Code of Conduct

To all directors, executives, and employees in the EFORL-AIM Group.

The Company has a code of ethics. Which are voluntary obligations which set standards and principles for the business activities of the Company as follows

The Company encourages directors, executives, and employees to apply the above principles. Bring it's as a working principle, including living until being habitual to grow the Company and personal life sustainably.

The Company, to be a leader in business, directors, executives, and employees must use Corporate Governance as a guideline for business operations. To build honesty, have a responsibility, and protect the interests of the interested parties as well as providing opportunities for the interested parties. To participate in corporate governance and give opinions on business operations to be a mechanism and process that will take care of the action seriously lead to the creation of a good corporate governance organization with standards for doing business to be accepted among all stakeholders.

This code of business conduct effective from December 19, 2019, onwards.

Introduction and Business Principles

With the Company’s vision that We aspire to become the leader in distribution and service in healthiness and medical equipment and supplies for the best living of human life.

The important thing can make us achieve that vision. Must achieve financial success and satisfying all relevant parties, including business ethics, which leads to the well-being of the people. This is identified in which things are right actions and which are wrong actions that cover what we say and do; this is the foundation of honesty and professionalism and combined with corporate values of the Company which is shown as follows.

Core Values

With characteristics and norms that are unique to the Company and affect behavior, which is a guideline for the behavior of directors, executives, and employees consist of

• Self-respect
• Accountability, and
• Integrity

Was developed into principles, values, standards, or rules of behavior, which are guidelines for decisions company procedures and systems in the guidelines

One : Promoting the benefits that stakeholders should receive and

Two : Respect the rights of departments and all interested parties affected by the operations of the Company.

The right decision

If directors, executives, and staff have difficulty making decisions or performing work regarding ethics that are not defined in the Company’s business ethics, the Company has specified a working process. To guide decisions or operations as follows.

Management and ethics

The Company has established guidelines for managing and maintaining business ethics as follows

1. All directors, executives, and employees must strictly adhere to the code of conduct.
   In case of violation or having acted in violation of the code of conduct, resulting in damage to the reputation and financial status of the Company until it became a criminal offense, the Company can file a legal action against the offender or at the discretion of the Company.
2. All directors, executives, and employees must sign and acknowledge this Code of Conduct and must oversee and encourage subordinates to comply with this code of ethics.
3. Executives and supervisors must be good role models in complying with the code of conduct. And must oversee and encourage subordinates to comply with this code of ethics.
4. Specifying the Audit Committee, which has authority and responsibility by presenting it in the audit committee charter.

Code of Ethics for the Treatment of Stakeholders

1. Treatment to shareholders

   The Company intends to be a good representative. Responsible and conduct business to create maximum satisfaction for shareholders. About sustainable growth with good rewards build an increase in company value in the long run. Have a standardized accounting system, and the report is reliable. To comply with the said principle, the Company, therefore, strictly adheres to the business ethics guidelines as follows.

   1) Sustainable company growth

   • Perform duties with honesty, honesty, and fairness to all shareholders.
   • Manage the business of the Company by using knowledge, experience accumulated, and management skills adapted to suit at full capacity in all cases, including the decision to take any action will be done with care and prudence.
   • Do not take any action that may cause a conflict of interest with the Company.
   • Establish a structure and operating system with standards and good control by fully using the knowledge and abilities with care with enough information and evidence that can be referenced, including adhering to the rules, announcements, regulations, and relevant laws.

   2) Information disclosure

   • Report the status and future trends of the Company to shareholders equally, timely, and completely according to reality.
   • It is not seeking benefits for oneself or related persons by using any information about the Company that has not been disclosed to the public.
   • Not disclosing sensitive or confidential internal information, which will lead to the disadvantage of the Company.

2. Treatment to customers

   The Company is committed to creating satisfaction and confidence for customers. By delivering good quality products and services at a reasonable price level, including maintaining good and lasting relationships. The Company has established guidelines as follows

   1) Committed to creating satisfaction and confidence for customers. To get good products and services with quality and reasonable prices as well as continuously raising the standards of work and service.

   2) Providing accurate and complete information regarding products and services without distorting or concealing facts, including maintaining good and lasting relationships.

