The Company does not commit any unacceptable forms of fraud and giving or receiving bribes. For the direct or indirect benefit of themselves or related parties, whether in person or not in person, with stakeholders who have conducted various business transactions of the Company, including prohibiting all employees and all levels from being involved in corruption and giving or receiving bribes in any form and strictly complying with this anti-corruption and bribery policy. as follows

1.  The Company will provide training and communication to all employees and all levels, including stakeholders, upon request to understand and raise awareness of the compliance with this anti-corruption and bribery policy.
2. Employees at all levels must not commit any acts that demonstrate fraud and giving or receiving bribes to stakeholders who have conducted various business transactions of the Company in order to gain benefits, advantages and maintain business operations.
3. Employees at all levels must not violate fraudulent conduct and provide or receive bribes related to the Company's business transactions, and do not ignore or neglect any actions that demonstrate corruption and giving or receiving bribes that must be notified to supervisors and cooperate in fact-checking.
4. The Company will provide fairness and protection to whistleblowers and cooperate in reporting corruption and giving or receiving bribes as defined in the Confidentiality and Protection Measures.
5. Employees of all levels who commit any acts of fraud and giving or receiving bribes shall be subject to investigation and punishment in accordance with the company's regulations and/or may be penalized under the compliance obligations if they are against the compliance obligations.

Best Practices.
Gifts or Receptions.
 

The Company recognizes that building good relationships with business partners is important to bring success in continuing to operate, but this must be avoided or acted openly. It is not concealed, is timely, appropriate for the situation and is within the scope acceptable by the Company and does not affect corruption and giving or receiving bribes, and must not contravene the rules, regulations, compliance obligations that the Company must comply with.

Gifts or receptions herein include cash, stocks, bonds, gift cards, tickets, tickets, performance or sports tickets, travel expenses, accommodation expenses, food, prizes, gifts, and more promotional Items. The Company's employment offers, or services and any valuable benefits or items provided by merchants, vendors, contractors, customers, or stakeholders of the Company, except gifts not exceeding 3,000 baht, are given in accordance with traditions and manners of opportunity and reception not exceeding 10,000 baht. This must be able to clarify the actions correctly and clearly.

In inevitable situations, employees are required to disclose gifts from merchants, vendors, contractors, customers, or stakeholders of the Company with a value exceeding 5,000 baht, and supervisors or above must disclose gifts or receptions worth more than 10,000 baht and send them to management team for further as a reward for employees at major festivals or charities as appropriate

Charitable Donations and Support.
    Charitable donations and contributions to the extent that it is appropriate with the aim of giving back to society. As well as public relations to enhance the company's image without aiming for business returns such as CSR projects, support for religious preservation. Supporting and assisting school supplies or education; however, it will not be a donation or support for bribery and must be done openly. It is not concealed, is timely, appropriate for the situation, and does not contravene the rules, regulations, compliance obligations that the Company must adhere to, political support.
  Charitable donations and support are 100%, must be approved by the Managing Director or authorized by the Company's regulations as strictly defined and collect evidence. Relevant documents showing charitable and supportive donations in its entirety

Political Support.
     Political support refers to helping on behalf of a company, whether it's financially, to support political activities, or to provide things or services. Advertising or supporting political parties donations to organizations with close to political parties, for example, unless they support democratic processes that are as required by regulations or compliance obligations.
      The Company operates a business that adheres to political neutrality. Employees of all levels have the right to freedom to participate in political activities under the provisions of the constitution. The Company does not impersonate employees and does not use its resources for the benefit of any political action, including prohibiting the use of its authority to invite pressure or force employees in the Company to support any political activities.        

          Experteam Company Limited is committed to providing quality service from equipment and equipment rental services. The company operates in the Sustainable Development Guidelines by building trust among stakeholders through excellent, transparent, corporate governance, and business governance and continuously improve the work process. We are committed to benefiting and growing with stakeholders. Participate in social and environmental responsibility with the framework of sustainable development management to be in line with international standards.

Best Practices

• Comply with relevant compliance obligations and requirements.
• Leading the organization towards sustainability with the concept of engaging with stakeholders and maintaining balance in the economy, society and environment to continuously improve capacity.
• Promote training, education, guidance, counseling, and engagement that focuses on how to follow sustainable development guidelines.
• Communicate sustainable development policies to stakeholders as well as set a good example of behaviors that contribute to a sustainable business culture.
• Continuously develop strategies and processes and reduce the impact of operations covering quality. Environment, Safety and Occupational Health.

