Anti-Corruption Policy

Anti-Corruption Definition

Corruption means any types of bribery such as an offer, promise, guarantee, inquire or acquisition on money, asset, or other inappropriate benefits from the government officers, government sectors, private sectors, or responsible person either in direct or indirect action so that such person could proceed or disregard his/her function in order to acquire, retain the business, recommend specific company to entity, or achieve any improper benefits in business transaction. Exception shall be applied in case of laws, regulation, statement, standard, custom, or business traditions enable to do so.

Anti-Corruption Policy

Director, Management Team, and SYMPHONY staff are prohibited from operating or accepting every type of corruption both in direct or indirect manner covering every business and related department in every country. The Anti-Corruption Policy is needed to be reviewed regularly, including with a possible revision of such policy and implementation provision in order to accord with business changes, regulation, standard, and laws.

Role and Responsililities

1. The Board of Directors is responsible for determining the policy, monitoring, and forming an effective system supporting Anti-Corruption act in order to affirm that the Management Team intensively concerns, emphasizes, and cultivates Anti-Corruption mindset as the Company’s culture.
2. Nomination and Corporate Governance Committee is responsible for considering the anti-corruption policy and propose for the Board of Directors’ approval and review, follow, evaluate the results as stated in the anti-corruption policy regularly to enhance the anti-corruption policy effectively.
3. The Audit Committee is responsible for revision of financial and accounting reports, internal control, internal audit function, and risk management so that such operations are concise, appropriate, effective, and conformed to global standard.
4. President, SYMPHONY Top Executives, and the Management are responsible for determining Anti-Corruption system, promoting, and encouraging Anti-Corruption manner conveyed to all staff and related parties. This also includes reconsideration on system or regulation in order to best adjust with business changes, regulation, standard and laws.
5. Internal Audit Director is responsible for auditing, assessment, and evaluations in business transactions whether they are accurate and complied with guidelines, Approval Authority, standard, laws, and policy in such monitored department in order to assure that the internal controls are sufficient and suitable for probable risk in corruption. This shall be directly reported to the Audit Committee.

Anti-Corruption Guidelines

1. The Board of Directors, the Management Team, and SYMPHONY staff in every level must follow with Anti-Corruption Policy and the SYMPHONY Code of Conduct by avoiding involving with any course of corruption in direct or indirect manner.
2. SYMPHONY staff shall not be negligent in any corruption conditions involved directly with SYMPHONY. All staff must notify such act to supervisors or responsible person, including collaborate with investigation. Any queries or questions are needed to be consulted by the supervisor or a responsible person who monitors the SYMPHONY Code of Conduct compliance provided in particular channels.
3. SYMPHONY shall provide fairness and safeguard staff who denies or informs corruption cases relating to SYMPHONY by applying Protection Policy for appellant or persons who incorporate with Anti-Corruption information as stated in the Whistleblower Policy.
4. A person who commits the corruption is equivalent to misconduct in the SYMPHONY Code of Conduct. This means such person is needed to consider discipline followed by SYMPHONY standard. Conviction on laws may be applied in case such act violates the laws.
5. SYMPHONY concerns the importance of dissemination, knowledge sharing, and communications with other people who involve or affect SYMPHONY so that those parties shall conform effectively to the Anti-Corruption guideline.
6. SYMPHONY strives to create and sustain organization’s culture representing that corruption is unacceptable in every business transaction dealing with both public and private sectors.

Provision in Implementation

1. This Anti-Corruption Policy covers to Human Resource Management process staring from recruitment, promotion, training, evaluation, and benefits provided to staff. Every supervisor in every level must communicate to staff in order to apply in business transaction under their responsibility and to monitor such implementation to be the most effective.
2. Implementation on Anti-Corruption Policy should be followed by guidelines in the SYMPHONY Code of Conduct, Corporate Governance guidelines, Stakeholders’ Guidelines, standard, every SYMPHONY related operation manual, and additional guidelines which will be formulated afterward.
3. To stress the attention on processes which incur a high risk in corruption, the Board of Directors, the Management Team, and the SYMPHONY staff must conform carefully in the following course of action.
   1. 3.1Gifts, Entertainment and Hospitality: Offering gifts or entertainment and hospitality activities must be complied with the SYMPHONY Code of Conduct.
   2. 3.2Charitable Contribution or Aid: Granting contribution or receiving the aid must be transparent and in accordance with stipulated laws by confirming that such transaction shall not be claimed as a bribery act.
   3. 3.3Business Relation and Procurement Process with the Public Sector: All types of bribery or illegal payments are prohibited in all business transactions, SYMPHONY operation, and connection to the government. Such implementation must be preceded transparently and in alignment with related laws and regulation.

Whistleblower System
Symphony Communication Plc. has purpose to initiate the Whistleblower System to report malpractice concerning unlawful conduct, non-compliance with the good corporate governance policy, unethical business practices, corruption, or unethical conduct. This channel does not handle malpractice reports about product or service quality.

All whistleblowers are required to submit factual information and must not incriminate others without sufficient evidence.

We will ensure fairness and protect the employees or third parties.

We will effectively safeguard your information and proceed with the utmost vigilance in handling your report.