Unimit Engineering Public Company Limited

Phrapradaeng Office:
109/92-95 Mu19 Soi Suksawat 66, Suksawat Rd., Phrapradaeng,
Samutprakarn 10130, THAILAND

Phone:  +66-2-4630100 (Automatic 4 lines), +66-2-8172121
              • finance Ext. 18
              • Direct line +66-2-4631808

Fax:      +66-2-4631910
E-mail:    IR@unimit.com


Home > Investor Relations > Anti-Corruption Policy

Anti-Corruption Policy

Anti-Corruption Policy


UNIMIT Engineering Public Company Limited (together with its subsidiaries,  “UNIMIT”  or the
“Company”) are committed to conducting our business in accordance with all applicable laws,rules
and regulations of the highest ethical standards, and this commitment is embodied in the Code of
Conduct and Ethics.

The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate UNIMIT’s commitment to
full compliance by the Company, its subsidiaries and affiliates, and its officers, directors, employees
and agents with Thailand’s National Anti-Corruption Strategy of National Anti-Corruption Commission
of Thailand (NACC) and any local anti-bribery or anti-corruption laws that may be applicable. This
Policy supplements the Code of Conduct and Ethics and all applicable laws and provides guidelines
for compliance with the NACC, and Company policies applicable to UNIMIT operations world-wide.

For the purposes of this Policy, a “contractor” or “supplier” is defined as a third-party entity or
individual who provides, and receives payment for, services or goods related to any aspect of a
UNIMIT operation, and includes consultants and subcontractors. A “non-supplier vendor” is defined
as a third-party individual, company, organization, and/or Government or Government-related entity
that will receive payment from UNIMIT, but will not provide goods or services in return.


This Policy is applicable to every employee of UNIMIT,   including senior executive and financial
officers, and to members of the  UNIMIT Board of Directors. The reporting requirement of this
Policyis also applicable to UNIMIT’s contractors and suppliers. This Policy is intended to supplement
all applicable laws, rules, and other corporate policies. It is not intended to supplant any local laws.


Corruption is the misuse of public power for private profit, or the misuse of entrusted power for
private gain. Bribery is the offer, promise, or payment of cash, gifts, or an inducement of any kind
offered or given to a person in a position of trust to influence that person’s views or conduct or to
obtain an improper advantage. Bribery and corruption can take many forms, including the provision
or acceptance of:

• Cash payments;
• Social benefits; or
• Gifts, travel, hospitality, and reimbursement of expenses.


All UNIMIT personnel and agents are strictly prohibited from any offering, paying, promising of any
beneficial or acceptable of any kinds where direct or indirect to the corruption activities involving
with the Government agencies or other Private sectors including their officers.

In addition,  UNIMIT’s books and records must correctly record both the amount and a written
description of any transaction. UNIMIT personnel must ensure that there is a reasonable relationship
between the substance of a transaction and how it is described in the Company’s books and records.

It is contemplated that UNIMIT will institute detailed procedures and standards related to training,
due diligence, the recording of transactions,and other areas, to implement the terms of this Policy
as following.

• Support travel expenses for Government officer
• Direct support and Compensation to Government officer
• Daily allowance for Government officer
• Gift, Party and Entertainments for Government officer
• Political support
• Donation


UNIMIT Board of Directors:
• Follow-up this Policy and assigning to the Management team for response.

Risk Management Section:
• Support the Management team, UNIMIT’s employee and other sections in order to achieve the
  efficient continuing operation including risk management where might to be occurred.

