directors, management and employees dutifully adhere to policy and code of conduct compliance.
  • Require all new employees of the Company and its subsidiaries to sign employment contracts which cover an acknowledgement of compliance of policy, code of conduct, or anti-corruption measures.
  • Provide orientations for the new directors, management, and employees in which topics includes corporate governance policy, anti-corruption policy, code of conduct and important guidelines that the directors, management, and employees should be aware of.
  • Provide trainings and assessment regarding corporate governance, anti-corruption, and code of conduct via animation-based training for management and employees of the Company and its subsidiaries on an annual basis. The training further provides guidance on the proper use of reporting channels on whistleblowing procedures and unethical business practices.
  • Require the principle of integrity and business ethics to be part of the performance appraisal.
 
Suppliers
  • Provide its potential suppliers the Supplier Code of Conduct so that they can evaluate themselves ahead of supplier selection in which crucial topics for self-assessment includes code of conduct, human rights and labor, occupational health and safety environment as well as laws and regulations. In addition, the service contract between the Company and its suppliers shall specifies that suppliers must acknowledge the intention to strictly conduct business with integrity, transparency in compliance with corporate governance, anti-corruption and anti-money laundering principle
  • Specify in the service contract between the Company and suppliers that business cooperation must be conducted strictly with integrity, transparency, and auditability in compliance with corporate governance policy, and abide by laws related to anti-bribery, anti-corruption and anti-money laundering and counter-terrorism and proliferation of weapon of mass destruction financing.

Coverage of Code of Conduct and Supplier Code of Conduct Acknowledgement

Code of Conduct
Code of Conduct
Acknowledge the practice and answer the self-evaluation form.
Supplier Code of Conduct
Acknowledge the practice

    Incident Reporting Channel, Measures to Prevent Incident Recurrence, and Mechanism to Protect Whistleblower

    The Company provides a channel for reporting potential incidents, implementing measures to prevent recurrence, and protecting whistleblowers by maintaining confidentiality and not revealing the whistleblower’s identity

    1. Whistleblowing of Corruption and Breaches of the Code of Conduct
    Information or complaint’s characteristics
    1. Information or complaint’s characteristics
    Complainants or whistleblowers may choose to disclose or withhold their names or personal information , provided that the complaint or information furnished is factual, clear, or sufficient to facilitate further investigation and appropriate action.
    Remarks: Should the complainant or whistleblower submit information that is incomplete, ambiguous, or otherwise insufficient, the Company reserves the right, at its sole discretion, to decline consideration of the matter.
    2. Channels to file complaints and suggestions
    Channels to file complaints and suggestions
    For customers or other stakeholders
    Website: https://www.ktc.co.th,
    Choose Whistleblowing of Corruption and Breaches of the Code of Conduct form
    E-mail: CG_Compliance@ktc.co.th
    Send Letter: Krungthai Card Public Company Limited, (Compliance Department) 591 Samatcha Vanich Building, 14th floor, Sukhumvit Road, Klongton Nua, Wattana, Bangkok 10100 Thailand
    For Employees
    E-mail: Send an email directly to the Board of Directors ,Management , or the Secretary of the Audit Corporate Governance and Sustainability Committee.

    The Board of Directors assigns the Compliance business unit to act as the central unit for providing consultations in case anyone has concerns or requires advice on whistleblowing or complaints concerning corruption and adherence to the Code of Business Conduct. In addition, the Company provides examples of whistleblowing/complaint to facilitate those who need advice

    whistleblowing contact
    3. Considerations
    Considerations

    The Company keeps the whistleblowing complaints confidential and refrains from disclosing the names or personal information of those who made the complaint or have cooperated in the investigation process. Nor will the Company demote, punish, or impose other negative measures on the employees who have refused to be involved in the corruption or Failure to adhere to the Business Code of Conduct, even when such refusal could cost the Company’s business opportunities. The Company also provides fairness to the individuals accused in such matters. The Human Resources business unit, the Compliance business unit, and other independent business units participate in the investigation process while having in place robust mechanisms to protect the whistleblowers’ rights.

    4. Disciplinary Actions
    Disciplinary Actions

    The company takes disciplinary actions according to the Company’s disciplinary rules, i.e. warnings, work suspensions, layoffs, and if such a breach is found illegal, per the law.

