Anti-Corruption

Policies

Anti-Corruption (click to view Thai version)

(Premier Technology PCL. and Datapro Computer System Co., Ltd.)

Premier Technology Public Company Limited and its subsidiaries conduct their business under the Premier Group’s philosophy: “Progressive Business, Secure Employees, Sustainable Society.” This serves as the Core Value that the Company has consistently adhered to as a guideline for its operations. The Company emphasizes Good Corporate Governance, operating within a management framework characterized by strong ethics, transparency, and accountability. Consequently, the Company has established a policy for the prevention and anti-corruption in all forms, requiring Directors, Executives, Employees, Workers, and any other individuals acting for the benefit of the Company to adhere to it as a standard of conduct in their operations.

Definitions
“Corruption/Fraud” means any unlawful act, regardless of its form, committed to seek undue benefits. This includes the performance or omission of any act in an official position or duty, or the performance or omission of any act under circumstances that may lead others to believe one holds a position or duty when they do not, or the misuse of authority in a position or duty to seek unlawful gain, whether for oneself or others. This also encompasses nepotism, favouritism, malfeasance, the use of patronage systems, and other unfairness that undermine justice and correctness both legally and socially. This includes acts such as: “Asset Misappropriation” means taking possession of another person’s property, or property owned by another, and dishonestly converting that property to one’s own or a third party’s possession. “Embezzlement” means deceiving another person by presenting false statements or concealing facts that should have been truthfully disclosed in good faith, resulting in the acquisition of property or causing the deceived person or a third party to execute, revoke, or destroy any legal document.
“Bribery / Corrupt Practice” means the performance or omission of any act in an official position or duty, or the misuse of authority in an official position or duty in all forms, whether it is giving or receiving a bribe, offering or promising to give, soliciting or demanding assets, money, goods, rights, or any other benefits that are contrary to morality, ethics, laws, rules, regulations, and policies, to a government official or any other person doing business with the Company or the Group companies, domestically or internationally, to obtain an undue advantage for the Company, oneself, or related persons.
Hiring Government/State Officials means the employment of an individual who is currently or was previously a government official, politician, or consultant to a government agency, to work for the Company with the intent to exploit relationships or internal information to benefit the Company or themselves, thereby creating a Conflict of Interest with the duties of the government agency or the business regulatory organization overseeing the Company, with the aim of gaining an unfair advantage, or establishing policies that favour the private entity for which the former official works.
“Facilitation Payment” means the unofficial payment of money to a government official, organization, or agency to expedite or stimulate the processing of applications, such as license applications, requests for certificates, receipt of public services, placement of orders, or the provision of various services.
“Political Contribution” means the support given to political parties, politicians, or similar activities, whether in the form of direct or indirect financial aid or any other benefit.
“Hospitality” means the offering or receiving of hospitality that is part of ordinary business practice or commercial custom, aimed at maintaining appropriate good business relations.
“Giving and Receiving Gifts” means the giving or receiving of money, vouchers, valuable items, goods, and services, whether given or received as social courtesy or under local customs and traditions, such as New Year’s gifts, birthday gifts, or gifts on the occasion of a new appointment.
“Conflict of Interest” means a director, executive, or employee conducting a transaction involving the company with the objective of obtaining personal benefit from the company’s operation, which conflicts with the company’s interests.
“Sponsorship” means money paid to or received from customers, trading partners, and business partners in a reasonable, transparent, and verifiable manner, or for socially beneficial purposes, provided it is not linked to the interests of any group or individual that might lead to corruption.
“Premier Group Code of Conduct” means the principles for the companies in the Premier Group to conduct business based on correctness and fairness, and mandates that employees within the Premier Group adhere to these guidelines, working with honesty, integrity, responsibility, dedication, discipline, unity, sacrifice, and continuous development, which are the enduring ethics and virtues of the Premier Group.
“Employee” means the following personnel: Employees working for the Company under an indefinite employment contract, including permanent employees and employees during the probation period. Employees working for the Company under a fixed-term employment contract.
