PTT Anti-Fraud and Corruption Policy
PTT Supplier Sustainable Code of Conduct
PTT Corporate Governance, Ethical Standards and Code of Business Ethics Handbook

PTT Corporate Governance, Ethical Standards and Code of Business Ethics Handbook, or CG Handbook, is an ethical practice guideline for good business practices, to which PTT personnel are required to strictly adhere as a framework in the business. The handbook overarches corporate governance practices, roles and responsibilities of the Board of Directors as an organizational leading team that sustainably contributes to the business. The determination of objectives and goals is oriented to sustainability, efficient promotion of the Board of Directors, recruitment and development of executive talents and personnel management, promotion of innovations and sustainable business operations. Appropriate risk management and internal control systems must be in place. It also includes the maintenance of  financial credibility, and complete and comprehensive disclosure of information, promotion of participation and communications with shareholders, including guidelines on ethics and business ethics. It describes the regulatory compliance and respect for universal human rights, anti-money laundering, political neutrality, conflict of interest and connected transactions, confidentiality, data privacy, insider information, customer and consumer treatment, competitor treatment, procurement and partner treatment, responsibility toward society, community and the environment as a whole, employee treatment, creditor treatment, internal control and internal audit, receiving and giving gifts, reception and other benefits, security, safety, occupational health and the environment, intellectual property, IT usage, responsible communications, complaints and violation of business code of conduct, and compliance with the no gift policy whereby stakeholders of all sectors are requested to refrain from giving gifts to personnel of PTT no matter the occasion. In this regard, directors, executives, and employees of all levels shall sign for acknowledgement and comply with the CG Handbook to demonstrate their commitments to the adoption of the best practices. The CG Handbook is thus comparable to a statute that requires strict adherence and compliance from all directors, executives, and employees. 

The Corporate Governance and Sustainability Committee assumes a responsibility to deliver policies and guidelines for good corporate governance, operational risk management and internal control, compliance with applicable laws, rules, and organizational regulations, anti-fraud and corruption, sustainability management, and social, community, and environmental care so that PTT can promote and stringently prioritize performing duties in accordance with the corporate governance principles. PTT has established a Governance Risk and Compliance Management Committee (GRCMC), chaired by Executive Vice President, with the Compliance and Governance Promotion Department responsible for defining annual PTT corporate governance and anti-corruption plans. The drafted plans shall be approved by the Corporate Governance and Sustainability Committee and PTT Board of Directors for further adoption in related functions and policy-based implementations through activities of several forms and campaigns to build responsibility awareness under the corporate governance principles among directors, executives, employees, and related parties; for example, GRC Camp, PTT Group CG Day, communications of CG Tips, CG Do & Don’t, GRC PODCAST, GRC Short VDO, GRC Lesson Learned via internal email, and the “CG Internet” system, as well as different training courses including COSO - Fraud Risk Management, Operation Risk and Internal Control Workshop, Criteria and Qualification Examination of Persons Engaging in a Business with PTT, enterprise-wide communications about the 5^th edition of CG Handbook. Besides, it also incorporates the compliance with the CG Handbook and Business Code of Conduct in the annual performance evaluation in part of Behavior KPIs (Corporate Values).

Business Code of Conduct

Regular communications and emphasis on the corporate governance principles and business code of conduct result in employees being equipped with enhanced knowledge and understanding about the principles and able to effectively apply them to their daily tasks. This routine of PTT is to confirm that the Company shall fairly operate its business with good corporate governance in mind while reducing risks of ethical violations through key activities as follows:

