Business Code of Conduct and Employee Ethics

1. Compliance with the Business Code of Conduct and Ethics

The Company in the business code of conduct and ethics means TTW Public Company Limited and its subsidiaries. This requires all executives and employees to be responsible for understanding and following the preliminary guidelines as specified in the Company's business code of conduct which covers the following issues:

• 1.1

  The persuasion, encouragement, and motivation the executives and employees to collaborate to create value for the business.

• 1.2

  The creation of confidence that the legal rights of stakeholders be protected.

• 1.3

  The treatment of stakeholders and all related parties with honesty, transparency, and fairness.

• 1.4

  The encouragement everyone to responsible for getting familiar and complying with the business code of conduct and ethics and company’s related policies.

2. In case of getting doubt in the compliance or considering that there are any part of the document should be revised or improved can report to the supervisor in the hierarchy.

3. Guidelines for business Conduct

• 3.1

  The Company adheres to comply with the laws applicable to the Company and trading business strictly and in accordance with business ethics.

• 3.2

  The Company believes that to conduct its business with integrity, ethics, and morals is correct and sustainable business conduct guidelines. The Company insist to conduct business with open communication both inside and outside the organization that must be accurate, fair, and provide the appropriate communication channels for each situation.

• 3.3

  The Company, executives, and employees will not communicate, publish, announce both inside and outside the organization with oral or written communications that are untrue, misrepresented, malicious or damaged to the reputation of an individual or group of people. The verbal communication of executives and staff are required with good language and tone of voice that do not affect the image and reputation of the Company.

• 3.4

  The Company will manage the operations with integrity, records of accounting correctly, propose the use of budget clearly, including evaluating investment projects with honesty, accuracy, transparency.

• 3.5

  The Company expects an honesty from employees at all levels in compliance with the Company's policy, accounting rules, and other internal controls. If employees found the violation of rules or policies of the Company that will result in corruption and dishonor to the Company, the employees should inform their supervisor immediately.

• 3.6

  The Company will operate the business by taking into account the duties and responsibilities towards the nation, religion, and monarchy institutions, including the law and good morals.

• 3.7

  The Company adheres to create a good working atmosphere and give opportunities for opinions, comments, and suggestions that are beneficial to the public.

• 3.8

  The Company will not discriminate on the basis of race, religion, gender, marital status, or physical disabilities.

4. Treatment of Shareholders

• 4.1

  The Company will use the best effort to create growth in order for the shareholders to receive good returns.

• 4.2

  The Company respects the rights of shareholders to obtain necessary information to assess the Company's management in order to make decision in voting on agendas of the shareholders' meeting. The Company will disclose the operating results with the correct and truthful information and report on the Company's financial position to shareholders constantly.

• 4.3

  The Company has a policy to record accounting transactions accurately and completely in accordance with accounting standards and relevant laws through the audits from an internal auditor, external auditor, and the audit committee.

• 4.4

  The Company will respect and maintain legal rights of shareholders, and shareholders will be treated with honesty, transparency and fairness.

5. Treatment of business counterparts and contract parties

• 5.1

  The Company intends to provide goods and services in a standardized manner and ethics. It operates under the following principles:

  1. There is competition from bidders and select appropriately and fairly.
  2. There are criteria for evaluating and selecting business counterparts and contract parties.
  3. Prepare an appropriate contract format.
  4. Provide a management and monitoring system to ensure that compliance with the conditions of the contract completely in order to prevent the corruption at every step of the procurement process.
• 5.2

  The Company intends to provide services according to professional standards with good quality, honesty and fairness.

• 5.3

  The Company has a policy to maintain the confidentiality of its business counterparts and contract parties in order to conduct business fairly and independently, and do not conduct business illegally between business counterparts and contract parties as well as do not bribe or provide any things to others for business benefits.

• 5.4

  The Company maintains conducting the business fairly. It is based on decision making criteria by comparing conditions, prices, quality, and services in a transparent and verifiable manner. However, it is forbidden to demand that business counterparts and contract parties give or receive any benefits in business operations.

• 5.5

  The Company adheres to develop and maintain sustainable relationships with business counterparts and contract parties about clear objectives in terms of product and management that is worthy of monetary value, technical quality, and mutual trust.

• 5.6

  The Company requires to properly conduct business between its business counterparts and contract parties, and be protected by laws related to consumer protection.

6. Treatment of business competitors

• 6.1

  The Company has a policy to conduct business fairly and without imputing or destroying competitors.

• 6.2

  The Company has a policy to compete with competitors according to the rules and framework of the competition law.

7. Treatment of Customers

• 7.1

  The Company has a policy to create customer satisfaction on the basis of maintaining the best interests of the Company.

• 7.2

  The Company has a policy in terms of producing and distributing tap water in order to meet the three characteristics as follow:

  1. Cleanliness in accordance with the requirements of industrial product standards.
  2. Sufficiency in terms of pressure and water supply.
  3. Continuity in both production processes and water supply.
• 7.3

  The Company will provide professional services to customers that exceed their expectations.

8. Treatment of Directors, Executives, and Employees

• 8.1

  The Company has a policy to determine remuneration for directors, executives, and employees at an appropriate and fair level.

• 8.2

  The Company pays attention on the welfare, security, and career advancement of employees.

• 8.3

  The Company has a policy for directors, executives and employees to be protected in performing their duties according to the law.

• 8.4

  The Company attempt to prevent accidents, injuries, and pain from occupation by the serious cooperation of all employees, and will limit and manage security risks that occur from working according to operating procedures.