   3) Provide product warranty providing after-sales service and other services under appropriate conditions and time frames.

   4) Prepare and develop systems to allow customers to make complaints about products, services, and best practices to provide customers with a prompt and timely response.

   5) Do not trade undue profits when comparing the quality of products or services of the same type or category and do not specify unfair trade conditions for customers.

   6) Strictly complying with various terms and conditions with customers. If unable to comply with the terms or conditions must notify customers in advance or as soon as they know they are unable to do so to find a suitable solution together.

   7) Directors, executives, and employees at all levels must keep confidential do not disclose customer information without first obtaining permission from the client or the authorized person of the Company except that the information must be disclosed to relevant third parties by the regulations of the law.

   8) Not discriminating against customers adheres to treating every customer in every group fairly, both products and services.

3. Treatment of trade partners and contractors

   The Company considers equality and honesty in business operations and mutual benefits with trade partners and contractors. The business partners are important in creating and delivering good products and services to customers. The Company will comply with the regulations. Laws and regulations that are strictly related and have good ethics in conducting business the Company has established guidelines as follows

   1) The Company will treat the partners equally and fairly and based on fair compensation for both parties as well as strictly abide by the contract or agreed on conditions.

   2) The Company intends to develop and maintain a lasting relationship that has mutual trust with suppliers and contractors with clear objectives regarding the quality of products and services suitable for the price.

4. Treatment to creditors

   The Company has established good practices for creditors as follows:

   1) The Company adheres to the contract agreement. Maintain and comply with trade and financial terms and conditions. Both in paying for goods repayment of principal, interest, and custody of assets, collateral, and other conditions.

   2) In the case that cannot be complied, must hurry to negotiate with creditors in advance to find a mutual agreement to solve the problem.

   3) Accurate financial information disclosure consistently completes, so the creditors are confident in their financial status and ability to pay off debt.

5. Treatment towards competitors

   The Company has set good practice guidelines for competitors as follows

   1) Performing by the rules of good competition.

   2) Not seeking confidential information of business competitors by dishonest or inappropriate methods.

   3) Not trying to damage the reputation of business competitors by making false accusations without ground.

Ethics of treatment of Company

The Company will comply with the laws and regulations of the government, including directors, executives, and staff must comply with regulations. Directors, executives, and employees must avoid and involve in illegal activities or against public order or good morals of the people. The use of directors, executives, and employees or company assets for illegal purposes is prohibited.

Aside from complying with the law, all directors, executives, and employees must perform duties following the ethical principles of business ethics, which is an asset for the Company.

1. Company laws and regulations.

   1) Directors, executives, and staff must strictly comply with the laws, regulations, rules, and orders of the Company.

   2) Violation of the law, shareholders’ resolution, Board resolutions, regulations, rules, or orders of the Company. By claiming that it was an act to increase profits for E for L Aim Group or any other reason, not a reason to listen.

   3) Directors, management, and staff members must perform their duties with honesty with due regard to the legitimate interests of the Company. However, there are gaps in the law or gaps in the regulations, rules, and orders of the Company.

2. Securities and disclosure of internal information laws

   1) Directors, executives, and staff must comply with the regulations of the Securities and Exchange Commission and strict relevant laws, which include disclosure of information to shareholders and or to the public equally.

   2) The committee, executives, and employees use internal information that has not been disclosed to the public or general shareholders for the benefit of private securities trading Considered as an unethical act of the Company.

   3) Prohibiting directors, executives, and related employees who know information about financial statements buy and or sell stocks 45 days before disclosure and 24 hours after the disclosure. For other significant information, directors are prohibited executives and employees who know stock trading information from the date they are informed and 24 hours after disclosing the said information to the Stock Exchange of Thailand.

   4) Disclosing information that affects Chief Executive Officer must approve business and stock prices. Chief Executive Officer will be responsible for the operation or assign any person to be responsible for disclosing the said information.

   5) The investor Relations Department is responsible for providing information to the public and investors. In which the organization that owns the data is responsible for supporting the data.

   6) Directors, management, and staff members must not comment on the trading of company securities unless it is related to the work assigned by the Company.

3. Protection of company assets

   1) Company property means movable property, Real Estate, technology, knowledge, information, copyrights, including any resources of the Company or which the Company has rights.