        Experteam Company Limited has a business policy and prioritizes the responsibility of benefits to related stakeholders. Corporate Social Responsibilities (CSR) is based on transparent business practices, verifiable ethics, and respect for human rights; avoid actions that may cause conflicts of interest and intellectual property infringement, and all forms of anti-corruption. The Company is committed to developing and improving the operation of the business while continuously improving. Fulfillment of the commitments to grow together continuously and sustainably with both organizations and stakeholders. In addition, all levels of employees in the organization have been communicated to comply with the audit and follow-up of the practices by the management team of the organization.  For improvement, amendment, or development, apply in the years to the next as appropriate. The company has a Corporate Social Responsibility policy as:

1. Good Corporate Governance / Fair Business Operations

           Experteam Company Limited has a policy to keep all employees together under Safety Occupational Health and Work Environments that are good, and pleasant to work, as well as treating employees at all levels as family members. There is no exploitation of each other.

•      Human Resource Management: The Company has an effective Human Resource Management System to achieve maximum efficiency, from recruitment, personnel development, compensation, and welfare, as well as continuous training for employees. Fair returns and proper welfare are defined. In addition, the Company promotes and encourages all employees to have the opportunity to advance their careers, promote participation, mentoring and learning at all levels of the organization and develop skills to enhance professionalism in the form of multi-skill workers.
•      Safety, Occupational Health and Working Environment:  The Company manages Occupational Health and Safety Management in accordance with international standards and establishes and communicates Occupational Health and Safety policies to relevant stakeholders. To compliance with the obligations, implementation of the operational outcomes, monitor and evaluate the effectiveness of Occupational Health and Safety Management System regularly for continuous improvement and improvement.  Under the definition of "comply with the law, work with safety, care about occupational health and work environment".

2. Anti-Corruption Policy

            Experteam Company Limited  is committed to not committing any action, including prohibiting all employees and all levels from involving in any unacceptable forms of fraud and giving or receiving bribes. For the direct or indirect benefit of themselves or related parties, whether in person or not as a currency, to the stakeholders who have conducted various business transactions of the Company. Covering the organization's rules and acceptance criteria on issues including gifts or receptions, charitable donations and support and strictly comply with this anti-corruption and bribery policy.

3. Respect for rights and practices / Respect for human rights

           Experteam Company Limited have an awareness of the importance of equality fairness. It also respects human rights principles. The Company recognizes the importance of children being able to grow up and be physically and mentally developed to be healthy. In all cases, the Company has imposed appropriate disciplinary penalties based on the heaviness of the offences as prescribed in the Company's work regulations and will treat the stakeholders with respect. Respect human dignity and individual rights and continue to communicate understanding with stakeholders as follows:

•      Discrimination and harassment: The Company shall respect and not discriminate in personal manners including race, religion, skin color, nationality, gender, marital status, sexual deviance, age, pregnancy, disability, national origin, union membership, political opinions, etc.
•      Forced labor and child labor: The Company prohibits forced labor, including penalty labor, including labor, to scrub debts, not accept persons under the age of 15 in all cases, either within the Company's own establishment or in the customer's workplace, and will not be involved in or supporting the use of child labor.
•      Freedom of association or grouping:  The Company does not interfere in activities in the right of privacy to adhere to beliefs or necessities based on race, nationality, religion, gender deviation, disability, such activities must not have a public impact on the work or the company.

4. Responsibility to Customers

           Experteam Company Limited is committed to providing quality work from equipment and equipment rental services. The company operates in the electrical and measuring Instrumentation service and projects according to customer requirements and commitments to be fulfilled, as well as continuously improving operational efficiency. To achieve maximum customer satisfaction, the Company is aware that it is able to provide quality services consistently. In addition to rigorous monitoring and control of operations, it is necessary to have continuous and sustainable management, as well as monitoring and considering internal and external issues. Requirements or expectations from all stakeholders involved to respond effectively. The Senior Management has communicated the company's Quality policy to employees at all levels and understands the awareness and uses it as a framework to determine the Quality objectives of each activity. We are ready to communicate Quality policy to stakeholders when requesting under the definition "Carry out compliance obligations, please customers, continuously improve quality, focus on service"

5. Community and Social Development

           The Company adheres to the policy of maintaining and connecting with nearby communities. Therefore, it supports community activities regularly. The project takes into account the appropriateness and benefits that communities and society will receive for sustainable community development, as well as sending our employees to participate in community activities, while promoting and encouraging employees to participate in volunteer work and public benefit activities with the community regularly, such as mangrove forest planting projects, garbage and sewage collection project on the seaside waste, collection and coral planting project, school building project, toilet building project for religious sites, lunch and scholarships for special children, forest planting and release projects for aquatic animals, etc

6. Protecting the environment

           Experteam Company Limited has established a clear environmental policy.  Employees at all levels of the organization shall strictly observe the guidelines and must adhere to the commitments that must be fulfilled, including internal systems to control and prevent environmental issues that will affect the loss of natural balance, Global Warming, air pollution, water pollution, general waste/solid waste, hazardous waste, hazardous chemicals resource, utility and quality of life. In addition, the Company has provided knowledge to employees at all levels to raise awareness and participate in campaigns to save resources and energy in areas such as electricity, water supply, oil, and paper under the following definitions: "Clean, Care and Safe, Environmental".

