นโยบายการต่อต้านทุจริตคอร์รัปชัน Anti Corruption Policy

Qualitech Public Company Limited (Company), its subsidiaries, affiliates, or any other companies that the Company has control over (if any), firmly upholds the principles of conducting business with integrity, ethics, transparency, and social responsibility towards all stakeholders. This commitment reflects the Company's unwavering dedication and determination to combat corruption in all its forms.

The company has formulated an anti-corruption policy, including the establishment of definitions, enforcement boundaries, roles and responsibilities, accountability, best practices, operational measures, as well as mechanisms for raising awareness and protecting whistleblowers, and imposing sanctions. This serves as a clear framework for conducting business operations and progressing towards a sustainable organization.

1. Policy and Conduct

• The executives and employees of Qualitech Public Company Limited (Company), its subsidiaries, affiliates, or any other companies that the Company has control over, are required to adhere to the anti-corruption policy and business ethics of the company. They must not engage in any form of corruption, whether directly or indirectly.
• The executives and employees of Qualitech Public Company Limited (Company), its subsidiaries, affiliates, or any other companies that the Company has control over, must not overlook, or remain indifferent when they encounter actions that fall within the scope of corruption associated with the company. They are required to report such incidents to the supervising authority or designated person in charge and cooperate in investigating the truth. If there are doubts or inquiries, they should consult the supervising authority or the designated person responsible for monitoring compliance with the company's code of conduct through the various specified channels.
• The executives and employees of Qualitech Public Company Limited (Company), its subsidiaries, affiliates, or any other companies that the Company has control over, will ensure fairness and protection for employees who refuse, or report incidents of corruption associated with the company. This will be done through protective measures for whistleblowers or individuals who cooperate in reporting corruption, as specified in the company's policy on disclosure and complaint procedures, and through the protection of whistleblowers as outlined in the company's Whistleblower Procedures.
• Individuals who engage in acts of corporate corruption are in violation of both the law and the ethics of the company. They will be subject to disciplinary action according to the regulations and provisions set forth by the company. Additionally, they may face legal consequences if their actions are deemed unlawful.
• Qualitech Public Company Limited (Company), its subsidiaries, affiliates, or any other companies under its control shall recognize the importance of disseminating knowledge and promoting understanding among individuals who have responsibilities related to the matter or may impact the company in matters that require compliance with this anti-corruption policy.
• To ensure clarity in handling high-risk matters related to the occurrence of corporate corruption, employees of Qualitech Public Company Limited (Company), and its subsidiaries, affiliates, or other companies under its control must exercise caution and comply with the provisions outlined in Sections 2 to 6 as follows:

2. Political Contributions

• Political contributions refer to both financial and non-financial support provided to political parties, politicians, or individuals running for political office. Non-financial support includes lending assistance or donating technological equipment or services without charge. It also encompasses the contribution of employees' working time.
• The company has a neutral political stance policy, which prohibits any support or engagement in activities that favor or promote any specific political party.
• Employees have the freedom to participate in political activities under the provisions of the Constitution. However, they must not covertly claim to represent the company or utilize any company property, equipment, or resources for personal gain in any political activities. If they choose to participate, they should exercise caution in any actions that could be misconstrued as the company providing support or endorsing any specific political party.

3. Charitable Contribution, Donations and Aid Grants

Charitable contributions, donations, and aid grants may pose risks to the company as these activities involve spending money without receiving tangible returns and can be used as a pretext or avenue for corruption. To ensure that charitable contributions have genuine intentions, the company has established policies, guidelines, verification processes, and control mechanisms as follows:

• Donations must be substantiated by evidence of actual charitable activities and efforts to support the success of the project's objectives, generating true benefits for society, or aligning with the objectives of socially responsible operations (Corporate Social Responsibility: CSR).
• Donations must be proven to be purely charitable and not associated with providing benefits to specific individuals or entities, except for general acknowledgments such as displaying logos, announcing the company's name at event venues, or engaging in media publicity.

4. Sponsorships

Sponsorships are a business promotion method used by a company, which differs from charitable donations. Sponsorships may have the objective of benefiting the company's business, brand, or reputation. However, they come with inherent risks as they involve paying for services or benefits that are difficult to measure and track. To mitigate these risks, the company has established policies, guidelines, verification processes, and control mechanisms for sponsorships as follows:

• Sponsorships must be substantiated by evidence that the recipient has carried out activities aligned with the stated project and has contributed to the success of the project's objectives, generating genuine benefits for society, or aligning with the objectives of socially responsible operations (Corporate Social Responsibility: CSR).
• Sponsorships must provide evidence that the funds or any other benefits that can be quantified, such as accommodations and meals, are not associated with providing compensation to specific individuals or entities, except for general acknowledgments as per common business practices.
• As a sponsor, it is necessary to prepare approval documents that include the name of the recipient of the sponsorship funds and the objectives of the sponsorship, along with all supporting documentation. These documents should be submitted for review and approval by the authorized personnel within the company based on their level of authority.

5. Receiving or giving gifts, souvenirs, or any other benefits.

The company recognizes that establishing good relationships with business partners is crucial to the continuous success of the company. Employees are allowed to give or receive gifts (Gifts) and/or welcome services (Hospitality) and/or other related expenses (Others) from any individuals, if they meet the following conditions:

• It is not intentionally done to coerce, manipulate, or reward any individuals to gain any undue advantages through inappropriate actions or clear or covert exchanges for assistance or benefits.
• It complies with relevant laws.
• It is given on behalf of the company, not in the name of the employees, and may be in the form of corporate-branded souvenirs.
• It is not in the form of cash or cash equivalents (e.g., gift cards or vouchers).
• It is appropriate to the situation, such as giving small gifts during Songkran, Chinese New Year, or New Year's celebrations, which are considered customary practices.
• The type and value are reasonable and properly presented according to customs. For example, in cases where the company is conducting a bidding process, employees must not accept gifts or welcome services from participating companies.
• It is transparent and not concealed.

Employees are allowed to receive gifts with a value not exceeding 2,000 Baht. In cases where they are unable to decline and must receive gifts exceeding 2,000 Baht, they must report it to their supervisor using the gift receiving report form and submit the received gifts to the Human Resources division for use as employee rewards or for appropriate charitable donations.

6. Conflict of interest

The company has controls and oversees transactions involving individuals with conflicts of interest, in accordance with the principles of good corporate governance, business ethics, and the regulations of the Securities and Exchange Commission and the Stock Exchange of Thailand.