24 Mar 2026

Anti-Corruption Policy Focus Mechanic Co., Ltd.

Anti-Corruption Mission Focus Mechanic Co., Ltd. adheres to good corporate governance in its business operations, striving to be an organization free from both internal and external corruption, and to serve as a part of supporting corporate governance in the business operations of the Thai industrial sector.

Anti-Corruption Policy Focus Mechanic Co., Ltd. prioritizes fair and transparent business operations. Therefore, the company has established practice guidelines for directors, executives, employees, and related parties to prevent corruption. This ensures that business decisions and operations that may involve corruption risks are considered and practiced with prudence, and as part of the organization's ESG (Environmental, Social, and Governance) policy implementation.

The development of this Anti-Corruption Policy aims to create organizational transparency, enabling the organization to operate efficiently and sustainably, building trust with customers, business partners, and stakeholders, and fostering a corporate culture rooted in integrity.

Building a culture focused on transparency helps all employees in the organization comply with ethical standards and relevant laws. Training and educating about the policy and related guidelines will enable employees to follow the policy correctly and effectively. Furthermore, encouraging employees and stakeholders to report suspected corruption and supporting fair investigations will strengthen a safe and trustworthy working environment for everyone in the organization.

Principles

1. Every work process must be transparent and auditable to prevent corruption.

2. Directors, executives, and employees of the company must strictly comply with the law and the Anti-Corruption Policy.

3. Promote participation among directors, executives, and employees in preventing corruption and reporting whistleblowing, and promote an organizational culture that does not tolerate any form of corruption.

4. The company provides an effective internal control system to reduce the risk of corruption.

5. The company provides an annual review of operations to ensure compliance with the Anti-Corruption Policy at least once a year.

Definitions

1. Corruption means the abuse of public power for personal benefit or bribery, and all conduct of individuals assigned duties and responsibilities in the public or private sectors that violates their duties inappropriately for their position as a state official, private agency official, agent, or other relationship status, with the intent to obtain any improper benefit for themselves or others.

2. Bribery means assets or any other benefits offered, promised, given, accepted, or requested to influence a decision in a manner that induces action or inaction in violation of duties and responsibilities.

3. Gift means any item with monetary value, including assets, cash equivalents, or items used for exchange for goods or services.

4. Giving Gifts means providing gifts, souvenirs, or any other assets according to custom, tradition, or local tradition, including occasions for expressing congratulations, gratitude, condolences, or expressions of goodwill and good relationships.

5. Hospitality means expenses for business entertainment, such as food and beverage hospitality, sports hospitality, and other expenses directly related to business practice or trade customs.

6. Donation means money or assets donated by the company for public benefit without expecting benefits that could be considered corruption.

7. Political Support means providing support to political parties in various forms, including giving or donating money, items, gifts, hospitality, or other forms of support that can be evaluated in monetary value, or providing indirect assistance such as advertising to support political parties or participating in political activities to gain a business advantage.

8. Facilitation Payment means a small amount of money paid to a government official unofficially only to ensure that the official will proceed according to the process or to stimulate a faster process where that process does not rely on the official's discretion.

9. Kickback means an amount of money negotiated to be deducted from the payment for goods and returned to the bribe recipient.

10. Conflict of Interest means actions where individuals, whether company employees, politicians, civil servants, or service recipients, have personal interests that influence their decisions or duty performance in their responsible position, affecting the public interest.

11. Government Official means political position holders, civil servants, or local employees with a permanent position or salary, employees or individuals working in state enterprises or government agencies, local executives, and local council members who are not political position holders, officials under local administration laws, including directors, sub-committees, employees of government agencies, state enterprises, or government agencies, and individuals or groups using or assigned administrative power of the state to perform any action under the law, whether established in the civil service system, state enterprise, or other state business.

12. Foreign Government Official means individuals holding legislative, executive, administrative, or judicial positions of a foreign state, and any individuals performing duties for a foreign state, including duties for government agencies or state enterprises, whether by appointment or election, permanent or temporary, and whether receiving a salary or other compensation or not.

13. Official of an International Organization means individuals working in an international organization or those assigned by an international organization to perform duties on its behalf.

14. Business Partner means sellers of goods or service providers, contractors, contract parties, and/or service providers, both legal entities and individuals, to the company.

15. Employee means those who are consented to work or provide benefits for or in the employer's business establishment.

16. External Stakeholder means individuals, groups, or agencies influencing the company's decision-making process, which can affect the company's goals and success. Stakeholders also include those affected by the company's decision-making process and those interested in the company's business operations.

17. Agent or Distributor: Agent means those with legal power to perform any action on behalf of another person, for example, the company has a policy to appoint official agents to pioneer the retail market.

18. Subsidiary means a company with a relationship in any of the following manners:

    1. A company related to the business operator by having a cross-shareholding structure, whether directly or indirectly, exceeding fifty percent of the total sold shares of that company.

