IFS Code of Business Conduct and Ethics

Vision

“To become the leading service organization in the country.”

Policy

IFS Group is committed to delivering service excellence, continuously developing and retaining high-quality personnel, upholding the highest standards of business ethics, and enhancing value for all stakeholders.

IFS Facility Services Co., Ltd. and its affiliated companies (“IFS Group”) are committed to developing organizational excellence across all areas of operation. The Company focuses on continuously improving human resources processes, operational resources, management systems, quality management, environmental management, occupational health and safety, and ethical business practices to ensure efficiency and effectiveness, maximize customer satisfaction, and support sustainable business operations.

The IFS Group Business Code of Conduct establishes guidelines and standards for employees, customers, suppliers, contractors, and business partners in accordance with the Company’s policies and operational principles. IFS Group is committed to respecting internationally recognized human rights and treating all workers with dignity and respect. This commitment applies to all categories of workers, including temporary workers, migrant workers, contract workers, directly employed workers, and all other forms of labor.

  1. Labor Standards

Employees shall not be required to pay any recruitment fees or any other employment-related fees to the Company.

  1. Freely Chosen Employment

IFS Group strictly prohibits all forms of forced labor, bonded labor, including debt bondage, involuntary labor, indentured labor, prison labor, slavery, and human trafficking.

The Company does not engage in or support the transportation, transfer, recruitment, harboring, or employment of individuals through threats, coercion, intimidation, abduction, fraud, or deception for labor or services.

Unreasonable restrictions on employees’ freedom of movement within Company facilities are strictly prohibited. This prohibition also applies to unreasonable restrictions on entering or leaving Company-provided facilities or accommodations.

Employees must receive written employment agreements in the local language containing complete and accurate terms and conditions of employment. Any amendments to employment conditions must comply with applicable local laws and provide equivalent or more favorable conditions to employees.

All work must be voluntary, and employees must have the right to resign or terminate their employment at any time in accordance with applicable laws and contractual obligations.

IFS Group shall not confiscate, destroy, conceal, withhold, or deny employees access to personal identification or immigration documents, including government-issued identification cards, passports, or work permits, except where required by law.

Employees shall not be required to pay recruitment fees or any other employment-related charges to the Company.

  1. Young Workers

IFS Group strictly prohibits child labor.

For the purposes of this policy, “child” refers to any person under the age of 15.

IFS Group does not employ workers under the age of 18 (“young workers”) due to the nature of the Company’s operations, which may involve hazardous working conditions, overtime work, and night shifts that may affect employee health and safety.

Accordingly, the Company only employs individuals who are at least 18 years of age.

  1. Working Hours

IFS Group establishes working hours in compliance with applicable labor laws and regulations.

Except in emergency or unusual circumstances, total working hours, including overtime, shall not exceed 72 hours per week. Employees are entitled to at least one day off during every seven-day period.

For operations performed under international customer standards, working hours may not exceed 60 hours per week, including overtime, depending on customer requirements and applicable standards.

  1. Wages and Benefits

IFS Group provides wages, compensation, and benefits in compliance with applicable laws and regulations, including minimum wage requirements, overtime compensation, and legally mandated employee benefits.

Employees shall receive overtime compensation at rates higher than regular hourly wage rates in accordance with applicable laws.

Wage deductions as a disciplinary measure are strictly prohibited.

The Company establishes clear payroll schedules for each pay period, as specified in employees’ employment agreements. Employees shall receive wage statements or payroll documentation to verify the accuracy of compensation for work performed.

The use of temporary workers, off-site workers, and outsourced personnel must comply with all applicable local legal requirements and restrictions.

  1. Humane Treatment

IFS Group is committed to maintaining a workplace free from harsh or inhumane treatment.

The Company strictly prohibits sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public humiliation, verbal abuse, or threats of such conduct toward employees.

IFS Group maintains clearly defined disciplinary policies and procedures to prevent and address such conduct and communicates these policies to all employees.

  1. Non-Discrimination

IFS Group is committed to providing a workplace free from unlawful harassment and discrimination.

The Company prohibits discrimination based on race, ethnicity, color, age, gender, sexual orientation, gender identity or expression, nationality, social origin, disability, pregnancy, religion, political affiliation, union membership, veteran status, protected genetic information, marital status, or any other protected characteristic under applicable law.

This commitment applies to all employment practices, including recruitment, wages, promotions, rewards, training opportunities, and other employment-related decisions.

Employees shall be provided reasonable accommodation for religious practices where appropriate and legally required.

Employees and prospective employees shall not be subjected to medical examinations or physical fitness tests that may result in discriminatory treatment unless required by law or necessary for workplace safety.

  1. Freedom of Association

In accordance with applicable local laws, IFS Group respects employees’ rights to freely establish and join labor unions, engage in collective bargaining, and participate in peaceful assembly.

The Company also respects the rights of employees who choose not to participate in such activities.

Employees and/or their representatives must be able to openly communicate and share ideas, concerns, and feedback with management regarding working conditions and management practices without fear of discrimination, retaliation, intimidation, punishment, or harassment.

  1. Health and Safety

IFS Group recognizes that, in addition to reducing workplace injuries and occupational illnesses, a safe and healthy working environment enhances operational effectiveness, service quality, employee retention, employee morale, and customer satisfaction while supporting compliance with applicable standards and requirements.

The Company also recognizes that providing employees with continuous information, education, and training is essential to identifying and resolving workplace health and safety concerns.

Recognized management systems and standards, including ISO 45001 and applicable International Labour Organization (ILO) occupational health and safety guidelines, are used as references in establishing this Business Code of Conduct and related safety management practices.

  1. Occupational Safety

IFS Group provides occupational safety training to ensure that employees possess the knowledge and competencies necessary to safely perform work involving potential hazards, including but not limited to chemical hazards, electrical hazards, other energy sources, fire hazards, vehicle hazards, and fall hazards.

