ANTI-CORRUPTION POLICY

Anti-Corruption Policy

We offer hardware and software solutions that help public and private organizations worldwide protect critical infrastructure and other major assets. We design security projects using high-quality networks, servers, storage, and video security and monitoring solutions. Our team consists of specialists who assist in designing tailored solutions, providing flexible, modular, and scalable systems that meet the specific needs of your business. Loxley Evolution Technology is committed to creating and maintaining strong relationships with customers, built on a foundation of excellence and trust.

Definition of Corruption

Corruption refers to bribery in any form, whether direct or indirect, involving the offering, giving, receiving, or soliciting of anything of value—such as money, assets, or other improper benefits—that could influence decision-making. This applies to individuals within an organization, government agencies, public officials, or private entities, with the intent to induce or prevent an action in a way that secures or maintains an undue business advantage. Exceptions apply in cases where such actions are permitted under applicable laws, regulations, official announcements, internal policies, local customs, or commercial practices.

Policy

The company has established a policy to prevent all forms of corruption, ensuring transparent and fair business operations. Directors, employees, officers, executives, and representatives acting on behalf of the company are strictly prohibited from engaging in or being associated with corruption, whether directly or indirectly.
Regular reviews and assessments of operational procedures will be conducted to ensure compliance with changes in relevant laws, regulations, and policies.

Duties and Responsibilities

  1. The Board of Directors is responsible for establishing policies and overseeing the implementation of a system that effectively supports anti-corruption efforts, ensuring that management acknowledges and prioritizes anti-corruption practices.
  2. The Executive Committee is responsible for promoting and supporting the anti-corruption policy and integrating it into the company’s human resource management. They will also review the appropriateness of systems and measures to ensure they align with changes in business, laws, and regulations.
  3. The Accounting and Finance Manager is responsible for reviewing and auditing operational systems to ensure they are in compliance with policies, procedures, and laws. This is to ensure that the company has an adequate control system to manage corruption risks and report findings to the Audit Committee.

Guidelines to Prevent Corruption Risks

  1. Gifts, Souvenirs, and Entertainment
    Building good business relationships with partners, creditors, or future customers may involve risks that could lead to corruption. Such relationship-building may include giving or receiving gifts, souvenirs, or paying for entertainment expenses. In some cultures, these practices are seen as normal, making it difficult to determine whether they constitute gifts or corruption.
    The company expects that those involved will exercise discretion in deciding whether the gifts, souvenirs, or entertainment expenses are appropriate for each occasion, suitable for the recipient, and in compliance with laws and social acceptance. All such transactions must be properly recorded, with supporting evidence, for future auditing purposes.
  2. Charitable Donations or Sponsorships
    Giving or receiving charitable donations or sponsorships must be done transparently and legally, without being used as an excuse for bribery.
  3. Government Transactions
    Engagement with government officials must be conducted transparently, directly, and in accordance with relevant laws to maintain trust with government agencies.
  4. Political Activities Support
    The company supports the right to vote in both local and national elections, as it is an important civic duty under a democratic system. However, support for or involvement in political activities must be done on a personal basis and cannot be represented as the company’s position.

Guidelines to Prevent Corruption Risks

  1. Any actions taken under the Anti-Corruption Policy should follow the guidelines outlined in the Corporate Governance Handbook, Business Code of Conduct, work regulations, and other relevant Company operational manuals, as well as any policies and guidelines that the Company may establish in the future.
  2. To ensure clarity in dealing with high-risk activities for corruption, Company personnel must perform their duties with caution, in accordance with the Company’s code of conduct, policies, and guidelines on the following matters:
    3. 2.1 Procurement activities must be conducted in accordance with the criteria or guidelines set forth in the procurement policy. These activities must be fair, transparent, and ethical. Company personnel must not engage in any business that may result in personal gain by using their position in procurement, whether directly or indirectly, nor use information obtained from procurement activities for personal or others’ benefit.
    2.2 Giving and receiving gifts, souvenirs, and business entertainment in accordance with customary business practices may be done reasonably and for the benefit of the Company’s business. However, it must not violate local customs, laws, or regulations both domestically and internationally, nor should it affect work-related decision-making or cause conflicts of interest. This must be done in accordance with the Company’s No Gift Policy and Guidelines for Receiving and Offering Gifts, Hospitality, and Other Benefits.
    2.3 Charitable donations and sponsorships Donations and sponsorships to government agencies or government officials, business partners, or any legally established organization must be conducted transparently and in compliance with the law, on behalf of the Company. This must be done according to the Company’s relevant policies and without consideration of reciprocal benefits or using it as a means for corruption.
    2.4 Transactions with government authorities and liaison with government officials The Company has a policy of not supporting the payment of facilitation fees that may lead to corruption. Transactions with government authorities must be conducted correctly, transparently, and in compliance with the relevant laws.
    2.5 Political activities support The Company has a policy of conducting business with political neutrality and encourages company personnel to exercise their political rights and freedoms in accordance with the law. Any support or participation in political activities must be done in a personal capacity and must not involve actions that may damage the Company or create the impression that the Company is involved.

Risk Assessment

Management must assess the risks associated with bribery and potential corruption and review the existing risk management measures to ensure they remain at an acceptable level.

Communication and Training

All employees will receive training on anti-corruption to raise awareness of this policy, especially regarding various forms of bribery and the risks associated with participating in bribery. Additionally, the company will make this anti-corruption policy available on the company website at www.loxleyevolution.co.th for employees to review at any time.

The training on this policy will also be part of the orientation for every new employee at the company. Furthermore, the company will encourage its representatives, business intermediaries, distributors, and service providers who engage in transactions with the company to adhere to the same corporate social responsibility standards as the company.

Report Fraud and Corruption

Within the Organization
  1. Supervisor or Executive
  2. Send an e-mail to: Info_loxleyevolution@loxley.co.th
Outside the Organization

Whistleblowing and Complaint Procedure

Any act of fraud or corruption constitutes a violation of the company’s personnel regulations applicable to employees, executives, and directors. Such actions are subject to disciplinary measures as specified in the company’s rules and may also lead to legal penalties if found to be in violation of the law.

Contact Us

Loxley Evolution Technology Co., Ltd.
102 Na Ranong Road. Klong Toey, Bangkok 10110, Thailand
Phone: (66) 0-2348-8811
Fax: (66) 0-2249-1692
E-mail: Info_loxleyevolution@loxley.co.th

Whistleblowing Form

If you did not receive a fair investment, or found guilty of Acts of unfair competition on the company and investors, The Audit Committee and / or Board of Directors will performed with a complaint and clues that you inform us as soon as possible to be fair to investors.

Please fill in your details below.

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