Goldcity Foottech Co., Ltd. Goldcity Foottech .Co,Ltd.

Company Business Ethics

The company has developed this organizational ethics code for all directors/shareholders/department managers and employees of the company to adhere to, as the company believes that ethical guidelines are an important tool for achieving better performance.

Principles

1. Honesty and Reliability

Since honesty is an essential component of credibility and trust, if the company does not receive credibility or trust, it will inevitably face problems in conducting business. The company therefore aims to achieve its success goals, which include gaining the highest trust and satisfaction from its customers. Therefore, directors/shareholders/department managers and employees of the company must adhere to honesty (Duty of Loyalty), fairness, and integrity to earn the trust of the company's customers.

2. Consistently show respect for others

Company employees must treat others as they wish to be treated themselves. Therefore, it is essential that everyone in the company shows respect to anyone with whom the company interacts or is involved.

3. Fairness and Non-Discrimination

Fairness and equality are essential components that must exist within the organization. Discrimination of any kind, whether based on nationality, ethnicity, gender, religion, age, ancestry, or for any other reason, is considered a serious violation of company policy.

Discrepancies may arise from the use or receipt of inaccurate information or services. Therefore, it is necessary for all company employees to exercise careful discretion and may seek advice from directors/shareholders/department managers if they believe they cannot make a judgment in such matters.

4. Do not infringe on any intellectual property, including copyrights and patents.

Infringement of copyrights, patents, trade secrets, and any licensing agreements or commercial contracts is a violation of the law in all cases.

The use of computer software in the daily work of company employees must comply with company regulations. No software may be duplicated unless properly authorized.

5. Confidentiality

Maintaining the confidentiality of information that the company has expressly or implicitly committed or promised to keep confidential, regardless of whether such information has not been publicly disclosed or is not related to any of the company's contractual obligations. All company employees must maintain confidentiality, as failure to do so could result in a loss of trust from customers, counterparties, suppliers, business partners, or any other individuals.

6. Accuracy of company data records

All company information must be stored and recorded accurately and promptly to ensure efficiency in operations. This includes all types of data, such as quality data, safety data, personal data, and financial and accounting data.

All company financial and accounting books and reports must accurately reflect transactions and events and adhere to generally accepted accounting principles, as well as good internal control systems.

7. Compliance with laws and regulations

The company expects its employees to prioritize conducting themselves and performing their duties in accordance with the laws and regulations relevant to the company's business, including compliance with legal requirements regarding tax filing and payment, which must be done within the specified timeframe and accurately after proper verification.

8. Fairness to business competitors

The company's policy is to compete fairly, yet with dedication and determination. At the same time, the company will not use illegal or unethical methods to gather information for competitive advantage, nor will it permit the theft or unauthorized use of any sensitive information, trade information, or trade secrets without permission from the data owner, or engage in any deceptive practices or actions to induce former or current employees of such companies to disclose confidential information to the company.

9. Responsibility to Shareholders

All company employees' operations, actions, and decisions shall be made to maximize the benefit of the shareholders only.

Company employees are prohibited from using company assets for personal gain or for any purpose unrelated to the company's business, or to create financial ties with suppliers, partners, or competitors of the company.

Code of Conduct for Company Directors/Shareholders/Department Managers

1. Company Information Disclosure and Public Relations

1.1 Be aware that when speaking or providing any information to external parties or the media, you must clearly specify the qualifications and credentials of the information provider, whether speaking in a personal capacity or in an official position. Disclose any conflicts of interest with groups or individuals who benefit from such information, statements, or opinions.

1.2 Be aware that speaking with colleagues or even relatives about matters one is not knowledgeable about, or speaking based on inaccurate information, not only damages one's own credibility but also the organization's credibility.

1.3 You should have a duty to assist, clarify, and make clear the content of the information related to your work or responsibilities for transparency, with the condition that providing such information does not affect others and is appropriate for disclosure.

1.4 Do not provide any information or news that is not part of your duties and responsibilities.

1.5 Exercise caution when providing information to external individuals or agencies regarding the company's activities or future business plans.

1.6 The provision of information and news should be clear, concise, use easily understandable language, and be careful not to mislead or confuse users about the facts. Emphasis should be placed on content rather than form, and important conditions or related assumptions should be fully stated.

2. Conflict of Interest

2.1 Do not engage in any business, operations, or investments that compete with the company, whether directly or indirectly.

2.2 You must not provide internal information or company secrets for personal gain, or disclose them to external parties or competitors, especially information that has not yet been publicly disclosed, or after leaving the company's employment, without written permission from the company. This includes, for example, information regarding resolutions, bidding prices, revenue plans, marketing plans, and forward-looking financial or business forecasts of the company.

2.3 In cases where directors/shareholders/department managers and/or their family members are involved in, or are shareholders or directors or advisors of, or have a direct or indirect interest in other companies outside the company group, such involvement must not conflict with the interests and direct duties within the company, and must receive prior written approval from the company.

2.4 Avoid, both personally and through family members, contact, giving or receiving gifts, money, or other benefits from others who have duties or business related to the company or business partners, except during festivals or customary traditions of appropriate value.