    2. A company related to the business operator through mutual controlling power.

    3. A company whose controlling person is the same individual as the controlling person of the business operator.

Duties and Responsibilities

1. The Managing Director has the duty and responsibility to supervise the company's anti-corruption in overview, as well as define and approve policies and guidelines related to anti-corruption, and emphasize and support an effective anti-corruption system to ensure management recognizes the importance and instills it as a corporate culture.

2. The Managing Director has the duty and responsibility to supervise the internal control system, accounting system, and financial reports, including any other related processes according to the Anti-Corruption Policy, guidelines, and related laws, to ensure processes have an effective, adequate, and appropriate internal control system capable of preventing corruption risks.

3. The Accounting Department or assigned department has the duty and responsibility to audit and review the company's internal control system to comply with the Anti-Corruption Policy and guidelines, including related laws, and investigate corruption complaints to ensure the company has an effective internal control system and report audit results to senior management and the Managing Director.

4. Executives have the duty and responsibility to communicate and implement the Anti-Corruption Policy, including providing internal control systems in each work process, providing training and knowledge about the policy to personnel at all levels, and reviewing policies and guidelines to align with business changes and laws.

Anti-Corruption Practice Guidelines according to the Anti-Corruption Policy

1. Directors, executives, and employees at all levels are required to comply with the Anti-Corruption Policy. It is prohibited to accept any form of corruption, directly or indirectly, including giving/receiving money, items, gifts, hospitality, donations, government support, political help, and any other benefits to seek profit from those doing business with the company.

2. The company requires all departments to have measures to prevent corruption in line with the policy, including updating and reviewing systems and measures regularly, with periodic corruption risk assessments.

3. Directors, executives, and employees must not neglect or ignore when witnessing actions that fall under corruption related to the company and must notify supervisors or related persons.

4. The company provides whistleblowing channels for reporting suspected corruption from both internal employees and external persons, ensuring fairness and protection for informants or those who refuse corruption.

5. The company has a policy not to demote, punish, or provide negative consequences to personnel who refuse to give bribes, even if that action causes the company to lose business.

6. The company provides continuous communication of the policy through channels like e-mail, the website, and notice boards, and provides training for personnel.

7. The company emphasizes promoting understanding for those related to the company, such as business partners, stakeholders, agents, and distributors.

8. To build good business standards, the company has a "No Gift Policy" during New Year and other occasions, and has no policy to pay facilitation payments in any form.

To ensure clarity in practice and prevent corruption risks, directors, executives, and employees must perform duties with caution in the following matters:

Practice Guidelines for Giving Gifts Directors, executives, and employees can give gifts, souvenirs, or other benefits to stakeholders under the following conditions:

1. Giving according to social tradition and not violating the law. For example, in Thailand, the gift value must not exceed 3,000 THB per person per occasion according to NACC regulations.

2. Gifts must not be cash or cash equivalents (e.g., gift vouchers).

3. Gifts or souvenirs must be products that promote the company's image, such as promotional media, Royal Project products, community products, or sustainability-supporting products.

4. Giving gifts must be in the company's name only, not in a personal name.

5. Giving must be appropriate to the context and situation. During bidding processes, refrain from giving gifts to government officials or related agencies.

6. Giving must have no malicious intent to dominate, induce, or reward anyone improperly.

7. Do not give gifts to spouses, children, or related persons of officials, customers, or partners, as it may be considered receiving on their behalf.

8. Giving gifts must be requested for disbursement and approved by the company's authorized person only.

Practice Guidelines for Receiving Gifts The company maintains a "No Gift Policy" for New Year and other occasions. Personnel must explain this to partners and stakeholders.

1. Directors, executives, and employees are required to refrain from receiving items or benefits from partners or those related to the business.

2. If receiving is unavoidable (e.g., the partner is unaware of the policy or in a situation where refusal is impossible to maintain relationships), follow these steps:

   • 2.1 A manager-level employee or above shall represent the receipt.

   • 2.2 Immediately submit the item with a report form to the Human Resources Department.

   • 2.3 The HR Department will record it and collect items for donation to charity. Perishable items expiring within 1 month will be distributed to personnel as appropriate.

3. Souvenirs with a value not exceeding 500 THB (e.g., calendars, pens, notebooks with company logos) are allowed to be received by a manager-level representative and reported to HR for appropriate distribution.

4. Awards or souvenirs from competitions or business partner contracts can be received in the company's name and will be considered company assets.

Practice Guidelines for Hospitality Hospitality can be provided to partners and stakeholders under the following conditions:

1. Must be directly related to business operations (e.g., food, beverage, or sports hospitality).

2. Must be in the company's name only.

3. Must have a reasonable value and be appropriate to the situation. Refrain from hospitality during bidding processes with government officials.

4. Must not take place in inappropriate locations.

5. Must have no malicious intent to influence or reward improperly.

6. Must be recorded in a report form and approved by the authorized person.

Practice Guidelines for Donations

1. Donation of company money or assets must be in the company's name only.

2. Donations must be to foundations, public charities, temples, hospitals, schools, or social benefit organizations.

3. Donations must be transparent and legal, ensuring they are not used as an excuse for bribery.

4. The HR Department is responsible for checking documents:

   • 4.1 Request letter stating items, amount, and purpose.

