นโยบายต่อต้านการคอร์รัปชัน

Eureka Design Public Company Limited (“the Company”), including its subsidiaries, associates, and any other entities under its control (if any), is committed to conducting business with integrity, honesty, transparency, and accountability toward society and all stakeholders in accordance with good corporate governance principles. This reflects the Company’s intention and strong commitment to combating all forms of corruption.

The Company has established this Anti-Corruption Policy, which includes clear definitions, scope of application, roles and responsibilities, guidelines, operational measures, reporting channels, whistleblower protection, and disciplinary actions to prevent corruption in all Company activities and business operations that may carry corruption risks. Accordingly, the Company has issued this written Anti-Corruption Policy to provide clear operational guidance and to support the development of a sustainable organization.

Anti-Corruption Policy Statement

Directors, executives, and employees of the Company, its subsidiaries, associates, or any entities under its control are strictly prohibited from engaging in or accepting any form of corruption, whether directly or indirectly. This applies to all business operations in all countries and all relevant departments. Compliance with this Anti-Corruption Policy shall be regularly reviewed, including the operational guidelines and requirements, to ensure alignment with business changes, internal regulations, and applicable laws.

Responsibilities

1. Board of Directors
   The Board is responsible for establishing, supervising, monitoring, and approving policies, as well as implementing an effective anti-corruption system. This is to ensure that the Company, subsidiaries, associates, or any entities under its control achieve the objectives of the Anti-Corruption Policy, and that management gives due importance to anti-corruption efforts, cultivating it as part of the corporate culture.
2. Audit Committee
   The Audit Committee is responsible for reviewing anti-corruption activities, financial reporting, internal control systems, internal audits, and risk management systems to ensure alignment with international standards and to ensure that Company operations are strict, appropriate, effective, lawful, and ethical.
3. Chief Executive Officer, Managing Director, and Executives
   Executives are responsible for establishing, promoting, and supporting systems to implement the Anti-Corruption Policy. They must ensure effective communication to employees and relevant parties, and review the suitability of systems and measures to align with changes in the business, regulations, rules, and legal requirements.
4. Internal Audit Function
   Internal Audit is responsible for proposing internal audit plans, conducting audits, and reviewing operations to ensure compliance with policies, guidelines, operational authorities, Company regulations, laws, and regulatory requirements. Internal Audit shall ensure the adequacy and appropriateness of controls that mitigate corruption risks and report findings to the Audit Committee.
5. Employees
   Employees must strictly comply with this policy. If any employee has doubts or encounters violations of this policy, they must promptly report to their supervisor or through the Company’s reporting channels as provided in the Whistleblowing Policy.

Guidelines for Practice

1. Directors, executives, and employees of the Company, subsidiaries, associates, or controlled entities must comply with the Anti-Corruption Policy and the Company’s Code of Business Ethics. They shall not engage in corruption in any manner, either directly or indirectly.
2. Executives and employees at all levels must not ignore or overlook any suspicious conduct related to corruption. They must report such incidents to their supervisors or responsible persons and cooperate fully in investigations. If unclear or in doubt, they should consult with their supervisors or the designated ethics compliance personnel through the established channels.
3. The Company, subsidiaries, associates, or controlled entities will ensure fairness and protection for employees who refuse to participate in corrupt activities or who report corruption, applying protection measures as specified in the Company’s Whistleblowing and Whistleblower Protection Policies.
4. Any individual found to have engaged in corruption is considered to have violated business ethics and shall be subject to disciplinary actions under Company regulations and may also face legal penalties if the conduct violates the law.
5. The Company, subsidiaries, associates, or controlled entities recognize the importance of disseminating knowledge and providing training to persons performing duties related to or potentially impacting the Company, ensuring understanding and compliance with this Anti- Corruption Policy.
6. For clarity in operations involving high corruption risk, employees of the Company, subsidiaries, associates, or controlled entities must exercise caution and follow the Company’s Anti-Corruption Handbook, which covers matters such as political contributions, charitable donations, sponsorships, gifts, souvenirs, other benefits, conflicts of interest, and the hiring of government officials.

Penalties

1. If an accused person is found to have committed wrongdoing, they shall be subject to disciplinary action as specified in the Company’s regulations. If the misconduct violates the law, the individual may also be subject to legal penalties, including civil, criminal, or other applicable laws. Disciplinary actions and/or decisions made by the Audit Committee or the Board of Directors are deemed final. If the accused is an executive or director, decisions made by independent directors shall be considered final.
2. Any employee who treats others unfairly, discriminates inappropriately, or harms others due to their reporting or whistleblowing shall be subject to disciplinary action. If such conduct violates the law, the employee may also be subject to legal penalties as applicable.