            2.5 Any personal benefits received other than those from the company should be immediately disclosed to the company.

Employee Code of Conduct

1. Company Information Disclosure and Public Relations

          1.1 Always remember that any statement or information given to external parties or the media must clearly specify whether it is made in a personal capacity or an official capacity, and if there is any conflict of interest with a group that benefits from such information, statements, or opinions.

            1.2 Always remember that discussing matters you don't truly know or discussing inaccurate information with colleagues, friends outside the organization, or even relatives, not only harms your credibility but also the organization's credibility.

            1.3 It is your duty to assist in clarifying and making clear the content of the information related to your work or responsibilities for transparency, provided that such information does not affect others and is suitable for disclosure.

            1.4 You should not disclose any information that is not part of your duties or responsibilities, unless approved by your supervisor.

            1.5 Care should be taken when providing information to external individuals or agencies regarding the company's future activities or business plans. Such individuals or agencies should be advised to contact the department responsible for providing information directly.

2. Conflicts of Interest

          2.1 Do not engage in any business, operations, or investments that compete with the company, whether directly or indirectly.

            2.2 Do not use internal information or confidential company information for personal gain or disclose it to external parties or competitors, especially information that has not yet been publicly disclosed, or after leaving the company's employment, without written permission from the company. Examples include information related to board resolutions, bidding prices, revenue plans, marketing plans, and financial or business forecasts of the company.

            2.3 Avoid, both personally and through contact, giving or receiving items, money, or other benefits from individuals whose duties or businesses are related to the company or its trading partners, except during appropriate festive seasons or customary practices. In such cases, the supervisor must be informed.

3. Conduct Regarding Money, Gifts, and Business Hospitality

            3.1 Receiving benefits and financial involvement with company business partners

                        3.1.1 Do not solicit or accept money, gifts, or other benefits from customers, distributors, merchants, contractors, suppliers of goods and services to the company, or from any other person doing business with the company. Additionally, employees should not engage in financial involvement such as joint ventures or trading, lending or borrowing money, collecting funds, cashing checks, buying goods on credit, buying, selling, leasing, or creating any financial obligations with the aforementioned individuals.

                        3.1.2 The company wishes employees to avoid giving or receiving gifts from parties involved with the company's business, except during appropriate festive seasons or customary practices and within reasonable value. Employees should consider consulting their immediate supervisor if in doubt.

                        3.1.3 Employees should avoid accepting hospitality that goes beyond normal professional relationships from individuals doing business with the company.

                        3.1.4 Receiving gifts in the form of commissions, loans, profit shares, share certificates, or other equivalent items is strictly prohibited.

            3.2 Granting benefits and financial involvement with company business partners

                        3.2.1 The company has a policy not to give cash gifts on behalf of the company, except in clearly defined cases, such as:

                                  a. Being moderate, infrequent, and appropriate for the occasion.

                                  b. Consistent with company policy regarding ethics.

                                  c. To ensure correct and ethical business decisions.

                                  d. Under good conduct and customs.

                        3.2.2 All gifts or cash must be expensed as normal employee expenses, but with accurate and clear documentation of the expense's purpose.

                        3.2.3 In conducting company business, employees may incur entertainment expenses within reasonable limits and with the approval of the highest-ranking supervisor of the department, and consistent with local customs. Generally, entertainment should not be frequent and should be within the scope appropriate to each individual's business responsibilities. It should be reciprocal to be considered a normal business expense.

4. Conduct

          4.1 Towards the company

                        4.1.1 Employees should be fully dedicated to their work, maintain discipline, be punctual and honest, and adhere to the company's policy of conducting business securely and profitably.

                        4.1.2 Employees should use and maintain company assets/equipment to their fullest potential and not use them for personal gain or to work for other establishments, even if those establishments operate in businesses unrelated to the company. This also involves fostering a sense of self-awareness, cultivating a love for frugality, and paying close attention to and assisting in any actions that preserve a clean, safe, and pleasant working environment.

                        4.1.3 Employees should avoid and be careful about expressing opinions, disclosing information or stories of other employees or management, whether related to work or personal matters, or criticizing them in a way that could cause damage or affect employees, management, or the overall image and reputation of the company.

                        4.1.4 Employees should constantly seek and acquire knowledge to become qualified and experienced personnel, while upholding principles of morality and integrity.

                        4.1.5 Employees should maintain and foster unity and solidarity among themselves, creating a working environment that encourages new ideas and exchange of opinions, as well as taking a serious and strict approach to all activities that enhance quality and organizational development towards excellence.

                        4.1.6 Employees should refrain from romantic relationships that could lead to favoritism towards colleagues or subordinates, which would harm the company.

                        4.1.7 The company has a policy that employees must share responsibility for the organization, meaning they should not remain silent when they see any individual or member of the organization performing their duties incorrectly or engaging in any actions that would harm the organization. They should warn that employee, and if the behavior cannot be changed, they should notify their direct supervisor in order of hierarchy. The company will not disclose the identity of such whistleblowers and will immediately investigate the facts.

