Organizational Importance and Commitment

The Company is committed to conducting its business with transparency and good governance, as demonstrated by the establishment of a clear anti-corruption policy. This policy aims to cultivate a long-term organizational culture free from corruption by ensuring that employees at all levels are well-informed and strictly adhere to the policy. Additionally, the Company encourages whistleblowing by providing protection to informants and ensures that all allegations of corruption are investigated fairly and transparently.

Opportunities and Impact

Anti-corruption efforts serve both as an opportunity to enhance credibility and trust among stakeholders, and as a key factor in achieving sustainable growth. At the same time, if the Company neglects proper practices and oversight processes, it could lead to reputational damage, financial loss, and a decline in public trust. Therefore, the Company places great importance on comprehensive and ongoing management of corruption-related risks.

Supporting the SDGs Goals

Goal 16:
Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels.

Stakeholders Directly Impacted

Customers
Customers
Operate with Business Code of Conduct, maintain customer confidentiality, and uphold fair contractual practices.
Trade Partners
Trade Partners
Conduct business ethically and treat each other fairly in accordance with agreements.
Employees
Employees
Ensure equal opportunities for career advancement.
Shareholders
Shareholders
Practice good corporate governance and treat all shareholders equally.
Regulators / Government Agencies
Regulators / Government Agencies
Conduct business and disclose information accurately and fully as required by laws and regulations.
Creditors / Lenders
Creditors / Lenders
Transparency in business operations.
Debtors
Debtors
Cooperation grounded in legal frameworks
Media, Analysts
Media, Analysts
Release financial and operation results correctly and transparently.
Competitors
Competitors
Do not infringe on intellectual properties or attempt to collect confidential information

Management Guidelines

At the Board of Directors’ Meeting No. 1/2015 held on 2 March 2015, the Company approved a formal Anti-Corruption Policy to serve as a guideline for employee conduct, in conjunction with the existing Corporate Governance Policy and Business Code of Conduct. The policy has since been updated to align more closely with the current social context and was officially announced on 27 February 2025. This updated policy outlines operational measures related to anti-corruption that cover the following business activities:

1
Procurement
2
Giving and receiving gifts, souvenirs, and business entertainment
3
Charitable donations and sponsorships
4
Transactions with government authorities and liaison with government officials
5
Political activities support

In executing transactions with the public sector, the Company has signed the Integrity Pact of Cooperation on Prevention and Suppression of Corruption in Public Procurement to promote transparent and fair procurement. The Company has also signed integrity pacts and Suppliers’ Code of Conduct with trade partners and business partners in other sectors to support a network of cooperation in anti-corruption throughout the business chain.


Communication and Training

The Company has continuously communicated and educated employees about the Anti-Corruption Policy and related practices, as well as applicable laws, regulations, and other relevant policies. Employees at all levels have access to these policies through internal communication channels and the Company's website. Additionally, all new employees are informed of the Anti-Corruption Policy and related practices through the new employee orientation program. This is to ensure that all employees are well-informed and strictly adhere to the policies collectively.


Promoting Anti-Corruption Practices Throughout the Business Value Chain

The Company has implemented a No Gift Policy, which prohibits the giving or receiving of gifts. This policy is communicated to all employees via email, intranet, internal communication channels, and the Company's website to ensure awareness and compliance. All employees are encouraged to refrain from giving or accepting any form of gift in connection with their professional duties, especially during the New Year or other occasions, in interactions with customers, business partners, and other stakeholders. Additionally, the Company has communicated this policy to its partners and relevant external entities to ensure mutual understanding and support for the No Gift Policy.


Monitoring Compliance

The Company conducts ongoing monitoring to ensure adherence to the Corporate Governance Manual, with particular focus on issues such as the use of inside information for personal gain, prevention of conflicts of interest, and anti-corruption measures. Additionally, the Company provides channels for whistleblowing and complaint reporting to facilitate transparency and accountability.


Whistleblowing / Acceptance of Complaints

The Company allows the general public to file a complaint upon finding any behavior of directors, executives and employees, that is inappropriate or in conflict with the Company’s business code of conduct or any other matters that may cause damage to the Company or the Board of Directors. The complaints/whistleblowing may be reported through independent directors or members of the Audit Committee to:

The Secretary to the Audit Committee

Loxley Public Company Limited

102 Na Ranong Road, Khlong Toey, Khlong Toey, Bangkok 10110

Or E-mail address : ac@loxley.co.th

Whistleblowing Form

Key Developments
The Company has reviewed and revised the No Gift Policy
To prevent risks arising from transactions that may lead to corruption in its operations. It has also sought cooperation from business partners, affiliates, and relevant agencies to comply with this policy.
Over the past year, there have been no violations of the anti-corruption policy, nor any complaints
related to inappropriate behavior or breaches of the Company’s Business Code of Conduct by directors, executives, or employees. The results of compliance monitoring have been reported to the Company’s Board of Directors.
Training on the topic “Guidelines for Anti-Corruption in Organizations”
was held on 6 June 2025, with a total of 65 participants, including board members, senior executives, and relevant staff. The training aimed to build a fundamental understanding of anti-corruption practices in the procurement process and to foster a strong and transparent organizational culture for long-term sustainability.