Potential workplace hazards must be identified and assessed. Appropriate controls shall be implemented through engineering controls, administrative controls, preventive maintenance programs, and safe work procedures, including lockout and tagout procedures.

IFS Group provides ongoing occupational health and safety training to employees.

Where hazards cannot be adequately controlled through these measures, employees shall be provided with appropriate, properly maintained personal protective equipment (“PPE”) and educational materials regarding associated workplace risks.

The Company also maintains procedures to protect pregnant employees and nursing mothers from high-risk working conditions and workplace health and safety hazards, including work-related risks, and provides appropriate facilities for nursing mothers where applicable.

  1. Emergency Preparedness

IFS Group identifies and evaluates potential emergency situations and events and implements measures to minimize their impact through emergency preparedness plans and response procedures.

Emergency response measures include emergency reporting procedures, employee notification systems, evacuation procedures, annual fire drills and evacuation exercises, appropriate fire detection and fire suppression equipment, adequate emergency exits, and post-incident recovery plans.

Emergency preparedness and response plans shall focus on minimizing risks and damage to human life, the environment, and property.

  1. Occupational Injury and Illness

IFS Group implements procedures and systems to prevent, manage, monitor, investigate, and report work-related injuries and occupational illnesses.

These procedures include measures to encourage employee reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate root causes, implement corrective actions, and facilitate employees’ return to work where appropriate.

  1. Industrial Hygiene

IFS Group assesses employees’ exposure to chemical, biological, and physical hazards.

Potential hazards must be identified, evaluated, and controlled in accordance with the hierarchy of controls. Hazards must be eliminated or controlled through appropriate engineering, administrative, and operational measures wherever possible.

Where risks cannot be adequately controlled through such measures, employees shall receive appropriate and properly maintained personal protective equipment.

IFS Group also conducts annual medical examinations for employees in high-risk positions.

Prevention programs shall include educational materials regarding the risks associated with workplace hazards.

  1. Physically Demanding Work

IFS Group evaluates and manages risks associated with physically demanding work, including manual material handling, repetitive lifting, heavy lifting, prolonged standing, repetitive tasks, and labor-intensive work activities.

Such risks must be identified, assessed, and appropriately controlled.

  1. Machine Safeguarding

IFS Group provides training to employees who operate cleaning equipment and machinery related to Company operations.

The Company conducts machinery safety assessments where equipment may present risks of injury to employees.

Appropriate physical guards, locking devices, and protective systems shall be implemented. Qualified technical personnel shall perform maintenance, inspections, and repairs of equipment and machinery at designated intervals to ensure proper operation and safety.

  1. Sanitation, Food, and Housing

IFS Group provides clean restroom facilities, safe drinking water, hygienic food preparation and storage areas, and sanitary dining facilities.

Employee dormitories or accommodations provided by the Company or its representatives shall be maintained in a clean, safe, and sanitary condition and equipped with appropriate emergency measures, adequate ventilation, secure personal storage areas for valuables and personal belongings, and reasonable freedom of entry and exit.

  1. Health and Safety Communication

IFS Group provides employees with appropriate health and safety information and training in languages understood by employees.

Employees shall receive information regarding identified workplace hazards to which they may be exposed, including but not limited to machinery, electricity, chemicals, fire hazards, and physical hazards.

Health and safety information shall be clearly posted within Company facilities or in designated locations accessible to employees.

Employees shall receive health and safety training prior to beginning work and on an ongoing basis thereafter.

IFS Group encourages all employees to recognize and uphold the importance of workplace safety.

  1. Environmental Responsibility

IFS Group recognizes that environmental responsibility is an essential component of global business operations. Operational activities must minimize adverse impacts on communities, the environment, and natural resources while protecting public health and safety.

Recognized management systems and standards, including ISO 14001, are used as references in establishing this Business Code of Conduct and may serve as additional sources of guidance regarding environmental standards and best practices.

  1. Environmental Permits and Reporting

All required environmental permits, approvals, registrations, and monitoring requirements, including those related to waste discharge monitoring, shall be obtained, maintained, updated, and managed in accordance with applicable laws and regulations.

IFS Group shall comply with all applicable environmental reporting requirements.

  1. Pollution Prevention and Resource Conservation

IFS Group implements programs and initiatives to minimize emissions, pollutant discharges, and waste generation, including eliminating pollution at the source where feasible.

Such initiatives may include the installation of pollution control equipment, improvements to operational processes, preventive maintenance activities, utility management improvements, and other appropriate measures.

The Company is committed to conserving natural resources, including water, fossil fuels, minerals, and forest products, through operational improvements, maintenance programs, material substitution, reuse, conservation, recycling, and other sustainable practices.

  1. Hazardous Substances

IFS Group identifies and labels chemicals and other hazardous substances that may pose risks to the environment if released.

Appropriate measures shall be implemented to ensure the safe handling, transportation, storage, recycling, reuse, and disposal of hazardous substances in accordance with applicable legal and regulatory requirements.

  1. Solid Waste Management

IFS Group implements systematic waste segregation practices and is responsible for identifying, managing, reducing, recycling, and disposing of non-hazardous solid waste in an environmentally responsible manner.

  1. Air Emissions

IFS Group primarily provides cleaning and facility services at customer locations and is not directly engaged in manufacturing operations.

Accordingly, the Company does not operate production systems involving direct emissions of volatile organic compounds (VOCs), aerosols, corrosive substances, particulate matter, ozone-depleting substances, or combustion-related emissions associated with manufacturing activities.

Where applicable, any air emissions shall be identified and appropriately managed prior to release into the atmosphere in accordance with applicable environmental requirements.

  1. Materials Restrictions

IFS Group complies with applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and operations, including requirements related to recycling and disposal labeling.

  1. Water Management

IFS Group implements water management programs within Company facilities and offices.

