PowerPoint Presentation

[Audio] Dear all top executives and managements Today, Compliance unit would like to provide regarding NICE policy training in Role of Management and Gifts and Hospitality this training is concerned about the role and responsibility of management level regarding policy, regulations and TMT Code of Conduct. And the regulation of Gifts and Hospitality in NICE policy..

[Audio] Please note that this training content is for internal use only, do not disseminate to outside the company" And please do not reproduce, copy, modify, falsify, or disseminate this training material without permission.

[Audio] This training is consisted of 2 topics as follows : First, Role of Management And second, Gifts and Hospitalities..

[Audio] Let's start with Role of Management first..

[Audio] Next, please allow me to suggest the topic today's which consists of 3 topics: Company's Direction, Role of Management, and the last topic-Caution points & Example of prohibitions.

[Audio] Let's start with the first topic: Company's Direction.

[Audio] Refer to President's Message ( May' 22) has determined the things that all employees must DO as follows: 1. All TMT employees must strictly comply with company's policies & guidelines 2. All TMT employees have obligation to report the violation and if the violation is fraud case, they must report that concern through Speak-up channel 3. All employees must uphold ethical standard as a good cooperate governance & transparency.

[Audio] Let's move to next topic: Role of Management.

[Audio] Before going to content, Please allow me to provide you the necessity which is to achieve company's direction, the role of management on NICE policies is one of the important tools which bring us to our succession. For NICE policies, we divide them into 2 groups: 5 conceptual policies which consist of Code of conduct, Anti-fraud policy, Anti-bribery and corruption policy, Speak-up policy and the last policy: non-retaliation Another group is operational policies which consist of 10 policies such as Gift & hospitality, donation & sponsorship, travel, indirect procurement, Disbursement, Non travel reimbursement, vendor & third party Due Diligence, Delegation of authority, Authorization manual or AM and the last one, Subsidies for contracts and tenders.

[Audio] Before going to content, Please allow me to provide you the necessity which is to achieve company's direction, the role of management on NICE policies is one of the important tools which bring us to our succession. For NICE policies, we divide them into 2 groups: 5 conceptual policies which consist of Code of conduct, Anti-fraud policy, Anti-bribery and corruption policy, Speak-up policy and the last policy: non-retaliation Another group is operational policies which consist of 10 policies such as Gift & hospitality, donation & sponsorship, travel, indirect procurement, Disbursement, Non travel reimbursement, vendor & third party Due Diligence, Delegation of authority, Authorization manual or AM and the last one, Subsidies for contracts and tenders.

[Audio] Starting with Conceptual policies: The roles and responsibilities for all management and executives are: Firstly, Demonstrate ethical leadership and inspire our employees to comply with NICE policies. Secondly, management must Act as a role model for our employees, and also give accurate and timely advice to them 3. Discuss Code of Conduct during meeting with their subordinates and throughout the performance review process. Also, Management must always communicate NICE policies to employees such as not providing/receiving bribes and so on Fifth, Management should recognize and reward ethical act of employees and must treat all employees fairly without harassment And the last one, let employees aware the different ways to report violations through Speak-up and ensure non retaliation will not happen in their responsible area..

[Audio] Next is the Roles & Responsibilities of Management according to operational policies. Management must review the completeness of document & information before approval. Must approve in the scope & limitation of authorization refer to Authorization Manual. Have to Create the approval checklist to ensure compliance with Authorization Manual. Always monitor the activities to ensure that they will comply with the objectives and company's' policies. And the last one in case of delegation, must delegate to the authorized persons in comply with NICE policy. Please be reminded that compliance as these roles is important unless it may cause you to be violated to company's rule & regulation..

[Audio] Finally, the last agenda regarding – Caution points & Example of prohibitions.

[Audio] It's important that all TMT managements must have a " zero tolerance" for Fraud, Bribes and Corruption. The examples of these concerns such as Don't obtain the improper benefits from forgery any receipts or documents Don't provide Bribes & Corruption for taking advantages or any benefits from government or third parties. Please be reminded that committing of Fraud, Bribes and Corruption may lead to the company's decisive actions such as discharge or company will take legal action..

[Audio] That is all of Role of MM training content, lastly, CU would like to wrap up and emphasize roles & responsibilities of all management as follows: All management must act as a role model and inspire employees to comply with NICE policy. Must report and encourage their subordinates to report the violation cases to company through Speak-up for investigation. Must review, approve and monitor all activities to ensure the compliance with NICE policy. And the last one, do not tolerance for any Fraud , Bribes and Corruption.

[Audio] Let's us move to another topic, Gifts and Hospitality policy.

[Audio] Next, please allow me to present the content today, which consists of 4 topics as follows : First, objectives and scopes. Second, definitions and concerned departments. Third, guidelines and Forth, do and don't..

