{"id":6,"title":{"en":"Anti-Corruption Policy"},"content":{"en":"
Anti-Corruption Policy<\/div>\n

The TCC Technology Group is aware of the potential risk and negative impact of corruption. This has led to the adoption of this Anti-Corruption Policy, which has been designed to be implemented with other processes, records, and functional steps as described in this policy. The goals of this policy are to assure general good governance, risk reduction, sustained positive company reputation, and compliance with any related Thai laws. This is accomplished through adopting general principles, stating formal goals, response processes, specific actions and role assignments, and training and awareness measures to counteract and respond to corrupt practices or activities of anyone within this stated document scope.<\/p>\n

PURPOSE<\/div>\n

The TCC Technology Group is aware of the potential risk and negative impact of corruption. This has led to the adoption of this Anti-Corruption Policy, which has been designed to be implemented with other processes, records, and functional steps as described in this policy. The goals of this policy are to assure general good governance, risk reduction, sustained positive company reputation, and compliance with any related Thai laws. This is accomplished through adopting general principles, stating formal goals, response processes, specific actions and role assignments, and training and awareness measures to counteract and respond to corrupt practices or activities of anyone within this stated document scope.<\/p>\n

SCOPE<\/div>\n

This policy applies to the whole TCC Technology Group: (1) T.C.C. Technology Co., Ltd., (2) Leap Solutions Asia Co., Ltd., (3) Shinasub Co., Ltd., and any companies which will be included in the TCC Technology Group in the future. It applies to all staff members within the organization, outsourced staff members, and vendors or sub-contractors working on behalf of the TCC Technology Group. All staff members and any parties working for or acting on behalf of one of the TCC Technology Group companies are required to be aware of and follow these guidelines, with related training requirements specified in this policy.<\/p>\n

DEFINITIONS<\/div>\n

TCC Technology Group: <\/strong>
(1) T.C.C. Technology Co., Ltd., (2) Leap Solutions Asia Co., Ltd., (3) Shinasub Co., Ltd., and any companies which will be included in the TCC Technology Group in the future.

Corruption:<\/strong>
wrongful use of position, authority, duty or company assets for one’s own or others’ benefit, or for any benefits which may cause damage to others in any form; including: bribery in any form of a public servant, a public or private sector official, or a responsible person, whether direct or indirect; granting, offering, receiving, requesting, agreeing to give, giving or promising to give a bribe; acting in personal interest which is in conflict with company interests; concealment of facts related to unethical conduct; and interfering with or obstructing proceedings by a government agency or officials working for such agencies.

Political Support:<\/strong>
contributing assets, money, items, rights, or any benefits, in any form, to help or support political parties, politicians, or related individuals, including direct or indirect personal participation in political activities.

Charitable Donation:<\/strong>
providing assistance by giving assets, money, items, rights, or any benefits, in any form, without the aim of getting a return.

Bribe: <\/strong>
compensation in the form of money, assets, or benefits, in any form, provided to particular individuals or groups of individuals to motivate such individuals to act or not to act, or to fail to act on their duties in a wrongful way regardless of whether it is their duty, in order to obtain benefits for oneself, for others, or for the company business or company subsidiaries or associated agencies.<\/p>\n

ROLES AND RESPONSIBILITIES<\/div>\n
    \n
  • Board of Directors: <\/strong>
    guide, determine, approve, and supervise policies related to anticorruption scope; provide resource support for implementation and ongoing activities (as coordinated with upper management staff) as necessary and appropriate.