Such programs include maintaining records, characterizing and monitoring water sources, water consumption, and wastewater discharge, identifying opportunities for water conservation, and controlling potential contamination pathways.

All wastewater shall be identified, monitored, controlled, and treated as required prior to discharge or disposal.

The Company regularly monitors the performance of wastewater treatment and containment systems to ensure operational effectiveness and compliance with applicable legal and regulatory requirements.

  1. Energy Consumption and Greenhouse Gas Emissions

IFS Group promotes employee awareness regarding energy consumption and greenhouse gas emissions through ongoing communication and education initiatives.

As the Company is not engaged in manufacturing operations, it does not maintain manufacturing-related energy consumption control systems or records.

However, IFS Group supports initiatives aimed at improving energy efficiency and minimizing energy consumption and greenhouse gas emissions throughout its operations.

  1. Ethics

To demonstrate corporate social responsibility and maintain successful relationships with customers, suppliers, business partners, and stakeholders, IFS Group is committed to upholding the highest standards of ethical conduct, including the following principles:

  1. Business Integrity

IFS Group upholds the highest standards of integrity in all business activities.

The Company maintains a strict zero-tolerance policy toward corruption, bribery, extortion, fraud, and all other forms of unethical or unlawful conduct.

  1. No Improper Advantage

IFS Group prohibits the offering, promising, authorizing, giving, soliciting, or accepting of bribes or any other improper advantage intended to obtain inappropriate business benefits.

This prohibition includes offering, promising, authorizing, giving, or accepting anything of value, whether directly or indirectly, for the purpose of obtaining or retaining business, directing business to any individual or organization, or securing any improper advantage.

The Company maintains monitoring, auditing, and enforcement procedures to ensure compliance with applicable anti-corruption laws and regulations.

Employees who violate Company rules, policies, or anti-corruption requirements shall be subject to disciplinary action.

  1. Disclosure of Information

All business transactions and negotiations shall be conducted transparently and accurately reflected in business records and documentation.

Information regarding labor practices, occupational health and safety, environmental practices, business activities, organizational structure, financial condition, and operational performance shall be disclosed in accordance with applicable laws, regulations, and industry practices.

The falsification of records or misrepresentation of conditions or practices within the supply chain is strictly prohibited.

  1. Intellectual Property

IFS Group respects intellectual property rights.

The transfer of technology and know-how must be conducted in a manner that protects intellectual property rights.

Customer and supplier information must be properly safeguarded and protected from unauthorized access, disclosure, or misuse.

  1. Fair Business, Advertising, and Competition

IFS Group is committed to maintaining fair business practices, ethical advertising standards, and fair competition.

The Company complies with all applicable competition and antitrust laws and prohibits anti-competitive conduct.

  1. Protection of Identity and Non-Retaliation

IFS Group maintains programs and procedures to protect the confidentiality, anonymity, and identity of employees, suppliers, and whistleblowers who report concerns or misconduct, unless disclosure is required by law.

The Company provides communication channels through which personnel may report concerns without fear of retaliation, intimidation, discrimination, or harassment.

  1. Responsible Sourcing of Minerals

IFS Group primarily provides cleaning and facility services and is not directly involved in manufacturing operations.

However, where applicable, the Company conducts appropriate due diligence regarding the sourcing and chain of custody of minerals and will provide customers with available due diligence information upon request.

  1. Privacy

IFS Group is committed to protecting personal information and privacy in accordance with reasonable expectations and applicable legal requirements.

This commitment applies to suppliers, customers, consumers, employees, and all parties conducting business with the Company.

IFS Group complies with applicable data privacy, information security, and confidentiality laws and regulations regarding the collection, storage, processing, transmission, sharing, and protection of personal information.

  1. Management Systems

IFS Group has implemented and established management systems within the scope of this Business Code of Conduct.

The management systems shall be designed to:

(a) comply with applicable laws, regulations, and customer requirements related to the Company’s business operations and services;
(b) comply with this Business Code of Conduct; and
(c) identify and mitigate operational risks related to this Business Code of Conduct.

The management systems should support continuous improvement and include the following fundamental elements:

  1. Company Commitment

IFS Group maintains corporate social and environmental responsibility policy statements that confirm the Company’s commitment to compliance and continuous improvement.

These policy statements are approved by executive management and posted in the local language within Company facilities.

  1. Management Accountability and Responsibility

IFS Group appoints senior executives and Company representatives responsible for implementing the management systems and related programs.

Senior management regularly reviews the status and effectiveness of the management systems.

  1. Legal and Customer Requirements

IFS Group maintains processes to identify, monitor, and understand applicable laws, regulations, customer requirements, and the requirements of this Business Code of Conduct.

  1. Risk Assessment and Risk Management

IFS Group maintains processes to identify legal compliance risks, environmental risks, occupational health and safety risks, labor practice risks, and ethical risks related to business operations.

The Company assesses the significance of each identified risk and implements appropriate procedures and physical controls to manage such risks in compliance with applicable regulations.

  1. Improvement Objectives

IFS Group establishes written objectives, targets, and action plans to improve social and environmental performance.

The Company periodically evaluates progress and achievement against such objectives.

  1. Training

IFS Group provides ongoing training to supervisors, department managers, and employees to update relevant information, implement Company policies, work procedures, and improvement objectives, and ensure compliance with applicable laws and regulations.

  1. Communication

IFS Group maintains processes for clearly and accurately communicating Company policies, practices, expectations, and performance to employees, suppliers, and customers.

  1. Employee Feedback, Participation, and Grievance Mechanisms

IFS Group maintains ongoing processes, including effective grievance mechanisms, to assess employee understanding and obtain feedback regarding workplace practices and working conditions covered by this Business Code of Conduct.

These processes support continuous improvement.

  1. Audits, Monitoring, and Assessment

IFS Group appoints a committee responsible for the management systems.

The Company conducts periodic self-assessments to ensure compliance with applicable laws and regulations, this Business Code of Conduct, and customer requirements related to social and environmental responsibility.