7. Personal Data, Confidential Information and Intellectual Property

           The Company places importance on maintaining personal data so that it is not misused properly. To prevent conflicts, unfairness, insecurity, and mental state of the person. Control the embezzlement or use of the Company's intellectual property and confidential information. In addition, partners must not use such assets and information unless approved by the Company in writing only, neither the Company and its partners have intellectual property or confidential information related to joint business operations. Appropriate precautions must be taken to prevent unauthorized disclosure or use of such assets and information, including instilling in them to make employees at all levels aware of the confidentiality of the Company and its partners, such as discussing or discussing confidential matters in public. This may cause damage or be used for the wrong benefit.

8. Unveiling Innovations from Social Responsibility Environment and Stakeholders

           Experteam Company Limited committed to supporting innovation both within the organization and cooperation with external stakeholders.  Innovation and support must be continuously improved or changed in a way that is appropriate and sufficient to benefit the organization to the maximum and can disseminate innovations from social and environmental responsibility to stakeholders, including paper savings, natural resources, to demonstrate the will and commitment to using resources to conduct business efficiently, which does not affect the operation of the organization.  It also focuses on energy saving, which uses technology in various social medial formats that are currently in operation instead of paper, such as communication. Sending information, saving documents, signing, sending reports and storing documents in electronic file format, etc.

        The Company is concerned about the health of employees and in response to the government's policy, the company has set up a policy to prevent drug and alcohol problems in the workplace to be treated as follows:

1. The Company considers the drug to be a danger that the company and all its employees must cooperate in the campaign to prevent and eliminate the problem of drugs.
2. Cooperate with the staff, Administrative staff or police on notification when found guilty of drug offences or providing information and facilitating the operation or inspection of officers.
3. Supervisors at all levels must behave as role models, lead, train, supervise, motivate all employees away from drugs.
4. The Company assumes that the addict is a patient and can randomly inspect the employees without prior notice.
5. Alcohol or drugs are prohibited at the company's premises or places where the Company rents work or the customer's area or project area.

Best Practices.

• The Company has authorized to randomly check the amount of alcohol and narcotics with employees as necessary and appropriate, and the results must be zero. Penalties must be in accordance with the Company's regulations or as required by the Compliance obligations. If the compliance obligations is imposed.
• Dissemination, clarification meeting or training for health promotion program to raise awareness of employees' consciousness to understand health promotion programs. Prevention and problem solving of drugs on an ongoing.
• ​​​​​​​Encourage employees to exercise regularly to stay healthy and to get away from drugs

       The Managing Director has established and announced to all employees of Experteam Company Limited to be informed and treated in general regarding the coronavirus preparedness and response policy. (COVID-19) as follows:

1. Survey employees in your organization or close friends about whether they have traveled to risky countries? If there is, the employee should stop working and performing the jobs at home.
2. Employees are prohibited from traveling to vulnerable countries. If you're still found to be traveling to a vulnerable country, you'll need to take a trip, the company will have a policy of suspending work until the outbreak calms down.
3. Establish a proactive action plan or risk management plan for the organization if there is an emergency (BCP) both in the care of employees and to engage in social responsibility. If an employee is infected with the virus, act quickly to stop the spread of the disease, and no information must be concealed to health officials or the public. Just to protect the reputation of the organization.
4. If there are a lot of sick employees, work should be temporarily closed.
5. Consider postponing or abstaining from events that require many people to gather.

Best Practices.

• The Company requires the preliminary physical checks of employees after the toolbox meeting is completed include temperature measurement, mask wear inspection, and inquiries of travel history and risky activities, etc.
• ​​​​​​​Provide training on knowledge and prevention methods regarding respiratory diseases caused by COVID-19 and daily cleaning to disinfect the area.  This ensures that all employees always work in a clean and safe environment.
• ​​​​​​​Disposable face masks must be thrown into special tanks only, and the company also provides services to all employees who provide services or maintenance to on-site customers. The same rules must also be followed.
• ​​​​​​​Strictly follow the coronavirus emergency preparation and response plan.