    Management staff (across all levels): encourage and support honest and ethical conduct in line with stated anti-corruption policies. Communicate such policies to all employees, requiring adherence and compliance, as well as provide adequate awareness and training as necessary and appropriate. Protect employees who oppose fraud and corruption, for example, by not demoting, punishing, or giving negative performance reviews to employees who reject fraud and corruption, regardless of the related secondary outcome(s). Review, examine, and revise systems and measures to ensure compliance with any changes as one sees fit, and procure assessment on corruption risk from time to time in order to identify highrisk incidents and to find suitable protection and revision methods.<\/li>\n
  • Internal audit: <\/strong>
    assign staff responsible for the review of policy content, training, and policy implementation to ensure that such implementation is efficient, correct, and suitable.<\/li>\n
  • External audit:<\/strong>
    engage an external auditor to ensure that the company's accounting information and financial performance are properly and correctly recorded, in compliance with accounting standards, related laws, and internal controls.<\/li>\n
  • Compliance:<\/strong>
    interpret related Thai regulatory requirements, do policy review, and review incidents \/ cases in relation to their legal context. Serve as a primary contact for whistleblowers. • Employees: strictly comply with policies, regulations, and commands of the TCC Technology Group related to anti-corruption, ethics, and the code of conduct of employees. Report to the Compliance department suspicious incidents or behavior, which may be corrupt actions of the Board of Directors, executives, employees, as well as external individuals such as trade partners, customers, and related individuals, according to the procedures set by the TCC Technology Group.<\/li>\n
  • HR:<\/strong>
    coordinate staff policy statements and training.<\/li>\n
  • Procurement: <\/strong>
    serve as the primary coordinator for purchasing, procurement, hiring service providers, and bidding processes.<\/li>\n<\/ul>\n
    POLICY<\/div>\n

    High-Level Policy<\/strong><\/p>\n

      \n
    • The TCC Technology Group abides by Thai laws on anti-corruption and has established these complete and effective anti-corruption policies and support processes as necessary and appropriate. These include defined role assignment, establishment of complaint channels, risk assessment, internal and external audit reviews of defined requirements and restrictions, and announcements and training. Other specific gift-related policies and procurement processes are described in this policy.<\/li>\n
    • The TCC Technology Group directors, executives, managers, and employees at all levels must be aware of their duties in adhering to ethical and transparent conduct, actively avoiding any acts of corruption, and not supporting acts of corruption in any way, and reporting any instances of personal benefit obtained through related unethical practices.<\/li>\n
    • The TCC Technology Group and all staff members must act in accordance with this policy, related legal requirements, and principles of good corporate governance. Such action supports the interests of stakeholders and strengthens company stability by limiting potential risks and impacts related to corruption. This policy sets a clear direction and identifies specific guidelines.<\/li>\n
    • The TCC Technology Group will arrange to communicate this policy to employees at all levels for acknowledgement and to implement it through various channels as necessary and appropriate, such as email notifications, and the training, as well as to communicate this policy to new employees to ensure awareness thereof. This policy is also set to be part of the training of new employees as the TCC Technology Group deems appropriate.<\/li>\n
    • Training and communication which will create awareness are the responsibility of all parties involved. This policy can be applied to all external policies, whether of government agencies or the private sector, which prohibit illegal and unethical acts or any personal gain that may cause damage to the company. All employees and personnel involved will be responsible for the consequences of such actions in accordance with the resolutions or penalties that have been imposed.<\/li>\n<\/ul>\n



      Political Neutrality <\/strong>
      The TCC Technology Group does not provide Political Support or conduct any action focused on any particular political party that may result in the loss of its neutrality or damage from its involvement and political support. All directors, executives, and employees have the legal right and freedom to be involved in politics, including the discretion to provide Political Support, but they must not perform political acts or conduct any related activities or use company resources, or use their position of director, executive, or employee for political actions and activities. If they would like to be involved in political activities, they must ensure that there will be no misunderstanding as to the political neutrality of the TCC Technology Group.

      Staff Guidelines <\/strong>
      Gifts:<\/strong> Directors, executives, and employees shall not accept money, gifts, gratuities, assets, or any other benefits, unless they are given as part of a convention that involves the tradition of gift giving or as a part of normal business operations. In the case that rejection is inappropriate, employees who accept money, gifts, gratuities, assets, or any other benefits must report that acceptance to the Compliance department. Randomly-selected prizes awarded at work events or functions are an exception; these are not subject to a review process.

      When giving gifts, assets, or any other benefits to any individuals, the TCC Technology Group staff must use their discretion in the granting thereof; such gifts, assets, or benefits must not be: inappropriate, extravagant, or uneconomical; against proper traditions; or unreasonable as part of normal business operations.

      The TCC Technology Group does not encourage trade partners, sellers, contractors, subcontractors, or individuals related to the business of the TCC Technology Group to give gifts, assets, or any other benefits to employees which may lead them to make decisions in the execution of their duties with bias or discomfort, or which may create conflicts of interest.