   2) Directors, executives, and staff have duties and responsibilities to use the Company’s assets economically and to the best of the Company. And take care not to damage the loss.

   3) Business information and documents are important assets of the Company. Each department must specify the period for document collection-the document’s secret class. And keep the said documents correctly, completely, and can be inspected.

   4) Employees must prepare business documents, accounting, and finance and reports that are submitted to government agencies and all other persons carefully and in good faith and must be recorded under the Company’s accounting procedures that comply with the established standards.

   5) Directors, executives, and staff must strictly comply with accounting, finance, and internal control principles. They must notify the responsible person in the department or the Audit Committee to acknowledged if any mistakes are found in operation.

4. Computer and communication systems

   1) Directors, executives, and employees must comply with guidelines and instructions regarding the use of computer and communication equipment. Including the electronic information of the Company strictly for the benefit of the Company as well as must not act in violation of the law or for the benefit of one’s own business, the Company has the right to inspect the use of computer equipment. Electronic data or various information technology such as data transmission, Data collection without needing permission.

   2) Directors, executives, and employees must avoid accessing websites that the Company considers illegal or violates good morals. And refrain from publishing such information or websites to others. Including must avoid visiting websites that are not known, which has security risks.

   3) Directors, executives, and assigned personnel only who has access to the data file Regardless of whether stored in the form of computer data files or others, directors are prohibited. Executives and employees who are not assigned to view, duplicate, publish, delete, destroy, or change information, change the password or other actions that may cause damage.

   4) Directors, executives, and employees who use the Company’s computer must use the software under the license of the copyright owner and only licensed for use by that Company to prevent the problem of intellectual property violations.

5. Intellectual Property

   1) Works resulting from the performance of duties are considered the intellectual property of the Company.

   2) Bringing the work or information which is the right of the third party received or will be used within the Company. Must be checked first to ensure that it will not violate the intellectual property of others.

   3) Upon retirement from being a director, executive and staff must deliver intellectual property, including works, inventions, etc. back to the Company quickly whether the data is stored in any form.

Procurement and Transaction ethics

The Company intends to provide products and services procurement. With standards and fairness to trade partners, contractors, to acquire products and services of good quality, reasonable price and beneficial to the Company, therefore, the details of procurement and transactions, are as follows:

1. Procurement

   1) The Company will have a procurement process according to the following principles

   • There is competition on the information received equally.
   • There are criteria for evaluating and selecting trade partners and contractors.
   • Establish suitable contract conditions.
   • Establish a management and monitoring system to ensure that it has fully complied with the terms of the contract and prevent fraud and misconduct at every step of the procurement process.
   • Paying to partners and the parties on time, according to the agreed payment terms.

   2) Prohibiting directors, executives, and employees use the information they received due to procurement, for one’s benefit and one particular contract partner or other unrelated people including not being involved in the procurement with a contracting party that is related to oneself, such as a family member, close relative or self-owned or a partner.

   3) Procurement must go through the steps by the regulations, orders, methods of procurement, and strictly carried out by the responsible department following the operating authority.

   4) Directors, executives, and employees must refrain from any actions that will help business partners do not have to pay any taxes that should be paid to the state.

   5) The Company will give priority to employment in the local area or the neighboring community. It is to create community relations. To support industrial businesses in the country and is to reduce operating costs.

2. Transactions between companies in the EFORL AIM Group

   1) Directors, Executives, and employees must carefully study the rules, methods, and procedures for authority to proceed by the procedures specified by the Company.

   2) When having a duty to be related to the connected transactions, Employees must report to the supervisor of the condition-detailed criteria or characteristics of the transaction.

   3) Projects or related transactions must be carried out under the rules. And the process of both laws and regulations issued by the government and strict company rules.

   4) If in doubt, ask the supervisor or accounting department.

3. Transactions with external parties or companies

   1) The transaction must take into consideration the quantity, value, price, quality, service conditions that are by the market mechanism, or fair price by not discriminating against or discriminating in business practices that are unjustified or unlawful.

   2) Directors, executives, and employees should avoid any transactions that may cause damage to the Company’s reputation, even if that transaction will allow the Company to receive business benefits.

