Whistleblowing and Complaints

TVD Holdings Public Company Limited

TVD Holdings Public Company Limited is committed to conducting its business with honesty, ethics, transparency, and social responsibility. The company takes into account the interests of all stakeholders and adheres to the principles of good corporate governance. It has a zero-tolerance policy towards all forms of corruption, both direct and indirect.

The company has established channels for whistleblowing or reporting any misconduct, including violations of laws, rules, regulations, corporate governance policies, business ethics, and the code of conduct for business partners. Stakeholders can submit reports or complaints along with supporting evidence directly to the company. The identity of whistleblowers or complainants will be kept strictly confidential. Access to such information will be limited only to those responsible for investigating the complaints.

Persons eligible to report misconduct or corruption include all stakeholder groups of the company, such as shareholders, customers, business competitors, creditors, government agencies, communities, society, executives, and employees. Regardless of the method used to report, the company will strictly protect the confidentiality of the whistleblower or complainant.

1. Matters Subject to Whistleblowing or Corruption Complaints

1.1 Witnessing corrupt practices directly or indirectly related to the organization, such as bribery or acceptance of bribes by individuals within the organization to or from government or private sector officials.
1.2 Witnessing violations of the company's procedures, inaccuracies in financial reports, or deficiencies in the system.
1.3 Observing weaknesses in the company’s internal controls that may raise suspicions of potential avenues for corruption.
1.4 Witnessing actions that cause the company to suffer losses or damage its reputation.
1.5 Witnessing violations of the law, regulations, or the company's code of business conduct and ethics.

2. Channels for Complaints, Whistleblowing, and Feedback

Whistleblowing and Complaints

For stakeholders:
Reports can be submitted to:

• Chairman of the Audit Committee
  Email: pongpanu_s@tvdirect.tv
  
  

• Internal Audit Department (Whistleblower System)
  Email: ir@tvdirect.tv
  
  

• TVDH Center
  Website: https://en.tvdh.co.th/for-more-information
  Phone: 0 2666 0999 (during business hours)

For employees:
Reports or complaints can be made through the Internal Audit Department, Human Resources Department, Corporate Governance Department, or a trusted supervisor at any level.

3. Protection Measures and Confidentiality

To protect the rights of complainants and those who provide information in good faith, the company will conceal names, addresses, or any other identifiable information of the complainant or informant. The information will be kept confidential and accessible only to those responsible for handling the investigation.

In the event of a complaint, the company will establish measures to protect the whistleblower, complainant, witnesses, and informants involved in the investigation from any form of retaliation, harm, or unfair treatment arising from their participation. If the company deems that there is a risk of damage or danger to the complainant, appropriate protective measures will be applied.

Any individuals who gain access to information as part of the investigation process are obligated to maintain strict confidentiality regarding the complaints and any related documents or evidence. Disclosure of such information to unauthorized persons is prohibited unless required by law.

4. Procedures for Fact-Finding and Disciplinary Action

4.1 In conducting investigations and gathering facts, the recipient of the complaint shall forward the matter to the designated investigators (“Investigator”) as follows:

• If the accused is below the Chief Officer level: The Chief Human Resources Officer and/or a person or unit assigned by the CEO will act as the Investigator.
  
  

• If the accused is at the Chief Officer level or above: The Chief Executive Officer and/or a person or unit assigned by the CEO will act as the Investigator.
  
  

The Investigator may invite any employee to provide information or request any relevant documents for the purpose of verifying facts.

4.2 If there is reasonable cause to believe that the accused has indeed engaged in corrupt practices, the accused will be informed of the allegations and given the right to defend themselves by presenting information or evidence to prove their innocence.

4.3 If the investigation confirms the allegations, the company will proceed as follows:

1. If the Investigator concludes that the accused has committed corruption, violated laws, regulations, company rules, or the business code of conduct, the individual may be subject to disciplinary action as prescribed by the company’s policies. If the corruption involves a legal offense, the person may also face legal consequences.
   
   

2. If the complaint is of significant concern—such as affecting the company’s reputation, financial status, contradicting business policy, or involving senior executives—the Investigator shall report the matter along with their opinion to the Board of Directors for further consideration.
   
   

3. If the complaint has caused harm to an individual, the Investigator may propose appropriate and fair remedies for the affected party as deemed suitable.