Anti Corruption and Bribery

Anti Corruption and Bribery

Long-Term Target 2028
The Company has renewed its membership with the Thai Private Sector Collective Action Against Corruption or CAC continuously.
Target 2023
The Company has renewed its membership with the Thai Private Sector Collective Action Against Corruption or CAC continuously.
Performance 2023
Continuous renewal of certification since 2016
Risk

If the Company does not have efficient means to protect and control corruption and bribery, these are not only illegal acts, but the Company will also be affected by reputation loss.

Opportunity

Stringent and efficient anti-corruption measures can help ensure transparency and auditability in the Company’s operation, thereby contributing to confidence of every stakeholder group.

The Company places great importance on conducting business with integrity and commitment to responsibility to all stakeholders.

The Company places great importance on conducting business with integrity and commitment to responsibility to all stakeholders. The Company also follows the good corporate governance and code of conduct in order to be transparent and be free from all forms of corruption, including not being used as a mean for money laundering.

Anti-Corruption and Bribery
Anti-Competitive
Anti-money laundering and Counter-Terrorism and Proliferation of Weapon of Mass Destruction Financing
Code of Conduct
1
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
2
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 CAC membership certification was renewed on June 30, 2022.

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 2023, the Company sends invitation letters to a total of 21 suppliers.

Cooperation with Stakeholders Against Corruption and Bribery

The Board of Directors, Management, and Employees

Provide learning tools to the directors, management, and employees to gain knowledge and understanding of the Company’s policies and its related regulations, such as the inclusion of anti-corruption to be part of the orientation session for newcomers: directors, managements, or employees regarding to corporate governance policy, code of conduct, and anti-corruption practice continuously. There will be a review of such topics through variety of communication channels, including animation – based training and annual assessment. Furthermore, new management and new employees are required to acknowledge and accept such policies on the day of signing the employment contract.

In 2023, 100% of total management and employees of the Company and its subsidiaries have studied and been assessed on corporate governance, anti-corruption, and code of conduct.

Suppliers
  • 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.
  • Before engaging in procurement, new suppliers must evaluate themselves, acknowledge, and comply with the Supplier Code of Conduct, including business ethics, human and labor right, occupational health and safety. The Company also urges its suppliers to join the CAC. To learn more about the KTC supplier code and conduct, please visit the Company’s website. (https://www.ktc.co.th/pub/media/sites/cs/assets/corporate-governance/document/ENKTC-GS-008-KTC-Suppliers-Code-of-Conduct.pdf)

    Whistleblowing

    1. Information or complaint’s characteristics related to corruption
    1. In case of Complaints Occurrence
    Information or complaint’s characteristics related to corruption
    Information must consist of first name and last name of whistleblower. The details of complaints or information must be true, clear, and sufficient to be investigated for further actions.
    Complaints concerning personal problems, conflicts, or anonymous complaints are not regarded as corruption whistleblowing or complaints.
    2. Channels to file complaints and suggestions
    Channels to file complaints and suggestions
    For customers, public or other stakeholders
    Telephone: Customer Service Center 02 123 5000, 24 hours a day Complaints Hotline 02 123 5000
    Fax: 02 123 5190
    Website: https://www.ktc.co.th, select “Contact Form”
    E-mail: CService@ktc.co.th
    Postal Letter: Krungthai Card Public Company Limited, 591 United Business Center II Building, 14th Floor Sukhumvit 33 Road, North Klongton, Wattana, Bangkok 10110 Thailand
    For Employees
    E-mail: Send e-mail directly to the Board of Directors and managements.

    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. In addition, the Company provides examples of whistleblowing/complaint to facilitate those who need advice

    3. Considerations
    Considerations

    The Company keeps whistleblowing complaints confidential and refrains from disclosing names or personal information of those who made the complaint, or cooperate in the investigation. Nor will the Company demote, punish, or impose other measures having negative impact on the employees who have refused to be involved in corruption, although such refusal would cost the Company business opportunity. The Company also provides fairness to the individuals accused in such matters.

    The Human Resources business unit, the Compliance business unit, and other independent department participate in investigation under whistleblowers’ rights protective measures.

    4. Disciplinary Actions
    Disciplinary Actions

    The company takes disciplinary actions according to the Company’s disciplinary rules, i.e. warnings, work suspensions, layoffs, or may be punished by law if such breach is illegal.