   3) Prohibiting directors, executives, and employees falsely use the name of the Company, Board of directors, or company employees in transactions that are not related to the Company even if it does not have a direct impact on the Company.

Code of Ethics for the Prevention of Conflict of Interest

The Company intends that the directors, executives, and employees try to avoid conflicts about interests that may affect any decision. In performing duties, the Company must uphold the benefits under the law and ethics.

1. Conflict of interest

   1) Directors, executives, and employees must avoid conflicts between their interests. And the Company’s interest in dealing with business partners and any other parties.

   2) While working for the E FOR L AIM group and after the operation is over, the directors, executives, and employees must not disclose the confidential information of the Company for the benefit of anybody. Whether electronic data Financial information Operation, business information, plans of the Company, and others.

   3) Directors, executives, and employees should not engage in any operation or investment, which is a competition or may compete with the Company’s business. In the case of the directors, executives, and employees, members of the family are involved. Or being a significant shareholder in any business that may have a conflict of interest or cause business conflicts with the E FOR L AIM group, must notify the Chief Executive Officer or Managing Director in writing as soon as possible.

   4) Directors, Executives, and Employees should refrain from holding shares that have the power to make decisions in the business of their competitors. If making the directors, executives, and employees commit or omit actions that should be performed according to their duties. In the case of the directors, executives, and employees acquired shares before being a director, Executives, and employees, or before the Company enters the business or acquired through inheritance. Directors, executives, and employees must report to the Chief Executive officer or supervisor.

   5) The executives and employees are directors, or consultants in the other Company, or other organizations, or other business associations, must not conflict with benefits and direct duty, including having to get approval from the Chief Executive Officer or Managing Director first.

   6) Executives and employees must not borrow loans from business partners whom the Company does business. Except for financial institutions as it may influence the performance of duties as a company representative.

   7) Prohibiting directors, executives, and employees pay or give company assets to anyone without approval from the authorized person by the approval authority table.

   8) Executives and employees must not use the time of the Company to work elsewhere except in the case of necessary with prior approval from the supervisor.

Ethics for Employees

The Company is aware of the value of human resources and wished for the Directors, Executives, and employees are proud of the organization, by enhancing the working atmosphere with participation and have equal opportunities to advance in their career and professional. Directors, executives, and employees will be developed, promoted, and knowledge comprehensively and continuously to create value and maintain business excellence.

1. Treatment to employees

   • The Company will treat the directors, executives, and all employees concerning honor and dignity.
   • The Company will hire the select people for various positions with fairness by considering the qualifications of each position, educational qualifications, experience, and other requirements necessary for the job without restrictions on gender, age, ethnicity, religion.
   • The Company will set compensation for executives and employees fairly as appropriate, comparable to the remuneration in the same industry or similar in size compared to the condition and nature of the job the Company’s performance and ability to pay that compensation.
   • The Company will encourage directors, executives, and employees are trained and developed. To improve work efficiency, analyze decision-making and to allow directors, executives, and employees have higher capabilities. And progress in their career.
   • The Company recognizes that good communication will lead to efficiency and good relationships to work together. Therefore, the Company will encourage directors, executives, and employees are always informed about relevant news as appropriate and as far as possible.
   • The Company will allow directors, executives, and employees to have communication channels. Suggestions and Complaints about frustration about work suggestions and complaints will be considered seriously. And fixing solutions for the benefit of every department and build good relationships in working together.
   • The Company will maintain the personal information of directors, executives, and employees, such as biography, health history, work history, or other personal information. Disclosure of the transfer of personal information of directors, executives, and employees to the public will able to get approval from directors, executives, and employees. Violation is considered a disciplinary offense unless done according to company regulations or according to law.

2. Employee behavior and the treatment toward others.

   • The supervisor should act respectfully for the employees, and employees should not do any actions which do not respect the supervisor.
   • All directors, executives, and employees must not take any actions that violate or threaten whether verbally or acts against others based on race, gender, religion, age, physical, or mental disability.
   • Directors, executives, and employees must perform their duties with honesty, care, to enhance the quality, efficiency, and development of the organization to excellence.
   • Directors, executives, and employees will not accuse the board of directors, executives, employees, or other employees by false statements.
   • Directors, executives, and employees will jointly create and maintain an atmosphere of unity and solidarity among the directors, executives, and employees.
   • Directors, executives, and employees should avoid any actions that may affect the reputation of the Company or maybe a problem for the Company. Directors, executives, and employees should maintain their honor to be accepted in society.

