Code of Conduct
Commitment
To reinforce the highest ethical business practices by focusing on cultivating an ethical culture, building employee awareness and understanding, and implementing an effective internal control system to gain stakeholder trust.
Materiality
The Bank is committed to operating its business with transparency, ethics and responsibility for all stakeholders in order to maintain its longstanding reputation and mitigate risks in doing business while building credibility of the Bank among all groups of stakeholders. We encourage all employees to observe high standards of ethics and comply with the Code of Conduct and Business Ethics, the Code of Conduct for Employees, and other related policies and practices of the Bank, as well as applicable laws. We emphasize awareness-building on the importance of performing duties with integrity, transparency and accountability as well as promoting effective governance by assigning key responsibilities under the “three lines of defense” principle to the Risk Management Division, Compliance Division and Audit and Control Division. Operating independently from the Bank’s Business Units, these divisions supervise the Bank’s risk management an ensure compliance with laws and regulations, and policies and practices of the Bank. Furthermore, we provide whistleblowing and complaint channels with clear, transparent and fair management processes for cases related to violation of, or non-compliance with, policies, regulations, the Bank’s Code of Conduct and Business Ethics, corruption and illegal actions.
Management Approach
Code of Conduct and Business Ethics
We believe that the code of conduct and business ethics is fundamental to conducting business for sustainable organizations. Thus, we encourage all employees to be aware of and adhere to the Bank’s Code of Conduct and Business Ethics. All executives
and employees have signed an acknowledgement of the Code of Conduct and Business Ethics and have the obligation to comply with it as well as other relevant regulations as stated in their employment contracts. Furthermore, they are also required to
attend a mandatory training program on the Code of Conduct and Business Ethics to ensure their awareness, understanding and strict compliance with the Code of Conduct and Business Ethics. In addition, we also require all of our subsidiaries to adopt the Code of Conduct and Business Ethics and adapt it as appropriate in accordance with the context of each company.
Code of Conduct for Employees
We encourage all employees, executives and directors to understand and strictly perform in compliance with the Code of Conduct for Employees, which is explained in detail during the orientation for new directors, executives and employees. Moreover, we have also published an employee handbook and
conduct internal communications on a regular basis.
Market Conduct
We realize that receiving fair service is a basic right of customers and a factor that attracts customers to use our services. Therefore, we have formulated a market conduct policy and guidelines as follows:
- Corporate Culture and Roles and Responsibilities of the Board of Directors and Senior Management
The Board of Directors and senior management are responsible for fostering ethical market conduct as part of the Bank’s corporate culture. - Product and Service Channel Development and Client Segmentation
We develop products and service channels that are suitable for the needs, financial ability and comprehension of each target group of customers, with due consideration of our employees’ selling capabilities and knowledge, our work systems and the system to ensure that selling such products and services to customers is conducted fairly. We recognize that in determining product terms such as benefits, prices and fees, we must consider fairness to customers and associated actual costs, while not joining with other providers to specify terms that are against customers’ interests nor offering bundled products unless it is justified on the grounds of risk protection of the main product. - Remuneration Scheme
Remuneration and penalties are determined for employees who provide services to customers as well as executives who are responsible for monitoring compliance with market conduct. KPIs are also properly defined to prevent sales propositions and recommendations that are irresponsible for customers (mis-selling). - Sale Process
Selling products and services to customers must not invade their privacy. Information provided to customers must be complete, not misrepresented or distorted. A system and processes to regularly check selling and service quality is in place, such as call backs, welcome calls and mystery shopping. In addition, sales and service offerings to vulnerable customers must be prudent and appropriate. Employees must understand the requirements and financial resources of customers as well as their ability to understand the service so they can provide sufficient information and knowledge about potential risks. - Communication and Training
We regularly communicate with employees to raise awareness and organize training programs to provide knowledge about market conduct. This includes providing informative content with details of new products or services, guidance on sales approaches using simple language, customer rights and market conduct guidelines. - Data Privacy Protection
We protect the privacy of personal customer data in accordance with applicable laws by designing, developing and testing work systems to ensure data security. - Problem and Complaint Handling
We have established processes for problem solving, complaint handling and whistleblowing, and put in place remedies to ensure speed, effectiveness and fairness during the resolution process. - Compliance Control, Monitoring and Audit (Three Lines of Defense)
We have adopted the “three lines of defense” principle for controlling, monitoring and auditing compliance with market conduct. This is also used to detect risks and anomalies while a tracking and monitoring system is in place for after-sales service. - Operations and Business Continuity
We have established operating systems and business continuity plans that cover operations in both normal circumstances and emergencies to ensure that customer requirements are addressed correctly, completely and in a timely manner. We have also prepared a manual and checklist for employees to use and provide ongoing training programs to prevent operational mistakes.
The Bank places high importance on market conduct for vulnerable groups such as the elderly (over 60 years), customers with limited financial knowledge or no experience in using products and services, and customers with communication or decision-making constraints, including those with hearing, visual or health impairments. Therefore, we have specifically established guidelines for providing products and services to vulnerable groups. For example, we take into account the objectives, risk appetite, financial ability and capacity to understand of customers when we offer products and services to them. In addition, an explanation of details, conditions, rights and exceptions must be clear and easy to understand, by highlighting or underlining key messages, while service staff should communicate slowly with a clear voice using simple language while stressing key points. If customers have questions, service staff must explain or clarify to them until it is confirmed that they have a complete understanding without doubts or further questions. Service staff must offer time as necessary for vulnerable groups to digest and understand the information provided and not rush them to make decisions.
