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Anti-Corruption Policy

2.4 Facilitation payment means expenses unofficially paid to officers of government as to
ensure that they will proceed according to process, or motivate them to proceed quicker which such

process does not require discretion of officers of government and it is lawful act of such officers;
moreover, it is the right that a juristic person is entitled to have according to the laws such as request
of a license, request of a certificate and public service.

2.5 Donation means giving or receiving cash, things, goods, services or any benefits without
expectation for returns by a person or a juristic person or through organizations for either charity or aid.

2.6 Sponsorship means money paid or received, things given or received, or returns given
or received which may be financially calculated, from customers, partners, business associates with
objectives for business, brand or reputation of the Company, and advantages to build credibility and
enhance business connection, which is given in appropriate occasion.

2.7 Government officer recruitment means employing a person who is or was a government
officer that means a person holding a political office, a government official or a local officer who
holds a position or has regular salary, an officer or a person who performs duties in a state enterprise
or a government agency, a local administrator and a local council member who does not hold a
political office, and an official under the local administrative laws. It shall also include committees,
subcommittees, employees of the government or state enterprises, and a person or a group of people

who exercises authority or is authorized to exercise the administrative authority of the government
to perform any act in accordance with the law whether it has been established in the government
system, state enterprises or other state affairs.

2.8 Political support means giving assets, money, things or any privileges to aid or support
or provide any benefits to political parties, politicians or persons related to politics as well as

supporting political activities either directly or indirectly.

3. Duties and responsibilities

3.1 Board of Directors
• Approve the Anti-Corruption Policy and procedures to be in line with the Anti-

Corruption Policy
• Establish confidence to the Company that the Management is aware of and focuses
on anti-corruption and fosters the organization culture
• Review the Anti-Corruption Policy and procedures annually

Internal Audit Division I Muang Thai Life Assurance Public Company Limited 8
(Internal Use Only)