1. Training on ethics and business code of conduct, e.g., training on and communications about good corporate governance and anti-corruption topics, as well as other training courses, for executives and employees. The training includes COSO-Fraud Risk Management, Operation Risk and Internal Control Workshop, Criteria and Qualification Examination of Persons Engaging in a Business with PTT, Corporate Governance and Anti-Corruption during orientation, TBU Pre-Career to cascade knowledge and shape correct and adequate practices on the basis of good corporate governance, business ethics, and business code of conduct, anti-fraud and corruptions.
2. Communication with executives and employees of 13 functions throughout PTT about the 5th edition of CG Handbook to strengthen their understanding about the contents of the new CG Handbook while also highlighting corporate governance practices, ethical standards, and business code of conduct of PTT, anti corruption-based measures of PTT, and communications about internal control in line with the COSO guidelines, which is to correctly and adequately guide work performance on the basis of good practices.
3. Communications through different channels and seminars, e.g., PTT directors and executives’ interview clips, etc., in order to raise awareness among executives and all employees about the implementation of good corporate governance, risk management, and monitoring of regulatory compliance with emphasis on expected behaviors based on the CG Handbook and anti-corruption measures.
4. GRC Camp, which has been carried out for 9 years consecutively to emphasize and strengthen understanding about the appropriate application of corporate governance principles, risk management, regulatory compliance at work for executives and employees. In 2022, the activity was conducted in a hybrid setting with high-level executives participating in knowledge-sharing discussions and exchanging their experience about their specific GRC implementation under the topic of  “Trust” & “Inspired” by Digital Integrity so that employees can further apply knowledge to work and jointly create value as a company that adheres to good governance, promoting the integrity culture of PTT and steering PTT business, both domestically and internationally, together in a sustainable manner.
5. PTT Group CG Day, which has been conducted for 14 years consecutively. PTT places importance on PTT corporate governance to comply with PTT management guidelines by appointing a Corporate Governance Committee, which is aimed at raising corporate governance standards among its affiliates to ensure that they are at the similar level. Moreover, it has laid operational plans and proactive public communication guidelines through the "PTT Group CG Day" activity in order to campaign, promote, and disseminate the good corporate governance practices of its affiliates, including PTT, PTTEP, GC, TOP, IRPC, GPSC and OR, to all stakeholders such as NACC Office, Securities and Exchange Commission, Stock Exchange of Thailand, Thai Institute of Directors Association, Anti-Corruption Foundation, Office of the Auditor General of Thailand, as well as PTT Group’s partners, boards of directors, executives, employees, etc.

Compliance System

PTT’s compliance system and corporate governance practices is externally assessed by Thai Institute of Director Association through Corporate Governance Report of Thai Listed Companies (CGR). The scoring and assessment criteria of CGR were developed by referring to the Organization for Economic Cooperation and Development (OECD) Principles of Corporate Governance and Thailand’s Corporate Governance Code for Listed Companies. CGR Evaluation methodology assesses on five governance categories:

1. Rights of Shareholders
2. Equitable Treatment of Shareholders
3. Role of Stakeholders; including internal compliance and control program to prevent and monitor a corruption risk
4. Disclosure & Transparency; including the quality of a statement confirming the company’s full compliance
5. Board Responsibilities; including whether the company have a compliance unit

Key Indicators

Employee understanding of CG (Percentage)

Feedback on the implementation of corporate governance and anti-corruption policies (Percentage)

Ethics for Practices with Business Competitors 

Business competitors are third parties with whom PTT competes liberally, adopting a capitalist approach. Competition shall be fair, without information distortion, deception, or other malicious means of competition. PTT has defined guidelines for practices with business competitors in its Corporate Governance, Ethical Standards and Code of Business Ethics handbook. However, in 2022, there was no disputes between PTT and its business competitors.

Complaint and Grievance^GRI2-26

Complaint and grievance mechanisms 

PTT has a grievance and complaint management policy in place to address and solve complaints within a clear and adequate time frame, in a fair and transparent manner, taking into account confidentiality and data protection of each lodgment, to ensure safety of complainants and witnesses. The complainants can track the status of their complaints through the provided complaint and labor relation system. Additionally, PTT arranged a channel for complaints regarding violations of Business Code of Conduct for third parties, namely Customer Relations Center 1365, Corporate Communications Function, the Office of the President and Corporate Secretary, Corporate Governance Regulation and Promotion Department and the Investor Relations Department.

PTT also designated a “Whistleblowing” channel on www.pttplc.com and “PTT Voice” (pttvoice@pttplc.com), which serves as a communication channel for stakeholders if they encounter any violation or corruption practice within the organization. This information will be delivered to the responsible department for further consideration and actions using the procedures in place. PTT has reviewed and improved PTT Public Company Limited's Regulations on Complaints and Whistleblowing, Malpractice, Misconduct, and Statutory Non-compliance 2022 to determine whistleblowing criteria and guidelines, providing clear guides for oversight and transparent, aligned investigation throughout the organization. Furthermore, there are protection and fair treatment measures for complainants and informants.

PTT Public Company Limited's Regulations on Complaints and
Whistleblowing,Malpractice, Misconduct, and Statutory Non-compliance 2022

In 2022, the Company received a total of 27 PTT-related complaints through the whistleblowing channel. Once completing the complaint management procedures, it was found that 25 complaints of which are false while 2 of them are currently under investigation and examination. If wrongdoing is found, disciplinary action or legal action will be taken, as well as informing suggestions to related agencies to consider improving the process or having measures to prevent a recurrence.

