BUSINESS OPERATION AND PERFORMANCE CORPORATE GOVERNANCE FINANCIAL REPORTS AND FINANCIAL STATEMENTS APPENDIX Company or via electronic means must be filed to the supervisor and the business supervision depar tment of GC immediately to ini t iate consideration process to determine whether there is conflict of interest against the Company and what further process should be. In addition, GC place importance on reporting action either in the case where there is incident leading to conflict of interest or not by requiring reporting duty every year and during the year if there is any occurrence of a conflict of interest incident. GC’s activities for the prevention of conflicts of interests in 2021 are summarized below: GC conducted follow-ups and successfully achieved 100% submission of annual conflict of interest disclosure reports by GC Groups’ Executives and employees through its system. The Internal Audit function conducted an audit of GC’s procedures and communications related to the disclosure of conflicts of interest and found that they were in compliance with relevant regulations. To enhance the internal organization supervision, in 2021, the Company has reviewed workflow in the Related Party Transaction to be in line with the current operation and regulations and procedures stipulated by the notifications of the SEC and SET on Related Party Transaction. (6) Anti-Corruption The GC group has objectives and focusing on carrying out the business by emphasizing anti-corruption efforts, GC also strives to comply with laws against fraud and corruption as well as bribery of both Thai and foreign public officials or officers of private organizations. The Company also seeks to cultivate anti-corruption consciousness in its employees at all levels to combat corruption of all forms. The Board of Directors has developed anti-corruption policy and included them in the Corporate Governance Handbook and Business Code of Conduct to ensure that Group Company observes the established policies and to serve as policy to which Directors, Executives, employee, contractor and any person that acts for the benefit of the company can hold on to as a standardized operation. Any violation of law is considered wrong and against GC’s policies and will result in disciplinary action and punishment according to applicable laws. Principles Directors, Executives, employees, contractors and any other person acting for the benefit of the Group Company has duties to follow the applicable laws, rules, regulations on anti-corruption, as well as the Corporate Governance and Business Code of Conduct Manual, policies, rules, practices and guidelines of the Company, perform their duties with transparency, refrain from any act which could be perceived as intentional fraud or corruption, be prohibited from asking for, undertaking or accepting corruption for one’s own and/or related persons’ benefits including friends and acquaintances, and be ready for examination on the performance of duty by auditor or the competent authority at any time. In this regard, the subsidiaries may consider to adopt such and operational measures of the Company to use in its operation as appropriate. Operation Measures of the Company 1. GC has established the Anti-corruption promotion working team whose duty was to ensure that the operation of the Company upholds the principles according to the Anti-corruption measures arbitrary to and in accordance with the Company’s commitment to become a member of the Thai Private Sector Collective Action against Corruption (CAC). 2. GC has procedures to review, examine and improve the Anti-corruption measures and report it to the Corporate Governance and Sustainability Committee annually in order to measure efficiency, improve and develop the measures to be included with the changing corruption risks. 3. GC has carried out the corruption risks evaluation and set up protective measures for operational control, environmental control and financial control, all of which documents has been observed. 4. GC has guidelines to assure the internal control relevant to the process for recording financial report, account book preparation and the maintaining of information. Any materiality of control weakness impact financial report will be reported to the Board of Directors. 5. GC is politically neutral and does not have policy to provide financial supports, resources or other properties either directly or indirectly to politicians or political parties or other political groups for the benefit of such politicians or political parties or groups. 6. GC does not have policy to make any facilitation payment to ease its business activity neither directly nor indirectly. This extensively includes any action or neglect of action considerable as unethically easing business activities. 183
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