1. Ensuring Awareness Among Executives and Employees
To ensure all executives and employees are aware of the Company's Business Ethics and Code of Conduct, every employee must sign and acknowledge their understanding of its contents. All new employees are required to sign a form confirming they have read and agree to comply with the provisions of this Code. Employees cannot claim lack of awareness or failure to sign the acknowledgment form as an excuse for non-compliance.
This Business Ethics and Code of Conduct will be regularly reviewed and updated to keep pace with evolving regulations. Any additions or removals of specific provisions must be communicated to the Board of Directors.

2. Actions Constituting Violations of Business Ethics and Code of Conduct
2.1 Non-compliance with the Business Ethics and Code of Conduct guidelines.
2.2 Advising, encouraging, or supporting others in non-compliance with the Code.
2.3 Neglecting or ignoring observed violations or non-compliance with the Code, particularly when aware or should be aware due to involvement in responsibilities.
2.4 Failing to cooperate with or obstructing investigations into alleged violations or non-compliance.

3. Guidelines for Addressing Violations or Non-Compliance with Ethics and Code of Conduct
All directors, executives, and employees must prioritize business ethics and the Code of Conduct. If a violation of business ethics and the Code of Conduct is observed, employees must report such conduct. If they witness a violation or non-compliance with the Code, or are compelled to act in a manner contrary to ethics and the Code of Conduct, employees can submit a complaint following the procedures below:

4. Managing Reports of Violations or Non-Compliance with Ethics and Code of Conduct
Upon receiving a report, the complaint recipient must collect facts and finalize an initial conclusion within 45 days from the date the report document is received.
The complaint recipient will then present the matter to management representatives. The management representatives involved in the deliberation include:
1. A representative from a department at a manager level or above within the complainant's reporting line, who must have no conflict of interest or benefit related to the complainant.
2. A representative from Human Resources management.
3. The Company Secretary or Head of Internal Audit.

Measures to Cease Violations or Non-Compliance with Ethics and Code of Conduct:
The management representatives involved in the deliberation will define measures to cease the violation or non-compliance with the Code and mitigate damages for affected parties, taking into account any distress caused. The outcomes of these actions must be reported to the highest-ranking supervisor of the affected party and to top management.

5. Disciplinary Action
The Company will determine appropriate disciplinary actions based on the nature and circumstances of each type of Code violation. The severity of the penalty will vary according to the seriousness of the offense. For minor or first-time violations, the Company will first issue a warning letter. The summarized findings and penalties will then be submitted for approval by the Chief Executive Officer / Managing Director. For severe Code violations, offenders may face serious penalties, including:

    • Suspension without pay
    • Termination of employment
    • Civil and criminal legal proceedings

The management representatives involved in the deliberation will summarize these findings and penalties for approval by the Chief Executive Officer / Managing Director.