Management Approach

PTT Board of Directors prioritizes conducting businesses on the foundation of honesty, fair and traceability, as well as anti-corruption and anti-bribery. Therefore, PTT is committed in driving the business according to good corporate governance, Ethical Standard and Code of Business Ethics, and PTT Group's Sustainability Management Framework. In order to continuously improve efficiency. PTT Board of Directors is well aware that transparent and ethical business establishes trust for all groups of stakeholders, and facilitates corporate sustainable development.

PTT has in place a grievance policy to receive, address and resolve grievances in a timely manner, ensuring fairness and transparency as well as confidentiality of the information provider' grievance provider. Employees who report a grievance can track its status visa the employee relations grievance system. The communication channels through which external parties can submit regarding violations of the Code of Business Ethics including the Customer Relations Center, PTT Call Center, Corporate Communications Function, the Office of the President and Corporate Secretary and the Investor Relations.

Additionally, PTT has established a channel for “Whistleblowing against Corruption’ at www.pttplc.com and through "PTT Voice" (pttvoid@pttplc.com) as an mean for stakeholders to communicate if they witness or encounter any corruption-related behaviors in the organization. Reported information are directed to the responsible functions to process per established procedures. PTT has measures regarding complaints, whistleblowing on corruption and non-compliance of the laws. The measures enable formulation of appropriate criteria and practice regarding complaints, whistleblowing and non-compliance against laws or corporate rules alike. This ensures transparency and streamlined approach throughout the entire organization. PTT has also implemented measures to protect any complainant or whistleblowers who provided relevant information and evidence on the matter.

• PTT Anti-Corruption Policy
• PTT Supplier Sustainable Code of Conduct
• PTT Corporate Governance Ethical Standards and Code of Business Ethics Handbook Revised Version 4.2

Code of Conduct

The Corporate Governance, Ethical Standards and Code of Business Ethics Handbook, or CG Handbook, is a set of guidelines defining the standards of good business ethics to which PTT's employees are required to adhere. The CG Handbook covers good corporate governance practices and provides clear explanations of shareholders' rights, responsibility to stakeholders, and transparent disclosure of information and responsibilities of the Board of Directors, including guidelines for the Business Code of Conduct and Ethics. It extends to cover legal compliance; international human rights principles; political contributions; interests and conflicts of interest; confidentiality and use of insider information; treatment of customers and consumers; treatment of creditors; procurement and treatment of suppliers; community, social and environmental responsibility; treatment of employees; treatment of creditors; internal controls and auditing; receiving and offering customary gifts, assets, or other benefits; safety, health and the environment; intellectual property and use of information technology; and grievances related to corporate governance. Currently, PTT revised the CG Handbook to include an additional requirement on insider trading, money-laundering, and gift giving in compliance with the No Gift Policy. All Board of Directors, executives and employees must sign an acknowledgment of the CG Handbook in order to demonstrate a commitment to embracing and applying best practices. In this way, the CG Handbook acts as a disciplinary guideline all employees strictly adhere.

The Corporate Governance Committee is tasked with the responsibility to grant policies and management approach regarding corporate governance, operational risk management and internal control, legal and regulatory compliance, anti-corruption and bribery, sustainable management, as well as society, community, and environmental management. This ensures that PTT has an active campaigning to promote the importance of adhering to good governance principles. PTT organizes for Governance Risk and Compliance Management Committee (GRCMC), of which senior executive vice president serves as the chair. The said committee serves as the focal point in PTT’s Anti-Corruption Operation Center (ACOC) in State Enterprises, which responses to the state’s policy and working directions. The Center works to ensure integrated approach in instilling values, preventing and tackling corruption within PTT. Good Governance and Corporate Ethics Department establishes PTT Annual Action Plan for Good Governance and Anti-Corruption. This action plan has been approved by Corporate Governance Committee and PTT Board of Directors. Relevant functions then take actions according to the plan and policy. The functions also organize various forms of activities to foster responsibility per good governance principles to the Board, Management, employees and relevant personnel. These activities comprise GRC Camp, PTT Group CG Day, CG Tips communication, CG Do & Don’t, CG Lesson Learned through E-Mail on “CG Intranet” available in PTT Intranet. There is also “CG Channel” available on PTT Workplace website. Learning through CG E-Learning system is also available for employees in all areas as a channel to thoroughly study good governance principles and code of ethics on their own. E-Learning uses a number of simulations to foster awareness on the importance of ethics in businesses. Employees can apply what they have learn in their routine practice, as appropriate. There are also evaluations at the end of each lesson. Furthermore, ethics in business is recognizes as one of the employees’ competency, affecting their career advancement and annual performance evaluation.