Be Clean, Safety and Environmental awareness

          The organization; Experteam Co. , Ltd. Committed to operate business includes quality and energy conservation along with a prevention of pollution from its activities, products and services especially reduce and prevent industrial waste spillage. The organization commitment to comply with applicable legal requirements and with other requirements and communicated all persons who working for or on behalf the organization includes a commitment to continual improvement and prevention of pollution, this environmental policy is available to the public upon request.

       Best Practices.

• Handing and prevention sewage spills and industrial waste from storing, collect & transport.

• Handing and prevention chemical and oil spills in operating areas.

• Handing, prevention and reduce transport pollution.

• Handing the effective use of natural resources including water, electricity, oil, paper.

• Promote and educate workers to be aware of their operations along with environmental protection.

• Handing and prevention fire emergencies from storing, collecting, transporting, and leaking industrial chemicals and waste.

          The Company recognizes the importance of equality, fairness, It also respects the principles of rights.  The company recognizes the importance of children being able to grow up and be physically and mentally developed to be healthy. Therefore, the company has a policy not to accept persons under the age of 15 to work in the Company in all cases, including prohibiting forced labor and penalty workers in all cases. The company shall treat the stakeholders in an honorable way. Respect human dignity and individual rights and continue to communicate understanding to stakeholders.

  Best Practices.

1. The Company places importance on privacy, equality without discrimination against stakeholders.
2. The Company will treat employees with employment, work compensation, welfare, development and training, promotion, discipline and punishment, performance is more than personality.
3. The Company will abide by its commitments to comply with its rights. Duties of employees of all types of contracts and terms of service to stakeholders.
4. ​​​​​​​The Company shall not impede or take any action that will affect the exercise of rights of employees or stakeholders that do not affect the Company's business in accordance with the regulations prescribed.
5. ​​​​​​​The Company shall respect and not discriminate in personal manners including race, religion, skin color, nationality, gender, marital status, sexual deviance, age, pregnancy, disability, national origin, union membership, political opinions, etc.
6. ​​​​​​​The Company does not discourage employment, services, compensation payments, training, promotion, termination of employment or retirement for racial, nationality, religion, disability reasons, sexual deviation, political participation, or union membership, etc.
7. ​​​​​​​The Company selects and pays compensation based on knowledge. Without discrimination, race, skin color, gender, age, nationality, sexual popularity, military status, marital status or physical impairment, which does not affect the position of duty to be performed.
8. ​​​​​​​The Company encourages employees to gain additional knowledge in addition to their knowledge of the job. For promotion, the Company will consider the knowledge, competency of each person mainly, and the employee must have knowledge of the job and skills to manage personnel in the unit.
9. ​​​​​​​Remuneration the Company will consider the same characteristics as the same amount as the same amount. The Company will pay the same compensation. Whether the employee is a woman or a man.
10. ​​​​​​​The Company treats male and female employees with equality unless the nature of the work or the condition of the work cannot be performed the same.
11. ​​​​​​​The Company does not allow all employees to behave, including gestures. Use of speech, physical contact, or acts characterized by oppression, coercion, sexual harassment, rape, sexual assault, or sexual exploitation.
12. ​​​​​​​The Company has no policy to force women to check for pregnancy and contraceptives for the sake of hiring or forced to leave their jobs.
13. ​​​​​​​The Company does not allow the punishment of employees for assaults such as lashings or profanity, sarcastically remarks, physical and psychological threats, or by cutting employee benefits.

Forced Labor and Child Labor

• The Company prohibits forced labor, including penalty workers, as well as workers for debts.

• Migrant workers who work in the workplace, the company must fully and strictly comply with its commitments, including supporting information, educating and communicating in language that facilitates operation and coexistence.

• Individuals under the age of 15 are not accepted to work in the Company in all cases.

• Employees have the right to resign as employees with appropriate prior notice period. In the case of stakeholders other than employees in the Company, the Company shall not unfairly terminate the employment contract without clarifying the clear reasons in accordance with the commitments set forth for compliance.

• The Company shall not employ or exploit child labor either within the Company's own establishment or in the client's workplace and will not be involved in or supporting the use of child labor.

Freedom of Association or Integration

• The Company does not interfere in activities in the right of privacy to adhere to beliefs or necessities based on race, nationality, religion, gender deviation, disability, such activities must not have a public impact on the work or the company.

• The Company respects the right to association or grouping according to its will, including the right to jointly negotiate for the interests of stakeholders. The group must not contravene the legal requirements or commitments to comply.