• 8.5

  The Company will provide the design of tools, equipment for the preparation of training procedures and operational control by taking into account the safety of employees’ life and property including the segment that the Company has run business.

• 8.6

  The Company will cooperate with government agencies and other organizations to halt any emergency or accident resulting from operations with speed, efficiency and guardedness.

• 8.7

  The Company will comply with laws and regulations strictly, and will apply international standards for safety management in the case that do not have applicable laws and regulations.

9. Duties to the Community, Society, Environment and Government

• 9.1

  The Company has a policy to operate its business with consideration to the community, society, environment, and the government sector, and will comply with all applicable community, social, environmental, and governmental laws and regulations.

• 9.2

  An omission to comply with the relevant laws, rules, and regulations may result in the person who did such omission and the Company will be held legally responsible for both civil and criminal law. Such person may be received disciplinary action and be terminated in accordance with the Company’s regulations. Therefore, in the event that there are doubts and do not understand about such laws, rules, and regulations if such laws, rules, and regulations are applicable to themselves or not, such persons should consult with their respective supervisors to find clarification on the matter.

10. Conflicts of Interests

• 10.1

  All executives and employees should avoid an action that may cause any conflict between the personal interests of the employees and the interests of the Company in contact with partners and others.

• 10.2

  Executives and employees will not use confidential information of the Company to disclose to other person during the Company's employment or upon leaving the Company's employment without permission from the Company.

• 10.3

  Executives or employees become directors or consultants in other companies or other business association organizations whether they acts on behalf of the Company or not, it must not be in direct conflict with their interests and duties and must be approved by the Company according to the Company's regulations.

• 10.4

  In the case of executives or employees and family members participate or are a shareholder in any business which may have benefits or cause business conflicts with the Company, such person must inform the Company in writing.

• 10.5

  In case of conflict of interest due to the events at that time and without the intention of management, employees, and related persons. If such person is aware that he or she is in such situation, he or she must report such incidents to the supervisor immediately for further solutions.

11. Use of inside Information for Securities Trading

Management and employees will strictly follow the document “Guidelines for the Prevention of Use of inside Information” determined by the Company that will not use inside information especially important information which has not been disclosed to the public under the Securities and Exchange Act, the regulations of the Stock Exchange of Thailand, and any other relevant laws for personal benefit or third parties, which affects the price or trading of securities of the Company and relevant companies.

12. Gambling, Drinking Alcohol, and Drugs

• 12.1

  The Company has a policy to prohibit executives and employees from possessing, buying, selling, moving, using, or drinking alcoholic beverages, drugs, or controlled substances (except prescription drugs) while they work or conduct the business of the Company except for banquets or other festive events that hold outside the Company's area.

• 12.2

  Executives and employees are prohibited from playing or being a participant in all types of gambling both inside and outside working hours or in the area of the Company.

13. Disclosure and Confidentiality

• 13.1

  The Company has a policy to manage an information in the Company effectively and publicize a necessary, accurate, and appropriate information to the public.

• 13.2

  The Company has a policy to maintain confidential information to be under the supervision of the responsible agency clearly and appropriately that includes the supervision of computer networks and software.

• 13.3

  Employees must not disclose the Company's information that have not been disclosed to the public, employees must not use any information that they has been known or prepared form their duties in the Company to use for personal benefits.

Confidentiality of information including personal information of employees which means an information about income and benefits and medical information. Such information will be able to publicize to inside or outside person the Company to use when it is absolutely necessary. Employees who are responsible for this personal data must comply with the said policy and the Company’s Privacy Policy with extremely guardedness and keeping confidentiality strictly.

14. Assets of the Company

Employees should use the Company's assets economically and with the maximum benefit, and do not use the Company's assets for personal benefit. All employees must be responsible for supervising about the Company's assets from being lost, damaged, misused, stolen, and destroyed. It does not only cover the performance of employees but also pay attention to the procedures of security and the alertness for the situation and events that may occur and cause the Company's assets damaged, stolen, or misused.

Company’s assets includes cash, financial instruments, company information, intellectual property, computer system software, software, electronic mail, documentation, tools, facilities, vehicles, company name, company logo, and equipment.

15. Other Work or Activities outside Working Hours

Employees who require to work or do activities outside of working hours must be approved by the supervisor in accordance with the Company's regulations.

16. Gifts and Hospitality

The Company has a policy to conduct business with transparency and morality. Therefore, executives and employees should not damage the Company's reputation by misconducting of any action that may be a charge of honesty and fairness, the guidelines that should be complied as follow:

• 16.1

  The Company requires the executives and employees to avoid giving or receiving anything or any benefits from business counterparts or who are involved in the Company's business, excepting in festivals or traditions and it is the suitable value which the receiver should consider.

• 16.2

  In the case of executives and employees received gifts in the form of money or items of high value, they should inform their supervisors and return such gifts or items.

• 16.3

  Executives or employees should avoid giving or receiving hospitality that exceeds the normal circumstance from other persons who conducts a business that is related to the Company's business.

17. Exceptions to Comply with the Business Code of Conduct and Ethics

The violations of the business code of conduct and ethics in this handbook may also cause a violator to be penalized by the provisions of the law and related regulations, and in some cases may result in the Company that the Company must be responsible according to such laws and regulations. In the event of occurring of such violations, the violator is not only punished by law but may also be received disciplinary action according to the Company's regulations that such violator may receive the exclusion or displacement.