Internal Auditor:
• Inspection and Investigation for any activity of each working unit according to the applicable
  rule of the policy, and evaluate both efficiency and sufficiency of internal controlling using the
  good corporate governance


Audits of UNIMIT sites, operating units, and contractors may be conducted periodically to ensure
that the requirements of this Policy and applicable procedures and guidelines are being met. Audits
may be conducted internally by UNIMIT, or externally by retained third parties. Audit documentation
shall include performance improvement action plans and the action performing should follow as below

1. UNIMIT Board of Directors should assign the Management team to communicate this policy as
    well as action performing to all UNIMIT personnel and agents.
2. Company should communicate anti-corruption policies and measures including internal whistle-
    blowing channels to the internal auditor for real operation.
3. Company should implement the regulations of disbursement with clearly defined for setting
    amount of limitation, approval authority table, objectives and recipient. All related documentary
    evidence have to be provided to make sure the disbursement for any corporate entertainment
    or gift will be complied and followed with  the policy, the procedure auditing would be carried
    out by Internal Auditor.
4. Company should audit Sales, Marketing, and Procurement as well as the contracts for seeking
    the risk of corruption regularly in order to make sure all functions are comply with disbursement
    procedures and purchasing policy. Internal Auditor should recommend and follow-up on
    appropriate corrective actions.
5. Company should organize the human resources management which reflects to the company’s
    commitment of anti-corruption policies and measures would start from the recruitment, training,
    evaluation, compensation and promotion.
6. Company should organize the internal control for financial, accounting, backup data and including
    others functions in the company which related to anti-corruption policies and measures.
7. Company should organize the risk management system in order to prevent and suppress
    corruption in the company.
8. Company should organize the internal audition to ensure that; inner control system and risk
    management system are effectively and assist the company to achieve its goals, as well as to
    ensure that every operation units comply with rules and regulations and to find defects and
    weaknesses in the operation. And, also to provide recommendations of operation system to
    improve efficiency and effectiveness in accordance with good corporate governance.
9. Company should set-up the anti-corruption measures as an internal control document complying
    with company’s regulation and policy.


Other UNIMIT policies impacted by, and which should be construed consistent with this Policy,
include the Code of Conduct and Ethics, the Code of Conduct Escalation Procedure, Procedures
for Implementing the Anti-Bribery and Anti-Corruption Policy, the Vendor On-Boarding Standard,
and the Supplier Code of Ethics.


UNIMIT Board of Directors will organize the measuring of whistle blowing to covering any breaking
the law,  ethic, or  any acting which might be caused to the bribery and corruption of UNIMIT
personnel and agents. This to be included the Invalid financial report, internal control defective
and mechanisms for protection of the informant in order to have overall taking care of company’s
benefit from any shareholder.


• Any breaking of the law, company rule, bribery and corruption by UNIMIT personnel and agents.
• Irregular of financial report and internal control system.
• Any effect to the benefit or reputation of the company.


• Feedback Box inside the Company.
• E-mail Address of the President at  (johnlu@unimit.com)
• Letter to:
  UNIMIT President
  UNMIT Engineering Public Company Limited (Prapadaeng office)
  109/92-95 Village No. 19 Soi Suksawat 66, Suksawat Road
  Bangpueng Sub-district, Prapadaeng District, Samutprakarn Province 10130 Thailand

  And, the internal auditor address following;
  P&L Internal Audit Company Limited
  73/290-294 The fifth AVENUE Building-B First Floor Krung Thep- Nonthaburi Road
  Bangkhen Sub-district, Nonthaburi Province 1100 Thailand
Tel. 022566100


• Preparing confidential information data base of the informant and setting the penalty to the
  officer who responsible of this data when opened to the public.
• Authorized people from Vice-President only can entrance to the confidential information data


Any doubting or other suggestion to this policy, please contact to Risk Management Section
UNIMIT Public Company Limited.


Any employee who violates the terms of this Policy will be subject to disciplinary action. Any
employee who has direct knowledge of potential violations of this Policy but fails to report such
potential violations to Company management will be subject to disciplinary action. Any employee
who misleads or hinders investigators inquiring into potential violations of this Policy will be subject
to disciplinary action. In all cases, disciplinary action may include termination of employment. Any
third party agent who violates the terms of this Policy, who knows of and fails to report to UNIMIT
management potential violations of this Policy, or who misleads investigators making inquiries into
potential violations of this Policy, may have their contracts re-evaluated or terminated.


This policy was written base on Thailand “National Anti-Corruption Strategy Phase-3” as detailing
from NACC at: https://www.nacc.go.th/ewt_news.php?nid=13495&filename=info





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