Anti-Corruption Guideline

6.1 Anti-Corruption Guideline

As corruption could occur in any forms, to emphasize the attention on processes which incur a high risk in corruption, the Board of Directors, executives, and employees of Mono Group in all levels must cautiously conform to the following course of action.

1. Facilitation Payment and Bribe

1.1 The Company has no policy on giving or accepting facilitation payment or “Bribe”.

1.2 Employees should be careful once they were requested to make payment on behalf of the Company and also need to consider about the purpose of the payment and whether the amount of the payment is appropriate. Employees should ask for receipt or written document with the details about the purpose of the payment. Any doubt or uncertainty should be informed to supervisor under the line of command.

2. Entertainment and Giving or Accepting Gifts

2.1 Employees are required to avoid entertainment or exchange of gifts that are too valuable or more frequent than it should be, except that it is for the purpose of business and to retain good relationship which is crucial for business operation. Employees must not expect for any services or in returns, specifically those that are inconsistent with the Business Code of Conduct. Approval for entertainment or exchange of gifts and the regulations on the request for payment shall strictly be followed.

2.2 Employees are allowed to give or accept gifts or services and cash or cash equivalents provided that all the following conditions are met.

– It is not an act to dominate, induce, or give in return to any persons in order to gain advantage through an improper act, or it is not an obvious or latent exchange of gifts so as to gain aid or benefit.

– It is a giving on behalf of the Company, not the employees personally, and made openly.

– It fits the situation, for example, giving minimal gifts during important festivals (for example, New Year, Chinese New Year, Songkran), which is considered a tradition. In addition, the gift should not be cash and its value must not exceed 3,000 Baht.

– Type and value of the gift is reasonable and timely, for example, promotional products with the logo of the Company (such as pens, caps, and T-shirts) or general souvenirs (for giving to employees or customers of business partners).

– It complies with the relevant laws.

2.3 Employees are allowed to accept a gift worth up to 3,000 Baht. If the value exceeds that, they shall inform customers, business partners, or stakeholders that it is a breach of the Company’s regulations. If unable to decline and having to accept a gift worth over 3,000 Baht, they shall send that gift to their supervisor under the line of command/ Human Resource Department, together with the filled out Gift Acceptance Reporting Form. That gift and form shall be later sent to Human Resources Department to be given as reward to employees or donated to charity on behalf of the Company as opportunity arises and as appropriate.

2.4 When doing business abroad or in different cultural setting which considers exchanging gifts of high value is proper business etiquette, employees are required to inform their supervisors if they give or accept such gifts in order to put in the record of the Company’s property.

3. Charitable Contribution or Sponsorship

Granting contribution or receiving donation or sponsorship must be transparent and in accordance with stipulated laws by confirming that such transaction shall not be claimed as a bribery act. Donation and sponsorship must not be perceived as being given for improper purposes. When a charitable contribution or sponsorship is made, it shall be transparent and in accordance with applicable laws. It shall also be approved by authorized persons with the approval limit in accordance with the Company’s policy.

In addition, the Company has an internal control system to confirm that sponsorship shall not be spent on any acts which could be claimed as corruption. The process for approval and the purpose for spending such sponsorship shall be in line with the internal control procedure, the purpose for approval, and the regulation of purchase requisition.

4. Political Contribution

4.1 The Company has implemented a neutral political policy. There shall be no political contribution for any political parties, political groups, or politicians, either directly or indirectly.

4.2 Employees have the right to engage in political activities that are compliant with laws, but must not make political activities in the Company. Political actions shall be taken after working hours. In addition, employees must not use the Company’s resources to take such action.

4.3 If the Company wishes to provide political support in order to promote democracy, such support must not violate the applicable laws or may not align with the expectation to be treated as a special reward.

Any support shall be performed in accordance with the regulations of disbursement by specifying the recipients, objectives, details, amount of money, date of disbursement, including all supporting documents and proposed to the approval consideration according to the authority of the Company.

5. Company and Individuals Involved in Business Relationship with Governmental or Private Sectors

5.1 The Company has encouraged its subsidiaries or companies under Mono Group that are under the control of Mono Technology PCL. to comply with the Anti-Corruption practices.

5.2 As for individuals, agents, intermediaries of both governmental and private sectors, business partners, contractors, product/ service distributors, and business related persons, the Company shall authorize a purchasing process for products/ services as well as evaluate the selection of distributors, contractors, and business intermediaries. These processes shall be conducted cautiously and transparently. The policy shall be informed. In addition, rules and conditions on purchasing process shall initially be followed.

Any support shall be performed in accordance with the regulations of disbursement by specifying the recipients, objectives, details, amount of money, date of disbursement, including all supporting documents and proposed to the approval consideration according to the authority of the Company.

6. Revolving Door

6.1 A government official who remains in his or her position shall not be employed or appointed a position, except for state enterprise which is allowed by the authorized department to appoint a government agency to work in the Company.

6.2 Two years cooling-off period shall be determined for the appointment of a former government official who resigned from his or her position, or a person who used to work with a regulator which directly related to the Company.

6.3 Due diligence of the person that the Company shall nominate as a director, a counselor, and an executive shall be established before the appointment in order to examine any issue which may lead to a conflict of interest.

6.4 The person shall be forbidden from a position or a duty relating to a conflict of interest in order to prevent abuse of power, such as disclosing secrets of the government sector that the person used to work with, lobbying for illegal interests, being assigned to contact the government sector that the person used to work with, etc.

6.5 Names and profiles of former government officials who have been appointed as counselors, directors, or executives of the Company shall be revealed in the Company’s publications, as well as identifying the reasons for appointing them.

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