  1. Corrective Action Process

IFS Group maintains a timely corrective action process to address deficiencies identified through internal or external assessments, audits, inspections, investigations, and management reviews.

  1. Documentation and Records

IFS Group creates and maintains documents and records to ensure regulatory compliance and conformity with Company requirements.

Confidentiality shall be maintained as appropriate to protect privacy.

  1. Supplier Responsibility

IFS Group maintains processes to communicate the requirements of this Business Code of Conduct to suppliers and to monitor supplier compliance with this Code.

Company Policies

Anti-Retaliation Policy

IFS Facility Services Co., Ltd. and its affiliated companies encourage and support the reporting of any fraudulent or corrupt conduct that may damage the Company’s reputation, credibility, customer trust, trust of business contacts, or otherwise cause harm to the Company.

If a report or complaint is received through any reporting channel, IFS Group will review and investigate the facts in accordance with Company procedures.

IFS Group confirms that it will not tolerate retaliation against any person who reports concerns in good faith.

Any person who believes that they have been subjected to any form of retaliation should report the matter as soon as possible to the Central Human Resources Department.

Any violation of or failure to comply with this policy by any employee will be subject to disciplinary investigation in accordance with Company procedures and may result in a warning, disciplinary action, or termination of employment. In addition, civil and criminal legal proceedings may be pursued if intentional misconduct is found.

Measures to Prevent and Stop Workplace Violence

Definition of Workplace Violence

Workplace violence means any behavior or action, including threats, use of violence, abuse, disturbance, harassment, intimidation, or threats of any kind occurring in the workplace that violates an individual’s physical or mental rights.

Expected Conduct to Prevent Workplace Violence

  1. All employees should respect colleagues, supervisors, and subordinates.
  2. All employees should reduce the risk of workplace violence by avoiding sarcastic, aggressive, mocking, hostile, rude, or impolite language; avoiding disputes or fights in the workplace; and not bringing weapons into the workplace.
  3. All employees should help monitor and report risky behavior to supervisors to prevent incidents that may lead to workplace violence. Employees should not ignore such issues if they occur with colleagues.
  4. Supervisors at all levels must act as good role models and have direct responsibility for preventing workplace violence.

Prohibited Conduct Constituting Workplace Violence

  1. Verbal conduct, such as mocking, sarcasm, threats, shouting, insults, or rude language that affects a person’s mental well-being and violates personal rights.
  2. Physical conduct, such as restricting freedom, fighting, kicking, punching, beating, or physically assaulting another person, resulting in physical or mental harm.
  3. Other conduct, such as displaying images, objects, or messages that express violence and affect the physical or mental well-being of individuals in the workplace.

Workplace Violence Resolution Process

  1. Where the matter can be resolved directly, the affected person or injured party may write to the offender to notify them that the behavior is unacceptable or request that the conduct stop.
  2. Where the matter cannot be resolved directly, the following actions shall be taken:

A complaint may be submitted to the offender’s supervisor after the incident occurs. The supervisor shall investigate the facts within 15 days. Failure to take any action shall be deemed neglect of duty.

A complaint may be submitted to the responsible department or designated responsible person. A meeting shall be arranged to discuss resolution of the matter and consider disciplinary action against the offender within 15 days.

Complaint Receiving Units

Complaints may be submitted to:

  • The offender’s supervisors at all levels
  • Legal Department: Legal Manager
  • Human Resources Department: Human Resources Manager and authorized personnel
  • 24-Hour Control Room for incident notification and reporting

Complaint Channels and Methods

Complaints may be submitted through the following methods and channels:

  1. Verbal complaint directly to the offender’s immediate supervisor or by telephone, where a written complaint cannot be submitted.
  2. Written complaint addressed to the executives of IFS Facility Services Co., Ltd. and its affiliated companies through any of the following complaint channels:

– Department complaint box
– Postal mail: 365/1 Phahonyothin Road, Anusawari, Bang Khen, Bangkok 10220, Thailand
– Email: info@ifs-thailand.com
– Line: @IFSTHAILAND
– 24-Hour Control Room for incident notification and reporting: 02-038-5188 Ext. 3116, 3118

Anti-Corruption, Anti-Bribery, Giving and Receiving Bribes Policy

IFS Facility Services Co., Ltd. and its affiliated companies are committed to conducting business with social responsibility and in accordance with the highest social and ethical standards under this Business Code of Conduct.

Corruption, bribery, or any attempt to engage in such conduct in the Company’s business operations is contrary to the Company’s core values and is strictly unacceptable.

All employees must strictly comply with the Company’s working practices in every activity related to business operations and must reject and oppose corruption in all forms, whether involving the public or private sector.

For the purposes of this policy, corruption and bribery include the abuse of power or authority for personal benefit or the benefit of others, including bribery, extortion, fraud, deception, collusion, bid-rigging, embezzlement, money laundering, promising, giving, accepting, or soliciting benefits in any form that induce any action contrary to law or contrary to duties and responsibilities.

All employees must comply with this policy.

The following conduct is prohibited:

  1. Soliciting, arranging, or accepting bribes for the benefit of Company employees or for the benefit of persons related to them.
  2. Offering, promising, or giving bribes to government officials or private-sector officials, whether directly or indirectly, on behalf of or for the benefit of the Company.
  3. Abusing authority or position dishonestly.
  4. Engaging in dishonest collusion for personal benefit in any form that violates the law or conflicts with duties and responsibilities.

Any violation of or failure to comply with this policy by any employee will be subject to disciplinary investigation in accordance with Company procedures and may result in a warning, disciplinary action, or termination of employment.

Civil and criminal legal proceedings may also be pursued if intentional violation or non-compliance is found.