The Company’s Directors, Executives, and Employees are prohibited from engaging in, accepting, or supporting all forms of corruption, whether directly or indirectly. Guidelines shall be regularly reviewed to ensure compliance with the policy, operational procedures, regulations, rules, announcements, laws, and changes in business practices. The Company shall support and encourage stakeholders, including customers, trading partners, contractors, or subcontractors, to adopt similar practices in not supporting and opposing all forms of fraud and corruption as the Company. Continuous review of compliance with the Anti-Corruption Policy shall be mandated. Anti-corruption and anti-bribery measures are an integral part of business operations and are the duty and responsibility of the Company’s Board of Directors, executives, supervisors, and employees at all levels, customers, trading partners, contractors, and subcontractors, to ensure that anti-corruption efforts achieve the specified policy objectives. The Company implements anti-corruption and anti-bribery measures and complies with relevant laws, including ethical principles. The Company shall continuously and regularly develop these measures by conducting a risk assessment on activities related to or susceptible to fraud and corruption, and preparing them as a guideline manual for relevant parties. The Company has no policy to support or donate to political parties or provide political contributions. The Company has no policy to pay money to customers or trading partners, hire government officials/state employees, or perform any act that constitutes support for all forms of bribery across all activities. This includes no policy on giving and receiving gifts, paying facilitation payments, giving or receiving hospitality, and/or providing sponsorship with the intent to improperly influence public or private officials to facilitate or benefit the Company. The Company shall implement and maintain appropriate internal controls consistently in all departments to prevent fraudulent or improper practices by employees. The Company shall provide anti-corruption and anti-bribery knowledge to directors, executives, and employees to promote honesty, integrity, and responsibility in performing their duties, and to communicate the Company’s commitment to anti-corruption. The Company shall provide protection to employees who do not support and/or reject corruption. The Company shall establish a mechanism for transparent and accurate financial reporting. The Company promotes various communication channels to enable employees and stakeholders to report suspicious information with confidence that whistleblowers will be protected from unfair penalties, unjust transfers, or any form of malicious action. This includes the appointment of personnel to investigate and follow up on all reported tips.
Duties and Responsibilities
The Board of Directors shall have the duty to: Consider and approve the Anti-Corruption Policy. Oversee the implementation of a system to effectively support anti-corruption efforts. Promote and support a corporate culture of conducting business with honesty and transparency. The Audit Committee shall have the duty to: Review and provide recommendations regarding the Anti-Corruption Policy and the implementation and adherence to the operational manual within the organization. Review the financial and accounting reporting system, internal control system, internal audit system, and risk management system to ensure that the Company complies with international standards, is rigorous, appropriate, up-to-date, transparent, effective, and verifiable. Executive-Level Employees shall have the duty to: Establish rules, regulations, and measures for employees to follow, including determining disciplinary penalties. Implement working systems that promote and support anti-corruption efforts, and review the appropriateness of various prevention standard systems to align with changes in business, regulations, and legal requirements. Promote and communicate to employees and all relevant parties to ensure their knowledge and understanding of this policy. Provide channels for reporting tips or complaints, and implement measures to protect whistleblowers or complainants. Report the operational results to the Board of Directors. Review / revise various policies. Employees at All Levels shall have the duty to: Understand and comply with the Anti-Corruption Policy by not engaging in corruption, either directly or indirectly. In case of doubt or discovery of a violation of Company regulations, report it to a supervisor or through the designated whistleblower channels provided by the Company.
Reporting Requirement The Company must report to the supervisor or through the whistleblower channels designated by the Company. Training The Company shall organize training and knowledge sharing on anti-corruption for the Board of Directors, executives, and employees to promote honesty, integrity, and responsibility in performing their duties, as well as communicating the Company’s commitment. Dissemination of Anti-Corruption Policy The Company promotes various communication channels to ensure that employees and relevant stakeholders are informed. Whistleblowing and Complaints When there is a doubt, belief, or good faith reason to believe that there is a violation or non-compliance with the Company’s Anti-Corruption Policy, all employees can inform the Company through various channels. The cooperation of all employees is considered a crucial factor in keeping the Company free from corruption and ultimately eradicating corruption from Thai society.
Whistleblowing and Complaint Channels Whistleblowing and complaints can be made through the following two channels: The Audit Committee of Premier Technology Public Company Limited The Company Secretary Premier Technology Public Company Limited No. 1 Premier Corporate Park Building,Soi Premier 2, Srinakarin Road, Nong Bon, Prawet,Bangkok 10250, Thailand Telephone: 0-2301-2071 Fax: 0-2748-2063 Email: Kulthida.act@pt.premier.co.th
The company will provide fairness and protection of rights to the whistleblowers or complainants in accordance with the law and the guidelines established by the company.
Penalties If genuine corruption is found, the company will impose disciplinary punishment on the offender according to the company’s rules and regulations, and they may also face legal penalties if the action violates the law. Policy Review The company will review the Anti-Corruption Policy regularly every two years. If no changes are made, this policy will remain in effect until amendments are added. The company wishes for all personnel of the company and its subsidiaries, as well as stakeholders, to cooperate in adhering to this policy for the continuous sustainability of society.
Announced on September 5, 2025.

Definitions