Anti-Bribery and Corruption Policy

1. Purpose

           The policy is established to set a framework for the Company’s personnel at all levels, its related persons, and its authorized persons. They are expected to carry out their responsibilities and duties in compliance with the policy, which include preventing, supervising, and refraining from any actions that lead or may lead to corruption as well as avoiding involvement with bribery in order to support the Company’s compliance with relevant laws.

2. Scope

           The policy applies to operations of the Company and its subsidiaries, collectively referred to as “the Company.” The Company’s personnel, related persons, and authorized persons must study and strictly adhere to this policy.

3. Effective Date

           This policy shall be effective from the date of approval by the Board of Directors.

4. Review Frequency and Revision

           This policy must be reviewed annually, or when a significant change arises.

5. Responsible Function

           The Compliance Office is the responsible function of this policy.

6. Definition

            “The Company” means Bangkok Life Assurance Public Company Limited.

            “Subsidiary” means companies in which the Company holds shares directly or indirectly over 50% of voting shares.

            “Personnel of the Company” means directors, executives, employees, and staff at all levels of Bangkok Life Assurance Public Company Limited and its subsidiaries.

            “Related Persons” means business partners, contractors, agents, consultants, or any person acting for or on behalf of the Company.

            “Corruption” means giving or offering money, property, or anything of value to government or private sector officials, either directly or indirectly, to induce them to act or omit to act in their official capacity, or to abuse their power to gain or maintain the Company’s business.

            “Bribery” means giving, offering, or receiving money, property, or anything of value to or from government or private sector officials to induce them to act or omit to act in their official capacity, regardless of whether such actions are abuse of power, or in a manner that goes against laws, moral integrity, or social ethics. Bribery inducement can take various forms, including money, gifts, hospitality, prizes, properties, or any other benefits. The objective is to gain or maintain the Company’s business or personal interests. The Company does not set a minimum monetary amount or value as an exception for giving or receiving bribes in any circumstances.

7. General Principle

           The Company is committed to conducting its business with moral integrity, adhering to responsibilities to all groups of stakeholders with ethics, honesty, transparency, fairness, and verifiability. The Company participates in the Thai Private Sector Collective Action Against Corruption (CAC) to demonstrate its intention and determination to combat all forms of corruption and bribery. To ensure that the Company’s operations comply with laws and align with good corporate governance principles and international standards on anti-corruption, the Board of Directors has established this Anti-Bribery and Corruption Policy.

8. Requirement

8.1 Zero-Tolerance Stance towards Bribery and Corruption

           The Company does not endorse the giving or receiving of money, property, or anything of value to influence an act or omission of an act for unlawful gains; and will adhere to anti-bribery and corruption laws.

8.2 Types of Transactions with Corruption and Bribery Risks

            The Company has established comprehensive risk control measures to prevent any of the following categories of actions from being used as a means of corruption or bribery.

8.2.1 Gifts and Hospitality

          The Company has established the No Gift Policy for its personnel to foster a transparent corporate culture. However, giving or receiving gifts or hospitality that adheres to traditions and the Company’s practices and codes of conduct is permitted.

8.2.2 Charitable Donations and Sponsorship

          Charitable donations and sponsorship must be consistent with the objectives of improving quality of life and truly beneficial to society. Therefore, the Company has established measures for evaluating charitable donations and sponsorship, considering factors such as the recipient of the donation or sponsorship and the intended purposes before making a donation or providing sponsorship, in order to prevent these channels from being used as tools for corruption or bribery. Furthermore, all donations and sponsorship must strictly adhere to the Company's rules and guidelines.

8.2.3 Facilitation Payment

          The Company does not allow facilitation payment that may potentially lead to corruption and bribery.

8.2.4 Political Contributions

          The Company is a politically neutral business organization and does not provide any assistance or support to any political party or political authority, whether directly or indirectly.

8.2.5 Employment of Government Officials

          The hiring or employment of current or former government officials must go through a transparent qualification and approval process, which is verifiable under the Company's procedures, in order to prevent conflicts of interest.

8.3 Corruption and Bribery Prevention Measures

            The Company has established a systematic and consistent management system to prevent and control the risk of corruption and bribery, as follows:

8.3.1 Risk Assessment

         Conduct a corruption and bribery risk assessment at least once a year, and whenever there are significant changes in operational processes, in order to establish appropriate and up-to-date control measures.

8.3.2 Communication and Training

         Implement communication and training programs for the Company’s personnel to foster understanding of risk types, situations that may lead to corruption or bribery, and prevention methods.

8.3.3 Policy Compliance

         The Company’s personnel must strictly adhere to this policy and are prohibited from participating in, supporting, or ignoring any act that constitutes corruption or bribery.

8.3.4 Whistleblowing Channels

         If you witness any incident or behavior that may constitute corruption or bribery, you must report it to executives, your supervisor, or the Company's designated whistleblower channel without delay, and cooperate with the investigation of the facts.

8.3.5 Monitoring and Evaluation

         The Company monitors the implementation of anti-corruption and bribery measures to assess their effectiveness and efficiency.

8.4 Protection of those who Refuse Corruption or Bribery

           The Company provides protection for its personnel, related persons, and authorized persons who refuse to engage in actions that may constitute corruption or bribery, ensuring that they will not be demoted, punished, or suffer any negative consequences, even if such refusal results in a loss of business opportunities for the Company.

9. Penalty

         Personnel of the Company, agents, financial advisors, and partners who violate this policy are considered having violated the Company’s code of conduct, and may constitute an offense against the Company's rules, as well as other applicable laws, regulations, rules, or requirements, as well as the termination of their business relationship with the Company.
​         External parties who violate this policy may constitute an offense against applicable laws, regulations, rules, or requirements, as well as the termination of their business relationship with the Company.