TYCOONS
Policy of Anti-bribery and corruption

           Tycoons Worldwide Group (Thailand) Public Co., Ltd. (hereinafter referred to as the Company) and its subsidiaries operate the business in compliance with all legal and regulatory requirements to ensure that legitimate business and importance to anti-bribery and corruption. In addition the policy's goal is to operate the company based on the principle of honest, fairness, and transparent management, it’s responsible for all interested parties. The behavior of directors, management, and employees are abiding by Business Ethics, Code of Conduct. It’s a part of the "Corporate Governance". The Company also stipulates anti-bribery and corruption policy as guidelines of business operating and therefore directors, management and all employees have to follow the implementation. The main contents are as follows:

Definition of bribery and corruption

           Bribery & Corruption means one gives or receives gifts, fees, rewards or any other favors to influence governmental officers or any other personnel in the business circle. This behavior triggers dishonest, illegalness, and fraud violating principle to gain commercial or financial advantage.

Policy of anti-bribery and corruption

           Directors, management, and employees of the Company and its subsidiaries are prohibited to give or receive directly or indirectly bribery and corruption in any manner whether it is accepted, giving or offering the monetary or non-monetary bribe with the relevant government agencies or private entities of the company's business operations or contact. The Company will execute the policy of anti-bribery and corruption strictly.

Responsibilities

           1 The board of directors is responsible for setting policy and to support and establish the effective anti-bribery and corruption systems for the management to understand the importance of anti-bribery and corruption, and instilled into the culture of the Company.

           2 The board of audit committee is responsible for reviewing the financial and accounting report, internal control systems, internal audit system and risk management system to ensure that is suitable, effective and in accordance with the provisions of the standard.

           3 President and management are responsible for setting systems, supporting and promoting the anti-bribery and corruption policy for all the employees and related personnel know. Its responsibilities also include review of the system to meet the change of the business regulations and laws.

           4 Chief of internal audit is responsible for execution, examining and reviewing the correction of the job compliance with the anti-bribery and corruption policy. Reporting to the board of audit committee.

Guidelines of practice

1 Directors, management, and employees of the Company and its subsidiaries must strictly comply with the policy of anti-bribery and corruption and code of conduct, as follows;

           1.1 No receive and give or offer bribes to any other person to obtain improper benefits with government agencies and private units at work contact.

           1.2 No accept gifts, entertainment, funding or other favors from client or vendor which worth more than the standard prescribed. Employees must report to the company when they accept the worth of gifts or entertainment is more than the company stipulation (provisions of the Code of conduct) for customs and rituals necessary.

           1.3 The Company has established internal control systems, stipulate the procedures of job execution in order to prevent bribery and corruption, people who has responsibility for approving payment must have clear evidence and be in accordance with company policy.

           1.4 Employees should not neglect or ignore the bribery and corruption or the behavior may occur bribery and corruption, must report to the management or report by the trail route of anti-bribery and corruption policy immediately. Employees and the informers who report the bribery and corruption will be protected by the Company.

2 The Company will provide related training courses in anti-bribery and corruption policies to employees, and encourage employees to perform their duties in an honest and responsible behavior.

3 Employees who breach or non-compliance with anti-bribery and corruption policy will be punished by regulations of the company and related laws.

Complaint notification of bribery and corruption

           The Board of directors has a clear path of notification bribery and corruption clues or reporting bribery and corruption directly to the company. If the bribery and corruption report are related with management, it will be submitted to the Board of audit committee to review and make the determination.