Corruption is defined as: the misuse of gained power or asset; behavior harming other people’s interests; bribery by offer; a promise, vow, request or receipt of inappropriate money, assets, items or other benefits from staff, employees or officers from government or private sectors, either directly or indirectly so that the recipient refrains from performing duties in order to receive or maintain the business/benefit or introduces business/ benefit to the Company; or to receive or maintain other inappropriate benefits unless those are not against the laws, regulations, announcements, articles, traditions, local customs or ethics in business.

This definition governs corruption in other forms which causes misuse of power such as: the giving of gifts or services; giving cash or items in lieu of cash; bribery to government officers and corruption between private-to-private.

In addition, the Company prohibits executives and staff from soliciting, arranging or accepting corruption for personal benefit or benefit of family, friends or associates.

The Company acts against corruption by clearly defining its corporate values, codes of conduct, policies and regulations, risk management, internal and external communications, training, internal control, follow-up and examination.

Policies, Duties and Responsibilities

1. The Company applies the principal of political neutrality and no policy is set to support politics for any political party or powerful political person.
2. The Board of Directors has the responsibility to set and enforce the anti-corruption policy to ensure that the management gives importance to this.
3. The Audit Committee has a duty and responsibility to review the system of finance and accounts reporting, internal controls, internal audit and risk management to ensure that the management complies with the Company’s policies and standards in regard with corruption and is concise, correct and effective.
4. The Managing Director has a duty and responsibility to provide system setting and support the anti-corruption policy, communicating this to staff and relevant persons including subsidiaries, joint venture partners or other companies that the Company has the controlling power or the business representative. The Managing Director is also responsible for revising the system and its practices to comply with any change of business, regulations, terms or provisions of the law.
5. The Internal Auditor has a duty and responsibility to examine and review the operation; to examine whether it complies with the policies, principles, laws and provisions of the compliance unit, in order to ensure that the Company has an appropriate and adequate internal control system in the subject of corruption risk and report this to the Audit Committee.

Procedures of Anti-Corruption Policy

1. Directors, executives and staff at every level shall comply with the anti-corruption policy, ethics and codes of conduct of the Company. They shall not become involved in corrupt acts by not proceeding with or accepting any corrupt act on behalf of himself, family, friends or associates either directly or indirectly.
2. If any staff should become a witness to an act of corruption within the Company, no staff shall ignore it. They shall inform the superior officer, internal auditor or Audit Committee for investigation. In case there is any doubt or problem, they shall consult with the superior officer, internal auditor or Audit Committee.
3. The Company shall provide justification and protection to the staff who refuses to participate in any act of corruption or informs the corruption involving the Company.
4. In transactions involving the government or private sectors, processes must be correct, transparent and appropriate according to the laws of Thailand in order to avoid any act which might persuade officers of the government or private sectors to act incorrectly or inappropriately.
5. The corruptor is considered a wrong-doer and shall receive disciplinary punishment and penalty by law.
6. The Company shall be transparent with its anti-corruption policy by publicising it through the Company’s intranet and website www.dusit.com

These procedures are set according to the internal control principle to comply with the Company’s policies and regulations.

Policy and Procedure for Non-Political Support

Definition of Political Support

Political support is to give: money, gifts, unpaid services or other to support a political party; become a representative of or participate in the political activity for the benefit of a political party or powerful political person(s).

The Company does not have political support policy

Practice for Non-Political Support

1. Avoid being a director or representative of any political party.
2. Avoid donations to any political party or organization involved with politics.
3. No contribution in either money or other benefits to support or assist any political party or any powerful political person(s).
4. Action according to laws of Thailand.

Policy and Practice for Charitable Contribution

1. No support or other acts expecting or gaining inappropriate benefits to the business.
2. Have a charitable contribution policy or gaining public interest to the institution or foundation which are listed according to Director-General of Revenue Department approved by Minister of Ministry of Finance.
3. Have a policy for charitable contribution to education or sport according to Director-General of Revenue Department approved by Minister of Ministry of Finance.

Policy and Procedure for Sponsorship

The Company has no policy to receive or use the fund from the supplier except those involving Food and Beverage (F&B).

All promotion funds requests must meet the criteria of an F&B promotion aiming for increasing: local and international revenue, guest spend, covers or PR image for outlets and hotels in local and international media.

Allocated fund utilization will only be approved if the promotion follows Dusit Standards.

Policy for staff recognition award, service charges and other expenses payment

The Company has a policy for staff recognition award payment on festive and traditional events, including staff recognition under other programs such as the Kob Khun programme. All hotels are required to establish staff recognition programmes in various categories.

The Company’s corporate governance stipulates not to request or receive money, assets or any other benefits from related business parties unless such receipt is owing to traditional providing (i.e. new year gift) and the said receipt shall be reported to the superior and proceed complying with the Company’s regulation.

The Company has declared that it is the duty of every one to monitor any wrongdoing and has therefore set the training and policy to inform all staff so that they understand participation in supporting or reporting when witnessing a wrongdoing.

The Board of Directors provides channels for all stakeholders to lodge a complaint the matter that may cause damage to the Company by submitting the complaint in writing to executive, internal audit and the Audit Committee and has a policy to protect whistle-blower as follows:

Complaint

If there is a doubt, or belief, or a reason to believe in good faith that there is an act that may cause damage to the Company in regard with illegal act, corporate governance, accuracy of financial reports, internal control deficiency, corruption, incompliance with ethics, rules or regulations of the Company: the staff should first consult a superior officer. However, in case there is the doubt that the superior officer is involved with corruption, the staff should consult with or report to the higher superior officer. If it is uncomfortable to do so, with sufficient witness or evidence for examination, the staff or a third party can report directly to the Managing Director or Audit Committee as shown on the Company's website: www.dusit.com

Protection of the Whistle-blower

The staff who informs, reports or provides any information under the scope of the complaint in good faith without intention to harm or cause damage to any person or the company shall be properly protected, such as no change of job, workplace, suspension, salary reduction, termination or other action deemed unfair to the staff.

In addition, the Company would require the staff or whistle-blower to provide name, surname and contact information in the case that more information is required. The Company shall protect the whistle-blower by keeping information of the whistle-blower confidential.

Procedure after the Receipt of Complaint

The receiver of the complaint shall monitor, analysis, and gather facts by himself or assigned person as to whether the complaint has any grounds. The procedure shall be set to stop the act that may cause damage to the Company and shall report to the Managing Director.

Report of Investigation’s Result

The receiver of the complaint or Managing Director shall report to the whistle-blower, if they identify themselves.

In case of the complaint has significant impact to the Company, Managing Director shall report the investigation’s result to the Audit Committee and /or Board of Directors.