Ethics for safety, health, and environment

The Company is committed to the directors, executives, and employees, including the communities around the workplace of the Company, well-being, and will maintain a good environment. The Company has specified working procedures. To be safe in working as per the requirements of relevant laws and regulations as follows.

1. Safety and hygiene

   • The Company tries to prevent accidents occupational injuries and illness with the serious cooperation of the directors, executives, and all employees, including to limit and manage security risks arising from business operations.
   • The Company will comply with all laws and regulations regarding safety strictly. And will implement credible safety management standards in the absence of laws and regulations.
   • The Company will arrange for the design of tools, equipment, well-organized regulations, action planning, and training executives, and staff to have knowledge and understanding. And receive enough information about workplace safety to prevent danger caused by tools, equipment, work methods, or various illnesses.
   • The Company will not allow directors, executives, and employees if health and body are not ready to reduce the risk of danger from work.
   • Executives and employees reporting to work with illegal substances in the body or influencing alcohol or other addictive substances at a level that can adversely affect work must be disciplined.
   • The supervisor is responsible for determining or disseminating guidelines to prevent and control accidents and hygiene issues from working for employees and related parties as well as organizing a committee for health examination executives, and employees.

2. Social and Environmental Responsibility

   • The Company has the policy to operate the business with concern to society and the environment. And will comply with the requirements According to relevant laws and regulations, Including regulations of local agencies such as the District Public Health Office.
   • In the absence of laws or regulations, the Company will treat society and the environment with responsibility by
     • Encourage directors, executives, and employees to have awareness and responsibility towards the environment.
     • Public relations with the community regarding environmental matters, including exchanging knowledge and experience with other agencies to preserve the environment and continuously improve operations to suit the environment.
     • Manage operations to prevent environmental impacts review and evaluate the operational results continuously and consistently. To track progress and to ensure that the Company complies with the environmental policy.
   • The Company will support and aid that is suitable for the society and community. Especially the communities around the company premises.
   • The Company will provide opportunities for communities and stakeholders. Participate in ideas for projects that may affect the community. Or complaints resulting from the Company’s operations.
   • The Company will cooperate in reducing the occurrence of waste or waste from the service process and general usage and will study and cooperate in the disposal of waste or waste correctly.
   • The Company will assess the risk and the impact on matters related to the environmental community health and safety before the budget is allocated into any activity/project.

Anti-Corruption Ethics

The Company is determined to prevent and combat corruption in all its forms, both directly and indirectly, and to enable business operations that may be at risk of corruption will be considered and treated carefully. The Company has therefore prepared “Anti-Corruption Policy” in writing by the Company and subsidiaries comply with the anti-corruption policy to strive to push and maintain the corporate culture as the main values by adhering to self-respect, responsibility, accountability, and organizational integrity.

1. Donations for charity and the public benefit

   The Company has the policy to donate for public benefit to the hospital, Public health department, other Departments, or organizations. The authority to approve the donation is specified in the authority table.

2. Donation

   The Company does not have an inappropriate donation policy.

3. Funding

   Funding refers to money paid to customers, partners, joint venture partners, or other persons sensibly with business objectives, Company reputation, or help strengthen business relationships and suitable for the opportunity transparent.

4. Receiving financial support

    

5. Process and control into consideration, requesting approval, donations, and funding.

   1) Donations and grants should comply with company policy.

   2) There is a clear objective of the donation and funding.

   3) There is a time limit.

   4) List of individuals, departments, or organizations that are specific to accepting donations or receiving support for use in various purposes.

   5) Must proof a receipt of goods or receipt that is correct or other evidence of payment such as a thank you letter etc.

   6) The approval authority is under the Company’s regulations by using the “Authority Table” for consideration.

6. Giving gifts or certify

   The Company has no policy to give of any kind to those who do business with the Company. Except for gift-giving and receptivity according to the appropriated tradition to maintain good relationships with businesspeople. Without hoping to receive a specific service or compensation, which is not correct by business ethics.

