Code of Conduct
The Bank places importance on good corporate governance, code of conduct for directors, code of conduct for employees, and business operations with responsibility to all stakeholders including shareholders, employees, customers, business partners, creditors, competitors, investors, government agencies, as well as society and environment. The Board and employees at all levels must formally sign for acknowledgement and strictly comply to the Code of Conduct.
ttb Culture (I CARE) and Code of Conduct are embedded into regular processes of the Bank to ensure all employees to work professionally and conduct business with integrity to deliver the greatest experience to customers. ttb I CARE comprising 5 core values has been established to encourage all employees to put customers at the heart of everything and at the same time, focus on integrity, challenge status quo, agility, respect and execution to ensure they work in the same direction. This is to drive the Bank to be an organization that Make REAL Change for the customers, staff, shareholders and society.
The Bank has established a Compliance Policy which defines roles and responsibilities, and reporting lines for effective implementation of the Code of Conduct and the fostering of a compliance culture. The Bank’s compliance procedure is established in accordance with the Bank’s Compliance Policy, outlininge the Bank approach to managing compliance and tools to be used. All employees receive training on the Code of Conduct every year to ensure compliance with applicable laws and regulations as well as ttb’s internal policies, procedures, and cultural values. Any non-compliance issues must be escalated through the established reporting line. In such cases, failure to comply will result in disciplinary actions and affect employee remuneration.
Market Conduct
As a financial institution, we place utmost importance on market conduct which is fundamental to our business in building and fostering customers’ trust and confidence in our bank. It is our responsibility to ensure fair dealing by offering products and services transparently, fairly, and responsibly, that are suitable to clients’ risk profile as well as their financial knowledge and understanding. We emphasize and promote fair financial services to prevent any form of discrimination against age, gender, sexual orientation, ethnicity, nationality, religions, beliefs, cultures, and socio-economic background, avoid misconduct, and treat every customer fairly and equally. Such responsibility extends to the safekeeping of customer information. By taking a customer-centric approach, we consider the benefits of our customers before the Bank. Hence, ttb is determined to serve our customers as follow:
- the Bank focuses on providing fair products and services, with sincere customer service and that they will not be taken advantage of;
- Customers receive appropriate and clear advice;
- Customers receive fair and reasonable prices and conditions;
- Customers can access the Bank's services conveniently and receive appropriate support; and
- Customers understand their rights and obligations when obtaining services from the Bank.
Furthermore, the Bank aims to create financial well-being for all customers as it is the fundamental to achieve their lives’ goals. To help customers towards financial wellbeing, the Bank has policies and standards in place to address and ensure client suitability and affordability, products and services suitability that address customers’ needs and lifestyles, and debt resolution and restructuring to not only protect them from over-indebtedness, but also promote good financial behaviors. These controls and our goal are also taken into account for products and services development to address the needs of customers at all stages of life. Hence, we hope it helps transforming customers’ financial journey to where they can meet their current commitments and have the financial resilience for the future.
Market Conduct Policy
Retail customer debt collection policy and practice
The Bank has specified a procedure on debt collection for retail customers in alignment with the Debt Collection Act B.E. 2558, Bank of Thailand’s guidelines on debt collection, Personal Data Protection Act B.E. 2562, and relevant laws and regulation. The bank’s assigned debt collectors must receive training to understand the procedure and guideline on debt collection and must pass the training exam before performing assigned duties. The bank regularly provides trainings for debt collectors to review of the knowledge and understanding on debt collection per the Bank’s regulations
The bank’s procedure on debt collection specifies explicit and appropriate roles and responsibilities of debt collectors and debt collection guideline. The guideline details, for instance, date, time, and place for debt collection, identification of debt collectors, verification of customer identity before providing debt information, frequency of debt collection, debt collection code of conduct, and etc.
In addition, the bank sets a standard fees of debt collection in accordance to the laws and regulations, and establishes complaint channel in case of inappropriate behaviors of debt collectors. In case of violations against the bank’s procedure which is considered disciplinary actions and punishable, there is a guideline on investigation of finding root causes, fact-checking procedures, and penalties.
Anti-corruption and Bribery
Corruption can greatly impact stakeholders’ confidence and trust in the Bank’s integrity. We conduct business under the principle of good governance as also reflected in the Bank’s Code of Conduct and adherence with the laws, regulations, and regulatory requirements in order to ensure transparency and corruption-free business operation as well as to prevent any corruption for personal benefits which may cause unfairness and damages to the Bank and the stakeholders.
Adhering with this standpoint, the Bank has joined the Thai Private Sector Collective Action Against Corruption (CAC), which reflects the Bank’s intention and attempt to be the organization with transparency and corruption-fee culture which creates sustainable growth to the Bank and increase value to the stakeholders in the long run. Additionally, the Bank created the Anti-Corruption Policy in addition to other policies to enhance clarity and coverage on anti-corruption, and determines the practices regarding direct and indirect anti-bribery or any form of bribery for benefits of the employees or related parties as well as outside parties to achieve international standard. The employees are also required to follows the policy in accepting gifts, presents, or entertainment party from private and public units.
