Thai Tokai Carbon Product Company Limited
Whistleblower Procedures and Policy

1. Whistleblower Policy

The Company Board of Directors provides an opportunity for all stakeholders and related parties that have notice, found evidence, suspecting others of holding evidence. Those acting on behalf of the Company having involved in any bribery or corruption either directly or indirectly which would lead to fraudulent offenses against the law, regulations, company policies, code of conduct for director, management and employee. Those receiving unfair justice in the workplace are able to notify such acts through the channel specified by the Company Whistleblower Policy.

  • (a) Any questionable or improper accounting, auditing or financial matters or procedures relating to the Company.
  • (b) Conflicts of interest.
  • (c) Vendor fraud.
  • (d) Misuse of the Company’s assets or property, expense account abuse, credit card fraud or other theft.
  • (e) Violations of safety or security concerns.
  • (f) Violations or suspected violations of any Company’s policy or any applicable law or regulation, including, without limitation any retaliation prohibited by this Policy.

The Company will retain the confidential information take into account the safety of the complainant unless required by law to disclose.
These procedures apply to all employees of the Company and related parties.

2. The Channels of Complaint, Practices are as follows;

The details of how a complaint can be made and how it will be handled are set forth below.

  • 2.1 Complainants are free to submit their complaints confidentially in writing or in person or through letters, e-mail or telephone calls, or feedback box.
  • 2.2 Complainants are free to submit their complaints to any of the following persons:
    • 2.2.1 Section Head
    • 2.2.2 Department Head
    • 2.2.3 Corporate Affairs Manager
    • 2.2.4 Company Secretary
  • 2.3 Complainants are free to submit their complaints to any of the following persons. If the complaint concerns any of the above persons, Complainants may make their complaints to a higher level e.g. Deputy Managing Director or Managing Director.
  • 2.4 If the complaint concerns financial improprieties (such as questionable accounting, internal accounting controls or auditing matters), Complainants may make their complaints directly to the Chairman.
  • 2.5 In case the complainant chooses not to reveal their name and identity, a detail facts and evidence must be presented to show that there are reasonable grounds to believe that any person is involved in bribery or corruption.

3. Action to Take After Receiving a Report

The Company will review all reports of Complaint and will investigate and take corrective action as appropriate.

4. Measures for the Protection of Complainants

  • 4.1 A complainant may choose to remain anonymous if deem not to disclose ones identity which could lead to insecurity.
  • 4.2 The Company will keep relevant information secret and take into account the safety of the complainants. Measures have been prescribed for the protection of the complainants who are employees, including those who cooperate to facilitate the investigation. These individual will be protected from unfair treatment as a consequence of the complaint, e.g. disturbances during work, reassignment or termination of employment.
  • 4.3 The Company will take all reasonable steps to safeguard the identity of the whistleblower. All complaints shall be treated as confidential.
    All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate the investigation or otherwise as required by law.

5. No Retaliation

  • 5.1 The Company prohibits unlawful retaliation for good faith reporting of complaints or participating in an internal or governmental investigation of possible misconduct.
  • 5.2 Any employee or officer who retaliates against someone in violation of this Policy is subject to discipline up to, and including, termination of employment.

6. Acting in Good Faith

Anyone reporting a complaint must act in good faith and have reasonable grounds for believing the reported conduct is improper or illegal. Making internal false allegations maliciously or not in good faith may result in discipline up to, and including, termination of employment.