Anti-Corruption

PTT has implemented PTT Anti-Corruption, as well as No Gift Policy in all season. PTT develops systems, mechanisms and measures to govern personnel’s duties. PTT also creates atmosphere and control environment to emphasize on morals and ethics at works, per good governance principles; promote refutation against all forms of corruptions, direct and indirect. PTT focuses on raising awareness tangibly and continuously at all levels, from the Board, Management, employees, and relevant personnel. PTT Anti-Corruption policy’s scope addresses the following definitions. 

• Fraud:

  refers to any actions taken for benefits through illegal means, either for themselves or others. The actions include the following. 

  • Asset Misappropriation
  • Financial Statement Fraud
  • Corruption comprises refer to the act of giving, proposing/committing/promising to give, receive or request for payments, assets or other benefit inappropriately. Such action maybe towards the state officials, private personnel, or relevant personnel, whether directly or indirectly. The action resulted in aforementioned individuals taking actions beyond their duty, or neglecting it – in order to attain or preserve inappropriate business or other benefits 

• PTT Personnel:

  refers to the PTT’s Board, Management and all level of employees

• PTT-Related Personnel:

  refers to workers, representatives, subsidiaries, or any personnel working for or on behalf of PTT, whether they have the authority in this capacity or not.

  For the second consecutive year, PTT is a member of Private Sector Collective Action against Corruption (CAC) having had membership since 2014. This affirms that PTT has been acknowledged by external functions for the capacity in transparent and traceable business operations; committing to fight against all forms of corruptions.

  Furthermore, PTT is a politically neutral organization. It is not PTT's policy to provide financial support to any political party. PTT is transparent in providing charitable donations and sponsorships, as stipulated in its anti-corruption measures covering the formulation and review of anti-corruption policies, internal audit reporting, relevant performance reviews, corruption risk assessments and appropriate reviews of anti-corruption measures. PTT actively communicates with stakeholder groups in order to prevent potential incidents of corruption in the organization and to build trust amongst external parties who can be confident in the organization's reputation for transparency.

Transparency

PTT maintains transparency in every aspect of its operations. Regarding financial aspects, PTT reports its financial performance in the Annual Report and Annual Information Registration Statement (Form 56-1), which is required to be submitted to the Securities and Exchange Commission (SEC) on a yearly basis. In addition, to evaluate employee compensation, PTT defines the compensation criteria for employees, top management and the Board of Directors, which are published in the Annual Report. For internal control, PTT conducts Control Self-Assessment (CSA). There is internal control assessment integrated with comprehensive risk assessment, addressing compliance to laws, regulations, rules, operational risks, and GRC Assessment-related risks in every process and support process. In addition, performance is reported through the Sustainability Report and Annual Report, which are verified by an external organization. These practices reflect PTT's good corporate governance and transparency.

PTT requests that all employees disclose any conflict of interests, whether their own, their relatives, or any related individuals, that may contract PTT’s interests This is reported through an annual conflict of interest report, and upon an incidence. Furthermore, Good Governance and Corporate Ethics Function consolidates information and prepare a summary report on conflicts of interests for the highest Management of each business line. The report is also presented to Good Governance Committee annually. Additionally, the information serves as a baseline information when there are grievances on conflicts of interests at work. It also aids supervisors in appropriate task allocation to employees, according to principles of transparency, business ethics on conflicts of interest and stakeholders.

Additionally, PTT has also deployed technology to aid in monitoring transparency and conflict of interests in the work process since 2014. PTT develops Continuous Control Monitoring and Auditing System (CCMS), which will report if findings meets criteria on suppliers and employees’ relations. The system summarize for supervisor for verification and development of appropriate next steps. This Monitoring and Auditing system is reviewed and improved annually. In 2019, there have been further development per users’ feedback, as follows.

• Shift frequency of monitoring from every six months to quarterly, to improve timeliness; supervisors can promptly make consideration and set management approach
• Merge identification information as founded from CCMS with reported information of employees in the conflict of interests systems, so that information review is quick and accurate 

Performance

Progress 

Code of Conduct

Effective communication on good governance principles and business ethics results in increased employee understanding on CG and their ability to apply such principles into their work. Given this, PTT would be able to operate business ethically, under a strong governance structure, and reduce risks from violations of business ethics.

1. Training about Business Code of Conduct and Ethic including "Good Governance Knowledge" Course for all employees during orientation. There is a CG E-learning system deployed as a learning media on the topics of good governance, business ethics, and how one can take anti-corruption measures. This is available for all employees at all sites. The course uses stimulated scenarios to help employees learn, gain greater awareness. Employees are able to apply their learning in practical situations as appropriate. There are also a test to evaluate employees’ understanding upon completion of the program. 

2. Communicate at meetings and various seminars, such as Town Hall, Leadership Development Program Reunion, Chansin Camp, and GRC talks to functions in different regions. Such communication creates awareness for management and all employees on good governance, risk management, and compliance to the laws, rules and regulations. The topic also emphasizes on adherence to CG principles, as well as anti-corruption measures. 