   To provide direction and support for the Company's information security operations to meet or comply with relevant business requirements, laws and regulations the company must have a duty to supervise the formulation of a written information technology security policy and the company communicates the said policy in order to understand and be able to follow it properly to those working under the control and supervision of the company. Especially between the information technology department and other departments within the company in order to be able to coordinate and operate the business according to the goals set Provide training or education to workers about cyber threats or new information in order for workers to be aware, aware and able to protect themselves from such threats to a certain extent as well as to arrange for a review of the information technology security policy at least once a year or when there is a change that affects the company's information technology security including an audit for compliance with the Data Security and Security Policy at least once a year, and make plans to improve and fix the problems found.

Information Security Systems and Guidelines

• Requires registration of an account for the electronic mail service (E-mail) must fill in the request for access to the electronic mail service (E-mail) by submitting the request to the E-mail system administrator.

• In the event that an unknown electronic mail (E-mail) is found, users are prohibited to press confirmation or browse to view information. and inform the information agency immediately.

• Passwords should not be saved or stored in the computer system. or installed in front of the computer.

• Always back up your data on a regular basis, e.g. once a month, once a quarter, etc.

• A request should be made to the information authority to conduct a computer system inspection and audit at least once a quarter.

• Do not install software or applications other than those specified by the Company for operational necessity.

• Do not disclose important confidential information about the work of an agency that has not been officially announced via the Internet.

• Assign access to the server by using username and password from information organizations only.

• Do not use resources and computer networks. to act illegally and contrary to the good morals of society

• Do not disrupt, obstruct, or damage the Company's resources and computer networks.

Comply with compliance obligations, work with safety, awareness for occupational health and operational environmental

          Throughout EXPERTEAM and its associated companies we are committed to achieving the highest Health, Environment and Safety standards across all our operations and consistently meeting or exceeding the needs and expectations of our Clients in the Oil and Gas Industry. To achieve this EXPERTEAM will:

1. Ensure that the safety and long term health of our employees and other individuals that maybe affected by our activities and that the protection of the environment receive equal priority with other business objectives, includes a commitment to provide safe and healthy working conditions for the prevention of work-related injury and ill health.
2. Accept that the health environment and safety are management responsibilities, which require a structured organization with committed and competent staff, and it appropriate to the purpose, size and context of the organization and to the specific nature of its OH&S risks and OH&S opportunities.
3. Provide project management with the support of safety specialist to assist line management to fulfill legal requirements and other requirements, set standards, and implement programs, measure performance for compliance and achievement.
4. Provide a safety management system, comprising of standards, procedures work methods and job safety analysis, which systematically identify all hazards within our activities and eliminate or preventive control the associated risk to provides the framework for establishing OH&S objectives.
5. Committed to the prevention of injuries, illnesses from workplaces including health care programs of the employees are ready to perform the tasks. by doing that physical checking should be doing within the time limit, accordance with the compliance obligation and customer requirements.
6. Establish mutually agreed interfaces with the clients management systems and clearly identify responsibilities and accountabilities through a site safety plan.
7. Ensure a clear multi-way communication system exists for all health, environment and safety issues through structured meeting, presentations and publications to the efficiency and effectiveness of the communication processes, including cover all other interested parties, internal and external communication to internally among the various levels and functions of the organization as appropriate, and the organization shall take into account diversity aspects (e.g. gender, language, culture, literacy, disability) when considering its communication needs.
8. Undertake assessments to ensure the competence of all our employees in performing their respective roles.

9. Evaluate and control of external providers for capabilities and performance to comply with standards set, procedures or compliance obligations.

10. Monitor the performance of our activities against established standards, procedures and criteria, to meet planned objectives.

11. Use the investigation tools of accidents and incidents as a management tool to provide analytical details and to identify inadequacies in management control.

12. Develop and maintain detailed audit procedures and schedules to verify compliance with OH&S management system and compliance obligations.

13. Continuously monitor and assess the performance and effectiveness of the health, environment and safety systems to provide for continual improvement.

14. Commitment to consultation and participation of workers, and where exist, workers’ representatives, are aware and contribute to the continual improvement in OH&S management system. 

15. Follow the requirements and procedures to achieve quality management system, environmental management system and occupational health and safety management system.

16. Empower everyone to exercise Stop Work Authority (SWA).

        Best Practices.

• Prevention and preparing for an effective response to emergencies.

• Handing and prevention accidents with workers reaching more than 3 days off in the operating area.

• Handing and prevention accidents with operators in the customer's workplace.

• Supporting participation, instruction, advice, and act on unsafe incident and behavioral reporting results.