[Audio] Let's start with first topic Objectives and scopes.

[Audio] The policy objective is to standardize procedures in order to promote fair competition and transparency and the second objective is to prevent the providing and receiving of inappropriate benefit that may damage our company or lead to bribery. This policy is implemented to all TMT's staff which consists Permanent, Contract and Sub-Contract employees.

[Audio] Next topic is definitions and concerned departments..

[Audio] Before going to the detail, we would like to explain the definitions of each item as follows : First, Gifts means any items of value given or received in order to foster good relationship or as a social courtesy. Second, Hospitality is meal and entertainment provided or received in order to foster good relationship or as a social courtesy same as Gifts Third, third party or business partner is any person or organization that performs services for or on behalf of TMT..

[Audio] And last, Government official is the national, provincial or municipal officials at any level whether in Thailand or abroad and whether operating in their official capacities or not. There are 5 types of government official in the policy..

[Audio] Next, I would like to explain the responsibility of each departments as follows : First User responsibility in providing Gifts & Hospitality is complete " Gifts and Hospitality Approval Form" and submit to CA via SAP and fill in the reimbursement form in SAP also when reimburse the expense. For receiving Gifts & Hospitality, user must complete "The receiving of Gifts, Hospitality and Travel Approval form" and submit to GM for approval in case the value of Gifts and Hospitality are more than 5,000 baht. Second CA departments have to verify the completeness of information in SAP before purchasing. Then purchase Gifts & Hospitality (Except : the case that user can purchase by user's self) Third CU will pre-approve in case of providing Gifts & Hospitality to Government official and assess, with Legal and concerned depts. , regarding relevant circumstance around Gifts and Hospitality to Government Official and ensure frequency limits to be comply with policy. And last, Accounting will approve reimbursement expense in SAP..

[Audio] Next topic, please allow me to explain the guidelines of Gifts and Hospitality.

[Audio] We would like to summarize the policy procedures in table as follows : -The recipient of Gifts and Hospitality is Government Official , Third Party and Business Partner We have 3 mains policy procedures as follows First, provide Gifts & Hospitality on behalf of TMT in order to foster good relationship as social courtesy. Second, appropriate value & timing and in accordance with applicable laws & approved amounts. and Third do not provide Gifts & Hospitality to close relationship members of Government Official, Third party and business partner. Next for the acceptable Gifts & Hospitality For Gifts, the gifts should have small value such as pen, Jacket with company's logo and offer on traditional or national holidays such as New year festival and offer according to cultural practice for example Congratulations. For Hospitality, The hospitality must have a valid purpose for example dinner after Business seminar. and must offer in suitable time , place and cost and have TMT's employee attend the hospitality. However, there are prohibit point as follows : For gifts, don't provide Alcohol beverage or luxury goods such as brand name And for hospitality, don't arrange in unsuitable location such as Massage parlors, Adult night clubs..

[Audio] For providing Gifts & Hospitality, the value and frequency can be explain the detail as follows : First, Government Official, the value of Gifts & Hospitality must less than or equal to 3,000 baht per head per occasion and must be pre-approved by CU. The value of 3,000 baht and the total of Gifts and Hospitality values are counted as total value, for example, provide car model 1,500 baht and meal 1,500 baht to Government official in the same meeting. The frequency is strictly specific that users can't give Gifts & Hospitality to the same person more than 1 time per day and more than 4 times per fiscal year. However, the frequency is counted of all departments in the company, for example, Department A give Gifts to Mr. X then Department B can't give Gifts to Mr. X on the same day or festival and user can check the frequency with CU. For third party and business partner the level of value and pre-approval are shown in the table and the policy don't limit the frequency of providing Gifts and Hospitality..

[Audio] Next is the condition of providing Gifts & Hospitality, which the employee must comply as follows : First, All activities must be approved before proceeding except the unexpected meal that the meeting has been continued until lunch or dinner time and incase of providing light snacks or beverage to dealers during training or business meeting which the maximum value is 7,000 baht. Second, users can provide Gifts & Hospitality by themselves as follows : For gifts, users can purchase the perishable gifts by themselves such as flower basket. However, the value must less than or equal to 3,000 baht for Government Official and 5,000 baht for Third Party and Business Partner (If value more than 5,000 baht for Third Party and Business Partner, must be purchased by CA). For hospitality, users can arrange the entertainment with small value that can't be purchased in advance. For example, entrance to golf driving range or arrange unexpected meal, providing light snack and beverage in comply with subject 1.1 and 1.2. Third, Do not provide cash or any equivalent items except condolence payments to Third Party or Business Partner which the value is not exceed 7,000 baht..

