The Spirit and The Letter

• Regulatory excellence • Working with customers & suppliers • Government business • Competing globally • In the Krungsri community • Protecting Krungsri assets SLTHETHEPIERTITT&ERปรชั ญา และสำนึก ในการปฏิบัติงาน

ContentsMessage from CEO 3 Regulatory excellence 18 • Regulatory excellence 20The Spirit & The Letter: Working with customers & suppliers 22Guiding the way we do business 5 • Improper payments 24Code of conduct • Supplier relationships 26Code of conduct 7 • International trade controls 30 • Money laundering prevention 32Your personal commitment 8 • Privacy 34Who must follow the spirit 9 Government business 36& The letter • Working with governments 38What employees must do 10 Competing globally 40 • Complying with competition laws 42What leaders must do 11Raise your voice: 12 In the Krungsri community 44 • Fair employment practices 46Your obligation to raise integrity • Environment, health & safety 50 • Security & crisis management 52concernsHow to raise an integrity 13 Protecting Krungsri assets 54concern • Intellectual property 56What happens when an integrity concern is raised • Controllership 58 14 • Conflicts of interest 62 • Insider trading & stock tipping 64Penalties for violations 15Corporate policies and 16 proceduresThe Spirit & The Letter policies 17 This booklet is the Bank’s property, please return it to HR when resign.

Message from CEO “The Spirit & The Letter” of the Bank is based on the values of honesty and integrity in accordance with the legal framework and the principle of good corporate governance. It aims to promote the Bank’s business conduct in a transparent manner, while being accountable towards all stakeholders, which ultimately is the basis of building strong foundation for a sustainable growth of the Bank. To comply with the Bank’s “The Spirit & The Letter”, employees do not only need to perform duties according to the provisions of laws and the Bank’spolicies (The Letter), but they also need to take into consideration the essence(The Spirit) of those written provisions. In so doing, the Bank should be able to shield its reputation and uphold customers’ confidence in the Bank’s products and services, which would contribute to a long-term and sustainable growth. Yours sincerely, Mr. Noriaki Goto Chief Executive Officer 3



The Spirit & The Letter:The conduct of every Krungsri employee may havean impact on our reputation. In each day that weperform our duties in conducting the Bank’s business,we must comply with the Spirit and the Letter whichhelps to ensure that we continue to conduct ouraffairs with unyielding integrity.All Krungsri employees also have the responsibilityto uphold the highest standards of ethical businessconduct. We seek to go beyond simply obeying thelaw – we embrace the spirit of integrity.The intent has been echoed and becomes apparent inKrungsri’s Code of Conduct which must be observedby every Krungsri employee everywhere and everyday. 5

KrungsriCode ofConduct

Krungsri Code of ConductObey the applicable laws and regulations governingour business.Be honest, fair and trustworthy in all your Krungsriactivities and relationships.….Avoid all conflicts of interest between work andpersonal affairs.…Foster an atmosphere in which fair employmentpractices extend to every member of the diverseKrungsri community.….Strive to create a safe workplace and to protectthe environment.….Through leadership at all levels, sustain a culturewhere ethical conduct is recognized, valued andexemplified by all employees. 7

Your Personal Commitment All Krungsri’s employees must familiarize themselves with the Code of Conduct and must abide at all time while employed by Krungsri. A notification is circulated notifying all employees to hold these codes as benchmark for conduct while under employment. Supervisors are tasked to observe and ensure observation of these codes by staff. Violators are subject to disciplinary action, including and not limited to termination of employment. You will be asked to acknowledge your awareness that every Krungsri employee must follow Krungsri Code of Conduct and Krungsri Corporate Policies and raise concerns about possible violations of law or conduct or policy with your manager, ombudsperson or compliance division. Visit onekrungsriportal.net for the complete and up-to-date policies. The Code of Conduct as laid forth is not all encompassing and is considered to be the task of employees of all levels to use personal judgment to determine the correct course of action in any given situation. Questions to pose to determine the correct action: 1. whether the course of action taken is moral, legal and is in compliance with guidelines stipulated by the Bank 2. whether the course of action increases personal integrity and that of the Bank and of others 3. whether the course of action is socially acceptable and can be openly disclosed 4. whether the course of action can be deemed by others as “improper” behavior8

