What to do into account that if a water and energy. In the Krungsri Community customer violates EHSComply with all law and regulations, it Continue to improve ourapplicable environment may impacts its ability EHS systems and perfor-health and safety (EHS) to repay our loan and mance as an integral partlaws and regulations and impact our reputation as of Krungsri’s operationalKrungsri EHS policies. a company that funds strategy an environmental hazardCreate and maintain a business. Present Ideas thatsafe working environment support the goals of thisand prevent workplace Eliminate unreasonable policy to your managerinjuries. EHS risks from Krungsri’s or your business’s EHS facilities, products, services manager.Assess EHS legal and and activities.reputational risks before Promptly alert youracquiring a new business, As practicable, reduce manager or EHS contactespecially a new business toxic and hazardous of unlawful or unsafeinvolved a hazardous materials; prevent pollution; conditions.business. and conserve, recover and recycle materials, operations should beConsider EHS impacts as taken into account as aa credit criterion – take potential to our operating risk and reputational risk.What to watch out for Inadequate securityUnsafe activities and guarding on equip- procedures or practices that may present safetyconditions, such as ment and machinery. threats to a facility and/ or employees.• Exposed or unsafe New business acquisitionswiring Failure to comply with that may increase or lead to credit and reputational• Blocked fire or health, safety or environ- risks to our bank. emergency exits mental regulations and 51• Working on procedures electrical or poweredequipment without EHS complaints orfollowing safety (e.g. unreported environmental,“lock-out, tag-out”) health or safety hazardsprocedures. or accidents or failure• Potential exposure to respond to concernsto serious infectious about possibility to damagediseases environment or public• Disabling safety health and safety that are control or protective involved our customers’
Security & Crisis management What to know In an age of increasing terrorist threats, protecting the security of our people, workplaces, information and business is critical. It starts with every business implementing a rigorous and comprehensive security and crisis management (SCM) plan. Krungsri’s SCM plan includes measures for preventing terrorist and other criminal acts on our employees, facilities, information, information technology (IT) infrastructure, business continuity and crisis management. In addition, employees must take every precaution to avoid doing business with known terrorists or those known to support terrorist activity. ? ANSWER TO QUESTION ON PAGE 49 No, do not process the request until the screening is done. Krungsri cannot agree to business for a customer until all required watch list screening has been performed.52
What to do Protect access to Ensure proper business In the Krungsri Community Krungsri facilities from all continuity plans areImplement rigorous but authorized personnel. prepared for anplans to address the emergency.security of employees, Protect IT Assets fromfacilities, information, theft or misappropriation. Screen all customers,IT assets and business suppliers, agents, dealerscontinuity. Create and maintain a and business partners safe working environ- against appropriateParticipate in your ment – this includes terrorist watch lists.business emergency identifying and reportingplanning and emergency indicators of workplace Report any apparentdrills. violence. security lapses to your manager, crisis manage-Comply with the Conduct appropriate ment leader or Krungsrientry and exit rules background checks on Ombudsperson.at Krungsri facilities, new hires and contractors,including wearing the wherever allowed byappropriate badge. law.What to watch out forIndividual at Krungsri Unsecure areas of a Unauthorized entry to a facilityfacilities not wearing facility where onlyappropriate badges and authorized personnelloitering in our premises. allowed to enterUnsecure IT assets such Security complaintsas laptop, servers, etc. from employees, customers or neighbors 53
Section Six Intellectual Property Controllership Conflicts of Interest Insider Trading and Stock Tipping Protecting Krungsri Assets
Consumer banking has internallyrevealed an innovative financial in-strument. A big customer of mineis pressing me to describe the newinstrument to her now because sheneeds to make her decision this week.I know Krungsri wants to protect thefeature but I’m not sure the applica-tion has been filed yet.Can I show the customer the newproduct?SEE PAGE : 56INTELLECTUAL PROPERTY 55
Intellectual Property What to know Krungsri’s intellectual property is one of its most valuable assets. All employees must work to safeguard our patents, trademarks, copyrights, trade secrets and other proprietary information. At the same time, it is critical that we respect the valid intellectual property rights of others. Unauthorized use of others’ intellectual property can expose the Company and even individual Krungsri employees to civil law suit and damages, including significant fines and criminal penalties. A key to protecting our intellectual property and, at the same time, guarding against these risks, is the timely and reasonable review of new Krungsri products, services, processes and software, for possible inventions and trade secrets and infringement of the intellectual property rights of others. ? ANSWER TO QUESTION ON PAGE 55 No. You should consult with your manager if the product has gone through internal approval process as well as regulatory process and reach the stage that you could release it to a customer.56