   Giving gifts and certifying should meet the following criteria.

   1) Must follow a tradition that has customary practices, which must be done with transparency.

   2) Must be estimated as appropriate and suitable for the occasion.

   3) Must not conflict with laws, regulations, and the Company’s ethics and policies.

7. Accepting gifts or certification

   1) Accepting gifts worth more than Baht 3,000. - (Three thousand baht) must reject them. If unable to reject the receipt, gift recipients must report to the highest supervisor according to the line of work. By using the report of accepting gifts or other benefits to deliver to be the property of the Company, if the received gift is cash to reject all cases.

   2) Goods receipt due to sales promotion, must not receive to obtain mutual business agreements and not for the benefit of any person, which can be received in the case of giving between the Company and the Company, by not violating the anti-corruption policy and have a clear receipt document can check.

   3) Certification should meet the following criteria.

   • Must follow a tradition that has customary practices, which must be done with transparency.
   • Must be approximately reasonable and suitable for the occasion.
   • Must not conflict with laws, regulations, and the Company’s ethics and policies.

8. Receiving discounts from partners

   Receiving discounts from partners in the form of money or other assets of value should follow general business practices and transparent.

9. Investment and trade

   The Company has an investment policy that adheres to the framework of good competition rules. To be fair.

10. Procurement

    The Company provides fair and transparent procurement for all parties. Procurement must present to the authorized person by the Company’s operating authority table and must comply with the regulations set forth by the Company.

11. Accounting and finance

    Receiving-payment

    The Company has the following guidelines for receiving or paying money.

    1. Receiving money from customers Juristic person or any other person.

       1.1) Before receiving the money, the finance department must always know what purpose it is to receive money. And there is a reasonable ground to receive the said amount of money.

       1.2) Not calling or receiving Financial benefits or other benefits from the payer to delay receiving the Company’s money or causing damage to the Company from not receiving money or receiving delay or receiving in full.

    2. Payment to creditors Juristic person or any other person.

       2.1) Before every payment, what is the purpose of the payment check for what purpose? And must go through accounting records from the accounting department and is a correct transaction according to accounting principles and relevant laws, if found incorrect or inappropriate items, to report to the supervisor and find a way to prevent and resolve to be by accounting principles and related laws.

       2.2) In every payment, approval for payment shall be by the operation authority table.

       2.3) To treat creditors or payees in an equal manner by paying according to the appropriate business conditions, do not discriminate against any creditor or payee with bias or unfairness.

       2.4) Not calling or receiving, do not offer or provide financial benefits or other benefits to creditors or payees that will cause damage to the Company.

12. Money Laundering Prevention

    The Company will act following the law on prevention and suppression of money laundering.

13. Operation Human Resources

    Personnel management process of the Company, covering anti-corruption policies, starting from recruitment, hiring, employment, compensation, and welfare payments.

14. Communication, training, and information disclosure

    The Company will communicate both internally and externally regarding anti-corruption policies and practices. To those involved in the appropriate channels.

15. Recording and data storage

    The Company has the policy to comply with standards, principles, including applicable laws regarding accounting and financial data reports. Including various business information by the law.

16. Internal Audit / Internal Control Process

    The Company has an internal audit process every quarter from companies that provide internal auditing services listed on the Stock Exchange of Thailand. By giving independence and unlimited boundaries for auditors in their operations In which the Company providing this internal audit service have examined according to the authority table, executed various commands covering Against corruption There is also an audit by the Office of Certified Public Accountants every quarter and every year. According to the requirements of the Securities and Exchange Commission Department of Business Development and the Revenue Department.

    The Company has specified the procedures for the inspection results as follows.

    1) The Company providing internal audit services must report the findings and issues at least once a quarter to the Audit Committee.

    2) If finding urgent issues, the Company that provides internal audit services will notify the chairperson of the Audit Committee immediately.

    3) The Audit Committee will be responsible for reporting the audit results to the Board of Directors.

17. Monitoring and review

    The Company requires regular control of operations under the anti-corruption policy through the internal audit process. And if finding issues or encounter an increased risk will present the Audit Committee and management to review and improve the anti-corruption measures manual to be appropriate.