• Handing and prevention injury and illness from working.

Comply with compliance obligations, Customer Satisfaction, continuously improve quality, Service focus

        The organization Experteam Co., Ltd. commitment to providing service quality from the rental of tools and equipment labor recruitment construction and project according to customer requirements and comply with compliance obligations. as well as continually improve operational efficiency for optimum customer satisfaction. The organization aware to usually provide all quality service besides the audit and strong operation control the organization have to sustainable management system, by the way the organization implement the quality management system as guideline to the organization's management. Top management would review and define the quality policy by commitment to comply with quality requirements and continually improve the effectiveness includes communicated and understood within the organization and provides the framework for establishing and reviewing quality objectives and communicate quality policies to stakeholders upon request.

        Best Practices

• Striving to provide ready and adequate personnel to perform the tasks requested by customers.

• Striving to provide services, tools, machines, readiness of devices.

• Development personnel qualifications to meet customer needs.

• Inspection and repair of tools and machines to service as planned.

• Development the delivery process on time as required by the customer.

• Increasing customer satisfaction by providing quality service.

• Development employee knowledge according to customer requirements.

• Preventive maintenance of machines efficiently.

• Monitoring, Measurement and operational consistency.

     Managing Director has set and announced to all employees in the company. Expert Team Co., Ltd. acknowledges and adheres to the general re-entry policy after injuries from work accidents, injuries, illnesses from work and illnesses due to work-related diseases as the following details.

We are committed to providing a safe workplace for our employees. Preventing work related illness and injury is our primary goal. Our early return to work provides opportunities for an employee who is injured on the job to return work at full duty. If the injured worker is not physically capable of returning to full duty, the program provides opportunities to perform the regular job with modifications or, when available, to perform alternate temporary work that meets the injured worker’s physical capabilities. We will make every reasonable effort to provide suitable return to work opportunities for every employee who is unable to perform his or her regular duties following a work related injury. This may include making accommodations to the employee’s regular job or, if available, providing temporary alternate work depending on the employee’s physical abilities. Injured workers who are participating in the return to work program are expected to provide feedback in order to improve the program’s future development.

Best Practices.

• Provide RTW monitoring for employees who had injuries and illness from work and will to return to work.

• Advise for self-treatment for who had injuries and illnesses by the factory nursing team.

• Campaign for exercise before work starts

Personal Data Protection Policy        
        
     Experteam Company Limited (collectively referred to as “EXPT”) respects the right to privacy and values importance to the protection of Personal Data in connection with or in conducting transactions with EXPT. Therefore, this privacy policy is prepared to provide governing criteria, mechanisms, measures and governance for managing Personal Data as follows:        
        
Scope of this Privacy Policy     
        
     This Privacy Policy applies to all employees which includes permanent employees, employees with definite contract period, temporary workers and contractors including Data Processor who processes Personal Data on behalf of EXPT. (where applicable)        
              
Collection of Personal Data       
        
     EXPT will collect Personal Data with purposes, scope and apply lawful and fair methods. The collection will be done only as necessary for the business objectives of EXPT.        
           
     In the case of collection of Sensitive Personal Data, TOP will ensure that the Data Subject acknowledges and give consent to such collection via electronic method or other methods. TOP will explicitly request for consent from the Data Subject prior to the collection of Sensitive Personal Data unless such collection of Personal Data and Sensitive Personal Data falls under an exception provided under the Personal Data Protection Act B.E.2562 or other laws.        
        
Personal data collected by the EXPT, such as        

-        Personal information such as name, surname, date/month/year of birth, age, gender, photograph, signature, place of work, job title, education history, working information, training history various works information according to a copy of a document issued by a government agency such as a copy of an ID card, copy of passport, copy of house registration, etc.        
        
-       Contact information such as address, telephone number, e-mail address, contact information, and other information that the EXPT can contact, etc.        
        
-        Financial information such as information on a copy of the bank book, tax identification number.        
        
-        Information used as evidence or in transactions such as personal information shown in the copy of the ID card, copy of passport, copy of name change certificate, copy of house registration, copy of driving license, copy of vehicle registration, manual vehicle registration number, copy of land title deed, copy of power of attorney, copy of office certificates, invoices, receipts, payment certificates and copies of professional or business licenses, etc.        
        
-        Technology information such as computer traffic information (Log), computer identification number (IP Address), geographic location information (Location) using location technology. Types of computer programs used to view websites (Browser) log data access to the website. Website information that users access before and after (Referring Website) records of website usage history Login Log, transaction Log, website Access Statistics Time of visiting the website (Access Time) information that was searched or visited. Information on the use of social media (social media), use of the various functions of the website and information that the EXPT collects through cookies (Cookies) or other similar technologies, etc.        
        