Retail customer debt collection policy and practice
The Bank has established policy, principle, procedure including guidelines on debt collection for retail customers in accordance with the Debt Collection Act B.E. 2558, the Debt Collection Supervisory Committee Notices, Debt Collection Guidelines issued by Bank of Thailand (BOT), Personal Data Protection Act B.E. 2562, Credit Data Business Operation Act B.E. 2545, and relevant laws and regulations. These cover details of the Bank’s regulations and procedure, personal identification, information disclosure, location or person, date, time and the amount of contact for debt collection purpose, including fees or expenditures (if any), rights and complaint channels for debtors, penalization for debt collectors or debt collection companies that are appointed by the Bank in case of violations of and non-compliance with the Bank’s policy and relevant laws and regulations. This is to ensure that the Bank has properly and fairly collected the debts.
Appointed debt collection companies for retail customers*
- Chalinthon and counsellor Co.,Ltd.
- Prachachon Law Office Co.,Ltd.
- Dharmsirirat Law Co.,Ltd.
- Nisit and Partners Co.,Ltd.
- Leader Group Co.,Ltd.
- Lawyer Smart Group Company Limited
- Max Group corporation Company Limited
- Nitirat Law and collection Co.,Ltd
- S.S.C.Law Office
* Remark: The debt collection companies have been appointed to clarify and provide information for the debt collection purpose only. The recruitment principles are in accordance with the Bank’s outsourcing policy and regulations and BOT announcement. The Bank reserves the right to change the debt collection companies without prior
notice.
Anti-corruption
The Bank has established an anti-corruption policy as an operational framework and its internal guidelines. Our employees, executives and directors are required to act in compliance with the policy in their habitual practices, thus nurturing a proper corporate culture. The policy also includes corruption risk management and whistleblowing channels. We also put in place an anti-corruption handbook as a practical guideline for employees, conduct an annual compliance
assessment checklist, and regularly raise awareness of the policy to employees at all levels through training and internal communication. In case of violation or non-compliance by any employee, the Bank will conduct an investigation according to the disciplinary procedures and impose appropriate penalties ranging from a verbal warning to employment termination or
legal action.
The Bank has been recognized as a financial institution that plays an important role in fostering anti-corruption and has been a certified member of Thai Private Sector Collective Action Against Corruption (CAC) since 2015 with its certified
membership extended in 2021.
Corruption Risk Management
To prevent and control the risk of corruption, we have established an effective corruption risk management process aligned with our business context as follows:
- Identification of any risk of corruption we may be exposed to through our operations or business activities.
- Assessment of the risk and severity of the impact.
- Adoption of preventive and control measures specific to the corruption risk that is applicable to the situation and business of each unit (these first three steps are carried out on an annual basis by executives and supervisors who are closest to the issues). All assessment results and related information will be collected and stored in a corruption risk database for further analysis and reference.
- Tracking, monitoring and audits are undertaken under the “three lines of defense” principle. Business unit heads and business unit compliance officers, as the first line of defense, manage risks pertaining to their units. The Risk Management Division and Compliance Division, the second of defense, oversees and monitors corruption risk management. The third line of defense, the Audit and Control Division, independently audits matters related to corruption and reports to responsible persons according to the line of command.
In 2022, the Bank had no corruption and bribery allegation or complaint against it from the Bank of Thailand, the Office of Securities and Exchange Commission, and the Office of the National Anti-Corruption Commission or the Anti-Money Laundering Office. We were not involved in any activity related to lobbyists, political support, political parties,
political candidates or political influencers, directly or indirectly.
Remuneration and Performance Linked the Compliance with Code of Conduct and Business Ethics
To escalate an effectiveness of the Bank’s corporate governance, we have integrated the compliance with our rules and regulations, and the compliance with our code of conduct and business ethics as performance criteria that are linked to remuneration and bonus for all level of employees in a particular year. In addition, the employees who are qualified for bonus must be those who do not misbehave which lead to disciplinary actions such as immediate dismissal or termination and those who do not get involved with fraud. If an employee still remains in the investigation process for high level of disciplinary/ corrective action, or are alleged to get involved with fraud, the employee will be temporarily restrained from bonus payment. In case the employee is proved no guilty or acquitted from any wrongdoings, the employee will be able to receive bonus.
Key Activities
Learning and Development for Executives and Employees
We have developed various training courses related to ethics, good governance and business ethics for executives and employees via our online platform, BBLearn. All employees can access relevant information and knowledge through smartphones, tablets and computers in a convenient and fast manner while post-learning knowledge assessments are also provided. Important courses are as follows
Reported Cases
We provide channels for all stakeholders to send information or file complaints related to suspicious behaviors or actions of the Bank and related parties including directors, executives and employees, that are potentially fraudulent or in violation of laws, regulations, the Code of Conduct, and policies and practices of the Bank, inaccurate financial reporting, failure of internal control systems, or misconduct that can cause damage to customers or the Bank itself.
Remark: *substantiated case that goes through investigation process with proof of evidence and disciplinary recommendation.
We have developed various training courses related to ethics, good governance and business ethics for executives and employees via our online platform, BBLearn. All employees can access relevant information and knowledge through smartphones, tablets and computers in a convenient and fast manner while post-learning knowledge assessments are also provided. Important courses are as follows
Reported Cases
We provide channels for all stakeholders to send information or file complaints related to suspicious behaviors or actions of the Bank and related parties including directors, executives and employees, that are potentially fraudulent or in violation of laws, regulations, the Code of Conduct, and policies and practices of the Bank, inaccurate financial reporting, failure of internal control systems, or misconduct that can cause damage to customers or the Bank itself.
|
Reporting areas |
Number of breaches in FY 2022 |
|
Corruption or Bribery |
0 |
|
Discrimination or Harassment |
1* |
|
Customer Privacy Data |
0 |
|
Conflicts of Interest |
0 |
|
Money Laundering or Insider trading |
0 |
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