Whistle-Blowing Measures

The Company has put in place complaint-making and whistle-blowing channels, covering complaint-filing, verification,
and summary of findings, together with protection of the complainants and related parties. The purpose is to handle complaints, comments, or suggestions from stakeholders that are affected or potentially affected by the company’s business or conduct of its directors, executives, or employees resulting from law-breaking or violation of the code
of conduct, as well as suspected corrupt practices.

Scope of Whistle-Blowing

Complainants

     Personnel, relevant officers, or a third party witnessing or becoming aware of suspected acts, including those affected by Thaioil Group’s business or the conduct of Company directors, executives, or other employees that violate laws, regulations, Thaioil Group’s Corporate Governance Code, Code of Conduct, policies, and regulations, and suspected corrupt practices.     
     To this end, wording for the complaints must be polite. Whistle-blowers may opt to remain anonymous. If so, their complaints should state enough facts or apparent evidence illustrating wrongdoing and fraud to enable further factfinding. Nevertheless, whistle-blowers’ identity revelation lends credibility to their complaints; communication can also be made for additional information that may prove helpful to the factfinding, not to mention the notification of the factfinding’s outcomes. Thaioil Group will keep whistle-blowers’ data confidential. Complaints should contain at least the following information:

1. (1) Name and last name, address, phone number, and E-mail address of the whistle-blower(s)
   (if they choose to come forward with their identification)
2. (2) Name and last name of the person(s) complained about
3. (3) Facts or behavior of such person(s)
4. (4) Supporting documents, if available.

Complaint-Making and Whistle-Blowing Process

     If one comes across a violation of the laws, regulations, corporate governance principles, code of conduct, Company’s policies or regulations, as well as suspected corrupt practices by Company’s directors, executives, or employees, one can file a complaint through designated channels. An employee coming across such acts should ask or consult his or her superior first. If unsure or uneasy to do so, he or she can use designated channels.

     Upon receiving a complaint, the recipient shall consider information or evidence for validity. The complainant is encouraged to disclose his or her identity. If the recipient found that the information is invalid, the recipient shall notify it to the complainant in case he or she reveals his or her identity.

However, if the information is valid, the recipient shall inform the Corporate Governance Manager for compliant registration.

Afterward, the recipient of a complaint shall consider suitable further action or forward the matter to relevant party (investigator) with due regard for freedom to duly act on the issue in question so as to find facts and track progress. This is to ensure that the Company’s actions fit the complaints. Below are the guidelines.

1. (1) Violations of personnel aspects of Company’s policies and procedures should be forwarded to the Human Resources Manager
2. (2) Violations of laws, regulations, Company’s policy and principles of corporate governance, code of conduct, or regulations should be forwarded to the Company Secretary
3. (3) Dubious acts for unlawful gains for oneself or other parties, including embezzlement, corrupt practices, and fraud should be forwarded to the Audit Committee or the Corporate Internal Systems Audit Manager
4. (4) If the matter under (1), (2), or (3) is complicated or involves several units, it should be forwarded to the Chief Executive Officer (CEO) and President, who will appoint an investigation committee to consider appropriate actions

     Subsequently, the investigator shall inform the Corporate Governance Manager for complaint registration, information recording, and follow on progress of such complaint.

     Investigator, under (1), (2), (3), and (4), shall verify and assess the fact and validity of the complaint. In case that an allegation (or a complaint) is proved valid, the guilty party is subject to the Company’s disciplinary measures or punishment by law if the violation is unlawful, or both.

     When the investigation of a complaint has been concluded, the investigator, under (1), (2), (3), and (4), shall report the resolution to the recipient of a complaint; the recipient then shall inform the complainant on such matter, in case he or she reveals his or her identity.

     The process from receiving a complaint until the announcement of complaint resolution to the complainant shall appropriately perform under a reasonable period of time.

False Reporting

     If reporting is proved to be based on distortion of facts or slander, whistle-blowers will be treated as offenders.
If they are Thaioil Group personel, punitive action will be meted out under Thaioil Group's regluations or as stated by applicable laws, or both. If they are external parties causing harm to Thaioil Group, they may face legal action.

Protection of Whistle-Blowers and Related Parties

     Whistle-blowers are to be suitably and fairly protected by Thaioil Group, which implies no change in job tittles, job nature, workplaces, job relief, threats, job harassment, dismissal, or unfair actions. Thaioil Group will keep their complaints confidential and not disclose them to unrelated parties except when required by law

Confidentiality

     Those with knowledge of complaints or related information must maintain confidentiality and not disclose it except when required by law. If this is intentionally violated, Thaioil Group will punish them under its regulations or take legal action, or both, as seen fit.

Complainance with the Personal  Data Protection Act

In accepting complaints and provision, if the whistle-blower goes public with his/her identification and provides personal data, the person accepting such matter must abide by the Personal Data Protection Act as follows:     

1. (1) Inform the whistle-blower about the Privacy Notice verbally or in writing using the same channel as that for
   whistle-blowing
2. (2) Gather, apply, or disclose (all referred to as “compile”) personal data according to the objectives stated in the Privacy Notice only, except where such compilation qualifies for legal exemption
3. (3) Delete or erase personal data or make them impossible to identify once such data are no longer needed or once past the period stated under the whistle-blowing process, as stated by the person accepting the matter
4. (4) Keep personal data secure under the personal data security measures defined by Thaioil Group and the law to prevent leaking of such data, etc.

Whistle-Blowing Channels

Stating explicitly that the information is confidential, whistle-blowers can file matters through the following channels: