and Use of Inside Information, the Company’s Good Corporate Governance Policy, and Handbook of the Code of Ethics. 4. The Company stipulated the guidelines on information disclosure and use of inside information, which included the supervision of inside information, information disclosure, internal and external communication, investigation in an event of information leakage and the establishment of the rules governing the trading of securities issued by the Company. In this connection, the following persons were prohibited from trading the securities during the period from fifteen days before the end of every quarter to two days after the disclosure of the financial statements and the financial position to the SET. The guidelines were stipulated in the Information Disclosure Policy and the Use of Inside Information. • Directors, executives, and employees of the Company or member companies of the Thanachart Group. • Persons whom the Company or member companies of Thanachart Group outsource work to. • Any individuals serving as advisors or any counterparty to a contract, who gives services to the Company or member companies of the Group. 5. The Company made arrangements for directors, executives and employees who were involved in the transaction with important information to sign a confidentiality agreement related to such transaction. 6. The Company set forth that the use of insider information for trading the Company securities or getting obligated in futures contracts related to the Company securities for one’s own benefits or the benefits of others or the disclosure of insider information to other party, directly or indirectly, regardless of whether the insider knew or should know that the other party might use the information for trading the Company securities or getting obligated in futures contracts related to the Company securities for one’s own benefits or the benefits of others were considered a breach of discipline and the insider would be subject to legal punishment. Measures Addressing Conflicts of Interest The Company places strong emphasis on prevention of conflicts of interest. As a result, it has established policies, made announcements, and issued rules and regulations, aiming at making the organization’s operation transparent and reliable. These include, among others, the following: 1. The Policies and the Handbook of the Code of Ethics consisted of guidelines which prohibited Directors, executives, employees and the parties concerned from seeking to gain benefits for themselves or for a group of people. 2. The Risk Management Policy of Thanachart Group set forth guidelines related to the execution of the Company’s transactions, inter-company transactions between member companies of Thanachart Group, the transactions of Thanachart Group’s member companies with major shareholders, Directors or persons with managing authority as well as related parties. The policy also covered guidelines on the use of services from service providers which are outside Thanachart Group as well as the use of services between member companies of Thanachart Group, services from major shareholders, Directors, persons with managing authority of member companies of Thanachart Group and related parties. In principle, the policy covered the following: • The Company has established rules and restrictions on the transactions with the above parties. • The Company has established procedures for obtaining advice in writing from the Compliance Unit before proposing the transactions to the persons who have approval authority, except the cases in which the transactions are deemed normal. 191 56-1 One Report / Annual Report 2021 Thanachart Capital Publ ic Company Limited
RkJQdWJsaXNoZXIy ODEyMzQ3