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Anti-Corruption Policy

5. Guidelines and operational requirements

Anti-Corruption Measure is formulated to combat risks and corruption. Directors, executives
and all employees must comply with Compliance Policy, Anti-Corruption Policy, No Gift Policy, Whistle-
Blowing Policy, Conflict of Interest Prevention and Management Policy, relevant rules and operation
manuals and other guidelines specified by the Company.

5.1 Gifts, gratuities, hospitality, reception and other expenses

• Employees can provide gifts, gratuities, hospitality, reception and other expenses by
tradition or general practice of the society. Employees must perform the action with
transparency and comply with the Code of Conduct and the laws.

• Employees must not request gifts, gratuities, hospitality, reception and other expenses
from normal duties, and must comply with No Gift Policy. In case employees cannot reject
gifts, gratuities, hospitality or reception, they must notify executives and keep a record and
collect information.

5.2 Charitable donations, grants, gifts, entertainment and other expenses

Employees are required to check charitable organizations, foundations, companies, and
stores to which the Company will make donations and/or provide financial support. It must be
ensured that donations and support will not be used as pretext for bribery and must act
transparently by specifying the name of donor and/or sponsor. It must be able to prove that such
activities bring real benefits to society and/or in accordance with the objectives of the operations
of the Company and the guidelines for charitable contributions, sponsorship, gifts, hospitality, and

expenses.

5.3 Facilitation payment

The Company does not have a policy to make facilitation payment for its businesses in
form of assets or any benefits either directly and indirectly to officers of government,
officers of foreign government, or officers of international organizations because the
facilitation payment is a high risk payment item that can be considered as illegal expense.

Internal Audit Division I Muang Thai Life Assurance Public Company Limited 11
(Internal Use Only)