Who must followThe Spirit & The LetterApplicable toDirectors, Officers and EmployeesSubsidiaries and Controlled AffiliatesEntities in which Krungsri owns more than 50 percent of the voting rights, orhas the right to control the entity, are required to adopt and follow KrungsriCode of Conduct and Corporate Compliance Policies.Non-controlled affiliatesNon-controlled affiliates should be encouraged to adopt and follow KrungsriCode of Conduct and Krungsri Corporate Compliance Policies.Third parties representing KrungsriKrungsri employees working with third parties, such as consultants, agents,sales representatives, distributors and independent contractors, must: • require these parties to agree to comply with relevant aspects of Krungsri Corporate Compliance Policies • provide these parties with education and information about policy requirements • take actions, up to and including terminating a contract, after learning that a third party failed to abide by Krungsri Corporate Compliance Policies. 9

What employees must doAll employees can contribute to Krungsri’s culture ofcompliance by understanding Krungsri policies, embracingKrungsri’s commitment to integrity and acting toenforce compliance and avoid violations.Employee responsibilities are as follows:Understand Krungsri Raise Your Concerns • Cooperate inPolicies • Promptly raise any Krungsri investiga- concerns about tions related to • Gain a basic potential violations integrity concerns. understanding of of any Krungsri the policy require- policy. ments summarized • Understand the in this booklet. different channels for raising integrity • Learn the details of concerns: manager, policies relevant to ombudsperson or your job. compliance division. • If a concern you • Check onekrungsri- raise is not resolved, portal.net for the pursue the issues! complete and Raise it through another of up-to-date policies. Krungsri’s channels. • Go to your manager, compliance division and legal advisory department with any questions about the policies.10

What leaders must doA manager / supervisor must create a culture of compliance in whichemployees understand their responsibilities and feel comfortableraising concerns without fear of retaliation; encourage ethical conductand compliance with the law by personally leading complianceefforts; consider compliance efforts when evaluating and rewardingemployees; and ensure that employees understand that businessresults are never more important than ethical conduct and compliancewith Krungsri policies.Manager / supervisor must also take the following steps to build andinfrastructure to prevent, detect and respond to compliance issues:Prevent Compliance Detect Compliance Respond to ComplianceIssues Issues Issues • Identify business • Implement control • Take prompt compliance risks measures, such as corrective action “dashboard” and to fix identified • Ensure that processes, “scorecards,” to compliance weak- tailored to address detect heightened nesses. your particular risk compliance risks areas, are communiated and/or violations. • Take appropriate and implemented. disciplinary action. • Promote an effective • Provide education ombudsperson • Consult with on Krungsri policies General Counsel and applicable law system. to employees and • Ensure that periodic and make (where appropriate) compliance reviews appropriate board members disclosures to and third parties. are conducted, with regulators and the assistance of law enforcement • Commit adequate business compliance authorities. resources to your champions and/or business’s compliance the Internal Audit program Staff 11

Raise Your Voice: Your obligationto raise integrity concernsRaising an integrity concern protects the Krungsricommunity: our company, our colleagues and ourstakeholders.If you have a concern about compliance withKrungsri policy, you have a responsibility to raisethat concern.Raise Concern Early Confidentiality Is Retaliation ViolatesThe longer we wait to Respected Krungsri Policyaddress a concern, the Your identity and the Krungsri absolutelyworse it may become. information you provide prohibits retaliation will be shared only on against anyone forYou May Remain a “need-to-know” basis raising or helping toAnonymous with those responsible address an integrityHowever, if you identify for resolving the concern. Retaliation isyourself, we are able to concern. grounds for disciplinaryfollow up with you and action which mayprovide feedback. include dismissal.12

How to Raisean Integrity ConcernKrungsri offers several channels for raising concerns.Use the channel that is most comfortable for you.Within Your BusinessGenerally, your supervisor or manager will be in the best position to resolvean integrity concern quickly. However, your direct supervisor is not your onlyoption. Other resources include: • Next higher level of management • Compliance Division • OmbudspersonKrungsri Ombudsperson Channel to contact the OmbudspersonKrungsri Ombudsperson process Telephone: 0 2296 5588allows you to voice your integrityquestions and concerns, anonymously Intranet: onekrungsriportal.netif you choose, and you will receive aresponse, if you identify yourself Mail: P.O. Box 169 Yan Nawa, Bangkok 10120 13