   • 4.2 Photos, plans, or building designs of the location.

   • 4.3 Organization establishment documents (if any).

   • 4.4 Verify the reason and report for approval.

   • 4.5 Upon approval, coordinate delivery and take photos. If not approved, notify the requester.

   • 4.6 Submit all documents to the Accounting Department as evidence for tax auditing (Request letter, photos, establishment docs, thank-you letter/receipt).

5. HR shall follow up after donation to ensure it aligns with the purpose.

6. Report any abnormalities or corruption immediately to the Managing Director.

7. Personnel found intentionally fraudulent in donations will be responsible for damages and subject to severe disciplinary action.

Practice Guidelines for Funding Support

1. Must ensure funding is not used as an excuse for bribery.

2. Must not act as a mediator in offering money or assets to officials for improper privileges.

3. Contacts with government agencies must be transparent and legal.

4. Must prove the requester actually performs the project activities for business promotion or CSR.

5. Use of company money must be in the company's name only with clear business/reputation purposes and auditable evidence.

6. Requester must seek approval with recipient name, details, and purpose, attaching:

   • 6.1 Request letter stating amount/assets.

   • 6.2 Recipient's establishment documents.

   • 6.3 Project principles, reasons, goals, and objectives.

   • 6.4 Photos of promotional activities (if any).

7. Funding must be requested and approved by the authorized person.

Political Support Guidelines Focus Mechanic Co., Ltd. values political participation but maintains transparency and fairness: 7.1 Prohibit donating money or assets to political parties, directly or through foundations. 7.2 Prohibit using company resources (working time, vehicles, office equipment) for political activities. 7.3 Prohibit providing special privileges to political parties or members (discounts, free services, internal info). 7.4 The company supports employees' political participation as individuals using their personal time and resources.

Practice Guidelines for Facilitation Payments and Kickbacks The company has no policy to pay facilitation payments or kickbacks to government officials, customers, sellers, or other business partners in any form, directly or indirectly.

Procurement and Third-Party Hiring Procurement must follow company regulations, be transparent, auditable, legal, and without hidden interests. Using third parties to contact government agencies must not involve transferring bribes to those third parties.

Human Resources Management The company emphasizes HR's role in strengthening a culture of integrity and anti-corruption.

1. Selection and Recruitment: Based on suitability, knowledge, ability, and ethics. Avoid conflicts of interest or improper interference.

2. Performance Evaluation: Fair and transparent, covering both work achievements and ethical behavior. Any violation of the Anti-Corruption Policy will be a factor in evaluation.

3. Compensation and Promotion: Based on performance, ability, responsibility, and ethical conduct. No rewards for those violating the policy; disciplinary action will be taken instead.

Actions Violating the Anti-Corruption Policy All employees have a duty to comply. Violations include:

1. Failing to follow the Anti-Corruption Policy.

2. Advising or supporting others to not comply.

3. Ignoring or neglecting witnessed violations related to one's responsibility.

4. Obstructing or not cooperating with investigations.

5. Unfair treatment toward those who report violations. Neglecting or intentionally failing to comply is considered a severe disciplinary offense subject to company regulations and legal action if applicable.

Whistleblowing Channels Personnel and stakeholders can report misconduct or suspected corruption with details (date, time, place, involved persons, evidence) through:

• Suggestion and Complaint Box

• Direct Report to trusted supervisors, HR Manager, or Managing Director.

• By Post:

  • Contact: Managing Director, Focus Mechanic Co., Ltd.

  • Address: 16, 18 Soi Phatthanakan 53, Phatthanakan Rd., Phatthanakan, Suan Luang, Bangkok 10250

• E-mail: teewin@focusmecanic.co.th, tanakarn.tientongtip@focusmechanic.co.th

• Website: https://www.focusmechanic.co.th/TH/home.html

• Office of the National Anti-Corruption Commission (NACC):

  • Address: 361 Nonthaburi Rd., Tha Sai, Mueang, Nonthaburi 11000

  • Phone: 02-528 4800-49, Hotline: 1205

  • Website: https://wbs.nacc.go.th/

Complaint Investigation Process

1. A Complaint Committee is appointed (Management, Accounting, and HR representatives):

   • Management: Supervises and coordinates.

   • Accounting/Assigned Dept: Investigates and collects evidence.

   • HR: Audits fairness and supports involved employees.

2. Acknowledge and record the complaint in the system within 3 working days.

3. Start investigation within 10 working days of receipt.

4. Complete investigation and evidence collection within 30 working days.

5. Notify the result to the complainant within 14 working days after completion. If more time is needed, notify the complainant of the progress.

Announced and Effective on March 20, 2026, or reviewed on March 20, 2026.

Approved by:
Mr. Tawatchai Tientongtip
Managing Director

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