      Charitable donations:<\/strong>
      Charitable donations shall not be exploited as a method to avoid the rules related to bribery, and they must be proceeded with transparently and legally. If the money or assets of the TCC Technology Group are used for charitable donations to temples, hospitals, clinics, or other charitable organizations, then certificates, documents, or evidence in respect of such donations that is clear and reliable must be obtained. Employees are required to comply with the company's policies in this regard.

      For the avoidance of doubt, sponsorship is different from a charitable donation as it is a channel to promote the company’s business.

      Penalty for non-compliance:<\/strong>
      The HR department will coordinate specific penalties for noncompliance with any of these requirements so that the penalties are in accordance with company regulations.

      Procurement Policy<\/strong><\/p>\n

        \n
      • Staff related to the procurement process and vendor \/ external provider selection and other decision-making must understand these guidelines and fully comply with them at all times. Personal relationships and decision-making regarding interactions with external parties outside of the company’s business scope must not conflict with these policies.<\/li>\n
      • The vendor selection process must be fair and impartial; it must also take into account the best interests of the TCC Technology Group, based on the use of segregated functional duties across clearly-defined and consistent individual and departmental roles. Decisions regarding major project vendor selection must be clearly justified and documented, and they must be based on multiple source selection.<\/li>\n<\/ul>\n

        A separate Supplier Code of Conduct in Annex 1 outlines specific policies, limitations, or restrictions related to vendor selection and ongoing supplier processes.<\/p>\n

          \n
        • The contracts of suppliers\/partners that violate the Supplier Code of Conduct in Annex 1 may be considered for termination (as the case may be).<\/li>\n<\/ul>\n
          SUPPORT PROCESSES<\/div>\n

          Announcements and Communication <\/strong><\/p>\n

            \n
          • There must be a communication, as necessary and appropriate, and implementation of anticorruption policies to all stakeholder groups, internally and externally, . It also communicates to the general public, subsidiaries, vendors, outsourcing staff, and other companies that the TCC Technology Group has the controlling authority to have its anti-corruption policies acknowledged and (to) apply them in practice.<\/li>\n
          • Website-based announcements fulfill this function externally as necessary and appropriate. Internal policy is formally announced, with awareness supported by training.<\/li>\n
          • The TCC Technology Group clearly communicates penalties for non-compliance with its anticorruption policies and measures; it also communicates its policy that there will be no demotion, penalty, or negative impact for directors, executives, and employees who reject or report corruption, even if such report may cause a loss of business opportunity. The TCC Technology Group clearly communicates penalties for non-compliance with its anticorruption policies and measures; it also communicates its policy that there will be no demotion, penalty, or negative impact for directors, executives, and employees who reject or report corruption, even if such report may cause a loss of business opportunity.<\/li>\n<\/ul>\n

            Complaint Channels and Whistleblower <\/strong>
            Protection The defined communication channels of the TCC Technology Group have been established to receive inputs, complaints, opinions, or suggestions concerning any impact on its business operations from the actions of employees or external staff that may indicate fraud or corruption. Complainants can inform the company of issues and evidence via the following channels:
            Complaints via e-mail or post: <\/strong>
            E-mail:<\/strong> compliance@tcc-technology.com
            Post to:<\/strong>
            Compliance Department T.C.C. Technology Co., Ltd. 1 Empire Tower 30th floor, South Sathorn Road Yannawa, Sathorn,
            Bangkok 10120

            Whistleblowers who inform the company of issues, including the company’s employees, customers, contractors, or other stakeholders who inform the company of clues or complaints, will be protected in accordance with their legal rights or guidelines set by the TCC Technology Group. All directors, executives, and employees of the company shall cooperate with corruption investigations.

            In this regard, complaints shall be treated as confidential. Whistleblowers can file complaints through more than one channel and are not required to disclose their identity. However, in the event that whistleblowers choose not to disclose their name, they must disclose facts in detail, or provide concrete evidence to prove that there has been an incident which led them to believe that there has been an occurrence of corruption, so that the TCC Technology Group can investigate fully.

            Risk Assessment <\/strong>
            A corporate business risk assessment, conducted by a risk assessment working group and reviewed by the TCC Technology Group executives, is the primary form of review. Corporate risk assessment results are reviewed quarterly, along with status updates related to prior planned treatments, and current issue statuses.

