Anti-Corruption Policy

1. Board of Directors It is responsible for considering and approving the policy. and support the fight against corruption or corruption in the company so that everyone in the company can understand and realize the importance of problems arising from corruption Corruption, including cases where the Audit Committee Has reported any corruption that affects the company. The Board of Directors is responsible for giving advice, suggestions, and consideration of punishment. And jointly find solutions to the problems for the President and Managing Director.
2. Audit Committee has duties and responsibilities as follows:
   1. Consider the Anti-Corruption Policy received from the Managing Director and managing director to be suitable for the business model company environment corporate culture and presented to the Board of Directors for approval.
   2. To review suitability of changes in the anti-corruption policy received from the Managing Director and managing director and presented to the Board of Directors for approval.
   3. Review the audit report of the internal control system. and risk assessment related to corruption as proposed by the Internal Audit Department. to ensure that such systems are vulnerable to This creates opportunities for fraud that affects the financial position. and operating results of the company is minimal and appropriate. with the business model of the company
   4. Receive reports of clues about fraudulent acts That people in the organization are involved in and check the facts as informed and propose the matter to the Board of Directors jointly to consider punishing or resolving the aforementioned problems

3. Internal audit department has duties and responsibilities as follows:

                   1. Perform duties in accordance with the specified internal audit plan and submit a report on Check the internal control system. and fraud risk assessment caused by Check the internal control system. Let the Audit Committee know.
                   2. Perform duties as assigned by the Audit Committee. in regard to fraud investigations related to the organization In addition to the internal audit plan that has been set

   4. Managing Director and managing director has duties and responsibilities as follows:

                   1. Establish anti-corruption policy to present to the Audit Committee
                   2. Communicate with personnel in the organization and related parties to be aware of the anti-corruption policy.
                   3. Review the appropriateness of the anti-corruption policy to suit changes in business or legal requirements. to present to the Audit Committee
                   4. Help the Audit Committee In investigating the facts as informed or tasks assigned by the Audit Committee regarding fraud investigations, which can be assigned to the management team that can help in investigating the facts.

Company Directors, Executives and Employees Employees of the Company Must strictly comply with the anti-corruption policy and business ethics. whether involved in corruption directly or indirectly by

        1. Do not do any behavior That shows that it is accepting bribes or giving bribes to stakeholders in matters that He performs his or her responsibilities either directly or indirectly in order to obtain benefits in a wrongful way. Must comply with the following:

                  1. Do not accept or give gifts, souvenirs that are Cash, checks, bonds, stocks, gold, jewelry, real estate or things of the same kind with those involved with whom he has contacted and coordinated both in government agencies and private agencies
                  2. Not accepting assets, things, gifts, tokens of any kind or other benefits which induces The omission of their duties. However, before accepting souvenirs, you should make sure that you have followed correctly. Laws and regulations of the company by things or gifts given to each other in the course of work. There should be a low price and suitable for each occasion.
                  3. Do not give any assets, things, gifts or gifts. or other benefits To influence decision-making or cause the recipient to not follow the same trade practices as other trading partners. In this regard, giving items according to various occasions or occasions Must not have a value that is beyond normal
                  4. Not being an intermediary in offering money, assets, things or any other benefits to persons related to Government business or any organization in exchange for special privileges that should not be obtained or cause Government officials ignore the rules. regulations and legal compliance as specified

       2. In procurement must proceed through the procedures in accordance with the Company's regulations It is transparent and can be checked.

       3. Expenses for business entertainment and other expenditures Related to the performance of business contracts can be done but must be spent reasonably. can check

       4. To donate to charity Must do as follows

                    1. Use of company money or assets to donate to charity Must be done in the name of the company only by Charitable donations must be foundations, public charitable organizations, temples, hospitals, nursing homes or organizations for social benefits. with certificate or reliable, can be verified and Proceed through the procedures according to the company's regulations.
                     2. Charitable donations in a personal name should be done, but must not be involved or cause suspicion that it is an act of corruption for any benefit

       5. In providing financial support Must do as follows

                     1. Use of company money or assets to support the project The name must be specified in the name of the company only. by the support paid There must be objectives for the business, good image and reputation of the company. The disbursement must clearly specify the purpose. and have verifiable evidence and Proceed through the procedures according to the company's regulations.

        6. Do not do anything related to politics within the company. and do not use any company resources to do so The Company is an organization that adheres to political neutrality and supports compliance with the law. and democracy Including no guidelines for providing political assistance to any political party either directly or indirectly

        7. If you see an action that is considered fraudulent or implied in corruption which directly or indirectly affects the Company, must not neglect or ignore such behavior Should notify the director, director or managing director. Immediately or notify via whistleblowing channels as specified in this policy.

