Conflict of Interest Policy
The Company operates the business with transparency, accountability, taking into account the best interests of all stakeholders under the legality and ethics, as well as avoiding actions that may cause conflicts of interest and may affect any decision. The Company has guidelines for directors, executives, employees, and those involved to uphold and practice.
Guidelines
- Avoid any action which may cause the conflict of interests of the Company, or being competed with the Company, or working other than the Company's work, or trading of the Company's securities.
- Adhere to do the right manners and legally, not acting improperly or refraining from performing duties in order for the benefits of themselves or others related which shall be considered to exploit or intend to damage other individuals.
- Refrain from seeking personal benefits by insider’s information obtained from their positions, duties and responsibilities, which shall be considered to exploit other shareholders. Therefore, the disclosure of interest information or the company’s securities holding or changes during the first month before Financial statements disclosure to the public, both their own and those connected shall be done. (Shall not buy-sell one month in advance before public disclosure of financial statements)
- Personnel, involving in the operation, have a duty to disclose information about his / her interest and relevant parties as soon as the transaction occurs. These are for the Company to investigate transactions that may have conflicts of interest, by assigning the Company Secretary to report each change of the interest, including reporting the Chairman of the Board and the Chairman of the Audit Committee for acknowledgment, as well as regularly monitor the connected transactions at the end each year.
- Avoid conflicts of interest. If any necessity of connected transaction to an individual who may have a conflict of interest with the Company, the transaction can be done by reporting and shall be approved by the Board of Directors. In this, the approval must be considered the benefits, fair and at arm's length transaction, including being the market price and able to compare prices with third parties.
- Employees shall refrain from shareholding in rival companies if the shareholding causes the employee to act or omit the action that shall be performed or affecting the duties.
- Employees shall disclose to the Company in the event that the employees or family members are shareholders in any business which may cause benefits or business conflicts with the Company. Whether employees or family members acquired those shares before being an employee, or before the Company will enter into such business, or acquired through inheritance.
- Employees shall avoid spending working time on searching data, contact or trading any securities or assets for the benefit of themselves or others, without benefit to the Company.
- Reporting of Conflict of Interest must have been approved by the Board of Directors. In all, to approve the connected transaction, the Company must have been taken into consideration of the best interest, fairness, rationale behind transaction and consistency with market practice.
- The Company has disseminated knowledge, communicated the policy to the personnel in charge since the beginning. The reviewal and auditing of policy to prevent to use insider’s information for the benefit of themselves or others shall be done by the Internal Audit Team.