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Facilitation Expense Policy

A facilitation expense is payment made to a public or government official that acts as incentive for the official to complete some action or process expeditiously. Saenthong Supply Comppany Limited is against corruption prohibits facilitation expense. It conforms to Millennium Pacific Food Principles (MPFP)

Charitable Contribution, Donations and Aid Grants Policy

Charitable contribution means donation either money or other giving forms such as knowledge or devotes time for to be the parts of social contribution activities follow purpose of corporate social responsibility (CSR) that do not anticipate the business profit.
A charity or donation or aid grants has to be proven that it has nothing to do with a reciprocal return with anyone or any organization except an action to honor the donor as normally practiced. Therefore, the donation has to transparent conducting and follow regulation.

Entertainment Policy

Entertainment is the normal business manner for building goodwill and strengthens working relationship among business associates. The entertainment is provided to outsiders such as government officer, banker, and guest from Millennium P, customer, and agent or component supplier.

The “provision of entertainment” by an employer refers to the provision of

  • Food and beverage
  • Golf expense
  • Food, beverage and souvenir for lecturer
  • Congratulations or condolement
    • Wedding ceremony, Funeral, Birthday, Ordination
    • Celebration and opening factory or Company
  1. Entertainment must be paid reasonably and verifiably. Reception must be organized with morality or business etiquette. The Company will not organize or enter into any entertainment as a means of gaining favorable term from that organization or its affiliates/connected parties in any other business agreement except congratulations or obituary which cannot avoid including wedding, funeral etc.
  2. Entertainment expenditure must get approval from the duly authorized executive of the Company. Entertainment must not be made or offered in conjunction with, as part of or in relation to any bid tender contract renewal or prospective business relationship

Policy of Receiving & Giving Gifts

Giving of gifts is the normal business manner for strengthen the good business relationship. Hence, the Company recognizes that fostering good relationships with business partners is important to its continued success.

A: About Receiving Gift

  1. Directors, top managements and staffs must not request such the gifts; receive money, any other things or benefits from outsiders and business partner; though those requesting will be own benefit or other that indicate to neglect on duty or break a law.
  2. The employees are prohibited to request or receive any gifts or benefits from sub-contractor, outsource, customer, trading partner or business partner which may affect to decide work with bias, worry or conflict of interest.
  3. Receiving of gifts or assets should obtain with morality or business etiquette which getting from associates. It should be received in general not specific, appropriate type and value, not take illegal assets and receive any gifts in term of cash, cash equivalent or easily changeable to cash such as gift voucher, cashier’s cheque, gold, bond or property.
  4. Receiving gifts or any benefits has to be on behalf of Company not the personal employee regarding the gifts come from business deal, transactions or any business base. Therefore, those received gift should belong to company’s activity and the company allows the head of that department to have an authority to manage such gifts on the transparently.

B: About Giving Gift

  1. Directors, top managements and staffs are prohibited to offer money, things or other benefits to outsiders such as government officer, broker, trading partner, customer or decision authorized person which those persons have dominated intention or compensate other to perform or not perform with a position of authority for gaining the advantage or exchanging something or persuading for making a decision or causing receiver acts like not to follow the regulation.
  2. Giving of gifts or other benefits has to appropriate in the circumstances, any festive occasion, tradition of business or business manner. For example, if the company is engaged in a tendering process; the employees must not accept gifts and/or hospitality from any participating company. Besides, the company should not give any gifts to government officer during to request any approval from government office.
  3. The company strictly prohibits the employees to give the gifts to any persons which is worth more than 3,000 baht to the government officer (This is by the regulation of government sector), business partners or any coordinated persons and these things as mentioned have not in term of cash, cash equivalent or easily changeable to cash such as gold, cheque, bond, stock and property; giving has to transparent and follows law.
  4. For business foreign partners, if the gifts value is worth more than 3,000 Baht by exchange rate conversion to Thai Baht currency. It will be considered by the highest superior of each department.

Sponsorship Policy

Sponsorship is the negotiated provision of fund, goods or services to school or central office units in exchange for advertising, publicity or other benefit.

  1. Sponsorship as part of advertising company and corporate citizenship activities, the company may support charities or provide sponsorship for example, Corporate Social Responsibility (CSR). Any such sponsorship must be transparent and properly documented. The company will only provide donations to organization that serve a legitimate public purpose and which are themselves subject to high standards of transparency and accountability.
  2. Sponsorship and Donation: anything of value (including money, gift in kind, access to or use of, or association with the company’s brand or image) offered or given to an entity or event outside. A donation or support has to be proven that it has nothing return but the company recognizes and improve the company image. Be compliant with any applicable laws, rule and regulations.

