Anti-Corruption Policy
Anti-Corruption Policy
Company Goldcity Foottech Co., Ltd.
Goldcity Foottech Co., Ltd.
Goldcity Foottech Co., Ltd. has campaigned against corruption among its personnel, as the company's directors/shareholders/department managers recognize the importance of preventing corruption. The general content has been included in the company's business ethics since the beginning. This Anti-Corruption Policy, as stated in this announcement, is intended to declare the company's commitment to preventing all forms of corruption and to ensure that everyone in the company understands anti-corruption practices under the same policy, and that all stakeholders involved with the company are aware of the company's strong determination to prevent corruption.
Anti-Corruption Policy
Directors/shareholders/department managers and employees are prohibited from engaging in any acts related to corruption in any form, for direct or indirect benefit to themselves, their families, friends, or acquaintances, whether as recipients, givers, or offerors of bribes, monetary or non-monetary, to government agencies or private entities with which the company conducts business or interacts. This Anti-Corruption Policy will be strictly adhered to.
Duties and Responsibilities
1. Directors/shareholders/department managers are responsible for considering and approving policies and supporting the prevention of corruption within the company, to ensure that everyone in the company understands and recognizes the importance of problems arising from corruption, as well as cases where the audit committee reports corrupt actions that affect the company.
2. Directors/shareholders/department managers are responsible for providing advice, recommendations, considering penalties, and collaboratively finding solutions. The Board of Directors has designated departments and individuals responsible for this Anti-Corruption Policy.
- Human Resources Department: The Chairperson of the Audit Committee is Ms. Mathuros Jinapan, Company Director/Human Resources Manager.
- Accounting – Finance Department: Mr. Chanon Sae-lee, Accounting-Finance Department Manager.
Anti-Corruption Guidelines
Directors/shareholders/department managers and company employees must strictly adhere to the anti-corruption policy and business ethics. They must not engage in corruption, directly or indirectly, by:
1. Not engaging in any behavior that indicates the acceptance or offering of bribes to stakeholders in matters for which they are
responsible, directly or indirectly, to obtain undue benefits. This includes:
1.1 Not accepting or giving cash, checks, banknotes, stocks, gold, jewelry, real estate, or similar items as gifts or souvenirs to related parties with whom they interact, whether in government or private entities.
1.2 Not accepting any assets, items, gifts, or other benefits that may induce them to neglect their duties. Before accepting souvenirs, ensure compliance with the law and company regulations. Items or gifts exchanged in a professional capacity should be of moderate value and appropriate for each occasion.
1.3 Not giving assets, items, gifts, or other benefits to influence decisions or cause recipients to not comply with commercial practices similar to other trading partners. Gifts for various occasions should not exceed a reasonable value.
1.4 Not acting as an intermediary for offering money, assets, items, or other benefits to business associates, government agencies, or any organizations in exchange for undue privileges or causing government officials to deviate from regulations, rules, and legal practices as prescribed.
2. Procurement must follow company procedures and be transparent and auditable.
3. Expenses for business entertainment and other expenses related to the performance of business contracts are permissible but must be reasonable and auditable.
4. Charitable donations must adhere to the following:
4.1 The use of company funds or assets for charitable donations must be made in the name of the company only.
Charitable donations must be made to foundations, public charities, temples, hospitals, healthcare facilities, or organizations for social benefit that are certified or trustworthy, auditable, and follow company procedures.
4.2 Personal charitable donations are permissible but must not be related to or raise suspicion of corrupt acts for any personal gain.
5. The use of company funds or assets to support projects must be in the company's name only. The funds disbursed must be for the purpose of business, good image, and reputation of the company. Disbursement must have clear objectives and verifiable evidence.
6. No political activities are to be conducted within the company's premises, and no company resources are to be used for such activities. The company upholds political neutrality, supports compliance with the law and democratic governance under the monarchy. The company does not provide political assistance to any political party, directly or indirectly.
7. If any acts of corruption or suspected corruption that directly or indirectly involve the company are observed, such behavior must not be ignored or overlooked. The company's directors/shareholders/department managers must be informed immediately or through the whistleblower channels specified in this policy.