General Provisions

Personnel at all levels of IFS Group, including employees, agents, affiliated companies, and any person acting for or on behalf of the Company, whether or not authorized to do so, must comply with the following guidelines:

  1. Comply with the Anti-Corruption, Anti-Bribery, Giving and Receiving Bribes Policy, the Business Code of Conduct, and all Company rules, regulations, and requirements, and must not be involved in corruption in any form, whether directly or indirectly.
  2. Perform duties transparently, including being prepared at all times for audits or reviews by the Company, IFS Group, or relevant authorities.
  3. Not engage in any act that indicates intent to commit corruption, bribery, or the giving or receiving of bribes involving persons connected with IFS Group in matters under their responsibility, whether directly or indirectly, for the benefit of the organization, themselves, or related persons.
  4. Directors, executives, employees, and any third parties related to the Company are prohibited from engaging in bribery, including giving, offering, or promising to give assets or any other benefits, or inducing participation in any action, whether directly or indirectly, that provides an advantage in bidding or supports bid-rigging with government agencies, resulting in an unfair advantage or improper benefit in procurement, contracting, or contract performance, whether before, during, or after bidding or contract execution, or for the purpose of securing any other improper benefit contrary to business ethics.
  5. Not ignore or neglect any suspected act of corruption involving the Company or IFS Group. Employees have a duty to report such matters to their supervisors or responsible persons and cooperate in fact-finding investigations.
  6. Directors, executives, and employees at all levels are prohibited from accepting gifts whose value exceeds customary and reasonable social practices.
  7. Directors, executives, and employees at all levels are prohibited from entering into transactions with the Company for their own benefit or for the benefit of related persons, except where such transactions are conducted at fair market value and in the ordinary course of business.
  8. Directors, executives, and employees at all levels who have a conflict of interest are prohibited from participating in the Company’s procurement decision-making process.
  9. Directors, executives, and employees at all levels have a duty and responsibility to safeguard and use Company assets for the maximum benefit of the Company and must not use such assets for personal benefit or for the benefit of related persons.
  10. The payment of money, provision of valuables, or provision of services, such as gifts, entertainment, or travel, to government officials, foreign government officials, or officials of international organizations, whether directly or indirectly, to cause such persons to act or refrain from acting unlawfully is strictly inappropriate and prohibited. This also includes encouraging or participating in such conduct by others.

Roles and Responsibilities

  1. Board of Directors

The Board of Directors shall review and approve risk management system assessment policies, including providing guidance and support for actions to reduce or control risks that may give rise to corruption in all Company activities. This is to ensure that employees at all levels understand, recognize, and consistently give importance to this matter.

In the event that the Audit Committee reports any corrupt conduct that affects the Company, the Board of Directors shall provide consultation, recommendations, and consideration of disciplinary measures, and shall work with the Executive Committee and the President to determine corrective measures to prevent the recurrence of such incidents or similar incidents.

  1. Audit Committee

2.1 The Audit Committee shall review the financial and accounting reporting systems, internal control systems, internal audit systems, and risk management systems to ensure that they are accurate, transparent, rigorous, appropriate, current, effective, and in accordance with international standards.

2.2

The Audit Committee shall receive whistleblowing reports of corrupt conduct and complaints involving persons within the organization, investigate the facts as reported, and submit the matter to the Board of Directors for joint consideration of disciplinary action or corrective measures.

  1. Board of Directors

3.1 The Board of Directors shall establish the anti-corruption policy and regularly review the policy to ensure that it remains appropriate for changes in the nature of the business, rules, regulations, or legal requirements relevant to the Company’s business operations, and shall submit the policy to the Audit Committee.

3.2

The Board of Directors shall communicate, provide training, and promote continuous awareness among Company employees and relevant parties regarding the anti-corruption policy and related practices.

3.3 The Board of Directors shall investigate and support all processes for fact-finding based on reports received or as assigned by the Audit Committee when corruption occurs. The Executive Committee and the President may assign members of the management team deemed capable of supporting the fact-finding process.

  1. Internal Audit Department

4.1 The Internal Audit Department shall perform audit and review duties in accordance with the annual internal audit plan approved by the Audit Committee. It shall submit reports on internal control audits and corruption risk assessments identified during audits to the Audit Committee immediately when any finding may cause a serious issue if not promptly addressed.

4.2 The Internal Audit Department shall perform duties assigned by the Audit Committee regarding investigations of corruption related to the organization outside the annual internal audit plan.

Guidelines for Compliance with the Anti-Corruption Policy

Conflict of Interest Guidelines

1. Employees shall perform their duties in the best interests of the Company, in compliance with laws and ethics, and with fairness and transparency.

2. Employees shall avoid involvement in any activities that may create a conflict of interest with the Company and shall not engage in any business that competes with or is similar to the Company’s business.

3. Employees shall not seek personal benefit from information or anything learned through their position, duties, or responsibilities.

4. Employees shall avoid engaging in any work outside the Company that may affect their responsibilities in any respect.

5. Directors and executives are required to report to the Company any interests held by themselves and/or related persons that are relevant to the Company’s management, including any direct or indirect shareholdings in the Company.

6. The Board of Directors and executives shall carefully, honestly, reasonably, and independently consider conflicts of interest involving connected transactions between the Company, its subsidiaries, and/or associated companies, within a sound ethical framework and with regard to the best interests of the Company. They shall comply with the rules of the Stock Exchange of Thailand and the Securities and Exchange Commission, and ensure that related information is disclosed accurately and completely.

Securities Trading and Use of Inside Information Guidelines

1. The preparation, maintenance, or disclosure of inside information must be carried out appropriately and in compliance with legal requirements, with consideration given to the overall impact on stakeholders.

2. Employees shall not use inside information relating to business operations or management that they become aware of through their duties to improperly seek benefits for themselves or others.

3. Directors and executives should avoid trading the Company’s securities during the period of 21 days prior to the disclosure of annual or quarterly financial reporting information until 24 hours after such information has been publicly disclosed.

