Nawarat Patanakarn Public Company Limited recognizes the importance of anti-corruption resistance. The Company encourages and supports all employees’ awareness on resistance of all types of fraud and corruption and has formulated the Anti – Corruption Policy as the practical guideline for directors, executives and employees as per detailed below:-

1. Duties and Responsibilities

1. The Business Code of Conduct Committee
   performs duties and responsibilities to formulate the Anti – Corruption Policy as well as to review and revise the Anti - Corruption Policy to be effective and proper according to the situation
2. The Board of Directors
   performs duties and responsibilities to approve the Anti – Corruption Policy and to ensure that efficient system for anti-corruption is provided to help executives, the management, employees and concerned persons realize the importance and put the policy into practice that it becomes a part of organizational structure
3. The Audit Committee
   performs duties and responsibilities to review and ensure that the Company has sufficient internal control and its business operation complies with the Anti – Corruption Policy
4. Executives and the Management
   performs duties and responsibilities to establish systems, provide support, promote and oversee to ensure that employees and concerned parties conform to the Anti – Corruption Policy, as well as to review suitability of the systems and measures to accommodate changes in business, regulations and official requirements.
5. The Internal Audit Team
   performs duties and responsibilities to conduct audit, review and ensure that operations comply with concerned policies, guidelines, regulations and laws and that the Company has proper and sufficient internal control systems for countering corruption risks which may arise and report the Audit Committee on any findings.
6. Directors, Executives and Employees
   perform duties and responsibilities to comply with the Anti - Corruption policy and shall not be involved in fraud and corruption, either directly or indirectly
7. Subsidiaries, Associated Company and Business Representatives
   must agree, accept and operate in compliance with the Company’s Anti - Corruption Policy

2. Scope and Practical Guideline

1. Nawarat Patanakarn Public Company Limited supports and encourages employees at all levels to become aware of fraud and anti-corruption and puts in place the internal control to prevent the Company from fraud and corruption, from offering and acceptance of bribe in all forms, all regions and all countries where the Company performs its works.
2. Directors, executives and employees at all levels must comply with the guidelines as per detailed below:-
   • Offering and Acceptance of Bribe
     Offering and acceptance of all forms of bribe in exchange of business advantages is prohibited. This includes delegating other persons to commit such actions.
   • Gifts, Hospitality and Other Benefits
     Offering and acceptance of gifts, assets, hospitality or other benefits to/from customers, business partners, or related parties must be in compliance with the regulation on “Offering and Acceptance of Gifts, Assets or Other Benefits” prescribed in the “Business Code of Conduct Handbook”
   • Political Contributions
     1. The Company is politically neutral; shall not directly or indirectly contribute and engage in any actions affiliated with political parties or groups.
     2. Directors, executives and employees have rights and freedom under the constitution to exercise political activities, but must not claim the status of being a director, an executive and an employee and must not utilize company assets or provide its services in support of political activities. If directors, executives and employees engage in any political activities, they must take particular care not to imply or mislead that the Company is supporting any political parties
   • Charitable / Public Benefit Contributions and SponsorshipAs a part of society contribution, the Company has the policy for charitable and public benefit contribution either money or other means such as stuff donation, activities participation, etc. and has formulated a guideline for making charitable contribution or sponsorship as follows:
     1. Offering or accepting charitable / public benefit contributions or sponsorships must be transparent, lawful, and ethical; does not expect any business returns and does not cause any damage to the public.
     2. Offering or accepting charitable / public benefit contributions or sponsorships shall not be used as an excuse for bribery.
     3. Use of the Company’s money or assets for charitable / public benefit contributions must be done under the name of the Company and has purpose to create good image and reputation of the Company
     4. Any actions taken must be in compliance with procedures of reviewing and approving charitable/ public benefit contributions or sponsorships as stipulated by the Company’s regulations
3. The Company is committed to create and sustain the organizational culture of zero tolerance of corruption when dealing with both government and private sector.
4. Directors, executives, and employees at all levels must not be negligent when witness any actions of possible corruption, and shall report the matter to his/ her supervisor or the responsible person and give full cooperation in investigation. Channels for hearing any complaint from external parties shall also be provided. In this regard, it shall be in compliance with the Company’s regulation
5. The Company must be fair and protect any employees who refuse to associate with or provide information about corruptions. Accordingly, the Company shall not demote, punish, or cause any negative consequence to such employee, although his/ her action may lead to the Company’s loss of business opportunity. The Company shall also be fair and protect employees or other parties who provide information or evidence about fraud and corruption concerned with the Company and its subsidiaries by applying protective measures for informants or person who cooperates in reporting of fraud and corruption  as specified in the Whistle Blowing Policy  
6. Directors and executives at all levels must demonstrate integrity and must be role model in following of the Anti – Corruption Policy. The Human Resources are assigned to educate, promote understanding, and encourage employees at all levels to strictly and continuously adhere to the Anti – Corruption Policy so that it becomes a part of the organizational structure.
7. The Anti – Corruption Policy covers human resources management procedures from recruitment, selection, promotion, training and performance appraisal. Supervisors at all levels are in charge of communication to their teams creating understanding and enabling all employees to apply the Policy to business activities within their scope of work as well as monitoring to ensure effective application of the Policy.
8. Any person conducting fraud and corruption is considered disciplinary violation of personnel management’s rules and regulations for employees and is subjected to disciplinary punishment as defined by the Company as well as lawful action if such conducts is illegal.
9. Any action taken under the Anti-Corruption Policy shall be in accordance with guidelines prescribed in the Company’s “Corporate Governance Policy”, “Business Conduct of Conduct Handbook” as well as related working manuals and any additional guidelines to be formulated in the future.
10. The Company will regularly review the practical guidelines and operating measures to be update and in comply with the changing of laws and business operation conditions 
11. The Company stipulates that communication and public relation activities of Anti-Corruption Policy are carried out via both internal and external media e.g. intranet, the Company’s website and annual report.

At the Meeting of the Company’s Board of Directors No. 3/2015 on March 13, 2015, the Board had resolution to get the Company to express the intention to join the Thailand’s Private Sector Collective Action Coalition Against Corruption initiated by Thai Institute of Directors (IOD). and now the Company has jointed in the declaration of intent on March 24,2017

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A Declaration of intent Collective Action Coalition (CAC)