What happens when anintegrity concern is raised Concerns about compliance with Krungsri policy will be investigated. Krungsri’s investigation process includes: 1. Assigning an investigation team Experts with the right knowledge and objectivity are assigned to investigate. 2. Conducting an investigation The team determines the facts through interviews and/or review of documents. 3. Corrective action If necessary, the team recommends corrective actions to the appropriate managers for implementation. 4. Feedback The person raising the concern receives feedback on the outcome.14

Penalties for violationsEmployees and supervisors who violate the spiritor the letter of Krungsri’s policies are subject todisciplinary action up to and including terminationof employment. Misconduct that may result in disciplineincludes: • Violating Krungsri policy • Requesting other to violate Krungsri policy • Failure to promptly raise a known or suspected violation of Krungsri policy • Failure to cooperate in Krungsri investigations of possible policy violations • Retaliation against another employee for reporting on integrity concern • Failure to demonstrate leadership and diligence to ensure compliance with Krungsri policies and lawKrungsri absolutely prohibits retaliation. 15

Corporate policies and procedures Your business may issue its own policies and procedures. You must follow those policies and procedures in addition to those described in this guide. Important: This guide and the policies described in it are not an employment contract. Krungsri does not create any contractual rights by issuing this guide or the policies.16

Regulatory Excellence Working with Customers & Suppliers Government Business Competing Globally In the Krungsri Community Protecting Krungsri AssetsThe Spirit &The LetterPolicies

Section One Regulatory ExcellenceRegulatoryExcellence

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Regulatory Excellence Virtually all of our Spirit & Letter policies are based on government laws and regulations. These regulations impact every business and every employee. Regulators establish and define the rules that we must comply with to conduct business. Effectively engaging with regulators as they establish regulations and assuring compliance with these regulations are critical to maintain Krungsri’s reputation for integrity. Today’s regulatory environment is becoming more and more challenging. Krungsri is subject to a growing number of regulations and enforcement activities. This environment demands that every employee and manager is aware, knowledgeable and committed to regulatory excellence. Responsibilities of all employees • Be knowledgeable about and comply with Spirit & Letter policies that affect your job responsibilities. • Be aware of the specific regulatory requirements that affect your business. • Gain a basic understanding of the regulators (who they are) and the regulatory priorities (What they require) that affect your business and your work. • Promptly report any potential issues that may lead to a regulatory compliance breach. • Always treat regulators professionally with courtesy and respect. • Assure that you coordinate with Bank’s designated persons when working with or responding to requests of regulators. ?20

Responsibilities of Managers Regulatory ExcellenceManagers have the following special responsibilities for regulatory compliance:Lead • Assure that you and your team are engaged in addressing regulatory policy, meeting regulatory requirements and managing regulatory risks. • Embed regulatory requirements into key operating processes.Assess • Determine the key regulators and regulatory requirements that affect your business operations.Resource • Assign owners for all regulatory risk areas to coordinate with bank’s compliance division. • Confirm that the right domain expertise exists to effectively manage regulatory relationships and compliance.Anticipate • Implement effective processes that alert you to new and changing regulations. Include regulation in your risk assessments.Relate • Develop and maintain effective relationships with regulators. • Work proactively with regulators on the development of regulations that achieve policy objectives efficiently and effectively.Control • Monitor execution and conduct audits to assure that processes which support regulatory relationships and compliance are operating effectively. 21

Section Two Improper Payments Supplier Relationships International Trade Controls Money Laundering Prevention Privacy Working with Customers & Suppliers

To introduce a new product to corporatecustomers, you arrange a conference ata beach resort hotel and invite the targetcorporate customers to join the conferenceat our bank expense, but also want to adda sea-diving trip.Can we fund the whole trip?SEE PAGE : 24IMPROPER PAYMENTS Your low-cost supplier offers good quality and reliable delivery at prices that can’t be beat. But you are un- comfortable with the working and living conditions it provides to its workers. Shrug it off, or make an issue of it? SEE PAGE : 26 SUPPLIER RELATIONSHIPS 23

Improper PaymentsWhat To knowAn improper payment to gain advantage in any situationis never acceptable and exposes you and Krungsrito possible criminal prosecution. Krungsri expresslyprohibits improper payments in all business dealings,in every location, with both governments and privatesector.Improper payments should not be confused withreasonable and limited expenditures for gifts, businessentertainment and customer travel and living expensesdirectly related to the promotion of products or servicesor the execution of a contract. These payments areacceptable, subject to specific Krungsri corporate andbusiness guidelines. ? ANSWER TO QUESTION ON PAGE 2324 You should consult your manager or contact compliance division to determine whether the trip is acceptable. Since we have to consider many factors which include whether your customer is a government official Krungsri or the customer’s policies, the Bank’s policies and any other relevant issues.

