1. Gifts, Gratuities and Other Payments Related to the Capital Market Business Group’s Business

• The Capital Market Business Group does not tolerate corruption. We prohibit any payments of any kind by any of our directors, employees, officers or agents, directly or indirectly, to any person, government, corporation or other entity for the purpose of improperly influencing the consideration of applications for a business activity or the receipt of other benefits, including the obtaining and retaining of business. We also require that expenditures involving government officials be approved in accordance with this policy.
  
  In addition to our policies, Thailand has strict laws regarding expenditures involving Government Officials. Thai anti-corruption laws prohibit such payments to government officials, foreign government officials or international organization officials.
• Pursuant to the Business Service Agreement with Merrill Lynch, Phatra Securities Public Company Limited (“Phatra”) has agreed to comply with U.S. Foreign Corrupt Practices Act (FCPA) which prohibits Phatra and its employees from providing money or anything else of value to government-related persons (including employees of government-owned or government-controlled entities) improperly to influence their official actions in order to obtain or retain business. These laws carry criminal penalties for violations, which could include substantial fines and possible imprisonment. These laws can be violated by the provision of something of value to the relatives of a government official if it is given with corrupt intent. In addition, violations of our policies in regard to expenditures involving government officials and our clients (“non-government clients”) may result in disciplinary action for the directors, employees and officers involved, up to and including termination.
• The Capital Market Business Group generally prohibits any form of political contributions whether made directly or indirectly by our directors, employees and officers on behalf of the Capital Market Business Group. Political contributions include, but not limited to any kind of contributions made to a politician, a political campaign or a political party.
• To ensure compliance with these rules, employees must be sure to follow the procedures for any gifts and entertainment of government officials and non-government clients set out in this policy.
• For the avoidance of doubt, no employees will suffer demotion, penalty or other adverse consequences for refusing to pay bribe even if such refusal may result in the Capital Market Business Group losing business.

2. Acceptance of Gifts or Entertainment

No employee or member of their families may, directly or indirectly, accept or receive bonuses, fees, gifts, frequent or excessive entertainment, or any similar form of consideration that is of more than nominal value from any person or entity with which the Capital Market Business Group does, or seeks to do, business. Employees should seek advice from Manager and relevant compliance unit(s) before accept any gifts or entertainment that may be considered inappropriate or raise conflict of interest. Inappropriate acceptance of gifts or any entertainment from vendor/party candidates or any person related with such candidates who may benefit from our awards is generally prohibited.

Employees are also required to comply with gifts acceptance guidelines in each department’s manual and the Gift Policy of Kiatnakin Phatra Financial Group as announced by the Group Corporate Communication.

3. Supervision of Anti-Corruption Implementation and Report on Anti-Corruption Compliance

The Audit Committee is assigned by the Board of Directors to oversight of internal controls, financial reporting processes and related functions including anti-corruption. In order to ensure the compliance of this policy, internal audit units and/or relevant compliance units will periodically report the result of auditing on the anti-corruption compliance of business units to relevant Audit Committee and/or other committees (if any).

4. Reporting Violation

Employees are able to raise concern or report any violation of this policy through organization’s channel without risk of reprisal.