[Audio] For receiving Gifts and Hospitality, we would like to explain the detail as follows : -Receiving Gifts and Hospitality, which the value exceed 5000 baht, must be approved by GM or higher positions. -We would like to remind all employees in 3 concerned points as follows : First, receiving Gifts, Hospitality and Travel from Government Official, users must complete " Receiving of Gift, Hospitality and Travel Approval Form." and submit to CU for approval in every cases. Second, receiving Gifts, Hospitality and Travel , which value more than 5,000 baht, with out permission, if the approval is denied, user must return those items to the giver. And last, the employee should refuse to receive the abnormally high value of gifts, hospitality, and travel..

[Audio] Next topic, please allow me to explain the guidelines of Gifts and Hospitality.

[Audio] In case of receiving Gifts & Hospitality, the employee should remember the main Do and don't as follows : DO 3 subjects First, Pre approve before proceeding with the activities, except in some exceptional cases in policy. Second, Users must verify the value of Gifts and Hospitality and request for approval in comply with approval level. Third, Users must not have any hidden intentions regarding Bribery and Corruption Don't 3 subjects First, Don't Provide cash or any equivalent items. Second, Don't provide Gifts and Hospitality to government officials over certain limits of values and times. Third, Don't provide Gifts & Hospitality to close relationship members of Government Official, Third party and business partner. ..

[Audio] Finally, we would like to wrap up the policy key points as follows : First, pre-approve before providing Gifts & Hospitality, except in some exceptional cases in policy. Second, Must not provide cash and equivalent items, except condolence payments for Third Party / Business Partner which the value is less than or equal to 7,000 baht. Third, Users can purchase the perishable gifts by themselves but value must less than or equal to 3,000 baht for Government Official and less than or equal to 5,000 baht for Third Party and Business Partner (If value is more than 5,000 baht, must be purchased by CA) And last, Receiving Gifts and Hospitality, if the value is exceed 5,000 baht, must be approved by GM or higher position. However, Receiving from Government Official must be approved by CU in every cases..

[Audio] It is very important that all employee do not commit any fraud , bribes and corruption. We would like to remind the 3 Don't as follows : -First, don't provide Gifts and Hospitality with the hidden benefit of Corruption or Bribery. -Second, don't receive Gifts and Hospitality and promise to return any improper benefits to the giver. And -Third, don't corrupt, forgery any related documents. Moreover, we would like to give the example for prohibition case that An employee receives a high value gifts from third party without approval and promises to provide the special service when they contacts TMT. Please be reminded that committing of Fraud, Bribes and Corruption may lead to the company's decisive actions such as discharge or company will take legal action..

[Audio] To study or get more detail such as full version of the policy including both conceptual and operational policies, you can access NICE policies at CU SharePoint or if you have any questions. Please feel free to contact CU department..

[Audio] Nevertheless, if you find any employees who do not comply with the policy or violate the rules of the company including any fraud, you can report directly to CU via phone, email, LINE application, or report to external channels by notifying KPMG, which has many channels as well such as phone calls, letters and e-mails. You can find the details of reporting channels at CU SharePoint or CU's promotion materials in email and working places in all locations. Please make sure that the reporting information is sufficient for company to take investigation and the reporting incident must be based on actual facts Unless it may lead to punishment as company's standards.

[Audio] Compliance Unit would like to thank you all of you for attending the training on Role of Management and Gifts and Hospitality and have always support CU's activities very well. Finally, I would like to ask you to register and finish understanding test under the VDO clip, there are 10 understanding questions in which you must answer all questions correctly with the full scores. In case that you do not get a full score on the test, please scan the QR code to take the new test until you get full 10 scores and to save the data in the system. Please click "Submit" button to complete this training. If you have any questions or suggestions, please always feel free to inform that concern to Compliance Unit. That's all for today, thank you so much..

Quiz. Have 5 questions and must past 100%. Question Yes No 1.Management should reward the employees who have good ethical act (Yes/No). O 2.Management must approve the proposal or activities by reference to the scope and limitations in Authorization Manual (Yes/No). O 3.Management do not have duty to communicate the company policies to their subordinate (Yes/No). O 4. Management must ensure the non-retaliation of employees in their department (Yes/No). O 5. TMT expects management to work with transparency and do not provide or receive bribes (Yes/No). O.

Policies No. Question Type Yes No Gifts & Hospitality 24 C Employees can provid e Gifts & Hospitality to Government Official but the value must not higher than 3,000 baht per head per occasion and must not give to them more than 4 times per fiscal year, (Yes/No) 1A P 26 C Employees can give cash or equivalent items to third party in order to congratulate them in any occasion, (Yes/No) 2A P 28 O Employees can provide Gifts to Government Official and request post-approval, (Yes/No) 3A P 29 O Employees can receive gifts and hospitality which the value is higher than 5,000 baht without approval from the GM, (Yes/No) 3B P 30 O Employees can buy perishable gifts like flower baskets (within the limits specified in the policy) by themselves and request for reimbursement , (Yes/No) 4A P.