What to do employee of a customer discretion in your favor – Working with to obtain or retain an and a facilitating pay- Customers & SuppliersBefore giving a gift, improper advantage. ment, which involvesengaging in customer the payments of a smallentertainment or reim- Never give a gratuity or amount of money tobursing customer travel other payment to government expedite a routine actionexpenses, make sure you officials or employees to which you are entitled.understand applicable to expedite a routinelegal requirements, the administrative action Never contribute Bankcustomer’s own rules and without fully disclosing funds or other bank assetsKrungsri corporate and it to General Counsel. for political purposesbusiness guidelines. Some national laws that without the prior approval prohibit bribery outside of General Counsel.Make sure records of that nation include ansuch expenditures accu- exception for ‘facilitating Require any person orrately reflect the true payments’ to expedite firm who representsnature of the transaction. a routine administrative Krungsri (such as consultant, action to which a person agent, sales representatives,Never offer a business is otherwise entitled. distributor or contractor) tocourtesy, such as a gift, These payments are comply with this policycontribution or entertainment, often illegal and Krungsri and related laws.under circumstances that strongly discouragesmight create the appearance them. Make sure you Follow your business’sof an impropriety. understand the difference due diligence procedures between a bribe – when selecting personsNever offer, promise, pay corruptly giving someone or firms to representor authorize anything of else a thing of value in Krungsri.value (such as money, exchange for exercisinggoods, services) to agovernment official orWhat to watch out forBackground information customer or government relationship”about existing or potential official Any request to make a payment in a country orthird-party representatives Any demand to receive to a name not related to the transactionthat indicates: a commission payment A commission that is• Allegations of improper before the announcement disproportionate to the services providedbusiness practices of an award decision 25• Reputation for bribes• Family or other Any suggestion to direct relationship that could Krungsri business throughimproperly influence a specific representativethe decision of a or partner due to “special

Supplier Relationships What to know Krungsri’s relationships with supplier are based on lawful, efficient and fair practices. We expect our suppliers to obey the laws that require them to treat worker fairly, provide a safe and healthy work environment and protect environmental quality. Following Krungsri guidelines helps ensure that our supplier relationships will not damage Krungsri’s reputation. ? ANSWER TO QUESTION ON PAGE 23 Do not shrug it off. It’s a big issue – our reputation depends on doing business only with suppliers that deal responsibly with their workers and with their local environment.26

What to do Provide a competitive Safeguard Krungsri’s Working with opportunity for suppliers confidential and Customers & SuppliersComply with Applicable to earn a share of proprietary informationLaws and government Krungsri’s purchasing with a confidentialityregulations covering volume, including small agreement, andsupplier relationship. businesses and businesses safeguard any supplier- owned by the provided informationDo business only with disadvantaged, minorities, protected by anysuppliers that comply women and disable confidentialitywith local and other veterans. agreement.applicable legal require-ments and Krungsri Safeguard “personalguidelines relating to data” obtained fromlabor, the environment, suppliers (for instructions,health and safety. see “Privacy” on page 34What to watch out forChoosing suppliers on managed by a relative in supplier facilitiesany basis other than or close friend Entrusting “personal data” or confidentialopen, competitive bid- information to suppliers without ensuring thatding Unsafe conditions in they have appropriate technical, physical, and supplier facilities organizational measures to prevent unauthorizedPotential conflicts access or useof interest in supplier Supplier employeesselection, such as accepting who appear to beimproper gifts or other underage or subject toitems of value coercionDirecting business to a Apparent disregard ofsupplier owned or environmental standards 27

A representative from a potential new customer or supplierhas given you his name card, containing his name andcontact details.Is it OK to put this information in a database whereother Krungsri staff can access it?SEE PAGE : 34PRIVACY

A long-time valuable customer of a branch Working withoften makes large amount of deposit and with- Customers & Suppliersdrawal, over THB 2 million, in cash but the valueper transaction is always less than THB 2 mil-lion. Having considered that the customer is avaluable customer to the branch and making valueper transection of less than THB 2 million is hisnormal behavior as a suspicious transaction.Should branch not report his behavior as asuspicious activity?SEE PAGE : 32MONEY LAUNDERING PREVENTION 29