What to do proprietary information • Permitting outsiders Protecting Krungsri Assets (i.e. information that is to use our proprietaryProtect our brand – use in confidence and not informationof our brand and bank’s publicly known orname shall be reviewed generally available) Understand yourby legal and compliance responsibilities to protect Consult with legal counsel our trademark andRespect valid patents, before: trade name. Consultcopyrighted materials with legal counsel ifand other protected • Soliciting, accepting you have any questionintellectual property of or using proprietary about the responsibilities.others. information of out- siders (for example, Comply with theConsult with legal counsel obtaining name list guidelines for use ofconcerning necessary from illegal source) the Krungsri’s and ourlicenses or approvals Financial Businessto use protected • Disclosing our pro- Group’s as our strategicintellectual property of prietary information partner, primary trade-other such as patents, to outsiders marks and trade names.trademarks orWhat to watch out forAccepting proprietary Using another company consulting with company legal counselinformation belonging to develop new products Employing a new person, especially ato outsider without first or software without a person who previously worked for a competitor,consulting company written agreement in without putting in place safeguards to preventlegal counsel place covering owner- the person from inadvertently disclosing ship and other rights in or using the proprietary information of theDiscussing Krungsri the developed intellectual previous employerproprietary informa- propertytion with customers orsuppliers Threatening anyone suspected of infringing any Krungsri intellectual property without first 57
Controllership What to know Controllership embodies three fundamental elements: (1) rules that classify transactions and balances appropriately; (2) systems and controls that protect assets and accumulate information consistently and correctly; and (3) financial and transaction reporting that is timely and unbiased. Controllership creates the right environment for disclosing timely, reliable and accurate information to government agencies and the public. ?58
What to do Maintain complete, Complying with estab Protecting Krungsri Assets accurate and timely lished documentFollow general accounting records and accounts to management proceduresprocedures, as well as appropriately reflect all as well as all applicableapplicable generally business transactions laws and regulationsaccepted accounting relating to the preservationprinciples, standards Safeguard all company of documents and recordsand regulations for assets (physical, financialaccounting and financial and informational) Preserve documentsreporting and records relevant to Provide timely, candid pending or reasonablyEnsure that financial forecasts and assessments foreseeable litigation,and non-financial audits or investigation,information and operating Maintain sound processes and as directed bymetrics are reported and controls company counselaccurately and in atimely fashionWhat to watch out forFinancial results that Physical assets or other pending or reasonably foreseeable litigation,seem inconsistent with resources that could be audits and investiga- tionsunderlying performance more fully used, reallocated Disposal of Documents or disposed of without knowing what is being discarded orInaccurate financial whether the documents are subject to legalrecords, such as over- Circumventing review preservation require- mentsstated travel and living and approval procedures False or exaggeratedexpense reports, or statements in e-mail, presentations or othererroneous timesheets Inadequate Routines documentsor invoices and Controls at newly 59 acquired businessesTransactions that are and at remote and/orinconsistent with good understaffed sites.business economics Inadequate RoutinesAbsence of controls to and Controls toprotect assets from risk preserve documentsof loss (including e-mail) for
I was chatting with my brother and mentioned that I had an upcoming business trip to close the deal for Krungsri to acquire Company X. Could this create a problem? SEE PAGE : 64 INSIDER TRADING & STOCK TIPPING60
Protecting Krungsri AssetsYour cousin owns a company that suppliesoffice equipments to Krungsri.Is that a prohibited conflicts of interest, nomatter what Krungsri’s function you’re in?SEE PAGE : 62CONFLICT OF INTEREST 61
Conflicts of InterestWhat to knowOn the job or in our free time, nothing you do shouldconflict with your responsibilities to Krungsri. Noactivity at work or at home should hurt Krungsri’sreputation or good name. Misusing Krungsri resourcesor influence is also prohibited. Even when nothingwrong is intended, the appearance of a conflict canhave negative effects. It is crucial to consider how youractions might appear, and to avoid the perception ofa conflict of interest. ? ANSWER TO QUESTION ON PAGE 6162 This is not explicitly prohibited, but the Conflicts of Interest policy requires that you disclose the situation to management, if you or your department is involved in the selection of the supplier or the ordering of supplies related to this supplier, and that you do not attempt to influence Krungsri business with your cousin’s company.