8. Directors/shareholders and department managers must recognize the importance of disseminating knowledge and providing advice to supervisors regarding anti-corruption to ensure employees comply with this anti-corruption policy, as well as serving as good role models in terms of integrity, ethics, and conduct.
Matters for Whistleblowing or Reporting Corruption
1. Corrupt acts directly or indirectly involving the company, such as observing company personnel bribing/receiving bribes from government officials or private entities.
2. Actions that deviate from company procedures or affect the company's internal control system, raising suspicion of potential corruption.
3. Actions that cause loss of company benefits or harm the company's reputation.
4. Actions that are illegal, immoral, or violate business ethics.
Channels for Whistleblowing or Reporting Corruption
The board of directors has assigned the audit committee to consider receiving reports and complaints regarding acts that may cause suspicion of corruption within the company, directly or indirectly, through the channels specified in this policy. Whistleblowers must provide details of the matter to be reported or complained about, along with their name, address, and telephone number for contact, and send it through the following channels:
1. Via email to the Chairperson of the Audit Committee: Mathuros@goldcitythai.com
Goldcity Foottech Co., Ltd., No. 78, Moo 5, Khok Kham Subdistrict, Mueang District, Samut Sakhon Province 74000, or
2. Via email to the Accounting-Finance Department Manager: Chanon@goldcitythai.com or
3. Via phone at 085-7044653 ext. 206, Human Resources Department.
4. Via the suggestion box (in front of Building 1 store).
If the whistleblower or complainant has a complaint against a director/shareholder/department manager, please send the complaint directly to the Chairperson of the Audit Committee.
Individuals who can report or complain about corruption include all stakeholder groups of the company, such as shareholders, customers, competitors, creditors, government agencies, communities, society, directors/shareholders/department managers, and company employees. Regardless of the method you choose to report, the company will keep your identity confidential.
Protection and Confidentiality Measures
To protect the rights of whistleblowers and informants who act in good faith, the Company will conceal the name, address, or any information that can identify the whistleblower or informant, and keep the whistleblower’s and informant’s information confidential, limiting access only to those responsible for investigating the complaint.
Those who receive information during the performance of duties related to the complaint are obliged to keep the complaint information and supporting documents of the whistleblower and informant confidential. Disclosure of information to other unrelated persons is prohibited, except when disclosure is required by law.
Investigation Process and Penalties
1. Upon receiving a tip-off, the Chairman and the Audit Committee will screen and investigate the facts.
2. During the fact-finding investigation, the Chairman and the Audit Committee will assign a representative (HR Manager) to periodically inform the tipster or complainant of the progress.
3. If the fact-finding investigation reveals that the information or evidence gives reasonable grounds to believe that the accused has committed fraud, the Company will grant the accused the right to be informed of the accusation and the right to prove their innocence by finding additional information or evidence demonstrating that they are not involved in the fraudulent act as accused.
4. If the accused has indeed committed fraud, such fraud is considered a violation of the Company's anti-corruption policy and business ethics and will be subject to disciplinary action according to the Company's regulations. If the fraudulent act is illegal, the perpetrator may also face legal penalties.
The disciplinary penalties according to the Company's regulations and the decision of the Chairman and the Audit Committee are final.
Dissemination of Anti-Corruption Policy
To ensure that everyone in the organization is aware of the anti-corruption policy, the Company will proceed as follows:
1. The Company will post the anti-corruption policy in a prominent location where everyone in the company can read it.
2. The Company will disseminate the anti-corruption policy through the Company's communication channels, such as the company website, online and offline channels.
3. The Company will organize anti-corruption policy training for new employees and conduct refresher training for employees at least every 2 years.
Anti-Corruption Policy This version has been reviewed and approved by the company's directors/shareholders/department managers at the company meeting no. 23 on October 10, 2568 (2025).
Figure 1: Employees registering for training
Figure 2: Employees attending training and listening to the speaker on the Anti-Corruption Policy
Figure 3: Speaker inviting employees to explain the Anti-Corruption Policy