Anti-Corruption Policy

CAC Policy Implementation Procedures   |  Code of Conduct and Ethics Escalation Procedure

UNIMIT Engineering Public Company Limited (together with its subsidiaries, “UNIMIT” or the “Company”) are committed to conducting our business in accordance with all applicable laws, rules and regulations of the highest ethical standards, and this commitment is embodied in the Code of Conduct and Ethics.

The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate UNIMIT’s commitment to full compliance by the Company, its subsidiaries and affiliates, and its officers, directors, employees and agents with Thailand’s National Anti-Corruption Strategy of National Anti-Corruption Commission of Thailand (NACC) and any local
anti-bribery or anti-corruption laws that may be applicable. This Policy supplements
the Code of Conduct and Ethics and all applicable laws and provides guidelines for compliance with the NACC, and Company policies applicable to UNIMIT operations world-wide. 

This Policy is applicable to every employee of UNIMIT, including senior executive and financial officers,  and to members of the UNIMIT Board  of  Directors.   The reporting requirement of this Policy is also applicable to UNIMIT’s contractors and suppliers. This Policy is intended to supplement all applicable laws, rules, and other corporate policies.
It is not intended to supplant any local laws.

“Corruption”  refers to the abuse of entrusted power for personal gain, or the misuse of authority granted for one’s own benefit, whether such actions directly or indirectly affect the organization or related parties.

“Bribery”  refers to the act of offering, promising, or giving money, gifts, or any other undue advantage or incentive to a person in a position of influence or decision-making authority, to induce that person to perform or refrain from performing any act, whether such act is lawful or unlawful.

Bribery and corruption can take many forms, including the provision or acceptance of: 
    • Cash, assets, or any items of value
    • Social or other benefits such as travel expenses, entertainment, facilitation payments, and other forms of support that are not customary or appropriate under normal business practices

“Supplier”  refers to any third party who sells or provides services and receives payment for goods or services related to the company’s operations, including consultants and subcontractors.

“Other Related Parties”  refers to individuals legally connected to the company’s directors, executives, or employees, such as spouses, children, parents, or other close relatives.

“Conflict of Interest” refers to situations where directors, executives, or employees engage in transactions related to the company with the intent to gain personal benefit in a manner that conflicts with the company’s best interests.

All UNIMIT personnel and agents are strictly from soliciting money, assets, or any other form of benefit, or from engaging in any act related to bribery or corruption of any kind, whether direct or indirect, for themselves, their families, friends, or acquaintances. This prohibition applies whether the individual is the recipient, the giver, or the proposer of a bribe, and regardless of whether the bribe involves money or other benefits. It covers all dealings with government agencies or officials, as well as with private sector entities or employees of private organizations with which the company conducts business.
    
In addition, UNIMIT’s books and records must correctly record both the amount and a written description of any transaction. UNIMIT personnel must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in the Company’s books and records. 

It is contemplated that UNIMIT will institute detailed procedures and standards related to training, due diligence, the recording of transactions, and other areas, to implement the terms of this policy as follows:
•  Support travel expenses for Government officers (if any)
•  Direct support and Compensation to Government officers (if any)
•  Daily allowance for Government officers (if any)
•  Gift, Party and Entertainments for Government officers (if any)
•  Political support (if any)
•  Conflict of Interest (if any)

UNIMIT Board of Directors
• Follow up this Policy and assign it to the Management team for a response.

Risk Management Section
• Support the Management team, UNIMIT’s employees and other sections in order to achieve the efficient continuing operation including risk management where might occur.

Internal Auditor
• Inspection and Investigation for any activity of each working unit according to the applicable rule of the policy and evaluate both efficiency and sufficiency of internal controlling using the good corporate governance.

Anti-Corruption Committee
• A group appointed by the executives to oversee, monitor, and support the efforts of directors, executives, employees, and various departments in mitigating risks related to corruption. The committee is also responsible for reviewing operations and implementing appropriate risk prevention measures.

Audits of UNIMIT sites, operating units, and contractors may be conducted periodically to ensure that the requirements of this Policy and applicable procedures and guidelines are being met. Audits may be conducted internally by UNIMIT, or externally by retained third parties. Audit documentation shall include performance improvement action plans and the action performing should follow as below items.

