4. GC has established guidelines for auditing internal control relevant to the recording of financial transactions, the preparation of books of account, and the safeguarding of information. Any material issues detected are reported to the Board of Directors. 5. As a policy, GC is politically neutral and does not provide financial support, resources, or other assets 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. As a policy, GC does not make any facilitation payment to ease its business activity either directly or indirectly and does not engage in or accept any act in exchange for business facilitation. 7. GC has established suitable and clear criteria for the hiring of government officers in order to prevent such hiring to be in exchange for undue benefits and has established measures to disclose information related to such hiring to the general public for transparency. 8. GC has established human resource management policies and procedures regarding nomination and selection, performance evaluation, remuneration, and promotion that reflect its anti-corruption commitment. 9. GC shall not demote, discipline, or cause any adverse effect on personnel who refuse to be involved in fraud or corruption, even though such refusal may cause GC Group to lose business opportunities. This policy is clearly communicated to all personnel. 10. GC consistently organizes training on anti-corruption actions and awareness for its personnel. 11. GC communicates its anti-corruption policies and practices to its subsidiaries, affiliates, other companies in which GC has controlling power, customers, suppliers, business partners, and stakeholders, as well as to the general public through various communication channels in order to keep them informed and enable them to adopt the anti-corruption measures. 12. GC adopts GC Group's No Gift policy to align with the Anti-Corruption Policy on the receiving/giving of gifts, organizing of banquets, or any other forms of benefits. This serves as guidelines to ensure that GC employees can conduct themselves appropriately. 13. The implementation of Anti-corruption Policy is in accordance with the guidelines specified in the Corporate Governance and Business Code of Conduct Handbook, as well as other regulations, policies, rules, and guidelines defined by the Company. 14. GC reviews its Anti-corruption Policy every three years to coincide with the re-certification of the Thai Private Sector Collective Action Against Corruption (CAC) or at an appropriate interval in accordance with the amendments of applicable laws, regulations, and rules. Any revision is proposed to the Board of Directors for consideration and approval. Disciplinary Actions 1. GC has put in place disciplinary actions for Directors, Executives, or employees who do not comply with its Anti-corruption Policy. These include the discharge of Directors from office and other disciplinary actions in accordance with the rules on disciplinary actions for Executives and employees; and legal actions in accordance to the applicable laws, rules, regulations, and corporate governance practices related to such act. 2. In the event that a person related to GC Group, or any customer, supplier, or business partner does not comply with the anti-corruption measures, GC Group may consider terminating any transaction with such person. GC declared its intention to join the Thai Private Sector Collective Action Against Corruption (CAC) on July 18, 2012 and was first certified as a member on July 4, 2014. It was recertified for the third time on June 30, 2023. In 2023, GC carried out activities that demonstrated its commitment to anti-corruption efforts. A summary is provided below: GC revised the Anti-corruption Committee (ACC) appointment order and expanded ACC’s roles and responsibi l ities to include fraud risk-related activities and the annual provision of recommendations on activities or transactions with corruption risks (transaction monitoring) in addition to the existing responsibilities, which included reviewing GC’s anti-corruption measures and corruption risk assessments currently deployed in the operational 204
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