TMBAM operates its business with integrity for the benefits of all stakeholders, namely, customers, shareholders, staff, business partners, creditors, governing authorities and society as a whole. We conduct business under the principle of good governance as reflected in the our Code of Conduct and adherence with the laws, regulations, and regulatory requirements in order to ensure transparency and corruption-free business operation as well as to prevent any corruption for personal benefits which may cause unfairness and damages to our Company and the stakeholders.
TMBAM sets it as an utmost priority in controlling and preventing internal/ external fraud by implementing the policies and anti- corruption practices to comply with the laws and standards pertaining to anti-corruption of Thailand such as the Code of Conduct, the policy pertaining to anti - fraud, gift, entertainment & anti –bribery in dealing with internal unit, private and public agents, for personal or business benefits, etc. To ensure directors and employees abide by this policy strictly. TMBAM gives importance to the communication on the compliance with the TMBAM’s Anti-Corruption Policy to all stakeholders, namely, customers, shareholders, staff, business partners, creditors, governing authorities and public in order to ensure transparency and corruption-free business operation and TMBAM will not support or participate in any suspicious activities which may lead to be corruption. TMBAM encourages all third party and public to comply with the anti- corruption practices.
Adhering with this standpoint, TMBAM has joined the Private Sector Collective Action Coalition Against Corruption (CAC) to affirm our intention and dedication to be the organization with transparency and corruption-fee culture, which shall create sustainable growths to our Company and all the stakeholders as mentioned above.
It is a core policy of TMB Asset Management Company Limited (TMBAM) that the TMBAM shall operate its business on the basis of best practices with integrity to all stakeholders, namely customers, shareholders, employees, business partners, creditors, investors, governing authorities and society as a whole, under principles of good governance as also reflected in the TMBAM’s Code of Conduct to ensure transparency, to act with zero-tolerance for corruption in any form, and to prevent any person from seeking benefits which would cause unfairness or damage to TMBAM and related persons.
This policy applies to directors and employees of the TMBAM and manifests TMBAM’s intention on anti-corruption. Giving and accepting a bribe or undue benefit is prohibited. Directors and employees in any position must not exploit their position for personal or other person’s benefit. In this regard, the Board of Directors and the management acknowledge the principle and the practice pertaining to this policy, give importance to the governance to ensure compliance with the policy, and encourage the employees to adhere fully to the business principles as prescribed in the TMBAM’s Code of Conduct. Severe penalties will be applied to anyone not complying with this policy.
The objectives of this policy are:
2. Scope of the policy
- 1.1To set out TMBAM ’s clear policy and provide for its implementation, to ensure that the company acts as a zero-tolerance organization on anti-corruption with full transparency.
- 1.2To ensure directors and employees abide by this policy strictly, including awareness of the participation and responsibility of TMBAM to prevent corruption
- 1.3To ensure prudent and appropriate decision making in any business that carries a potential risk of corruption.
- 1.4To help building the culture of the company to avoid any corruption within the company, and provide guidance on anti-corruption to the directors and employees at all levels.
- 1.5To ensure that TMBAM has a Anti-Corruption Policy consistent with that of TMB Bank Anti-Corruption Policy in the context of TMBAM’s business.
- 2.1The policy covers TMBAM’s practices on anti-corruption, and such practices are consistent with TMB’s Bank Anti-Corruption Policy in the context of TMBAM business.
- 2.2The policy provides the TMBAM’s directors and employees at all levels with guidance on anti-corruption.
- 2.3The policy will help building the culture of TMBAM to avoid any corruption within TMBAM.
- 3.1The Company (or TMBAM) refers to TMB Asset Management Ltd.
- 3.2Directors refer to the Company’s directors.
- 3.3Employee refers to any person who is employed and is given salary by TMBAM.
- 3.4Corruption means the offering such as promising or act leading to (including the expectation of) benefit in any manner or form (cash, gifts, loans, rewards, payments, entertainment or preferential treatment) from bribe and inducement or receipt of and any request for such bribe, inducement including benefit in any manner or form by the TMBAM, any of its directors or employees, any government or private sector entity or official or employee thereof or any person in authority, whether directly or indirectly, whereby it causes an act of breaching the laws, TMBAM’s rules, regulations and orders, or an act of misconduct or negligence in performing a duty in order to receive inappropriate benefits or personal benefits, or benefits of relevant persons and/or cause damages to TMBAM.
