Anti-Corruption Policy

Anti-Corruption

The Company focuses on sustainable business practices by prioritizing good corporate governance and adequate internal control systems. We have established a clear and comprehensive the Anti Corruption Policy with precise definitions of corruption and operational guidelines communicated to both internal and external stakeholders. Furthermore, the Company conducts audits and assessments to identify corruption risks across its business activities. Control and monitoring measures are implemented for processes susceptible to misconduct to ensure operational integrity and transparency. We also maintain communication channels for stakeholders to report whistleblowing leads, suggestions, or complaints regarding corruption directly to the Audit Committee.

Membership in the Thai Private Sector Collective Action Against Corruption (CAC)

Plan B has formally pledged its intent to combat corruption and has maintained certification as a member of the Thai Private Sector Collective Action Against Corruption (CAC) for nine consecutive years since 2016. This achievement underscores our dedication to transparent operations and good governance in alignment with national standards. We adhere to business ethics and conduct operations with responsibility toward the community, society, the environment, and all stakeholders across the supply chain. Our sustained CAC certification provides empirical proof of our zero tolerance policy toward corruption in any form.

Expanding Governance to the Supply Chain

Plan B recognizes that building a transparent society requires collaboration from all sectors, especially business partners throughout the value chain. Over the past year, the Company has proactively promoted integrity values through the following initiatives:

• Open Letters to Business Partners The Company issued communications regarding its anti corruption policies and invited partners and business alliances to join the Thai Private Sector Collective Action Against Corruption (CAC). This effort aims to establish clean business standards and mitigate corruption risks within procurement processes and joint operations.
• Ethical Supplier Governance Beyond invitations, compliance with anti corruption policies is integrated into the Supplier Code of Conduct. This ensures that all stakeholders operate in alignment with the governance and ethical standards defined by the Company.

Awareness Building and Executive Oversight

Furthermore, the Company mandates that all employees undergo rigorous assessments on the Code of Conduct and Anti Corruption policies. Every employee is required to meet all passing criteria to ensure comprehensive awareness and cultivate ethical behavior. These communication and enforcement efforts are extended to business partners to foster a collective transparency network throughout the supply chain.

In terms of governance, the Managing Director and Chief Executive Officer are responsible for monitoring and ensuring the efficiency of anti corruption initiatives. Regular reports are submitted to the Chairman of the Board and the Audit Committee to review and update policies and control measures, ensuring continuous alignment with business evolution and international standards.

Anti Corruption Guidelines

Personnel at all levels of the Company must strictly adhere to the following established guidelines:

• Commitment to the Zero Tolerance Policy Every individual must strictly comply with the Anti Corruption Policy, the Code of Conduct, and internal regulations. No person shall engage in any form of corruption or bribery, whether direct or indirect, to demonstrate our steadfast commitment to business transparency.
• Prohibition of Bribery Any action indicating intent to offer or receive bribes from stakeholders regarding assigned responsibilities, whether directly or indirectly, for the benefit of the organization or associated parties, is strictly forbidden.
• Whistleblowing and Reporter Protection Personnel must not ignore or neglect behaviors that may constitute corruption and are obligated to report such incidents to supervisors or through designated channels. The Company provides robust protection measures for whistleblowers and those who refuse corruption, ensuring no demotions, penalties, or negative repercussions, even if such refusal results in lost business opportunities.
• Caution in High Risk Activities Operations involving potential corruption risks must be conducted with extreme caution. If legal or regulatory uncertainties arise, personnel must seek written consultation from the Compliance or Legal Department before proceeding. Special focus is required for the following areas:
  • Gifts and Hospitality The receiving or providing of gifts and hospitality must strictly comply with the guidelines defined in the Corporate Governance Manual regarding the Gift Policy. Such actions must be conducted with transparency and reasonableness, ensuring they are never utilized as tools to influence business decisions.
  • Charitable Donations Donations must be executed in the Company’s name to support organizations with legitimate social objectives. These entities must be credible and verifiable, with all contributions following formal approval procedures to prevent donations from being used as a pretext for bribery.
  • Sponsorships Sponsorship funds must be clearly attributed to the Company with the intent of promoting business operations and a positive corporate image. All sponsorships must undergo transparent approval processes and remain legally verifiable.
  • Public and Private Sector Procurement Business relationships, procurement, and transactions with both the public and private sectors, including interactions with government officials or relevant parties, must be conducted with honesty and transparency in full compliance with applicable laws.
  • Political Neutrality The Company maintains a firm policy of political neutrality. While all personnel possess legal political rights and freedoms, they must refrain from using Company resources or engaging in activities that compromise corporate neutrality or result in damage from political involvement. The Political Participation Policy has been implemented as a standard guideline for personnel at all levels.
• Integration into Human Resource Management Anti corruption policies are formally integrated into human resource processes, covering recruitment, training, performance evaluation, and promotion. Supervisors at all levels are responsible for communicating and ensuring strict policy compliance within their respective departments.

Penalties and Anti Corruption Whistleblowing

Negligence or non compliance with anti corruption guidelines constitutes a severe disciplinary breach and a violation of employment terms, which may lead to criminal prosecution. Such actions significantly impact the Company’s reputation and operational standing. Consequently, any employee or stakeholder witnessing corruption has an obligation to report to supervisors or via formal corporate channels immediately.

Whistleblowing and Grievance Channels

The Company provides secure and accessible whistleblowing mechanisms for all stakeholder groups. Corruption concerns can be reported directly to the Audit Committee, which comprises independent directors, through the following channels:

1. By Mail to Audit Committee 1700 Plan B Tower, New Phetchaburi Road, Makkasan, Ratchathewi, Bangkok 10310
2. By Email to Audit Committee auditcommittee@planbmedia.co.th
3. By Email to Company Secretary companysecretary@planbmedia.co.th
4. By Telephone +66 (0) 2530-8053-6 ext. 131 or 134

The Company ensures maximum confidentiality for all reports. Whistleblowers are fully protected under organizational measures stipulated in the Whistleblowing Policy.

Grievance Management Process

To ensure transparency and fairness, the Company has established standardized operating procedures as follows:

• Initial Screening Stage Upon receiving a report, the Company Secretary gathers and filters the submission. Issues unrelated to corruption are forwarded to the responsible departments for resolution. Regarding potential corruption matters, a preliminary assessment of evidence is performed. If a report is found to be groundless, the conclusion is communicated to the complainant.
• Reporting and Investigation Stage If a report is substantiated, the Company Secretary initiates the formal procedure. For urgent or severe cases, preliminary findings are reported to the Executive Committee and the Audit Committee with a copy provided to Internal Audit. The Secretary then coordinates with Human Resources to appoint a fact finding committee for further disciplinary action.
• Overview Reporting Stage The Company summarizes whistleblowing statistics, operational status, and investigation outcomes for reporting to the Audit Committee at least every six months. This process serves to monitor progress and evaluate the overall effectiveness of internal control systems.

Whistleblower Protection and Performance Results

Plan B places the highest priority on protecting the rights of whistleblowers and informants through its Non retaliation Policy. The Company ensures the confidentiality of names, addresses, and any personally identifiable information by maintaining all data under the strictest security. Stakeholders may refer to the Whistleblowing and Grievance Policy for further details.