3. GRC Camp is ongoing for the 6^th consecutive year to develop PTT employee representatives selected to be the business line’s GRC Agent. They communicates and share knowledge on good governance, risk management, compliance to rules, regulations and laws, to colleagues. They apply knowledge for routine work as appropriate. GRC Camp comprises of seminars and workshops to enhance understanding in GRC. There are also recreational activities, which are embedded information for CG, Risk & Internal Control, Compliance, and Culture. These activities are arranged in the form of activity bases.

4. PTT Group CG Day is ongoing for the 11^th consecutive year, reflective of PTT’s priority to align corporate governance approach of PTT Group’s own subsidiaries. PTT appoints Good Governance Committee to achieve this. PTT Group has a target to elevate the standard of good governance in PTT Group to be at the same level. Similarly, the target includes aligned development of work plan, proactive public relations through “PTT Group CG Day” continuously. Such activities serve to campaign, promote and disseminate good governance of PTT Group’s flagship companies, such as PTT, PTTEP, GC, TOP, IRPC, GPSC and OR to stakeholders in all sectors. Stakeholder comprise Stock Exchange of Thailand (SET), Securities and Exchange Commission (SEC), Thai Institute of Directors (IOD), Office of Ombudsman, suppliers, the Board, management, and PTT Group employees. 

Anti-Corruption

Every PTT employee can become a whistleblower (person notifying any unusual ongoing) to ensure transparency, good governance, and corporate sustainability. In 2014, PTT announces PTT’s and PTT Group’s Anti-Corruption Policy to be implemented across PTT for Management and employees for acknowledgement and to uphold as standard of practice. The policy is disseminate to all stakeholder groups for their acknowledgement and practice. PTT also takes on Certification Process for Private Sector Collective Action Against Corruption (CAC) to certify PTT’s status as member of CAC. The process consists of “Self-Evaluation Tool for Countering Bribery” to assess the strengths, comprehensiveness and effectiveness of PTT’s Anti-Corruption policy and measures. PTT was certified for the second consecutive year in 2018. Presently, PTT is committed to inviting and promoting business partners, such as suppliers, sales representatives, to be part of the coalition, in order to remove corruption risks in its entity from the supply chain.

• In 2015, PTT was assessed according to Anti-Corruption Progress Indicator from Security and Exchange Commissions (SEC) and Thaipat Institute, and was rated Level 5: Extended (the highest level). This demonstrates PTT’s actions according to Anti-Corruption Policy, covering all PTT Group affiliates. PTT also drives for business partners, consultants, middlemen or representatives in businesses, as well as suppliers, to follow the policy and practice for zero tolerance against all forms of corruption.
  
  
• In 2016, PTT was ranked by Transparency International to be one of the most transparent companies at 22^nd out of 100 companies in emerging market, comprises 15 countries. The result was considered from various information, such as anti-corruption policies, corporate disclosure, and venture companies, PTT Group’s subsidiaries, as well as financial information of companies active abroad.
  
  
• In 2017, PTT received Transparency Appreciation Award, which is the target award for PTT’s 3-year aspiration under the vision, Pride & Treasure of Thailand. PTT receives the award as “State enterprise with excellent development towards ethical and transparent operations” at Excellence Level. There were 2 awards in total, comprises Integrity Culture and Work Integrity.
  
  
• In 2018, PTT was awarded Transparent Company Award fro National Anti-Corruption Commission (NACC) and Excellent Ethics Award from Thailand’s Chamber Commerce’s Honorary Ethical Award. This was the first year PTT received the two aforementioned awards, a great honor to PTT; as PTT’s operations have uphold transparency and honesty as the core principle. It was this stance that enables PTT to be trusted by all groups of stakeholders. Furthermore, PTT maintains the performance in the Government’s Integrity & Transparency Assessment (ITA), by National Anti-Corruption Commission (NACC) and was ranked at a very high level for the fifth consecutive year.
  
  
• In 2019, PTT was awarded Transparent Company Award from National Anti-Corruption Commission (NACC) for the second consecutive year. This demonstrates PTT’s commitment in operating with transparency, traceability and consideration to stakeholders of all sectors. Furthermore, PTT maintains the performance in Integrity & Transparency Assessment (ITA) in operations of governmental departments from National Anti-Corruption Commission (NACC)at high level throughout the years. Assessment against criteria in 2019 reveals the results to be at Level A.

Transparency

PTT requests all employees to disclose a conflict of interest report annually and notify suspected conflicts of interest to their supervisors. If a conflict is found, supervisors would develop corrective action plans, for example, by defining temporary measures or rotating employees in order to reduce potential risks.

Percentage of employees completing their conflicts of interest reports