Political Contribution Policy

Policy contribution refers to financial support or donation of items and/or participation in activities to political parties, politicians or candidates for a political

  1. The Company support political affairs under democratic system but do not promote the employees to participate in political activities acting on behalf of AJT for obtaining the competitive advantage of business; or bringing assets, tools, equipment of Company to utilize for political.
  2. The Company supports employee to take their personal right as a good citizen according to the law by participating in political activity under constitutional provisions but employees are prohibited to participating any the activities that may cause the misunderstanding that company involves or support to any political party.
  3. All employees have their own right but they do not allow arrogating the right of employee to gain or bring the Company’s assets or any equipment for gaining the advantage of political which it is caused other to misunderstand the Company acts like supporting the political parties.

Policy for Notifying Clues or Complaining

The company gives an opportunity to employees and interested person for complaining or notifying of infraction, bribery and corruption which is not conform to company ethics.

In case of employees suspect or find the evidence of someone who gives or receives bribery or corruption, they have to report to their superior or GA department manager suddenly.

 Policy to Fight against Bribery or Corruption

  1. The company is committed to all employees that nobody will be punished or will be affected from declining of bribery even it is caused the company to lose business. Moreover, the company does not allow anyone to threaten employees who always follow the regulations. In case of employees believe that they are threatening, they have to report to their superior and line manager or GA department manager.
  2. In case of any employees are not confident about the bribery or corruption matters or if there is any question, they should consult with their superior and line manager or GA department manager.
  3. In case of required any gifts or other benefits which are apart from this criterion and could not decline those matters, employees should consult with their superior and line manager or GA department manager.
  4. The Company will punish in disciplinary to employees who are against this regulation or do the infamous conduct of Millennium P including any superiors who neglect of making a mistake or acknowledging mistakes but do not handle. All employee must follow this policy whether they understand or not. Furthermore, employees may be punished by the law in case of breaking the law.

 Risk Assessment

Millennium Pacific Food emphasizes risk assessment and makes an assessment of actual incidence of corruption and bribery in the Company. They should be considering by probability, effect and look defensive measure.

Risk assessment is defined as the possibility that an event will occur and adversely affect the Company. The executive must evaluate and review the risks assessment on regular basis for decrease and protect.

 Company or Person on Correlated Business

Millennium Pacific Food will inform and support to Company or Person on Correlated Business to practice Anti-Bribery and Corruption Policy

All employees is prohibited to hire any representatives or agents with bribery proposal.

 Data Management

The Company has a standard policy, principle and laws about accounting and finance, all expenses must have supporting document including managing and maintaining Company’s data.

The Company does not allow recording false data, incomplete information, adjusting account and not using non-budget for support or concealing inappropriate payment.

 Human Resource

Human resource policy is part of human resource management including recruitment, training, evaluation, remuneration and promotion.

 Training and Communication

  1. The anti-bribery and corruption policy will be communicated to agents, intermediaries, suppliers, clients and others who deal with Company by encourages every person it deals with to adhere to similar standards of corporate responsibility.
  2. The anti-bribery and corruption policy will be constantly communicated within organization along with organize in-house training to top managements and employees for realizing to this policy; especially any bribery forms, the risk from involve with bribery as well as the process of report in case of finding or suspecting the bribery or corruption.
  3. All employees will be trained in anti-corruption for realizing this policy. Besides, this course will be a part of orientation for newcomers.

 Related Regulation

For the regulation of working about giving a present for the reception or donation.

  1. Guideline for approval and the expenses for the entertainment
  2. Guideline for Employees on Giving and Receiving Festival or Any Belongings
  3. Regulation for expense authorization

 Follow Up and Auditing

President should revise this policy appropriately when there is some changing and assign the risk management team to follow up of using the regulation and advising it to employees continuously.

All activities in matter of Facilitation expense, Charitable Contribution, Donations and Aid Grants, Entertainment, Receiving & Giving Gifts, Sponsorship, or Political Contribution should be inspected and analyze in Company’s activities matter whether being within the scope of bribery and corruption or not , by Risk Management team.

Internal Audit Millennium Pacific Food (Thailand) Ltd. should always audit the internal controlling system and any procedure to ensure the effectiveness of anti- bribery and corruption.

This Regulation is effective from April 1 st, 2014
Saengthong Pacific Food.

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