International Trade Controls What to know Japan has laws and the Foreign Exchange & Trade Law of Japan or so called “JFEL Sanction” to its embargoed countries or sanctioned persons, and the United States has laws and regulations to control financial service transactions crossing its borders and financial transac- tions services to its embargoed countries or sanctioned persons, so called “U.S. Sanction”. As a member of United Nations, Thailand adopts certain UN’s directives and sanction program, so called UN Sanction. In addition, The United States also controls the release of technical information to non-U.S. nationals. It is important that we carefully observe Internatioal Trade Controls (ITC) laws in connection to trade services business, international fund transfer business and importing of software and technology for our own use. ?30

What to do Screen your transac- Be caution of any Working with tions against all restrictive trade Customers & SuppliersComply with relevant applicable rules that practices or boycott,laws and regulations as restrict transactions especially restrictivethey relate to providing with certain sanctioned imposed under Japancross-border financial countries, persons and and/or U.S. sanctionedservices. prohibited end uses. program – facilitating such a restrictive tradeEnsure providing Screen all your could damage bank’saccurate and complete business partners business and reputation.information to authorities. involved in internationalCheck documents transactions against Consult with yoursupporting cross-border government-provided manager if a transactiontransactions to ensure watch lists. Follow your involves a restrictiveour service not violating business’s “Know Your trade practice.relevant laws and Customers” procedures.regulations.What to watch out forReluctant or otherwiseunsatisfactory Involvement of parties Transactions involving an embargoed country,answers by a customer or activities suspected a citizen or representatives of an embargoed countryto questions, i.e. about of any connection with or an individual or entity subject to abeneficiary or origin of the development of sanction program.product imported/ biological, chemical orexported. nuclear weapons, or ballistic missiles 31

Money Laundering PreventionWhat to knowPeople involved in criminal activity – e.g. terrorism, narcotics,bribery, and fraud – may try to “launder” the proceeds oftheir crimes to hide them or make them appear legitimate.More than 100 countries now have laws against moneylaundering, which prohibit conducting transactions thatinvolve proceeds of criminal activities. A related concernis that legitimate funds may be used to finance terroristactivity.Krungsri is committed to complying fully with all anti-moneylaundering and anti-terrorism laws. Krungsri will conductbusiness only with reputable customers involved in legitimatebusiness activities, with funds derived from legitimatesources. Krungsri shall implement risk-based “Know YourCustomer” due diligence procedures calibrated to the riskin question, and to take reasonable steps to prevent anddetect unacceptable and suspicious forms of transactions.Failing to detect customer relationships and transactionsthat place Krungsri at risk can severely damage Krungsri’sintegrity and reputation. ? ANSWER TO QUESTION ON PAGE 2832 Our AML law requires reporting cash transaction valued THB 2 million and up and any person of integrity will follow the law. Avoidance of fllowing the law is red flag of a suspicious activity. Should you have any doubt whether or not you should report as a suspicious activity, please consult compliance division.

What to do customers, agents and checks, or checks on be- Working with business partners to half of a customer from Customers & SuppliersComply with all applicable ensure that they are an unknown third party).laws and regulations that involved in legitimateprohibit money laundering business activities and If you encounter a waringand support and financing their funds come from sign of suspicious activity,of terrorism, and that legitimate sources. raise your concern torequire the reporting of compliance division, legalcash or suspicious trans- Follow your business’s advisory departmentactions. Understand how rules concerning accept- or General Counsel andthese laws apply to your able forms of payment. be sure to resolve yourbusiness. Learn the types of pay- concern promptly before ments that have become proceeding further withFollow your business associated with money the transaction. Ensure“Know Your Customer” laundering (e.g. multiple the resolution is wellProcedures. Collect and money orders or travelers documented.understand documenta-tion about prospectiveWhat to watch out forA customer, agent or Early repayment of a Transactions involving foreign shell or offshoreproposed business loan in cash or cash banks, unlicensed money remitters or currencypartner who is reluctant equivalents. exchangers, or non-bank financial intermediaries.to provide complete Structuring of transac- tions to evade recordinformation, provide Transactions that are keeping or reporting requirements (for example,complete information, unusual or complex patterns multiple transactions below the reportableprovide insufficient, false or inconsistent with the threshold amounts)or suspicious information customer’s business or Request to transfer money or return deposits to aor is anxious to avoid re- payment terms or reflect third party for reasons unknown.porting or record keeping no real business purpose. 33requirements. Unusual fund transfers toPayments using monetary or from countries unrelatedinstruments that appear to the transaction.to have no identifiablelink to the customer, or Transactions involvinghave been identified as locations identified asmoney laundering secrecy havens or areasmechanisms of known terrorist activity, narcotics trafficking or money laundering activity.

Privacy What to know A growing number of countries are more stringently regulating the collection and use of consumers’ “personal data” (names, home and office contact information and other data). In addition, many countries regulate personal data of company representatives in business- to-business transactions. A few countries even regulate the privacy of information relating to corporations. Krungsri is committed to handling personal data responsibly and in compliance with applicable privacy laws. ? ANSWER TO QUESTION ON PAGE 29 No, the information is personal data unless he has granted express consent.34

What to do legitimate business unauthorized access in Working with purposes only. processing of personal Customers & SuppliersLearn and comply with data or accidental lossthe followings as they Use “Anonymous” or destruction of personalapply to personal data data (names removed data.including: and not identifiable) If you learn that personal or “aggregated” data data has been used in • Applicable laws (summarized so as not violation of this policy and regulations of to be identifiable to an or your business privacy jurisdictions from individual) instead of implementing procedures, which the personal personal data where or if you learn that the data is collected appropriate or required. security of any system and in which it is or device containing processed or used. Limit access to personal personal data has been data to individuals who compromised, • The privacy policies need it for legitimate immediately notify your of Krungsri and business purpose. manager, compliance your business division or legal Use care to prevent advisory department. • Any contractual obligations that apply.Collect, process anduse personal data forWhat to watch out forInadequate access or Sharing of personal Transfers of personal data between countries,security controls for data with unaffiliated without considering applicable legal require-personal data, such as third parties, such as ments.e-mailing or otherwise vendors or suppliers,distributing personal who lack appropriatedata to a larger group security safeguards orthan legitimately needed restrictions on informationor leaving printouts use.with personal data at aprinter, copy machineor fax machine for othersto see. 35

Section Three Working with GovernmentsGovernmentBusiness

You propose a complexrisk management productto a customer who is agovernment agency. Youknow other banks alsopropose similar productsto the customer. Once thecustomer agrees to buy ourproduct, you immediatelysign the contract.Is it OK to urgently signthe contract even beforeensuring the customerfully understands therisk associated with theproducts and can enterinto the contract?SEE PAGE : 38WORKING WITH GOVERN-MENTS 37

Working with Governments What to know When Krungsri works as a direct or indirect counter party with governments and government-owned enterprises, in the course of our work, we frequently interact with government agencies and officials. In every instance, Krungsri employees must apply the highest ethical standards and comply with applicable laws and regulations, including certain special require- ments associated with government transactions. ? ANSWER TO QUESTION ON PAGE 37 We should ensure that the government agency has capacity to undertake the risk and enter into the contract to protect bank from business risk as well as reputational risk.38

What to do of Krungsri’s working and communicated to Government Business with Governments the responsible parties.Abide by applicable policy.laws and regulations Be truthful and accurate Do not make anyrelating to working with when dealing with unauthorized changesgovernments, particularly government officials or deviate fromspecial requirements and agencies. contract requirementsassociated with without the writtengovernment contracts Adopt processes that approval of theand transactions. ensure reports, certifi- authorized government cation, statements and official.Require anyone bank proposals are current,works with – i.e. as a accurate and completeconsortium member, a and that contractfinancial advisor – to requirements areprovide financial services adequately identifiedto government to agreeto comply with the intentWhat to watch our forSpecial requirements withdrawing a loan prior (unless the contracting officer or agency leaderthat apply to transactions to the completion of a has specifically and lawfully authorized thewith governments, task as specified in the information’s release)including commercial government contract. Negotiation for employ- ment with governmenttransactions between official or government official’s family membersprivate parties financed Violating government while the official has the ability to influenceby government agencies regulations that establish decision making about contracts with theor international agencies. gratuity restrictions or government. bidding procedures.Incorrect or unauthorizedcharges on government Accepting informationcontracts. about a government’s competitive selectionDeviations from contract of a supplier, or com-requirements, i.e. allow petitors’ bid or proposal 39

Section Four Complying with Competition LawsCompetingGlobally

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Complying with Competition Laws What to know Krungsri commits to operate our business with good governance. Not only by strengthening our own good governance culture, we would like to extend good governance to our societies and communities we live in. Our competition laws, even though they are aimed to prevent unfair competitions among players in industrial sectors, we, as a financial facilitator to industrial sectors, require prior review in order to prevent the act of supporting customers violating competition laws. ?42