-        Recording still images and movies through CCTV, recording conversations or data.        
        
-        Other identifiable individuals.        
              
     Sensitive data, which means personal data that is the inherently private matter of the data subject under Article 26, of the Personal Data Protection Act B.E. 2562 such as Face Scan / Face Recognition, religious or blood type information as shown in the copy of ID card (if any), criminal history information including alleged offenses or prosecution, health information, racial information, etc. There is no policy to store your sensitive personal information. Unless the EXPT has your express consent. or any other cases as required by law.        
                
     In the case of a transaction or contract, If you do not provide personal information or providing inaccurate or out-of-date personal information to the EXPT may affect you that you may not be able to transact with the EXPT, or may not be convenient or unable to comply with existing contracts with the EXPT and may cause damage or loss of opportunity and may affect compliance with any laws, that you or the EXPT must comply with.        
           
Source of personal information        
        
The sources of personal data the EXPT collects and receives is as follows:        

-        The EXPT receives personal information from you directly, such as when you fill out various forms through the EXPT's website, or other channels provided by the EXPT when you enter into a contract with the EXPT, when you deliver documents and copies of documents containing personal data to the EXPT or when you ask for information, give comments or feedback, or send complaints to the EXPT by telephone, email, fax, mail, information about the use of the EXPT's website or applications, the use of cookies (Cookies), IP address, etc.              
-        The EXPT receives personal information from third parties or from other sources such as government agencies. Department of Business Development website Revenue Department websites, other websites, etc.        
        
Purpose of Collection and Use of Personal Data       
        
     EXPT will collect or use Personal Data for the benefit of EXPT’s operations or to improve the quality and efficiency of work and/or to comply with laws or regulations applicable to EXPT’s operations. EXPT will collect and use such Personal Data only for the period necessary for carrying out the purpose as informed to the Data Subject or in accordance with what the law specified.        
        
-        For the purpose of creating and managing contracts between EXPT with any counterparty, including the EXPT's performance in accordance with the contract        
        
-        For procurement purposes or registration of new contracting parties or any other person with similar characteristics as well as the processing of requests of the parties or any other person of a similar nature.        
        
-        To record the EXPT's creditors invoicing issuing tax invoices, EXPT credit bureau disbursement including various financial transactions and accounting operations of the EXPT.        
        
-        For the purpose of verifying or identifying your identity in the case of accessing various services, entering into a contract, performing duties under the contract to ensure that the services provided, including all EXPT communications, are secure and confidential.        
        
-        For the purpose of communicating or coordinating the EXPT's operations or missions with third parties, contractors or contract parties        
        
-        For the purpose of complying with the law related to the operation of the EXPT and lawful orders of government agencies and related officials, such as business registration with the Department of Business Development Notification of registration of personnel or persons related to the law Preparation of tax reports for submission to the Revenue Department accounting audits by auditors, etc.        
        
-        For the purpose of publicizing information, news and activities of the EXPT such as training, meetings, seminars, company projects relationship building activities Organizing social activities, etc.        
        
-        To create a database of participants in the event project participants attendees’ participants or EXPT participants, including analyzing the data and surveying the behavior of such individuals        
        
-        For the purpose of health, occupational and safety management of contractors. Organizing an annual health check both general health check-up and occupational health check-up (Health check according to risk factors). Health insurance and health readiness assessment. It is also used as information for reporting, investigation, causal analysis or the development of preventive health management and to formulate measures to prevent incidents occurring.        
        
-        To protect health from dangerous communicable diseases that may spread within the EXPT by screening people entering and leaving the premises Including tracking and providing reports on travel that may pose a risk of spreading the disease.        
        
-        For inspection and security within the building or EXPT premises and safety risk assessment including entering and exiting the EXPT's premises. Exchanging tickets for a building or EXPT premises and recording the information of entering and leaving the EXPT's premises and taking pictures inside the building or EXPT or around the surrounding area with CCTV.        
        
-        For the establishment of legal claims compliance or exercise of legal claims or raising the defense of legal claims various litigation as well as legal enforcement proceedings such as investigations and/or investigations by government officials, case preparation, litigation and/or court defenses, etc.        
        
-        For the EXPT's internal audit or audit to ensure compliance with operational standards and in accordance with relevant regulations or laws.        
        
-        For information management within the EXPT and security surveillance in the EXPT's system.        
        
-        EXPT will not engage in any actions that is different from the purpose specified for the collection, unless        
         1        A new purpose has been communicated to the Data Subject and consent has been obtained from the Data Subject.        
         2        Such action is for the compliance with the Personal Data Protection Act or other relevant laws.         
        
