Giving/ Receiving of Gifts and Souvenirs

RATCH Group Public Company Limited's Order

# Khor.5/2021

On Giving/Receiving of Gifts and Souvenirs

On the upcoming New Year's occasion, the company would like to announce the no gift practice to all employees adherence to the international standards of good governance and transparency in business operation and to align with the company’s Anti-Fraud Corruption Policy:

1. In this order,

• "Company" means RATCH Group Public Company Limited.
• "Board of Directors" means the Company's Board of Directors.
• "Chief Executive Officer" means the Company's Chief Executive Officer.
• "Gifts or souvenirs" mean any items of value the Company gives or receives from business partners or outsiders as a gesture of goodwill. The value must be reasonable and in line with local traditions and relevant laws.

2. The giving and receiving of gifts and souvenirs must follow the following rules, to ensure transparency and zero expectation for benefits or other returns possibly deemed an act of fraud or corruption:

• Giving and receiving gifts and souvenirs are allowed as part of local traditions but must appropriately conform with business objectives and not influence the operations or the decision-making process of the Board of Directors, the Management or outsiders. The Company's employees must not solicit gifts or souvenirs during their business dealing with public officers or the employees of private organizations.
• Giving/receiving gifts and souvenirs must be transparent without expectation for benefits or anything in return.
• Giving/receiving gifts and souvenirs must comply with relevant laws and the Company's related policies, regulations and orders.
• Giving/receiving gifts and souvenirs must be done solely on behalf of the Company.
• The gifts and souvenirs must not value more than 3,000 Baht.

3. Examples of gifts and souvenirs the Company's operators can or cannot give or receive are as follows:

• Gifts and souvenirs that can be given or received:
  - Promotional items or sale-promotion items which are of small value like pens, notebooks, calendars and glasses that bear organization’s logos.
  - Traditional-given gifts/baskets.
• Gifts and souvenirs that must not be given or received:
  - Cash
  - Cash equivalents like vouchers, stocks, bonds, gold, jewelry, real estate, etc.

4. The Company's operators must follow the gift and souvenir giving/receiving procedures.

• The division planning to send out gifts and souvenirs need to fill up a request form and seek the approval of supervisors holding the Division Head position or higher. The gifts and souvenirs must not value above Baht 3,000. In the event that gifts and souvenirs valued above Baht 3,000 are necessary, the permission from the function's chief is a must and such giving must not exceed the Board of Directors-approved annual budget. The authorized person must also review if the purpose of such giving conforms with the prescribed guideline and procedure.
• Upon receiving the approval, the business unit’s requester forwards the approval form to the Public Relations Department for the preparation of gifts and souvenirs.
• The Public Relations Department records the given gifts and souvenirs in the Gift and Souvenir Register, which controls and tracks the Company's giving of gifts and souvenirs to business partners and external parties.
• The Public Relations Department prepares a quarterly gift and souvenir report for the Chief Executive Officer.
• The Internal Audit Division reviews the gift and souvenir procedure on an annual basis, to ensure an efficient, effective and appropriate internal control.

5. The receiving of gifts and souvenirs must comply with the following procedure:

• The division receiving gifts and souvenirs prepares a gift and souvenir report form for the function chief's approval. Authorized persons can direct the recipient to return gifts and souvenirs to the givers, should such gifts and souvenirs be considered inappropriate.
• With the authorized person's approval, the division on the receiving gifts or souvenirs sends the approval form to the Public Relations Department so that the accepted gifts and souvenirs are recorded in the Gift and Souvenir Receiving Register that controls and tracks the Company's acceptance of gifts and souvenirs from business partners and external parties.
• The Public Relations Department prepares a gift and souvenir acceptance report for the Chief Executive Officer's consideration on an annual basis.

6. Any employee who violates the Company's guidelines or uses gifts and souvenirs as an excuse or a means towards corruption is considered committing a severe disciplinary offence.

This order shall take effect from today onwards.

Announcement Date: 24 August 2021

Chief Executive Officer