Complaints of unfair treatment^{GRI 205-1, GRI 205-2, GRI 205-3, GRI 406-1} (Cases)

In addition, there was a total of one case of disciplinary misconduct – violations of Business Code of Conduct, being found after an examination process/ disciplinary investigation process. This case was caused by a violation, avoidance, non-compliance with, or ignorance of relevant policies, laws, rules, regulations, requirements, orders, as well as lawful orders given by the superiors, whether or not it causes damage to PTT. In this regard, PTT shall investigate, examine, and banish punishment upon the violating parties based on the personnel management regulations.

Anti-Fraud and Corruption^GRI205-3

Objectives/Targets

PTT is committed to conducting its business with integrity, transparency, fairness and in accordance with the corporate governance principles while complying with applicable laws, rules, and regulations, both domestically and internationally, and not tolerating fraud and corruption of all forms, whether directly or indirectly. Therefore,  PTT requires its directors, executives, employees, contractors, as well as other persons working for the benefits of PTT, or on behalf of PTT, to strictly comply with PTT's Anti-Fraud and Corruption Policy. 

The Corporate Governance and Sustainability Committee (CGSC) assumes responsibilities to deliver policies and guidelines for good corporate governance, operational risk management and internal control, compliance with laws, rules, organizational regulations, anti-fraud and corruption, and receiving complaints and whistleblowing, including supervision and follow up on operations to ensure that the management has placed their attention to anti-fraud and corruption, and strictly complies with anti-fraud and corruption measures. PTT established a Governance Risk and Compliance Management Committee (GRCMC), chaired by Executive Vice President and serving as a state enterprise anti-corruption center of PTT, which reflects government policies and directions to form a connection and integration, instilling the spirits of prevention and working against corruption, with the Corporate Governance and Promotion Department responsible for formulating annual corporate governance and anti-corruption action plans for PTT. The plans were approved by the Corporate Governance Committee and PTT’s Board of Directors for further implementations, practices, and operations.

Management Approach

PTT announces PTT's Anti-Fraud and Corruption Policy and No Gift Policy. It has developed systems, mechanisms, and measures to supervise the performance of personnel while also creating an atmosphere and ensuring the environment of business integrity and ethics, in accordance with the corporate governance principles, and not tolerating corruptions of all forms, whether directly or indirectly. PTT emphasizes on concretely raising awareness of employees at all levels, from directors, executives, employees to related persons and continues to operate PTT's Anti-Fraud and Corruption Policy, which covers the following areas:

• Corruption (Fraud) refers to any action to seek unlawful benefits for oneself or others. This includes actions such as: 
  

  • Asset misappropriation: To possess property that belongs to others, or which is also owned by others, and to fraudulently misappropriate that property for one's own or for a third person.

  • Embezzlement: To fraudulently deceive others by displaying false statements or concealing facts that should have been disclosed. By such embezzlement, one can obtain property from the deceived person or a third party, or cause the deceived person or any third party to make, withdraw, or destroy any rights document.

  • Financial statement fraud: To mislead accounting amounts by exploiting gaps of the accounting principles and alternative measurement and accounting disclosures to modify the information in the financial statements as desired for a wrongful purpose.

  • Corruption: To demand, accept or agree to accept, give, ask to give, or offer/pledge/promise to give assets or other benefits to government officials, government agency, officials of private agencies, private agencies so that such persons or entities exercise their existing powers to act, not to act, to expedite or delay any action, which conflicts with their powers and duties and is to obtain unlawful benefits, whether for oneself or others, or maintain business or any other benefits that are inappropriate for business, except for the cases where laws, customs, and traditions allow to do so.
• PTT personnel refers to directors, executives and employees at all levels of PTT.
• Persons related to PTT refers to employees, representatives, consultants, affiliates or any person acting for or on behalf of PTT, whether or not they have the authority to do so.

In addition, PTT is a politically neutral organization. There is no policy to support any political party, whether financially or non-financially. It is transparent with respect to charitable donation and sponsorship, as specified in anti-fraud and corruption measures, namely defining and reviewing anti-fraud and corruption policies, assessing related performance results, risk management and internal control process review, to adequately prevent fraud and corruptions with consistent communications to different groups of stakeholders, including employees and suppliers, through annual supplier seminars. This is to prevent potential corruptions within the organization and to strengthen trust of third parties in the transparency of PTT’s operations.