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

    To ensure compliance with the Anti-Corruption policy and measures, the Internal Audit business unit and the Compliance business unit will regularly monitor for potential risks, improper internal controls complaints, and recurrent incidents that resemble corruption. Both parties will document any corrective actions taken to prevent repeat incidents and minimize future impacts, and will report regularly to the Audit, Environmental, Social Responsibilities, and Corporate Governance Committee.

    Remarks
    1. 1. Processes and operational timeframes are in accordance with the Human Resources business unit operating manual under the topic Employees Disciplinary Procedures.
    2. 2. In case of complaints against the directors, the complaint will be reported to the Audit, Environmental, Social Responsibilities, and Corporate Governance Committee for consideration.
    Number of Past Case (2018-2022)
    7

    The Company does not receive any complaints/whistleblowing regarding to corruption during the past 5 years.

    Number of Present Case (2023)
    7

    The Company does not have any pending complaints/whistleblowing under consideration regarding to corruption.

    In 2023, with the establishment of regulations and preventive measures as well as appropriate internal control and risk management systems, the Company reported operating results to the Audit, Environmental, Social Responsibilities and Corporate Governance Committee as follows:

    Audit Results, conducted by the Internal Audit business unit : None of the department does not comply with the Anti-Corruption policy or measures.

    3
    3.Anti- Competitive

    Anti - Competitive Practices

    The Company places emphasis on fair business practices within legal framework by recognizing business ethics, the interests of customers and suppliers, and fair competition with other business operators within legal framework of the trade competition law. Under the Company’s guidelines on treatment of competitors, which are set out in the corporate governance policy and the Code of Conduct, the guideline on treatment of trading partner with competitors is prescribed as follows: “…committed to fair business practices and compliance with 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.” Such guidelines also cover engaging in commercial activities and legal act of making a contract, or any undertaking of the Company.

    Number of Past Case (2018-2022)
    7
    The Company has not been fined or found in violation of anti-competitive practices in the past 5 years.
    Number of Present Case (2023)
    7
    The Company has not been fined or found in violation of anti-competitive practices.
    4
    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).
    5
    5.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”)

    Code of Conduct Compliance

    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 in order to communicate results or promote awareness and understandings.
    • 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 principles.

    Coverage of Code of Conduct and Supplier Code of Conduct Acknowledgement

    Code of Conduct
    Acknowledge the practice and answer the self-evaluation form.
    Supplier Code of Conduct
    Acknowledge the practice
      Actions in case of violation or non-compliance with code of conduct
      Information or complaint’s characteristics
      Information must consist of first name and last name of whistleblower.
      The details of complaints or information must be true, clear and sufficient to be investigated for further actions.
      Channels to file complaints and suggestions
      • Trusted Superior
      • Human Resources business unit
      • The Audit, Environmental, Social Responsibilities, and Corporate Governance Committee, through the secretary of the committee.
      • Email CG_Compliance@ktc.co.th Superiors or the Compliance Business Unit will answer questions or provide consultation regarding the Code of Conduct compliance.
      Considerations

      When the Company receives the information, the complaint will be forwarded to the Compliance business unit to coordinate with the Human Resources business unit in order to proceed according to the human resources regulations as well as standard operating procedures pertaining to the process for determining disciplinary actions against the wrongdoer.

      Disciplinary Actions

      Take disciplinary actions according to the Company’s disciplinary rules, i.e. warnings, work suspensions, layoffs, or may be punished by law if such breach is illegal.

      Prevention and Reporting

      The Company has established regulations, preventive measures as well as appropriate internal control system and risk management. In the event of the Code of Conduct violation, the Company will consider and find solution to the problem that has been notified to prevent the problem recurrence. Moreover, the Company regularly reports its corporate governance compliance and complaints relating to non-compliance with code of conduct to the Audit, Environmental, Social Responsibilities, and Corporate Governance Committee.

      (Please refer to additional details in under “Code of Conduct” topic)
      The Number of Code of Conduct Violations
      7
      In 2023, The Company received 0 complaint regarding to code of conduct violation

      Annual audit by an independent external agency for the year 2023

      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 principles.

      Legal Dispute

      None