Anti-Corruption and Bribery Policy

Updated on 8 December 2022

We, ThaiQuest Limited (“ThaiQuest”), adhere to conducting business with social responsibility and against Corruption and Bribery. Any Corruption and Bribery or related attempt in ThaiQuest’s business dealings is unacceptable and shall not be tolerated.

This Anti-Corruption and Bribery Policy (“Policy”) applies to ThaiQuest and its affiliates, directors, employees, and all related businesses. ThaiQuest’s directors and employees shall be responsible for extending the Policy and its implications, to the extent applicable, to all agents, business partners, suppliers, customers, and others who are involved in all business dealings with ThaiQuest.

All directors and employees are informed of this Policy’s zero-tolerance principle on Corruption and Bribery and the consequences of breach. This Policy and its implications shall also be disclosed to agents, business partners, suppliers, customers, and third parties who have or may have business dealings with ThaiQuest.

All directors and employees are required to comply with this Policy. Specifically, the Policy prohibits all ThaiQuest’s directors and employees from the following activities:

(1) Any offering, promising, giving, accepting, or soliciting of an advantage, in any form, as an inducement for an action which is illegal or a breach of a person’s fiduciary responsibilities (“Bribery”).
To avoid any doubt, “an advantage, in any form” may include but not limited to cash, gifts, gift certificate, discount, entertainment, hospitality, forbearance, training, travel, service, or other item having a monetary value which may be provided either directly or through third parties or for third parties.

(2) Any soliciting, arranging or accepting a bribe for the benefit of the director, employee, or for the benefit of their family, friends, associates, or acquaintances

(3) Any offering, promising, or giving a bribe to public officials, public or private organizations, or other private individuals, directly or indirectly, on behalf of ThaiQuest and its affiliates.

(4) Any abuse of entrusted power or authority for private gain, including bribery, extortion, fraud, deception, collusion, cartels, embezzlement, money laundering, and other similar activities (“Corruption”).

This Policy constitutes the minimum requirement for Anti-corruption and Bribery. A higher standard may be imposed by specific legislation or regulation for certain business transactions and within ThaiQuest’s regulations.

Directors and employees shall use good judgment to avoid actions that are considered Corruption and Bribery, including but not limited to the following actions.

– Unlawful or non-compliance political contributions

– Non-transparent charitable contributions to unregistered charity having unclear contribution purpose

– Non-transparent sponsorships, without clear contracts and proof of payment, which may be used as cover for Corruption and Bribery

– Facilitation of payments that may lead to Corruption

– Giving or receiving gifts, hospitalities, or entertainment which do not fall within the local cultural norms or appear to obligate or burden the recipient to return favor, which may lead to Corruption.

Any breach of the Policy by a director or employee shall be investigated in accordance with ThaiQuest’s disciplinary process and may result in an admonishment, suspension, or termination of appointment or employment. In the event of a willful breach, ThaiQuest may pursue both civil and criminal remedies.