PTT strives to upgrade itself to become a trusted company in order to support PTT's operations and business expansion that requires rapid response to changes while also adhering to transparent operations under good corporate governance, risk management, anti-fraud and corruption, adequate internal control, and compliance with laws and regulations (Governance Risk and Compliance: GRC). Therefore, a third party screening program was provided to establish standards for assessing qualifications of the parties engaging in transactions with PTT to ensure that they are concise and appropriate with an effective risk management and internal control system in place. In 2022 , the Company were open for opinions from relevant entities to drive the auditing process of third-party transaction transparency to cover all processes that involve PTT and implemented criteria and reviews of qualifications of those engaging in transactions with PTT and also started to develop a database system to audit transparency, serving as a center for information necessary for risk assessment. This will help such operations be efficient, convenient and timely.

PTT has been certified as a member of the Thai Private Sector Collective Action against Corruption (CAC) for the third consecutive years, with 2014 being the first year it became a CAC member. This confirms that PTT has been recognized by an external agency for its potential in operating a transparent and verifiable business with a commitment to rejecting corruptions of all forms. At present, PTT aims to encourage its business partners, suppliers and distributors, etc., to participate in this certification program in order to eliminate potential risks of corruptions throughout the supply chain.

Fraud and corruption risk assessment

PTT has prepared a fraud and corruption risk management handbook since 2017, which was approved by PTT Management Committee (PTTMC), and requires annual reviews to ensure that it is in line with the business and related criteria. This handbook is to supplement the fraud and corruption risk assessment at the process level in order to reduce the likelihood and severity of impacts possibly caused to the Company from such risks of fraud and corruption, and corresponds to internal control measures suitable for juristic persons to prevent state official bribery prescribed by the NACC according to Section 176 of the Organic Act on Anti-Corruption, B.E. 2564 (A.D. 2021), and best practices according to the PTT's Anti-Fraud and Corruption Policy in part of fraud and corruption risk assessment in workplace so that internal control measures can be suitably planned.

Since 2017, PTT has conducted fraud and corruption risk assessments, and in 2019, it scoped the assessments to cover the entire organization through the GRC-guided internal control assessment.

In 2022, a fraud and corruption risk assessment was conducted involving department-level functions and direct subordinates totaling 145 departments. The assessment started from defining processes at the department or the direct subordinate level, divided into Core Process, based on roles and responsibilities, and Support Process, which is required from all functions.

It was found that the control score based on the Anti-Fraud and Corruption Policy (Fraud Risk) was equivalent to 3.99 (out of 4). There are 4 processes prone to very high risks, namely corporate governance and organization leadership, implementation of business law, legal administration and accounting management. Overall, the score demonstrates adequate control while internal control measures are always observed.

Training, communications about anti-fraud and corruption

PTT places importance on enhancing knowledge and understanding of directors, executives and employees on anti-fraud and corruption through different training courses such as training and communications on good corporate governance and anti-corruption topics, to name a few, for executives and employees, e.g., COSO - Fraud Risk Management course, Qualification Criteria and Examination for Transactional Relationship with PTT course, and the Good Corporate Governance and Anti-Fraud and Corruption course, during orientation sessions or for the TBU Pre-Career, etc. This is to suitably cascade knowledge and shape the practices related to good corporate governance, ethics and code of conduct in business operations, as well as best practices against fraud and corruption.

PTT provides e-learning courses to encourage employees to study, understand the corporate governance principles, business ethics and best practices in anti-fraud and corruption so that they can adopt them for their daily practices. There are three courses in total, namely 1) CG and Anti-Fraud and Corruption e-Learning, the content of which is consistent with the fifth version of CG Handbook, covering the required good practices, e.g., prevention of the use of insider information, prevention of conflicts of interest and anti-fraud and corruption, etc.; 2 ) Conflict of Interest course; and 3) Introduction to the Organic Act on the Prevention and Suppression of Corruption, B.E. 2561 (A.D. 2018). In 2022, PTT required all employees to study and set them as one of corporate KPIs, in part of the non-compliance section. There were 95.16%, 93.93% and 93.90% of employees participating in the training, respectively.

In addition, all directors, executives and employees are required to study, understand and acknowledge the CG Handbook, part of which is the Anti-fraud and Corruption Policy, through signing. In 2022, 100% of directors, executives and employees signed and acknowledged the CG Handbook.

Acknowledgment of CG Handbook  (Percentage)

KPIs, Performance and Awards