        8. Directors and executives must realize the importance of disseminating knowledge and giving advice in order to create understanding among their subordinates. about anti-corruption for employees to comply with According to this Anti-Corruption Policy, as well as being a good role model in honesty, ethics and code of conduct. 

Whistle-blowing matters or complain about fraud

1. Witnessing corrupt actions directly or indirectly related to the organization, such as seeing a person in Bribery/Bribery Organizations government officials or private agencies
2. Found an act that violates the procedures according to the company's regulations. or affects the Company's internal control system to the point that it is suspected that it may be a channel for fraud.
3. Witnessed an action that caused the company to lose benefits and affect the reputation of the company
4. Found illegal acts, immoral, business ethics

The Board of Directors has assigned the Audit Committee to be considered for receiving clues Complaints about actions that may cause suspicion that it is a fraud or corruption that directly or indirectly affects the company through the receiving channels specified in this policy.

The whistleblower must specify details of the matter to be whistleblowing. Or complaints with names, addresses and phone numbers that can be contacted and sent to the channels for receiving complaints as follows:

1. Channel 1 by post By addressing the envelope to • Chairman of the Audit Committee or • Audit Committee or • Secretary to the Audit Committee. and sent to ALT Telecom Public Company Limited, No. 52/1 Moo 5, Bang Kruai-Sai Noi Road, Bang Si Thong Subdistrict, Bang Kruai District, Nonthaburi 11130
2. Channel 2 Via electronic mail (E-mail) send to E-mail address : auditcommittee@alt.co.th
3. Channel 3. Website The details can be specified in the topic "Contact" website https://alt.co.th

However, if the whistleblower or complainant have a complaint via web page Please send your complaint directly to the audit committee.

Person who can report clues Or complaints about corruption are all stakeholders of the company. including shareholders, customers, competitors government creditors, communities, society, executives and employees of the Company. The company will keep your confidentiality.

In order to protect the rights of complainants and informants who act with good faith. The company will hide the name, address or any information. that can identify the complainant or informant and keep the information of the complainant and informant confidential It is limited to those who are responsible for investigating complaints. only can have access to such information.

In case of complaint Managing Director or managing director The Audit Committee is responsible for protecting whistleblowers. Or complainants, witnesses and persons who provide information in the investigation to find out the facts, not to suffer trouble, harm or unrighteousness. arising from notifying clues, making complaints, being witnesses or providing information by requesting complainants to submit complaints directly to the Audit Committee

The Managing Director managing director Have a duty to exercise discretion to order as they see fit to protect whistleblowers. or whistleblowers, witnesses, and persons providing information in the investigation. not to suffer trouble, harm, or unrighteousness arising from whistleblowing, complaints, witnesses, or providing information

             Managing Director managing director Able to assign work to any executive to act on their behalf in exercising discretion to order the protection of the whistleblower's safety. or complainants, witnesses, and persons who can give informationbyThe assigned executive mustIt has nothing to do with the whistle-blowing matter. or complain either directly or indirectly directly or indirectly (such as the accused is directly subordinate to them)

In this regard, the person receiving information from performing duties related to complaints Have a duty to keep information, complaints and evidence documents of complainants and informants confidential. Do not disclose information to other people who do not have related responsibilities, unless it is a disclosure required by law.

1. When receiving a whistleblower Managing Director managing director and the Audit Committee will be the one to screen. investigation
2. During the investigation Managing Director managing director and the Audit Committee May assign representatives (management) to periodically report progress to whistleblowers. or file a complaint. actually commit fraud The company will give rights to the accused. acknowledge the allegations and give the accused the right to prove himself or herself by seeking additional information or evidence showing that he has no involvement with the dishonest act as alleged
3. If the accused actually committed fraud Corruption is considered a violation of the Anti-Corruption Policy. Company's business ethics will be subject to disciplinary action according to the regulations set by the company has been specified and if the act of corruption is illegal Offenders may face legal penalties. Disciplinary action according to the company's regulations Managing Director's decision managing director considered final

In case of complaint Managing Director or managing director The Audit Committee is responsible for accepting complaints, finding information, and investigating facts. as notified To report to the Board of Directors to jointly consider and determine the penalty as deemed appropriate.

So that everyone in the organization is aware of the anti-corruption policy The company will proceed as follows.

1. The company will post an announcement of the anti-corruption policy. in a conspicuous place Everyone in the organization can read it.
2. The Company will publish the Anti-Corruption Policy. through the Company's communication channels such as electronic mail (E-Mail), the Company's website Annual Disclosure Report (56-1) and Annual Report (56-2) The Company will provide anti-corruption policy training. to new employees
3. The company will review the anti-corruption policy. consistently every year

This shall be effective from 16 July 2015 onwards.