                        4.1.8 The company has a policy that employees should always remember that being an employee of the organization means performing assigned duties. Therefore, no matter how difficult or easy the task, employees should not refuse until they have performed their duties to the best of their ability and have continuously consulted with their supervisor.

                        4.1.9 Employees should respect the company or institution or the company's policies. Whatever the company's policy may be, it should always be remembered that the policy is established based on the suitability of the company and employees as a whole for the maximum benefit of the majority of employees, and should not speak ill of the company or its policies, or in other aspects, without factual information.

            4.2 Towards supervisors

                        4.2.1 Employees should respect and honor their supervisors.

                        4.2.2 Employees should listen to advice from their supervisors and follow the chain of command.

                        4.2.3 Employees should follow the orders of their supervisors, provided such orders are legitimate. However, if there is any reason or event that makes it impossible to comply with an order, the supervisor must be notified immediately.

          4.3 Towards subordinates

                        4.3.1 Employees must treat subordinates fairly and appropriately in all matters, especially regarding overall personnel management.

                        4.3.2 Promote and develop knowledge and skills for work performance.

                        4.3.3 Listen to feedback and suggestions from subordinates and endeavor to reconcile ideas for the benefit of the company.

                        4.3.4 Understand the working conditions, methods, and procedures, and willingly provide advice, support, and resolve problems arising from work.

                        4.3.5 Be polite and respectful towards subordinates, acknowledging their individuality and human dignity. Do not disparage or use language that could cause disunity.

            4.4 Towards colleagues

                        4.4.1 Employees must adapt to working with others, show respect, and listen to colleagues' opinions.

                        4.4.2 Employees must be diligent in their duties and responsible towards colleagues, cautioning or advising when a colleague acts incorrectly or inappropriately, and exercising patience and mutual assistance.

5. Employee External Activities

          5.1 Employees must dedicate their full time to the company's work. When participating in external activities, employees must be careful and avoid situations that could lead to doubts about their honesty, personal gain, and competing with the company or its clients.

            5.2 Employee Representation to External Organizations: Employees must clearly state whether they are acting in a personal capacity or as a company representative.

            5.5 Any remuneration received from external activities where the employee participates as a company representative must be reported to the supervisor and is subject to the supervisor's discretion.

6. Client Confidentiality

          Maintaining client and internal company confidentiality is a critical factor in earning client trust. The Company has established the following guidelines:

            6.1 Client information and documents must be stored securely, and care must be taken to prevent unintentional disclosure of client information.

            6.2 Client information must not be disclosed to employees of other departments or other individuals, which could affect the client's interests or reputation, except:

            (1) Written consent from the client to disclose information has been obtained.

            (2) A court order or order from an authorized official under Thai law requires the reporting or disclosure of information.

            (3) The disclosure of information is made to prevent potential damage to the company resulting from illegal actions by the client, or it is a report of work performance as assigned.

7. Procedures for Handling Complaints from Customers and Other Stakeholders

          The Company has established a Whistleblowing Policy to ensure fair consideration of complaints for all parties involved. Therefore, the Company sets forth the following rules:

            7.1 The Company will not consider anonymous complaints or complaints submitted on behalf of others.

            7.2 Complaints from stakeholders must be submitted in writing, with clear details including the full name of the complainant and the accused, the reason for the complaint, and the requested action from the Company, along with supporting documents (if any), and submitted to the relevant department.

            7.3 The Company will establish a committee to consider and proceed as appropriate.

            7.4 The Audit Committee will compile client complaint letters and related evidence for reference and future review.

Scope, Duties, and Responsibilities of Directors/Shareholders/Department Managers

            Directors/Shareholders/Department Managers have the following scope, duties, and responsibilities:

            1. Accept all assigned policies and management tasks.

            2. Formulate strategies to achieve goals in accordance with the operational plan and established policies.

            3. Approve significant capital expenditures as specified.

            4. Consider and approve the operational plans and policies of each department, and monitor and execute work according to the established plans and policies.

            5. Issue orders, regulations, announcements, and memos to ensure operations comply with company policies and benefits, and to maintain internal discipline.

            6. Approve the appointment, employment, transfer, and termination of employees.

            7. Oversee employee conduct to ensure business is conducted ethically, in compliance with laws, morals, and good culture towards shareholders, customers, employees, and directors/shareholders/department managers.

            8. Promote organizational development and personnel to their full potential, fostering a culture of professional ethics.

            9. Support and promote the study and development of new technologies in the process of increasing productivity and continuous business development, utilizing existing resources to their full potential.

            10. Act with honesty, integrity, and diligence in protecting the company's interests.

Appendix
Pictures from the Business Ethics Training

Figure 1: Employees registering for Business Ethics training.

 
Figure 2: Employees attending Business Ethics training.


Figure 3: Employees attending Business Ethics training.


Figure 4: Directors and executives attending the company's Business Ethics training.


Figure 5: Directors and executives attending the company's Business Ethics training.


Figure 6: Directors and executives attending the company's Business Ethics training.

Figure 7: Employees reading the Business Ethics and Anti-Corruption Policy notice at the factory entrance/exit.

Directors and Executives Meeting on Anti-Corruption Policy Training