Anti Corruption Policy
1) Statement of Intent
PRE adopts a zero-tolerance stance toward all forms of bribery and corruption. This includes giving or receiving
bribes, soliciting or accepting any undue advantage, bribery of public officials, collusive tendering/bid-rigging,
facilitation payments, and fraudulent or misleading accounting—whether directly or indirectly, and whether
conducted by employees or via any third party or business partner.
2) Scope
This Policy applies to all directors, executives, and employees of PRE, as well as consultants, contractors, agents,
suppliers, and business partners acting for, on behalf of, or in collaboration with the Company.
3) Governance and Responsibilities
• Board of Directors / Managing Director: Approves this Policy, sets the ethical culture of the organisation,
and oversees implementation and performance.
• Line Managers: Assess corruption risks within their functions, implement internal control and review
mechanisms, and evaluate effectiveness at least annually.
• Policy Owner / Ethics Coordinator: Maintains whistleblowing channels, delivers training, responds to
queries, tracks complaints, and reports to senior management.
• Employees and Business Partners: Comply with this Policy, declare conflicts of interest, and promptly
report suspected violations.
4) Key Controls
4.1 Gifts, Hospitality, and Business Expenses
• Offering or accepting anything of value to improperly influence a decision is prohibited.
• Gifts and hospitality must be appropriate, transparent, recorded, auditable, and compliant with applicable
laws and accepted norms.
• PRE sets monetary thresholds per instance and per year and requires each instance to be approved and
recorded in the internal system. (Company to insert limits.)
4.2 Donations, Sponsorships, and CSR
• Must have a legitimate purpose, must not be a disguised bribe, must be fully documented and traceable,
and must receive prior approval under delegated authority.
4.3 Facilitation Payments
• Strictly prohibited. In a genuine emergency where personal safety is at risk, any such payment must be
reported immediately to the line manager and the Policy Owner.
4.4 Dealings with Public Officials and Bid-Rigging
• It is prohibited to offer, promise, give, request, or accept any advantage to/from public officials in order to
obtain or retain business or secure any improper benefit.
• Collusive tendering/bid-rigging with public or private entities is strictly prohibited.
4.5 Conflicts of Interest
• Any actual or potential conflict—e.g., personal relationships with suppliers, shareholdings, or other
interests—must be disclosed promptly to the line manager/Policy Owner, together with proposed
mitigation.
4.6 Third-Party Due Diligence
• Conduct pre-engagement screening and periodic reviews of third parties, considering (among other
factors) their anti-corruption policies, internal controls, breach history, training, and whistleblowing
channels.
• Contracts must include an anti-corruption clause, audit/right-to-audit provisions, and termination rights in
the event of a breach.
4.7 Books and Records
• Financial records and supporting documents must be accurate, complete, and truthful, with no off-book
accounts, and with adequate evidence for all transactions.
4.8 Training and Communications
• Provide training to relevant personnel at least annually and during onboarding; communicate this Policy
via the Company website and the Code of Ethics on an ongoing basis.
4.9 Whistleblowing and Non-Retaliation
• Multiple reporting channels are available, including a dedicated email: [email protected], an
online form, and postal mail.
• PRE will maintain confidentiality to the extent possible and prohibits any retaliation against reporters or
witnesses acting in good faith.
4.10 Monitoring, Review, and Disciplinary Action
• PRE will review risks and internal controls annually and investigate any credible concerns.
• Violations may result in disciplinary action under Company rules and/or legal proceedings.
5) Integration with the Company’s Core Activities
As a sustainability/ESG advisory firm, PRE will:
• Apply this Policy across all services, including ESG strategy advisory, ESG reporting, and other
Company activities.
• Include anti-corruption requirements in TORs and in contracts with consultants, partners, and suppliers.
• Publish this Policy on the Company website as a public reference.
6) Review and Effective Date
This Policy is effective from 1 January 2025 (B.E. 2568) and will be reviewed at least annually, or sooner upon
any material change in applicable laws or standards.
PRE Sustainable Consultancy Co., Ltd. hereby declares its commitment to full and strict compliance with this
Policy.
Pasapon Sariman
Executive Director of PRE Sustainable Consultancy Co., Ltd