Acknowledging the significance of this matter, the Bank has zero-tolerance for bribery and corruption in any forms. The bank promotes this commitment by stating in Code of Conduct and Anti-Corruption Policy, which provides guidelines for directors, executives, and all employees to operate and conduct business in a transparent manner, prohibiting its directors, executives, and employees to bribe or offer gifts or money to individuals, government officials/government entities, or companies to gain undue business benefits or influence over business dealings. It also prohibits any engagement of corruption-including expression of interest or acceptance of such acts for the benefit of oneself or other persons. There are disciplinary measures and penalties for those who fail to comply with the policy. The Bank shall also provide protection and fairness to employees who deny an act constitutes corruption or report an incident of corruption. These will help increase the employees’ awareness of the anti-corruption culture and ensure that the Bank operates with full transparency.
Anti-money Laundering
The Bank aims to conduct business only with parties that are involved in legitimate activities and shall neither offer our services nor provide any assistance in facilitating transaction which, we have good reasons to believe, may be associated with money laundering, terrorism or other criminal activities.
The Bank is committed to conducting all its business in conformity with the prevailing laws and regulatory requirements on anti-money laundering and combating financing of terrorism and proliferation of mass destructive weapons as they apply to its operations and business activities. TMB has adopted the regulatory requirements and guidelines of the Anti-Money Laundering Act B.E.2542 (1999) (Consolidated) (AML Act) and Counter Terrorism and Proliferation of Weapon of Mass Destruction Financing Act B.E.2559 (2016) (CTPF Act) under the direct supervision of the Anti-Money Laundering Office. Moreover, it is also a key objective of the Bank to follow international best practices/standards.
Whereas compliant with regulations, the Bank also emphasizes on Risk Management and Integrity as parts of the Bank’s Cultural Values. The Bank maintains a risk governance structure that is intended to strengthen risk management while ensuring that risk-taking authorities are cascaded down from the Board to the appropriate committees and functional levels, risk issues and the changing regulatory and business environment are managed in an efficient and effective manner. In conclusion, the Bank has zero risk tolerance to intentional breaches and non-compliance with laws, regulations, governance and ethics. Within the Bank, AML/CTPF refers specifically to the following risk areas:
- Money Laundering (ML)
- Terrorism and Proliferation of Weapon of Mass Destruction Financing (TPF)
- Export Trade and Sanctions (economic, financial and trade)
- Ultra-High Risk Countries (UHRC), which are countries where the Bank prohibits new and existing customer engagements and transaction with.
The Bank prohibits business relationships when the Bank cannot form a reasonable belief that it knows the true identity of the client and/or Ultimate Beneficial Owner (UBO)s and/or the nature of business or formal requirements concerning the identification of the client and/or UBOs are not met. The Bank will not accept assets that are known or suspected to be the proceeds of criminal activity, enter into/maintain business relationships with individuals or entities known or suspected to be a terrorist or a criminal organization or member of such or listed on sanction lists, maintain anonymous accounts, accounts for shell banks or pay-through accounts, enter into relationships with clients from Special Risk Countries, Ultra High Risk Countries (UHRCs) or enter into relationships with clients operating in prohibited industries. The Bank must have processes in place to discontinue any existing relationships or positions involving these countries.
Anti - Money Laundering/Counter Terrorism and Proliferation of Weapon of Mass Destruction Financing Policy (AML/CTPF)
Gift, Entertainment, Donation, and Sponsorship
The Bank expects the highest level of personal and professional conduct by all employees, Board of Directors of ttb, business partner and third parties. Under principles of Good Corporate Governance, the Bank does not allow staffs and closely related individuals to receive gift, entertainment, travel and accommodation offered by third parties.
Gift, Entertainment, Donation, and Sponsorship Policy
Whistleblower / Grievances
‘Whistleblowing’ means the reporting by employees of suspected misconduct, illegal acts or failure to act within the organization. The Bank is committed to achieve the highest standards of products and services. To help achieving this, we encourage the freedom of speech. The Bank has Whistleblowing Policy and guideline for employees and all stakeholders’ complaints to ensure that all stakeholders can communicate, report, or complain about improper actions such as violations of laws and regulations, misconduct and unethical behaviors, embezzlement, frauds, corruption, violation of rights, and any matter that lead to the Bank’s damage. In addition, the Bank must ensure that the complaints will be forwarded to the concerned work units for quick investigation and correction as well as reporting to the appropriate parties.
The Bank encourages and enables the employees and other stakeholders such as customers and counterparties to:
- Make a confidential report of any suspected wrong-doing;
- Promote the highest standards of ethical conduct and compliance with applicable laws, regulations, policies, rules, codes, requirements and obligations of the Bank; and
- Protect the legitimate interests and reputation of customers, employees, and the Bank
The Bank provides channels to enable the stakeholders to report or make complaints either in writing or through the Bank’s website. Moreover, the Bank establishes the monitoring process including the channel for reporting any breach cases regarding the Bank’s code of conduct, related internal control and related policies.
Whistleblower Policy