            Internal Audit Process Review <\/strong>
            Internal audit process review is conducted along with the annual review of information security by the staff dealing with standardized assurance. All groups with primary responsibilities must be reviewed in relation to the scope of these duties. Evidence of effective process and requirement fulfillment must be documented by checklist-based notes, with any non-conformances or opportunities for improvement documented and followed up on; any problems are solved in accordance with the procedures of the internal audit process, the management review process, and the corrective action process.

            Related Accounting Review <\/strong>
            The TCC Technology Group arranges an effective annual external accounting and finance audit to ensure that it is complying with the relevant standards, laws, and practices. The details of controls are as follows:<\/p>\n

              \n
            • Internal controls<\/strong>
              The payment process: <\/strong>approvals for all payments are processed by the authorized persons under the Company’s Power of Authorization, which shall be in accordance with the scope of authority granted by the relevant authorized persons.

              The collection process:<\/strong> the company issues receipts for all collections from customers and cash deposits into the company’s bank accounts every day, and strictly and routinely processes bank reconciliations.<\/li>\n<\/ul>\n

              External controls<\/strong><\/p>\n

                \n
              • All the accounting and financial processes and records, including all documents, are audited annually by an independent and unbiased auditor, with all findings reported for managementlevel review.<\/li>\n<\/ul>\n
                Training and Awareness<\/div>\n

                The TCC Technology Group arranges training related to its anti-corruption policies and measures for directors, executives, and employees, and also provides orientation to new employees as necessary and appropriate. Training and notifications must be provided related to initial process and requirement development (policy roll-out), new hires, and ongoing refresher awareness as necessary and appropriate. Related work processes for vendor or trade partner selection must be clearly documented and reviewed for ongoing effectiveness as necessary and appropriate. Human resource management in relation to selection, performance evaluation, remuneration, and promotion of employees must also be structured transparently and fairly.<\/p>\n

                REFERENCES<\/div>\n

                HR Policy, staff conduct guidelines:<\/strong>
                Employee Handbook

                Training Reference: <\/strong>
                HR annual planning, and the attendance records of training that has been conducted<\/p>\n

                Annex 1 Supplier Code of Conduct<\/div>\n
                  \n
                • Delivery of products and services<\/strong>
                  Suppliers \/ partners must deliver products and services that are of a high quality and fairly priced. A thorough vendor selection process and an annual vendor evaluation process ensure that good value and effective provision of external services are selected and maintained.<\/li>\n
                • Legal compliance <\/strong>
                  Suppliers \/ partners must obey all related Thai laws and local regulations, including the rules that apply to conducting business and licenses required for all service and equipment provision purposes.<\/li>\n
                • Corruption and bribery<\/strong>
                  The TCC Technology Group maintains a clearly-defined anti-corruption policy, with defined roles, and expresses its intention to strictly adhere to the policy on corruption, extortion, fraud, and bribery. If any partner is involved in paying or receiving bribes, its contract may be under consideration for termination, and the TCC Technology Group will not accept liability for any damage incurred by such partner as a result of the termination of the contract.<\/li>\n
                • Gifts \/ Awards Major<\/strong>
                  suppliers \/ business partners must be informed that TCC Technology Group employees will not give or receive gifts, awards, or any benefits that will influence operational decisions, or that will cause unfair benefits, except for giving or receiving according to customs or standard business practices.<\/li>\n
                • Conflicts of interest<\/strong>
                  Major suppliers \/ business partners must notify the TCC Technology Group immediately of any action that may create a conflict of interest between the management, employees, and personnel of the TCC Technology Group, and its business partners.<\/li>\n
                • Trade secrets \/ confidentiality<\/strong>
                  A process must be maintained by major suppliers \/ business partners to prevent the leakage of confidential information, whether it is business information or personal information of the TCC Technology Group staff. Signed non-disclosure agreement protections must be in place with the TCC Technology Group business partners, suppliers, and customers to protect them from the release of sensitive and internal company information.<\/li>\n<\/ul>\n
                  \n


                  View Anti-Corruption Policy in .pdf<\/a>
                  Message from the Managing Director Re: Anti-Corruption Policy <\/a><\/p>"},"published_date":"2025-07-26","is_active":1,"created_at":"2025-11-26T03:43:14.000000Z","updated_at":"2025-11-26T06:51:06.000000Z"}