Risk Assessment on Corruption
Since 2013, the Company has required all of its working units and subsidiaries to conduct risk assessment on corruption at least once a year. The year 2015 is the third year of implementation under this requirement. 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.
- Risk identification, chief of each working unit of the Company and those of its subsidiaries shall identify possible risks.
- 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.
- 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.
- 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.
- 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 for the risk to be at acceptable level with appropriate cost, then reports results of the risk assessment to the Audit Committee and the Board of Directors for consideration and granting approval.
- 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.
- 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.
- 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 the private sector’s Collective Action Coalition,
- 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,
- Participating in the contest of the “Project to Assess Operations for Sustainability Re Anti-Corruption Progress Indicators of Thai Listed Companies” of 2015 organized by Thaipat Institute, and the Company has won level 3 of the sustainability development in terms of anti-corruption of 2015, upgraded from level 2 in 2014 due to the progress in prevention against involvement in corruption,
- Executives’ cooperation in providing answers to the opinion survey of private companies relating to corruption problems of the IOD,
- The President and the Executive Vice President led Supalai’s employees to join the counter-corruption parade and listen to the panel discussion on “Active Citizen, People’s Power Against Corruption” on the National Counter-Corruption Day,
- 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. As for new employees, they shall learn about the policies and practical guidelines to counter dishonest acts once they begin working in additional to the knowledge gained from the orientation organized for new employees.
Moreover, the Company has provided a channel for accepting reports on clues and complaints on corrupt acts. Clues or complaints can be sent directly to e-mails of the Company, email@example.com. This submission channel has been widely promoted for all parties’ acknowledgement whether the Company’s employees or the third parties. PR leaflets have been sent to all trading partners i.e. contractors, banks or supplier. Recording and gathering of statistical data is required to follow designated procedures, such as the number and types of clues received, investigated, and those subject to action. Result of implementation to each clue or complaint including annual statistics of number of clues or complaints must be reported in writing for the Audit Committee and the Board of Directors to monitor the progress and to improve some of the Company’s working procedures that might cause any form of corruption.
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 2015, 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.