5. Compliance with Policy
- 4.1This policy covers directors and employees of the company and strictly prohibits them from acts of corruption, including giving and/or receiving any bribe or undue inducement or benefit in any form, directly or indirectly, for personal benefits or benefits of family, acquaintance, or third person.
- 4.2Directors and employees shall not neglect, refrain, or ignore any incident or action in the TMBAM which can be corruption, but shall report the matter to supervisor or responsible person to take action according to the TMBAM’s rules and regulations as well as government regulation.
- 4.3TMBAM provides justice and protection to employees who duly report any incident of corruption or possible corruption, as well as to anyone submitting a “whistle blower” report regarding corruption, even though such action may cause TMBAM losing business opportunity. The employee will not be demoted, punished, or receive any bad impact. On the contrary, penalties will be applied to anyone not complying with this policy, including not reporting any violation.
- 4.4If any director commits corruption or fails to comply with this policy, the Board will ensure that appropriate action is taken.
- 4.5In case of corruption by any employee, it will be considered as a violation of TMBAM’s Code of Conduct and the penalty action will be determined according to TMBAM’s regulations. If the corruption is considered to be a violation of laws, the case will be brought into the legal process.
- 4.6TMBAM gives importance to the communication on the compliance with the TMBAM’s Anti-Corruption Policy to employees, third party and public, namely persons having vested interest with TMBAM, governmental units, and private entities making transactions with the TMBAM, or any action having impact or damage to TMBAM and its reputation.
- 4.7TMBAM will not support or participate in any suspicious business which may lead to be corruption.
- 4.8To create and sustain the culture of non-tolerance with corruption is TMBAM’s ambition. In this regard, TMBAM also encourages all employees to embed a culture of non-tolerance with corruption in dealing with government sector, private sector , or within TMBAM.
- 4.9The anti-corruption practice is implemented along with the practice on anti-money laundering.
- 4.10The system for internal and external complaints is available through such as Contact Us, and Online Complaint Submission In addition, the internal and external controlling procedure including audit of operations and accounting treatment, as well as fraud investigation are imposed to follow up and evaluate the company’s business operations with transparency and corruption-free.
- 4.11TMBAM will publish the Anti-Corruption Policy to the employees and public through TMBAM’s communication channels and determine Compliance to be responsible for providing the consultant service on anti-corruption to the employees under confidentiality.
- 5.1All practices in this policy are determined in line with TMBAM Code of Conduct and regulations, which must be strictly complied by the TMBAM’s management and employees, as well as in line with the regulations, the guidelines, and the practices to be determined in the future.
- 5.2TMBAM shall have processes and procedures on human resources which reflect TMBAM s intention on anti-corruption, for example nomination and selection procedure especially on any position with specific qualification, promotion, training, performance evaluation, justification and punishment.
- 5.3TMBAM shall conduct the overall assessment on corruption risk on annual basis, together with considering to determine or improve measures or practices on anti-corruption to be appropriate for all high risk business units and including the identification of units and transactions which by their natures involve a potentially high corruption risk.
- 5.4To ensure the clear understanding on transactions with high-risk of corruption such as giving or accepting gifts, presents, entertainment, donation for charity, or providing financial support or donation to political parties, activities, or procurement, directors and employees must adhere to the process, procedure, revision procedure, controlling measure, and reporting procedure as prescribed pursuant to this policy, TMBAM’s Code of Conduct, or other policies or regulations.
- 5.5Instruction on the Anti-Corruption Policy must be included in the orientation for new directors and employees with details so as to ensure the appropriate practice. Also, the penalty actions are to be communicated and clarified.
- 5.6Continual planning and training shall be conducted for directors and employees to emphasize TMBAM’s intention on the implementation of this Anti-Corruption Policy and to encourage the zero-tolerance culture.
- 5.7In case of significant or urgent issue which indicates corruption, the employees shall report the incident to their Head of Department or to the Head of Compliance or to Managing Director.
- 5.8Measures of anti-corruption must be documented according to TMBAM’s principle of internal control and regulations to be in compliance with the Anti-Corruption Policy. TMBAM shall set out guidelines and practices as well as audit according to the principle of internal control which are in compliance with the Anti-Corruption Policy. The guideline and practice are documented and communicated to the employees for acknowledgement and adherence, and reviewed to be up-to-date.
- 5.9This policy is provided as the guideline on anti-corruption for TMBAM and its produced based on and consistent with TMB Bank’s written Anti-Corruption Policy, and shall be concurred by the TMB Bank.
- 5.10All business units shall consider the TMBAM documents within their own responsibilities which can be related to an anti-corruption matter and revise them as necessary to be in line with this policy.