Alucon conducts its business with fairness based on a philosophy that the Company shall demonstrate a keen sense to social responsibility and the best interests of its stakeholders in alignment with the principle of Business Ethics Guidelines.

To ensure that Alucon has a proper policy determining responsibility, guideline, and regulation as a tool to prevent corruption from all business transactions, Alucon has arranged a written guideline called ‘Anti-Corruption Policy’ in order to prudently make a decision on any course of action that could possibly lead to corruption and to serve as an apparent guideline in performing business and effectively developing to sustainability organization. 

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 the 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.

"Conflict of interest" means a conflict of personal interest with the interests of Alucon, either directly or indirectly. 

"Facilitation Payment" means a small amount of expenses paid to the state officials informally to ensure that they shall proceed an action or to accelerate the procedures under legitimate authorization, and such procedures are generally considered as legal right belonging to any juristic persons such as an application for license or certificate or the use of public services. 

Anti-Corruption Policy

Director, Management Team, and Alucon employees 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 Responsibilities 

1. The Board of Directors is responsible for determining the policy, monitoring, and forming an effective system supporting Anti-Corruption act in order to firm that the Management Team intensively concerns, emphasizes, and cultivates Anti-Corruption mindset as the company’s culture.

2. The Audit Committee is responsible for revision of financial and accounting reports, internal control, and internal audit function so that such operations are concise, appropriate, effective, and conformed to global standard.

3. The Risk Management Committee is responsible for designing, developing, implementing, and monitoring risk management policies and frameworks in order to be effective and ensure that the organization has adequate and appropriate risk management.

4. Chairman, Managing Director and the Management are responsible for determining Anti-Corruption system, promoting, and encouraging Anti-Corruption manner conveyed to all employee 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 Auditor is responsible for auditing, assessment, and evaluations in business transactions whether they are accurate and complied with guidelines, 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 Director, the Management Team, and Alucon employees in every level must follow with Anti-Corruption Policy and the Alucon Business Ethics by avoiding involving with any course of corruption in director in indirect manner.

2. Alucon employee shall not be negligent in any corruption conditions involved directly with Alucon.  All employee 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 Alucon Business Ethics. 

3. Alucon shall provide fairness and safeguard employee that denies or informs corruption cases relating to Alucon by applying Protection Policy for appellant or person 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 Alucon Business Ethics. Conviction on laws may be applied in case such act violates the laws. 

5. Alucon concerns the importance of dissemination, knowledge sharing, and communications with other people who involve or affect Alucon so that those parties shall conform effectively to the Anti-Corruption guideline. 

6. Alucon strives to create and sustain organization’s culture representing that corruption is unacceptable in every business transaction dealing with both public and private sectors. 

7. Directors, executives or employees must not get involve on personal interests that conflict with Alucon's interests. Whereas, potential conflict of interest is based on the principle that the directors, executives or employees must make business decisions that take into account the best interests of Alucon. Employees must not allow personal reasons or their related families to influence decisions that deviate from the above principles.

Provision of Implementation 

1. This Anti-Corruption Policy covers to human resource management process starting from recruitment, promotion, training, evaluation, and benefits provided to employee.  Every supervisor in every level must communicate to employee 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 Business Code and Ethics, Corporate Governance guidelines, Alucon Policy 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 Alucon employee must conform carefully in the following course of action. 

3.1 Gifts, entertainment and hospitality offering gifts or entertainment and hospitality activities must be complied with the Business Codes and Ethics. 

3.2 Charitable 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 Business relation and procurement process with the public sector all types of bribery or illegal payments are prohibited in all business transactions, Alucon operation, and connection to the government.  Such implementation must be preceded transparently and in alignment with related laws and regulation. 

3.4 Hiring of government employees: hiring of government employees who may create a conflict of interest is prohibited.

3.5 Facilitation Payment: it is prohibited to make facilitation Payment to state officials in any cases as this is likely to become a potential risk of bribery or illegal payment.

Communication and Training

1. Alucon shall communicate and disseminate the Anti-corruption Policy to Alucon employee through various channels, such as orientation for new directors and employees, training sessions or seminars as well as internal public relations within working place and electronic systems.  Alucon shall also periodically communicate to Alucon employee various forms of corruption, risks of being involved in corruption, and how to submit information.  This is to ensure that Alucon employee acknowledge and implement the policy.

2. Alucon shall communicate and disseminate the Anti-corruption Policy as well as whistleblowing channels to the public and stakeholders via various channels, such as websites, annual reports and etc., to foster an understanding and support anti-corruption efforts.

3. Alucon employee who have any inquiries about this policy may consult their supervisor, management, company secretary or directors.

Monitoring and Reviewing 

Monitoring and reviewing of anti-corruption measures must be carried out to ensure that any change in risk and situation concerned with this Policy shall be recognized.  The Audit Committee shall review the anti-corruption measures as well as the related internal control system, while the Risk Management Committee takes responsibility for regularly reviewing the corruption risk assessment and reporting to the Board of Directors.  The Board of Directors shall review this Policy every year.

Punishment

The Company shall impose appropriate punishment on employee who is found to be in non-compliance with the Anti-corruption Policy.  Such punishment includes termination of employment, in accordance with the Company’s work regulations.  Besides, they may be taken a legal action if the act is considered to violate the law.