1. UNIMIT Board of Directors should assign the Management team to communicate this
      policy as well as action performing to all UNIMIT personnel and agents.
2. Company should communicate anti-corruption policies and measures including
      internal whistle-blowing channels to the internal auditor for real operation.
3. Company should implement the regulations of disbursement with clearly defined for
      setting amount of limitation, approval authority table, objectives and recipient. All
      related documentary evidence have to  be provided to make sure the disbursement
      for any corporate entertainment or gift will be complied and followed with the policy,
      the procedure auditing would be carried out by Internal Auditor.
4. Company should audit Sales, Marketing, and Procurement as well as the contracts
      for seeking the risk of corruption regularly in order to make sure all functions are
      comply with disbursement procedures and purchasing policy. Internal Auditor should
      recommend and follow-up on appropriate corrective actions.
5. Company should organize the human resources management which reflects to the
      company’s commitment of anti-corruption policies and measures would start from
      the recruitment, training, evaluation, compensation and promotion.
6. Company should organize the internal control for financial, accounting, backup data
     and including others functions in the company which related to anti-corruption
     policies and measures.
7. Company should organize the risk management system in order to prevent and
     suppress corruption in the company. 
8. Company should organize the internal audition to ensure that; inner control system
     and risk management system are effectively and assist the company to achieve its
     goals, as well as to ensure that every operation units comply with rules and
     regulations and to find defects and weaknesses in the operation.  And, also to
     provide recommendations of operation system to improve efficiency and
     effectiveness in accordance with good corporate governance. 
9. Company should set-up the anti-corruption measures as an internal control
     document complying with company’s regulation and policy.

Other UNIMIT policies impacted by, and which should be construed consistently with this Policy, include the Code of Conduct and Ethics, the Code of Conduct Escalation Procedure, Procedures for Implementing the Anti-Bribery and Anti-Corruption Policy, the Vendor On-Boarding Standard, and the Supplier Code of Ethics. 

UNIMIT Board of Directors will organize the measuring of whistle blowing to cover any breaking of the law, ethics, or any acting that might be caused by the bribery and corruption of UNIMIT personnel and agents. This to be included the Invalid financial report, internal control defective and mechanisms for protection of the informant in order to have overall taking care of company’s benefit from any shareholder. 

Subject of Information for Whistle Blowing and Request
• Any breaking of the law, company rules, bribery and corruption by UNIMIT personnel
   and agents.
• Irregular financial reports and internal control system.
• Any effect on the benefit or reputation of the company.

Notification Channel for Whistle Blowing and Request
• Feedback Box inside the Company.
•  E-Mail Address :
       E-mail Address of the President :
        E-Mail : bundit@unimit.com
      Company Secretary e-mail :
        E-Mail : cac@unimit.com
• Letter to :
       UNIMIT President 
       UNMIT Engineering Public Company Limited (Prapadaeng office)
       109/92-95 Village No. 19 Soi Suksawat 66, Suksawat Road
       Bangpueng Sub-district, Prapadaeng District, Samutprakarn Province
       10130 Thailand

Mechanisms for Protection of the Informant
• Preparing confidential information database of the informant and setting the penalty to
   the officer who responsible of this data when opened to the public.

Query or Suggestion
Any doubts or other suggestions to this policy, please contact the Risk Management
Section UNIMIT Public Company Limited. Company Secretary
Email : cac@unimit.com  Phone: +66 2 463 0100 ext. 26    

Any employee who violates the terms of this Policy will be subject to disciplinary action. Any employee who has direct knowledge of potential violations of this Policy but fails to report such potential violations to Company management will be subject to disciplinary action. Any employee who misleads or hinders investigators inquiring into potential violations of this Policy will be subject to disciplinary action. In all cases, disciplinary action may include termination of employment. Individuals who demonstrate a strong commitment to anti-corruption measures, including whistleblowers, may be given special consideration in performance evaluations, compensation, and career advancement. The company will not demote or take disciplinary action against any employee who refuses to engage in corruption, even if such refusal results in a loss of business opportunity for the company. Any third party agent who violates the terms of this Policy, who knows of and fails to report to UNIMIT management potential violations of this Policy, or who misleads investigators making inquiries into potential violations of this Policy, may have their contracts re-evaluated or terminated.

This policy and its implementation guidelines shall be reviewed at least once a year by the responsible unit, or whenever there is a significant change in applicable laws or relevant regulations.

The company provides multiple channels for communicating policies and publicizing information, including the company website, email, and notice boards. Training programs are organized for the board of directors, executives, and employees at all levels, especially for those involved in activities with a higher risk of corruption.

For further reference, please visit the website of the National Anti-Corruption Commission (NACC) at: https://www.nacc.go.th