What to do Do not facilitate a Avoid contracts with Competing Globally customer who intends suppliers or businessObserve competition to use our facilitation partners that couldlaws about how business as a vehicle to evade create appearance ofshould be conducted. competition laws; for improper agreements example using our letter or understandings.Review and understand of guarantee to bid aboth Krungsri and b government project but Do not facilitateusiness-specific policies not intend to win the customers or suppliersand procedures, and if bid or just to make the who do not intend toyou have questions or bidding appeared to be use our facilitation forissues, bring them up transparent, using our their own use (in otherwith General Counsel. fund to facilitate unlawful words, customers merger or acquisition or suppliers who areObserve our customers’ or to facilitate market nominees of unknownbehavior concerning activities in which will persons).violations of competition result in monopolizinglaws and if any, take the market or evadinginto consideration as a anti-dumping law.criterion to grant a loanto such customers.What to watch out forExclusive arrangements produce / to supply Arrangements that restrict customers’– if our customer or / to use its products choices.supplier is contracted, or services, ensure theas an exclusive or customer or the sup-sole agent / broker / plier does not violatelicensee or licensor, to competition laws. 43

Section Five Fair Employment Practices Environment Health & Safety Security & Crisis ManagementIn theKrungsriCommunity

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Fair Employment Practices What to know Fair employment practices do more than keep Krungsri in compliance with applicable labor and employment laws. They contribute to a culture of respect. Krungsri is committed to complying with all laws pertaining to privacy, working time, wages and hours, no employment discrimination and freedom of association. Beyond legal compliance, we strive to create environment considerate of all employees wherever Krungsri business is being conducted. ?46

What to do Provide a work environment If a conflict arises In the Krungsri Community free of improper harass- between the require-Base employment decisions ment and bullying. ments of this policy andon job qualifications the laws, customs or(e.g. education and Respect the privacy practices of a particularexperience) and merit rights of employees by area, consult with(an individual’s skills, properly, maintaining management andperformance values, and transferring General Counsel toleadership and other personal data. (While determine the mostjob-related criteria). seeking to maintain appropriate course employee privacy, of action.Make all employment Krungsri reserves therelated decisions and right to monitor useactions without regard of company property,to person’s race, color, including computers,religion, national origin, e-mail, phones, proprietarysex (including pregnancy), information, etc. insexual orientation, age, accordance withdisability, veteran status applicable law.)or other characteristicprotected by law.What to watch out forA hostile work environ- Violating a labor law – Disclosing employment data to a person whoment (for example, for example, wages paid does not have business need, authority or thetelling jokes or displaying for working overtime, subject’s consent.materials that ridicule or working hours of staff Taking an adverse action against an employeeoffend a member of a working in shift. (e.g. firing) because the employee has raised aparticular race, religion concern about a violation of policy or law.or sex). Refusing to work, or 47 otherwise cooperateMaking unwelcome with, certain individualssexual advances to because of their race,another employee or religion, sex or otherperson with whom you characteristic protectedwork by law

A department places 50 boxescontaining documents to be de-livered to warehouse for recordkeeping in the next few days. Theboxes are placed along a walkwayand take some space of fire-exit.It is difficult for 2 persons to walkpassing through the area at thesame time.Should you place those boxesthere?SEE PAGE : 50ENVIRONMENT, HEALTH & SAFETY

In the Krungsri CommunityA customer requests to transfer money to a recipient inMexico. I don’t have time to check the customer’s andthe recipient’s name against our watch list. I know thatMexico is not a country sanctioned by the UN or the U.S.Can I process the money-transfer request now andI will check the names later?SEE PAGE : 52SECURITY & CRISIS MANAGEMENT 49

Environment Health & Safety What to know Protecting the environment and the health and safety of employees Is the law – and Krungsri believes it is also the right thing to do. Through management leader- ship and employee commitment, Krungsri commits to provide safe workplaces, not only for staff safety but also for customers or anyone who visit our workplaces. This policy affects all bank activities – not just bank’s workplaces, but everything we do – for example, acquiring a new business or providing customer service or driving a car on bank business. ? ANSWER TO QUESTION ON PAGE 48 No, blocking the walkway of the fire exit would be considered as an unsafe working environment. Thus, do not place any article blocking the fire exit.50