Disclosure of Personal Data       

-        EXPT will not disclose Personal Data to any persons without obtaining consent from the Data Subject and will only disclose in accordance with the informed purpose(s).        
        
-        EXPT may need to disclose Personal Data to its affiliates or other persons both within Thailand and in foreign countries for the benefit of EXPT’s operations and provision of services to the Data Subject. In disclosing Personal Data to such persons, EXPT will ensure that such persons maintain confidentiality of the Personal Data and refrain from using such Personal Data for any purpose other than those as specified by EXPT.        
        
-        EXPT may disclose Personal Data under the requirements of the law such as disclosing Personal Data to government authorities, government agencies, regulator including in an event of request for disclosure made by virtue of the law.        
        
Personal Data Retention      
        
     The EXPT will keep your personal information for as long as is necessary for the fulfillment of the purposes stated to you or for the purposes set out in this policy. In the event that you terminate the relationship or terminate the contract with the EXPT or no use of services or EXPT transactions. The EXPT will store your personal information for a specified period thereafter, or store for a period of time specified by law or by age or for the exercise of legal claims. The company will delete or destroy personal information or make personal information non-identifiable to the person who owns the information. The retention of personal data will be in accordance with the EXPT's Data Retention Policy, which may keep your personal data longer than required in the event that it is required by law.        
        
Security of Personal Data     

-        EXPT will provide appropriate security measures for Personal Data and comply with the laws, policies, regulations, requirements and practices on the protection of Personal Data for the employees and other relevant persons.        
        
-        EXPT will support and encourage employees to have knowledge and awareness of duties and responsibilities for the collection, use, and disclosure of Personal Data so that TOP can comply with the Privacy Policy and Personal Data Protection laws correctly and efficiently.        
        
Data Subject Rights        
     
-        Right to access and request a copy of Personal Data about the Data Subject or right to request the sources of Personal Data EXPT receives without the Data Subject’s consent.        
        
-        Right to object the collection, use and disclosure of Personal Data of the Data Subject        
        
-        Right to request for delete or destruction or anonymization of Personal Data        
        
-        Right to restrict the use of Personal Data        
        
-        Right to withdraw consent for the processing of Personal Data that has previously been given, in any cases such withdrawal will not affect the collection, use or disclosure of Personal Data that has already been consented for.        
        
-        Right to request for correction of Personal Data        
        
-        Right to Personal Data portability        
        
Review and change of Privacy Policy       
        
     EXPT may update or revise this Privacy Policy from time to time to comply with legal requirements, changes in EXPT’s operations including opinions and suggestions from various agencies. EXPT will announce changed for acknowledgement.        
            
6.3)    Contact of Complaint  
        
        Internal and external stakeholders or complaints can be made in accordance with the channels specified by the Company. Details of complaints and contact phone numbers are required; send to receiving channel as follows;
             
6.4)    Conducting Investigations and Penalties    
        
     After the Company receives any clues or complaints, Directors who face the Audit Committee must conduct an immediate audit without delay. The procedure for conducting investigations and considering penalties. as follows;        
             
     When a complaint is received Managing Director, Director, will be the moderator, investigate the facts and periodically report them to complain.  If a fact-finding investigation finds that reasonable information or evidence is believed to have been committed inconsistent with the policies and guidelines set forth in accordance with this compliance obligations, the company will not be able to do so. The Company shall give the accused the right to be informed of the allegations and give the accused the right to prove themselves. By seeking more information or evidence that shows that he had nothing to do with the alleged assault. If the accused has acted inconsistently with the policies and guidelines set forth in accordance with this Compliance obligations, the accused will not be required to comply with the accused shall be investigated and considered disciplinary action in accordance with the rules and regulations prescribed by the Company. The perpetrator may face compliance obligations punishment.        
                
     In the event of fraud and bribery policy and practices, the Company will not have a policy to reduce positions, punish, leave work, or suffer other negative consequences that result from refusal to participate in fraud and giving or receiving bribes, even if such refusal may result in loss of business opportunity.        
        
6.5)    Protection and Confidentiality Measures    
        
     The Company will conceal and keep confidential information that can identify complaints in practices that do not comply with this compliance obligations Policy and Guidelines.  It restricts access to complaints information or only to the audit committee that conducts investigation responsibilities. Unless it is a disclosure as required by the compliance obligations, including the protection of a complaint. Witnesses and individuals who provide information in the investigation without suffering harm or unlawfulness a result of providing information and supporting clues or complaints.