Whistleblowing

The Company encourages directors, executives, and employees of the Company and stakeholders. Participate in overseeing legal compliance Related rules Principles of good corporate governance and business ethics Including reports and complaints about illegal behavior or ethics or behavior that may indicate corruption or misconduct of people in the organizations more transparent and effective. Therefore, the Company has set a standard for reporting clues. Including establishing mechanisms for protecting whistleblowers and the respondent and pay more attention to the collection of confidential information, which will be known only to those assigned and related to building confidence for the whistleblowers as follows.

Whistleblowing measures

1. Whistleblowing measures The Company encourages all employees and stakeholders to notify the Company of the clues immediately if found to be misconduct or behavior suspected of having committed the following offenses.

   • Illegal practices or relevant regulations, including business ethics.
   • Corruption and bribe.
   • Suspicious actions relating to money laundering, finance, accounting, including audits and controls.

2. Definitions

   • “Whistleblowing” means providing information to a company about actions that are believed to have committed an offense under 1
   • “Whistleblower” means a director, employees, stakeholder, or third party.
   • “Claimant” means the secretary of the Audit Committee.

3. Channels and methods for reporting clues

   Clues can be reported in writing by “Report Box for Complaint and Whistleblowing” at E FOR L AIM Public Company Limited Office No. 432, 434, 436, and 438 Ratchawithi Road, Bangyikhan Subdistrict, Bangplad District, Bangkok 10700.

   The methods for reporting clues are as follows

   1) Clue informer submits the matter in writing that “Report Box for Complaint and Whistleblowing.”

   2) Clue informant presenting the Audit Committee when the Audit Committee has considered, if having willed appoint a fact-finding committee based on the clues that the complaint, however, if the respondent is a person in the department or project line, supervisors, or supervisors in the said project will not participate in the investigation of facts unless it is an explanation as requested by the investigation committee.

   3) Clue informant that has been reported all information must be kept confidential without disclosure to third parties or the outsiders. If not allowed by the Chairperson to search for the facts about the said clue. The name of the whistleblower and the complainant will not be disclosed to prevent such persons from being affected.

   4) The whistleblowers will receive an investigation report and the company’s operations within 2-4 weeks after giving a clue. If the fact search is not complete within the deadline, the investigation team will report the progress to the whistleblowers every two weeks.

4. Information about whistleblowers

   Whistleblowers should notify name-surname, phone number. So, the Company can contact and ask for more information. In the case that the whistleblower does not wish to disclose the name. The Company may search for clues that have been reported if you believe that the above clues will cause damage to the Company.

5. Protection of whistleblowers

   To build confidence for the whistleblower. The Company will protect the whistleblowers. The names of the whistleblowers will be kept, including the whistleblowing report and the fact-finding secret. Only the relevant parties will receive the information.

   Whistleblowers will be protected from being impacted at work. Those who bully the whistleblower or disclose the information of the whistleblower with dishonest intent must be punished as appropriate.

   Also, the receiver must set measures to protect the whistleblowers and the person providing information in the investigation to prevent danger and suffering or unrighteousness due to clues, testimony, or information.

6. Protection of the complainant

   The Company recognizes the responsibility to the respondent. The information about the respondent will be kept confidential during the investigation, and the investigation results will be considered. If no such decision has been made, the investigation team will allow the respondent to clarify the complaint before considering the decision, including the results of the investigation.

7. Intentionally giving false clues

   If the whistleblower intentionally makes a false statement, it will not be protected under this measure. And will receive disciplinary action or being prosecuted according to law.

8. Consideration of penalties

   If the investigation results reveal that the respondent is truly guilty, or the whistleblower has intentionally made a false statement. The receiver shall be notified of the cushion for proposing the matter together with the opinion and determining the method of disciplinary action and according to the relevant laws to the person with the power to consider the procedure.

9. Reporting clues

   The clue taker is the reporter and presents the whistleblowing report to the Board of Directors. The secretary of the Board of Directors will gather information and present it to the Board of Directors for approval to disclose in the annual report.

1. I have received and read the massage in “Business ethics of E FOR L AIM Public Company Limited.”
2. I understand and will adhere to the principles of this Code of Conduct as a best practice.