Page 131 - Amata-one-report2020-en

BUSINESS OPERATION AND OPERATING RESULTS CORPORATE GOVERNANCE FINANCIAL STATEMENTS ENCLOSURES

2. A transaction is made by considering the interests of the Company as if it were transactions with third parties.

3. There is a follow-up and audit system to ensure that the transaction is done in accordance with the procedures.
The Company has an Audit Committee responsible for reviewing and providing an opinion on connected
transactions or transactions that may lead to conflicts of interest. This Company also disclose details of
such transactions in accordance with regulations of the Stock Exchange of Thailand and the Securities and
Exchange Commission

In the past 2020, no conflict of interest occurred.

2. Internal Information Management

The Company sets the regulation to prevent Insider Trading by a member of Executive Committee and staff
(including spouse and minor) who have access to information, as follows:
1. The Company prohibits a member of Executive Committee and staff (including spouse and minor) who have
access to information to buy or sell the Company’s securities within one month prior to the disclosure of the
three-month financial statement and the annual financial statement. The prohibition extends to the Blackout
Period (24 hours after the financial statement disclosure).

2. Any committee and staff who have access to non-public information which may affect the price of the Company’s
securities shall be prohibited to trade the Company’s securities not until 24 hours after such information is disclosed
to the public. The Company also prohibits its executives and departments to disclose any non-public information
to person outside company or person who is not in charge to prevent the misuse of such information.
3. Member of the Board of Directors and Executive, including spouse/cohabiting couple and minor children, who
change an amount of his or her shareholding must report to the Securities and Exchange Commission of
Thailand within three days of the transaction date, in accordance with Section 59 of the Securities and Stock
Exchange Act 1990.

In 2020, no any Director or member of executive buy or sell the Company’s securities during the prohibition period.
The Company also promote the “No Gift Policy” to its Directors, Executives and employees as well as all stakeholders.

3. Anti-Corruption
The Company is against all forms of corruption, based on the recognition that giving bribes and other acts of
corruption are dangerous and destructive to fair and equitable competition as well as damaging to both the economy
and society as a whole. As such, the Company does not have any policy whatsoever to offer any money or any other
types of rewards and inducements to any external organizations or to any officials of public offices/agencies in order
to gain any improper benefits or competitive business advantage; or to offer money so as to speed up any business
procedures or to gain any special treatment and convenience. As a result, the Company’s Board of Directors No.
5/2019 dated August 14, 2019 approved the Anti-corruption Policy and Whistleblowing Policy. These policies are
applied to Directors, executives and employees. The Company encourages its subsidiaries, affiliates, affiliates, joint
ventures, and business partners to apply this Anti-corruption Policy as a guideline.

The Company realizes that it is a part of the society and wishes no more corruption occurring in Thailand, thus,
on February 1, 2018, the Company announced its intention to join the Thai Private Sector Collective Action Coalition
against Corruption (CAC). On September 30, 2020, the Company was certified as a Collective Action Coalition against
Corruption in Private Sector.

Amata Corporation Public Company Limited 131