4. Directors, executives, and employees must not disclose information that has not been publicly disclosed and must not trade the Company’s securities when they are aware of non-public information.

Procurement Guidelines

1. Procurement must be conducted in accordance with the criteria or procedures prescribed in the Company’s procurement regulations and consistent with the applicable authority levels. Procurement must be fair to all relevant parties. Decision-making must consider the reasonableness of price, quality, and services received, as well as applicable standards that suppliers or service providers should maintain, such as environmental standards and industry standards.

2. Procurement personnel must not engage in any business that may provide personal benefit by using their procurement position, whether directly or indirectly.

3. Procurement personnel must not use information obtained through procurement activities for personal benefit or for the benefit of others.

4. Directors, executives, employees, and any third parties related to the Company are prohibited from engaging in bribery. This includes giving, offering, or promising to give assets or any other benefits, or inducing any person to participate in any action, whether directly or indirectly, that provides an advantage in bidding or supports bid-rigging with government agencies, resulting in an unfair advantage or improper benefit in procurement, contracting, or contract performance, whether before, during, or after bidding or contract execution, or for the purpose of securing any other improper benefit contrary to business ethics.

Forms of corruption include political contributions, charitable donations made to benefit the Company’s business, sponsorships intended to create a business advantage for the Company, and other expenses that may serve as channels for relevant persons to engage in corruption, such as gifts and customer hospitality. Such conduct may lead to the improper use of authority, including bribery of government officials, giving gifts or services, giving cash or cash equivalents, and bid-rigging.

 

Government Relations Guidelines

1. IFS Group shall strictly comply with all applicable laws and relevant procedures.

2. In conducting transactions with government agencies or interacting with government officials, all actions must be carried out properly, transparently, and directly. Employees must not take any action that may induce a government official to perform or refrain from performing any duty.

3. Establishing acquaintances or maintaining appropriate relationships on customary occasions, festivals, or traditional events may be permitted, provided that such conduct remains within appropriate boundaries.

4. Supporting government activities or donating assets may be permitted only through a proper and transparent approval process and within an appropriate value limit.

Guidelines for Giving or Receiving Gifts, Assets, or Any Other Benefits That May Influence Decision-Making

1. “Gift expenses” refer to expenses incurred in the Company’s activities to build positive business relationships or, on certain occasions, as an expression of social courtesy.

Gifts may take various forms, including money, goods, services, gift cards, or similar items. Such expenses may be considered bribes if they are provided to induce a government official to act improperly or in violation of official duties.

2. Employees should not receive or provide hospitality, gifts, souvenirs, or any other expenses that are excessive, unnecessary, or inappropriate for government officials or persons conducting business with the Company.

Giving or receiving such items in accordance with customary practice, tradition, culture, or social courtesy may be acceptable, provided that it is reasonable, appropriate, and consistent with Company policies, regulations, and customary practices for each occasion.

Supporting documentation for expenses must be retained. Expenses must be recorded based on actual amounts incurred, and receipts or supporting evidence must be maintained for future verification.

3. Employees must not solicit, receive, or provide money, assets, goods, or any other benefits to business-related parties where such conduct may unfairly influence any decision, is intended to induce an improper act or omission, or is provided in exchange for an undue privilege.

Hospitality Guidelines

1. “Hospitality expenses” refer to expenses incurred in the Company’s activities to build positive business relationships or, on certain occasions, as an expression of social courtesy.

Hospitality expenses may include accommodation, transportation for site visits or study visits, meals, and beverages. Such expenses may be considered bribes if they are provided to induce a government official to act improperly or in violation of official duties.

2. Hospitality provided to government agencies or government officials on each occasion must not exceed the value permitted by law.

Such expenses must not be paid to induce a government official to act improperly, perform or refrain from performing any duty, or make any decision for the Company’s business benefit.

All hospitality expenses must be recorded based on actual amounts incurred, and receipts or supporting documentation must be maintained.

3. Business hospitality expenses should be used appropriately and must reflect actual expenses incurred.

Such expenses must be reported and/or approved by the supervisor of the relevant business function in accordance with the Company’s approval authority matrix.

4. Reimbursement of hospitality expenses must not include expenses incurred by employees’ family members.

Facilitation Payment Guidelines

1. “Facilitation payments” refer to small, unofficial payments made to government officials solely to ensure that the official performs a routine process or to expedite such process.

Such process must not require the government official’s discretion, must be a lawful duty of that government official, and must involve a legal right that the Company is already entitled to receive, such as obtaining permits, certificates, or public services.

2. IFS Group has no policy to make facilitation payments.

However, a facilitation payment may be made only where an employee is in a situation involving a threat to physical safety or reasonably believes that their life is in danger.

If such payment is made, the employee must prepare written documentation and submit it to their supervisor for review.

The purpose and nature of the payment must be accurately recorded.

Charitable Donation and Sponsorship Guidelines

1. IFS Group supports charitable donations and sponsorships that contribute to community and social development, improve quality of life, strengthen the economy, and enhance the resilience of communities and society.

Charitable donations and sponsorships provided to charitable organizations or other entities must be reviewed and approved by the Board of Directors or an authorized person of the Company.

A written request must be prepared, specifying the name of the donation or sponsorship recipient and the purpose of the donation or sponsorship, together with all supporting documents.

The request must be submitted to the authorized approver for consideration in accordance with the Company’s approval authority levels.

The Company must maintain review, monitoring, and verification processes, as well as evidence or acknowledgment letters from the receiving organization, to ensure that funds are used for the stated purpose.

2. Sponsorship is one method of promoting the Company’s business and is distinct from charitable donations.

Sponsorship may take various forms, including support for cultural, arts, educational, or similar activities.

3. Employees must exercise caution to ensure that charitable donations and sponsorships are not used as a means to avoid anti-bribery controls or conceal bribery.

All charitable donations and sponsorships must be conducted transparently and in compliance with applicable laws.