What to do of a conflict with your Krungsri position, infor- Protecting Krungsri Assets job or Krungsri’s interests mation or propertyDisclose (in writtenform to your manager Do not Misuse or Get Approvals beforeand to compliance) all use for personal gain accepting officer orof your outside activities, Krungsri resources, director positions withfinancial interests or intellectual property, an outside businessrelationships that may customer contracts while you are a Krungsrieither present a conflict time or facilities – this employee.or the appearance of includes office equip-one. ment, e-mail and Get your Manager’s computer applications Approval when acceptingUse good judgment in not-for-profit boardall personal and business Do not Take for positions, particularly ifdealings outside your yourself personally the organization has aKrungsri job any opportunities that Krungsri relationship or Krungsri could have an might expect KrungsriAvoid Actions or interest in that result financial or otherRelationships that may through the use of supportcause potential conflictor create the appearanceWhat to watch out forFinancial Interests in if you’re making decisions Misusing Krungsri Resources, your positiona company where you (on Krungsri’s behalf) or influence to promote or assist an outsidecould personally affect that involve them activityKrungsri’s business with Hiring, Promoting or Directly Supervising athat company (for example, Personal Discount or other family member or close frienda customer, supplier or benefits from suppliers, Personal Relationshipsinvestment) service providers or that may conflict with your Krungsri responsi- customers that the bilities or compromise company interestsPart-time Jobs which public or your Krungsri 63you perform using peers do not receiveKrungsri hours or Krungsriequipment or materials Directing Business to suppliers when youGifts of other than know they are ownednominal value from or managed by yoursuppliers, customers or family members orcompetitors, particularly close friends
Insider Trading & Stock Tipping What to know In the course of your job, you may learn of material information about Krungsri or other companies before it is made public. You may be the relationship manager of the company or may simply overhear a hallway conversation or come across a memo left at a copy machine. Using this information for your financial or other personal benefit or conveying this information to others constitutes a violation of this policy and may even violate the law. This includes buying or selling the securities of any company about which you have material non-public information and giving this “inside information” to anyone else who might base financial trades on the information you’ve shared. ? ANSWER TO QUESTION ON PAGE 61 Yes, if Company X is a public company and the possible acquisition of Com- pany X has not been publicly announced. If your brother trades Company X stock based on your tip, both of you could be charged with insider trading.64
What to do else buy or sell the outside the Company Protecting Krungsri Assets securities of any unless it is necessaryDo not Buy or Sell company, including for the Company’sthe securities of any Krungsri, while you business activities.company, including have inside informationKrungsri, either directly about the company. If questions Arise,or through family (This is known as consult companymembers or other persons “tipping.”) counsel beforeor entities, while you trading in the securityare aware of inside Maintain the or disclosing companyinformation about the Confidentiality of informationcompany. (This is known Company informationas “insider trading.”) and do not convey information to anyoneDo not recommend orSuggest that anyoneWhat to watch out forNon-public information Buying or Selling a Discussing Krungsri Business with familyWhich, If Disclosed, Security because you and friendswould reasonably be hear or learn of information Talking about what you’re Working Onexpected to affect the at work that you thinkprice of a security or will make the price gowould influence your up or down once it’sdecision to buy, sell or publicly announced.hold a security, such asan earnings announce- Engaging In Tradingment or a prospective Activity around theacquisition announce- time of a significantment (this is known as company announce-“inside information”) ment 65
NOTE
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