Anti-Bribery and Corruption Policy

ABOUT THE ANTI-BRIBERY AND CORRUPTION POLICY

1. YKK (Thailand) Co., Ltd. (the “Company”) is committed to conducting business in an honest, transparent, and just manner while taking all stakeholders into consideration.
2. As such, to ensure that the Company has in place an appropriate policy outlining responsibilities and appropriate operating procedures to prevent corruption and bribery, as well as to ensure that all business decisions which may be at risk of corruption and bribery are considered and managed with proper deliberation, the Company has established this Anti-Bribery and Corruption Policy (“Policy”) to provide clear guidelines of conduct for all employees.
3. The Company and its employees must not engage in or accept bribery and corruption in any form, whether directly or indirectly. This Policy applies to all business of the Company. In addition, the Company shall ensure regular assessments of compliance with this Policy as well as conduct regular reviews of operating rules and procedures, to ensure alignment with changes in the business or relevant laws and regulations.

APPLICABILITY

1. This Policy and all relevant applicable laws and regulations shall apply to and be complied by all employees and parties acting on behalf of the Company or working for the Company, including without limitations to contractor, sub-contractor, agents, consultants, suppliers, vendors, service providers, and any associated third parties.

WHAT IS BRIBERY AND CORRUPTION?

1. Bribery is the giving, offering, promising to give, requesting, or accepting money, assets, or any other benefits to influence the public official, state agency, private entity, or any person to act improperly in the performance of their functions or to reward them for acting improperly, or where the recipient would act improperly by accepting the benefit.
2. Benefit includes, but is not limited to, gifts, hospitality, fees, services, discounts, promise to award a business deal or anything else of value.
   1. Examples of bribery:
      • Offering a potential customer tickets to a sporting event, but only if they agree to do business with the Company.
      • Giving a luxurious hamper to the public official with the intention that the permit the Company applies for will be approved.
3. Corruption is a form of dishonest or fraudulent conduct done by a person entrusted with a position of authority.
   1. Example of corruption: A public official wrongfully using his position to threaten or request certain business benefits or decisions from the Company.
4. Public official means a person holding a political office, a government official or a local government officer who holds a full-time position or receives a regular salary, employees or staff of state enterprises or state agencies, local administrators and council members who do not hold a political office, employees (as defined in the Local Administration Act), as well as committee members, subcommittee members, employees of the state or state enterprises or state agencies, and any individual or group of individuals with governing authority or acting on behalf of someone with such authority to undertake a particular action by law, regardless of whether the position was gained through the government bureaucratic system, a state enterprise, or other state entity. This also includes officials of foreign states or officials of international organization, as specified in Section 4 of the Organic Act on Supplementing the Constitution Relating to the Prevention and Suppression of Corruption, B.E. 2561.

OUR COMMITMENT

1. The Company shall commit to the following :-
   1. must abide by this Policy ensuring that the Company has no part in corruption or bribery, whether directly or indirectly;
   2. act honestly, fairly, openly in our business conduct and ensuring the Company is free from any influence of bribery or corruption;
   3. shall provide safe channels of communication to allow employees of the Company and all stakeholders to request advice, report wrongdoing, make suggestions, or submit grievances related to corruption and bribery. The Company shall ensure fairness and protection measures are afforded to any person filing a complaint or providing cooperation in reporting corruption and bribery, in line with the guidelines set out in the Company’s Whistleblowing Policy;
   4. uphold, comply and adhere to all applicable international and national laws and regulations relevant to anti-bribery and corruption;
   5. to implement and enforce internal regulations, policies and system to prevent the risk of bribery and corruption; and
   6. to monitor and ensure compliance of this Policy at all times.

RED FLAGS

1. The following is a list of possible red flags that may indicate the existence of bribery or corruption. This list is not exhaustive and it is only for illustrative purposes only.
   1. Any employee becomes aware that a third party engage in, or has been accused of engaging in, improper business practices;
   2. Any employee learns that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;
   3. A third party insists on receiving a commission or fee payment before committing to sign up to a contract with the Company, or carrying out a government function or processes for the Company;
   4. A third party requests payment in cash and/or reuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
   5. A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
   6. A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
   7. A third party requests to provide employment or some other advantage to a friend or relative;
   8. An employee of the Company receives an invoice from a third party that appears to be non-standard or customized;
   9. A third party insists on the use of side letters or refuses to put terms agreed in writing; and
   10. Any employee notices that the Company has been invoiced for a commission or fee payment that appears large given the service stated to have been provided.

RESPONSIBILITIES OF EMPLOYEES

1. To achieve our commitment, the Company’s employees shall strictly adhere to this Policy and any related policies such as but not limited to the Company’s Gift-Giving & Receiving Policy.
2. Employees of the Company must notify their supervisor or submit a whistleblowing report as soon as possible if they believe or suspect that a conflict with this Policy has occurred or may occur in the future or if the employee becomes aware of any of the matters stated in clause 5 of this Policy.