Political Contribution Guidelines

1. “Political contributions” refer to both monetary and non-monetary support provided to political parties, politicians, or political candidates.

Non-monetary support includes lending or donating equipment, providing technology services free of charge, and allowing employees to spend working hours on political activities.

2. IFS Group does not engage in providing assistance, support, or representation for any political party in public activities, whether through financial contributions or any other form of support.

The Company shall not take any action that may cause others to believe that IFS Group is politically affiliated with, supports, or favors any political party or political authority, whether directly or indirectly.

3. If IFS Group intends to provide political support for the promotion of democratic principles, such support must comply with all applicable laws and must not be made with the expectation of receiving special treatment or improper benefits in return.

Any political contribution must be supported by a written request specifying the recipient and purpose of the contribution, together with all supporting documents, and submitted to the Executive Committee for approval.

4. Directors, executives, and employees have the legal right to political freedom and participation. However, they must not engage in any activity that may compromise the Company’s neutrality or cause damage to IFS Group as a result of political involvement.

5. Directors, executives, and employees must not conduct political activities within Company premises or use any Company resources for political purposes.

Training and Communication Guidelines

All executives and employees shall receive regular training on anti-bribery and anti-corruption practices to ensure awareness and understanding of this policy.

Training shall include various forms of bribery, risks associated with involvement in bribery or corruption, and procedures for reporting suspected or observed bribery or corruption.

All employees shall receive a copy of this policy to ensure they understand the Company’s anti-bribery and anti-corruption requirements.

Employees may also access the policy and any updated information through the Company’s official website and communication channels. The Company shall notify employees of any significant changes to the policy.

Training on this policy shall form part of the orientation process or pre-employment onboarding for all new employees of IFS Group.

Whistleblowing and Complaint Reporting Channels and Protection Measures

IFS Group provides reporting channels for employees and stakeholders to report violations, fraud, corruption, or misconduct.

The Company has established investigation procedures, protection measures, and remediation processes for whistleblowers and complainants in accordance with the Company’s Whistleblowing and Complaint Handling Policy.

Disciplinary Actions

Any violation of, or failure to comply with, the following policies and guidelines shall result in disciplinary action in accordance with the Company’s work rules and regulations:

  1. Anti-Corruption Policy Guidelines
  2. Conflict of Interest Guidelines
  3. Securities Trading and Insider Information Guidelines
  4. Procurement and Purchasing Guidelines
  5. Government Relations Guidelines
  6. Guidelines for Giving or Receiving Gifts, Assets, or Other Benefits That May Influence Decision-Making
  7. Hospitality Guidelines
  8. Facilitation Payment Guidelines
  9. Charitable Donation and Sponsorship Guidelines
  10. Political Contribution Guidelines
  11. Training and Communication Guidelines

Violators may also be required to compensate the Company or affected parties for any damages resulting from such misconduct and may be subject to civil or criminal penalties if the conduct violates applicable laws.

 

Whistleblowing and Fraud Complaint Policy

In accordance with the principles of good corporate governance regarding stakeholder responsibility, the Board of Directors of IFS Group has approved the Whistleblowing and Fraud Complaint Policy as a mechanism to enable the Company to receive reports and complaints concerning violations of laws, work regulations, Company policies, and the Company’s Code of Business Conduct that may result in damage to the Company’s assets, reputation, or credibility.

The policy applies to reports submitted by employees and all groups of stakeholders. IFS Group encourages the disclosure of information related to fraud, bribery, corruption, or misconduct. Employees and business partners who report information in good faith shall be protected from retaliation, discrimination, or unfair treatment.

The Company has established the following whistleblowing policy and reporting procedures.

Communication and Disclosure of the Whistleblowing and Complaint Policy

The Human Resources Department shall communicate and promote understanding of the Whistleblowing and Complaint Policy, complaint handling procedures, and reporting channels to directors, executives, employees, and all stakeholder groups.

The policy shall also be disclosed through appropriate communication channels, including monthly management meetings and the Company’s official website.

Whistleblowing and Complaint Reporting

1. Directors, executives, employees, and all stakeholder groups who become aware of any violation of the Company’s Code of Business Conduct may submit whistleblowing reports or complaints to the Chairman of the Audit Committee, designated complaint handling units, or the Human Resources Department.

2. Whistleblowing reports or complaints should include the complainant’s full name, contact number, factual details, supporting evidence, and any relevant documentation, if available.

The Company shall keep the complainant’s information strictly confidential.

In cases where the complainant chooses to remain anonymous, sufficient factual details or credible evidence indicating misconduct or fraudulent activity must be provided.

3. Reports or complaints may be submitted through the following channels:

3.1 Written Correspondence

Board of Directors or Human Resources Department
IFS Facility Services Co., Ltd.
365/1 Phaholyothin Road, Anusawari, Bang Khen, Bangkok 10220, Thailand
Tel: +66 2 552 5015
Fax: +66 2 972 3877

3.2 Email Reporting

Human Resources Manager or Complaint Handling Unit
Email: info@ifs-thailand.com

3.3 24-Hour Control Room and Incident Reporting Center

Tel: +66 2 038 5188 Ext. 3116, 3118

3.4 Line Official Account

Line ID: @IFSTHAILAND

Complaint Review and Investigation Process

Upon receiving a whistleblowing report or complaint regarding suspected fraud or misconduct, the Company shall proceed as follows:

1. The complaint recipient shall collect and review all relevant facts concerning the alleged misconduct, violations, or unethical behavior.

2. The complaint recipient shall report the matter to the Independent Director responsible for conducting the investigation.

The investigation process shall be completed within 30 days and shall classify issues according to relevant categories, including management, employee development, factual investigation, and related matters.

3. The complaint recipient shall submit findings to the Independent Director for further investigation and determination of corrective actions to prevent or stop any legal or policy violations.

4. The Company shall consider disciplinary action against individuals who violate the Anti-Corruption Policy or Company work regulations, as deemed appropriate.

