Policies and Actions in Preventing Corruption 1. Introduction Scan Inter Public Company Limited is aware of defending companies, clients, customers, trade partners, employees and asset from financial risks, or any actions that violate laws or are unethical actions. Therefore, the management sector needs to communicate about the policies and actions in preventing corruption towards internal and external clients, trade partners and general staff. We are determined to manage the business ethically, morally, honestly and want these qualities to occur permanently within staff, sales staff, clients and customers, trade partners, or with any person that we share business relations with. We will support ethical and honest work from staff and managers. Violations and dishonesty regard from persons related to the Company that may lead to financial damage, discredit, loss of credibility, negative image to the public, relationship damage between clients, customers or trade partners, employee loss and loss in law prosecution. The Company is determined to cease, prevent corruption and follow all forms of anticorruption laws by creating an anticorruption culture which is an important factor that shall contribute to reaching the Company’s objectives. The operation system that was initiated, reporting system and administration systems that are related to important missions are good basics that will defend the innocent while strengthening the rules will make the wrongdoers unable to do the deed that violates laws or regulations. The truth must be considered and the asset that was mishandled must be returned or compensated for. 2. Anti-Corruption Policy The Company initiated an anti-corruption policy by not permitting employees or those without any duties to bring cash or assets to use personally or wrongly, if so then that action will be seen as intentional wrongdoing. Reprimands include job suspension, dismissal, damage compensation, criminal prosecution which will be evidence-based, therefore any employee who sees or knows of the misdeed of corruption, stealing or defalcation must notify the HR Manager or other superiors that they are reporting to. The Company has assigned the Risk Management and internal control sector take responsibilities in continuously testing and assessing risks from corruption by presenting the results to the Risk Management Committee and report to the Company Committee accordingly. 3. Definitions and Examples of Corruption • Definitions Corruption means intentionally committing misdeeds or lies with reconsideration or defalcating asset for personal benefits and causes disturbance to others, money or asset defalcation without authority of possession but not legally or rightfully theirs. • Examples of Corruption Examples of Corruption to the Company are examples as follows, A. Neglect of sending money into the Company’s bank account when dateline is required and/or has no money collecting receipt B. Disclose broker or other sales support or other lists that actually has never happened with an intention of corruption C. Use inventories in a wrong way or use office equipment or apparel or other assets for personal use or benefits e.g. goods, permanent asset in staff accommodations without written permission from a superior or authorized person. D. Intentionally sending Company information to other people with results that the Company loses income or is intentionally damaged. E. Dealing with trade partners in receiving goods that weren’t sent, were sent by the wrong type or is not following Company standards. The examples above must be eliminated. 4. Corruption Prevention By the law, corruption must be legally prosecuted according to the misdeed. Intentional corruption is a severe criminal case. The Company determines policies to control and prevent corruption as follows, A. Set a compilation of business morals and ethics for everyone to follow. B. A history check of all staff must be completed e.g. criminal records, work experience, education record, and referrals from employments before. Follow corporate governance. C. Control suitably in misdeeds investigations along to standards of operations and a system of pre notifying dangers. D. Support all trade partners to have anti-corruption process All staff must be trained to not corrupt. New staff must agree to this policy in the orientation stages before starting work. 5. Corruption Reporting All staff must read and clearly understand this policy. He/she must also report suspicious activity or a notification of wrongdoing to their superior along the hierarchy structure. However, if there is a reason to believe that that superior was involved, leads must be notified to the Hiring Manager Reporting to the police must happen within 2 months of the misdeed, and must prepare the evidence. It is the duty of the director to collaborate with the legal sector. If evidence was gathered enough to point to corruption, disciplinary steps must be taken as the HR team will be asked for consultancy for the accuracy of legal prosecution. 6. Wrong Accusation If intentions of discrediting groups to people and the companies occur, the accuser might be disciplinary reprimanded or discharged. 7. The Process of Reporting Wrongdoings The management team must carry out their actions as follows, For clarity in the reason of corruption, the HR team must carry out an investigation to find the truth or find an accurate report. When a corruption report is set, the accused must be immediately suspended and must send a form to the personal surety (if one) while the superior carries on the duties instead of the accused. Clear evidence in checking inventories, reports or other related documents. When others are added, it must be counted and signed in words for evidence. If the accused is not cooperating, the superior must record it for evidence before counting of goods or assets. If other documents are required afterwards, 2 witnesses (or a number according to the law) must sign their names on the form. Documents enclosed for the crime, witnesses and all documents must be safely kept and sent to the legal team until the case is closed. 8. Damage or Loss Compensation When damage or a loss occurs from misdeeds of staff, it must be compensated in full rate to the Company (and interest rates according to the law) by deducting from the assurance. The limitations of fines aren’t fixed. Police reports and criminal cases must be reported as stealing and corrupting in every case. 9. Defensive Measurements in Preventing Relatedness in Corruption. The Company has predetermined an act regarding monitoring and supervising to prevent and follow risks from corruption and has set actions to prevent corruption as follows, • Declare conditions of receiving and giving presents • Communication or policy reveal and actions for external persons • Assigned the internal control check and supervise important info and regular auditing e.g. receiving cash. • The Company has a policy of assigning the executives to report the actions following measures and report suspicious issues to the Committee urgently. • The Company has a policy of assigning the audit committee or auditors verify the completeness of the process and all measures regularly.
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