Risk Assessment on Corruption
Corporate Risk Management
The Company has established the dishonesty risk assessment in every unit of the Company and its subsidiaries. All the working units have to identify and rank the risks on corruption in their units by likelihood and effect and also figure out a risk reduction, prevention and countermeasures for possible corrupt actions, whereby the assessors shall assess risks with regard to type of business activity, operation procedures, industry conditions, business logic, related anti-corruption policies, as well as the available policy manual that specifically gives directions for each act of corruption, such as accepting-giving gift and hospitality, provision of financial support or political contribution that all executives, supervisors and employees of the Company and those of its subsidiaries are required to strictly follow as informed and trained.
The Company’s risk assessment comprises the following procedures.
1. Risk identification, chief of each working unit of the Company and those of its subsidiaries shall identify possible risks.
2. Risk assessment, after the risks are identified, their impact on goal achievement as well as the likelihood and possible degree of impact will be assessed.
3. Risk management, strategies or activities shall be designed to keep risks at the Company’s acceptable level. The Company shall have to consider whether existing risk management plans are adequate for risk reduction and impact mitigation.
4. Controlling activities, that is, the Company’s policies or operation procedures namely approval, review, account reconciliation and division of work shall be applied to ensure appropriate and timely risk management.
5. Risk Monitoring and reporting, this is to monitor and improve the activities for assessment of all kinds of risks on a continual basis. Information on risk regarding dishonesty and corruption will be compiled and reported to the Risk Management Committee. The Committee assesses and analyzes risk, prioritizes risks, prescribes guidelines and strategy for managing risk regarding dishonesty and corruption in order to control the risk to be at acceptable level with optimal cost, then reports results of the anti-corruption risk assessment to the Audit Committee and the Board of Directors for consideration and granting approval.
6. Communication, by arranging for communication on risk management according to the approval of the Audit Committee and the Board of Directors to concerned parties in order to prepare manuals and practical principles to be communicated to every member of the unit for acknowledgement and compliance.
7. Following up results, according to opinions of the Audit Committee and the Board of Directors including the compliance with the practical manuals at least once a year.
8. Reporting, by the Audit Committee on compliance with practical manuals to the Board of Directors annually.
The Company’s President is a role model leader of the organization who implements anti-corruption policies seriously, namely,
- Presenting commitment in fighting against dishonest acts through the message from the President regarding counter-corruption measures in order to notify all stakeholders,
- Adopting the intention to fight against corruption with Thailand’s Private Sector’s Collective Action Coalition Against Corruption (CAC),
- Being appointed as member of the Anti-Corruption Cooperation Subcommittee to consider Ministry of Finance’s guidelines for cooperation to prevent malpractices and increase transparency in procurement,
- The President’s signing to be a member of the PACT Network,
- Executives’ cooperation in providing answers to the opinion survey of private companies relating to corruption problems of the IOD,
- The President provided support to the knowledge test activity relating to counter-corruption measures via the Company’s online system and presented rewards to employees with highest score.
Performing duties as a role model by the leaders of the organization in this manner can create confidence among all employee in order for them to join hands in fighting against dishonest acts, and all employees shall strictly comply with the counter-corruption policy.In addition, the Company has prepared practical methods to counter malpractices in order to control, prevent and monitor risk from such dishonest acts.The Company has disclosed such practices in its intranet and has provided knowledge regarding policies and methods to counter corruption on a quarterly basis via “Noo Dee’s Stories” Project, in which knowledge has been communicated to all employees of the Company and its subsidiaries through the Pop-Up emails on the computer screens of employees, public relations boards at various points in the Head Office and the office of every project of the Company, including its subsidiary Companies. All new employees have to learn and acknowledge the policies and practices regarding anti-corruption immediately after joining the Company and in every orientation course for new employees. The Company has also conducted public relations on such policies and practices to the third parties and all of its suppliers.
In addition, the Company has also established procedures to record and collect statistical data on the number of whistleblowing, types of clues, the number of clues that have been investigated, the summary results of the investigation of each complaint including the report on annual statistical whistleblowing or complaints to be submitted to the Audit Committee and the Board of Directors in writing. This is for the purpose of monitoring progress and improving the Company’s operations to prevent the acts of corruption in all forms.
From the corruption risk assessment processes, the results were contributed to an anti-corruption policy and established operation guidelines to prevent corruption regardless of bribes, gifts, rewards, conflict of interest, etc. To ensure the policy compliance, responsible persons have been assigned to monitor risk-prone operation under the supervision of the management. The management has intention to encourage the Company’s and subsidiaries’ employees and contractors not to involve in corruption. Such intention was stressed to all business and trading partners at the annual thank you party organized for the contractors. If contractors have any comment to express, or if any unfair treatment was found, they can directly make report or comment to the Company’s senior executives or send via email at firstname.lastname@example.org.
In 2018, the policies, operation guidelines, punishment, monitoring and review measures relating to countering dishonesty and corruption were included in the Company’s Code of Conduct to be strictly complied with by directors, executives and employees of the Company. All employees are also required to sign to acknowledge the Company’s policy every year.