The Company shall also consider appropriate remediation measures for affected parties.

5. Where the complainant has disclosed their identity, the complaint recipient shall communicate investigation results to the complainant.

In significant cases, investigation outcomes shall be reported to the Chairman of the Board and/or the Board of Directors.

Protection Measures for Whistleblowers and Complainants

1. Whistleblowers and individuals cooperating in investigations may choose to remain anonymous if they believe disclosure could result in safety risks or damages.

However, disclosure of identity may enable the Company to provide updates, clarify facts, and implement protective or remedial measures more effectively.

2. IFS Group shall not disclose the name, address, image, or any information that could identify the whistleblower or cooperating individual unless disclosure is required by law.

3. Complaint recipients shall maintain confidentiality and implement safety measures to protect whistleblowers and cooperating individuals from unfair treatment, including reassignment, changes in job duties, relocation, suspension, intimidation, workplace harassment, or termination arising from the complaint.

4. If whistleblowers or cooperating individuals believe they may face danger, hardship, or damages, they may request appropriate protection measures from the Company.

The Company may also independently implement protective measures without request if it determines there is a reasonable risk of harm or retaliation.

5. Individuals who suffer damages or hardship shall receive appropriate and fair remediation through the Company’s established procedures.

Company Guidelines for Employees

  • Employees must comply with Company work regulations and applicable laws.
  • Employees must perform their duties honestly, responsibly, and with quality standards.
  • Employees must treat customers, colleagues, and business partners professionally and appropriately.
  • All forms of harassment, including sexual harassment, are strictly prohibited.
  • Employees must not disclose personal information or misuse confidential information for personal benefit or in ways that harm others.
  • Consumption of alcohol or use of illegal substances during working hours or within Company premises or client sites is strictly prohibited.
  • All employees share responsibility for maintaining a workplace free from discrimination, harassment, retaliation, or unlawful conduct. Employees who believe they have been subjected to discrimination, harassment, or retaliation are encouraged to report such incidents immediately.

Company Guidelines for Customers and Business Partners

  • IFS Group communicates its operational guidelines and standards to customers and business partners through appropriate communication channels.
  • The Company delivers services in accordance with established standards for quality, hygiene, and workplace safety.
  • Customer information shall be treated as confidential.
  • Customer complaints and feedback are considered essential for continuous service improvement.
  • The Company evaluates procurement and service delivery based on quality, operational efficiency, environmental considerations, and workforce standards.
  • IFS Group operates in compliance with competition laws and related regulations. The Company shall not engage in or discuss anti-competitive practices with competitors, including price fixing, service allocation, market sharing, bid rigging, information exchange, discount arrangements, bonuses, or similar conduct.
  • IFS Group maintains the highest standards of integrity in all business operations and adopts a zero-tolerance approach toward bribery, corruption, extortion, and fraud in all forms. The Company does not accept gifts or gratuities from business partners except for items of nominal value given in accordance with customary local business practices.

Company Guidelines Toward Society

  • IFS Group is committed to promoting a safe workplace, protecting the environment, conserving natural resources, and acting as a responsible corporate citizen in every community where the Company operates. All employees and contractors must work safely and ensure that health, safety, and environmental requirements are incorporated into daily operations, projects, and programs.
  • The Company respects the rights of all employees to establish or participate in employee associations and collective bargaining activities in accordance with applicable laws. Where freedom of association or collective bargaining rights are restricted by law, the Company shall facilitate alternative lawful means for employee representation and dialogue. Employee representatives selected by employees shall receive equal treatment and appropriate support.
  • IFS Group maintains a policy of equality, non-discrimination, and fairness in all aspects of human resource management, including recruitment, hiring, compensation, benefits, transfers, promotions, disciplinary actions, training and development, termination, resignation, retirement, and social activities. Decisions regarding personnel management shall be made without discrimination based on age, race, color, ancestry, ethnicity, national origin, physical or mental disability, medical condition, genetic information, marital status, sex, pregnancy, childbirth, breastfeeding, gender identity, gender expression, sexual orientation, religion, political opinion, military or veteran status, lawful leave status, protected legal status, or any other non-job-related factor.
  • The Company prohibits forced labor and does not employ individuals under the age of 18. Employees are free to resign in accordance with Company regulations. IFS Group does not participate in or support any form of forced or involuntary labor and shall not require employees to submit deposits, guarantees, or identity documents as a condition of employment unless required by law.
  • IFS Group pays wages at rates no lower than the legally required minimum wage and considers employees’ basic living needs and reasonable disposable income. Wages and compensation shall be paid in Thai currency according to scheduled payroll periods. No unlawful deductions from wages or compensation shall be made. Employees shall receive written explanations detailing compensation payments for each pay period.
  • The Company supports employee development and encourages employees to participate in training programs relevant to their responsibilities. Employees demonstrating exemplary conduct are recognized and supported.
  • IFS Group provides safe working conditions and environments for pregnant employees. The Company shall not terminate employment, reduce positions, or diminish benefits due to pregnancy.

IFS Group Commitments

IFS Group is committed to:

  • Continuously developing and improving management systems in compliance with applicable laws, local regulations, and recognized internal and external standards to which the Company subscribes.
  • Improving measurable performance in occupational health, safety, environmental management, and sustainable operational resilience in response to unplanned incidents.
  • Protecting the health and safety of all individuals involved in Company operations by identifying and eliminating causes of accidents, injuries, and illnesses.
  • Promoting healthy lifestyles and encouraging employees to actively maintain their personal health and well-being.
  • Supporting sustainable economic growth while minimizing environmental impacts through pollution prevention, continuous improvement, and responsible operations.
  • Collaborating with business partners, customers, and stakeholders to share best practices and performance standards related to health, safety, and environmental excellence.
  • Supporting communities in all regions where the Company operates through environmental, educational, social, and community development initiatives.
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