    5. Correction, Prevention, and Reporting Process
    Correction, Prevention, and Reporting Process

    The Company has established procedures, preventive measures, and appropriate internal control and risk management systems by having the Internal Audit and the Compliance business units responsible for gathering information related to complaints, risk assessments, inadequate internal controls, or repeated occurrences of corruption-related and business ethics incidents. These units document corrective measures to prevent recurrence or mitigate potential future impacts. A report is then submitted regularly to the Audit, Corporate Governance, and Sustainability Committee for acknowledgment.

    Remarks: The guidelines for disciplinary actions, including procedures and timelines, shall comply with the Human Resources business unit’s operating manual under the “Employees Disciplinary Procedures” section.
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    4.Anti-Money Laundering and Counter-Terrorism and Proliferation of Weapon of Mass Destruction Financing

    As the Company is committed to prevent any individual from using the Company as a channel for money laundering, terrorist financing, and proliferation of weapon of mass destruction financing, policy and measures are established and approved by the Board of Directors in order to ensure that the Company’s business operations are undertaken in accordance with the law and regulations of the relevant government agencies. The policy comprises of :

    Know Your Customer Due Diligence (KYC/CDD)
    Before building customer relationships or conducting transactions, the Company requires customers to identify themselves by providing information and evidence required by the law. In order to assess the risk of money laundering, customer verification both face-to-face and non-face-to-face are undertaken. In the case of high-risk customers, approval from the Company’s senior management or authorized officer is required, alongside with intensive customer verification and regular review of customer information.
    Sanction List Screening
    Before building customer relationships or conducting transactions, the Company must screens customers against Thailand & US Sanction Lists.
    Politically Exposed Person (PEPs)
    The Company regards politically exposed persons (PEPs) as having a high risk of money laundering. In building customer relationships with PEPs, intensive customer verification and regular review of customer information is required, alongside with approval from the Company’s top management.
    Customer Account Activity Monitoring
    The Company requires monitoring and review of customer account activity until the customer relationship is terminated in order to evaluate whether the customer conducts transactions consistent with his or her occupation and the source of income notified to the Company.
    Transactions Reporting
    The Company has in place a reporting process for transactions, namely cash-related transactions and suspicious transactions.
    Record Keeping
    The Company requires the relevant data to be stored for 10 years from the date of account closure or termination of the customer relationship.
    Personnel Training
    The Company organizes knowledge trainings, including assessments to evaluate employee knowledge and understanding in e-Learning format.
    Operational Audit
    Require that the compliance business unit and internal audit business unit as well as Krungthai Bank, in its capacity as parent company, must dutifully audit compliance with the policy on Anti-Money Laundering and Counter-Terrorism and Proliferation of Weapon of Mass Destruction Financing (AML/CFT&WMD).
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    5.Anti- Competitive

    Anti - Competitive Practices

    The Company places importance on conducting business fairly within the framework of the law, with a focus on ethical trade practices, the interests of customers and partners, and fairness in competition with other businesses under the legal framework of trade competition laws. The guidelines for engaging with competitors are outlined in the Corporate Governance Policy and the Code of Conduct, prescribing the commitment to fair business practices and compliance with the competitive framework without defaming, harassing, hampering free market mechanism, impeding or restricting business operation of others, monopolizing the market, or distorting the facts about competitors. Avoid agreeing or discussing with an employee of any entity or other financial business operator about physical location, geography, marketing, interest rate and various fees as well as any product, service or business plan, which may adversely affect business competition of the Company. These guidelines extend to the Company’s trade activities, contractual arrangements, and other business operations

    Number of Past Case (2019-2023)
    7
    The Company has not been fined or found in violation of anti-competitive practices in the past 5 years.
    Number of Present Case (2024)
    7
    The Company has not been fined or found in violation of anti-competitive practices.
    Reporting on Breaches
    7
    In 2024, the Company recorded no incidents of corruption or breaches of the Code of Conduct.

    Annual audit by an independent external agency for the year 2024

    The Company was audited by the Bank of Thailand, as a port of its audit to examine the assets and liabilities of the Bank and companies in its financial business group and compliance audits with the Market conduct and Responsible Lending principles.

    Legal Dispute

    None