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Anti-Corruption Policy

E FOR L AIM PUBLIC COMPANY LIMITED
Anti-Corruption Policy

E FOR L AIM PUBLIC COMPANY LIMITED is committed to conduct business with honesty, transparency, and according to corporate governance principles. The Company has signed the Statement of Intent of Private Sector Collective Action Coalition Against Corruption – CAC to show its commitment and earnestness to combating corruption in all its forms.

To ensure that the Company has a policy to demonstrate the responsibilities, practical guidelines, and operational requirements to prevent corruption of all business activities of the Company to make decisions and conduct business that may be exposed to corruption risk, the Company has developed an “Anti-Corruption Policy.” This is a clear guideline for conducting business and develops into a sustainable organization.

Definition of Anti-Corruption Policy

Corruption means bribery, regardless of its form. Promise to give to a pledge to claim or receive money, property, or any other improper benefits with government officers, government sector, private sectors or a person who has a duty whether direct or indirect. To allow such people to act or refrain from performing his duties; This is the acquisition or maintain of the business. The Company will not be liable for any loss or damage arising out or in connection with its use unless the law, ordinance, regulations, local traditions or a commercial conspiracy.

Anti-Corruption Policy

The directors, executives, and employees of the Company are prohibited to perform or to accept corruption in any form, either directly or indirectly. It covers all businesses and all related organizations, and regularly reviews the compliance with this anti-corruption policy, review the practical guidelines including, and compliance requirements to match business changes, regulations, and legal requirements.

Responsibilities

  1. Board of Directors has the duty and responsibility to set policies and supervise a system that supports effective anti-corruption. To ensure that the management realizes and values the anti-corruption and cultivates the corporate culture.
  2. Audit Committee has duties and responsibilities to review financial and accounting report systems, internal controls, and the internal audit system.
  3. Risk Management Subcommittee has duty that also supports the implementation of anti-corruption risk management system ensures that the standards are in line with international standards, are concise, appropriate, up-to-date and effective.
  4. Chief Executive Officer and the Executive have the duty and responsibility to establish a system and to promote and support anti-corruption policies, to communicate to all employees and stakeholders. Review the appropriateness of the systems and measures to be in line with changes in business, regulatory, and regulatory requirements.

Practical Guidelines

  1. Directors, Executives, Employees of all levels must abide by the Anti-Corruption Policy and the Code of Conduct, which must not be involved in corruption either directly or indirectly.
  2. EFORL employees do not neglect or ignore, when seeing the actions that corrupt the company. To notify the supervisor or the person in charge if you have any questions or concerns, consult your supervisor.
  3. The Company shall ensure fairness and protect employees who refuse, or report corruption related to the Company by applying a complaint protection measure or collaborators in reporting corrupt corruption as the Company set in the practice “Receiving complaints and reporting offenses” (Whistle blower Policy).
  4. The corrupt offense to the Company Code of Conduct which must be disciplined in accordance with the rules set by the Company. In additional, it may be punished by law, if the action is illegal.
  5. The Company is aware of the importance of disseminating knowledge and understanding to other persons who must perform duties related to the Company or maybe the impact on the Company. This is in line with the Anti-Corruption Policy.
  6. The Company is committed to creating and maintaining a corruption that is unacceptable both to transactions with the public and private sectors.

  1. Anti-corruption policy covers the human resource process, from recruiting or selection, promotion, training, employee performance appraisal, and reward. The managements and supervisors at all levels communicate, understanding employees to use in business activities that are in charge and to supervise the operation to be efficiency.
  2. To implement any anti-corruption policy, use the guidelines set forth in the Code of Conduct, Corporate Governance Manual, Policy and guidelines for stakeholders, including regulations, and the employee’s manual that associated all other practices will be further define by the Company.
  3. For the sake of clarity in dealing with high risks of corruption, Board of Directors, Executives, and employees of the Company at all levels must be treated with caution in the following matters.

    3.1. Gifts, receptions, expenses
    Giving, receiving gifts are in accordance with the Code of Conduct.

    3.2. Charity donation or support money
    Giving or receiving donations, the funding must be transparent and legal; be sure to donate; the money was not used as an excuse for bribery.

    3.3. Business Relations and Procurement with Government
    Do not give or accept bribes in any type of business. Company Operations and contact with the public sector must be transparent, honest and must comply with the relevant laws.

Announced on 25 September 2018

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