Importance
AOT operates with a firm commitment to ethical principles, emphasizing integrity, transparency, accountability, and zero tolerance for all forms of corruption. This commitment extends to preventing negative impacts on the environment, ensuring fair labor practices, and upholding human rights. AOT’s approach aims to build trust among all stakeholder groups and to comply with the ethical standards for state-owned enterprises, in accordance with the Constitution of the Kingdom of Thailand and the National Anti-Corruption Strategy.
Policy
AOT requires all members of the Board of Directors, executives, and employees at all levels to adhere to the Company’s Corporate Governance Policy, Anti-Corruption Policy, and Code of Conduct as stipulated in the “AOT Good Corporate Governance Manual 2024” In addition, AOT has established clear guidelines and practices on conflict of interest, as well as the “AOT Risk Management Manual 2024” focused on corruption-related risks, to serve as a framework for ethical conduct across the organization. In pursuit of sustainable growth across all dimensions of its operations, AOT has also introduced the AOT Sustainable Supplier Code of Conduct. This framework encourages business partners to operate with transparency, uphold ethical standards, respect human rights, ensure occupational health and safety, and consider the broader social and environmental impacts of their operations. These expectations are enforced through robust corporate governance and alignment with internationally recognized best practices.
| Ethical Issues | Relevant Policies |
|---|---|
| Bribery & Corruption |
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| Discrimination |
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| Confidentiality of Information |
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| Conflict of Interest |
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| Antitrust/Anticompetitive practices |
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| Insider Trading/Dealing |
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| Environmental, Health and Safety Management |
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| Whistleblowing / Complaints |
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| IT Security |
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* AOT has established formal procedures for receiving complaints or whistleblower reports related to ethical conduct in operations, in order to ensure that all reported matters are properly monitored and addressed.
In the event that a violation of the Business Code of Conduct is confirmed, AOT shall take disciplinary action and impose penalties on the responsible party in accordance with the Company’s regulations. The Corporate Compliance and Anti – Corruption Department is responsible for analyzing the root causes, reviewing relevant processes to prevent recurrence, and reporting on compliance with the Business Code of Conduct to the relevant committees, including the Audit Committee, the Corporate Governance Committee, and the Board of Directors of AOT.
In addition, AOT has established a policy to integrate corporate governance, risk management, and compliance (GRC) into a unified framework in order to elevate its organizational management to align with international best practices. This integration ensures that all departments, systems, processes, personnel, and data are aligned systematically, enabling AOT to achieve its defined strategies, objectives, and targets while also taking into account the expectations of its stakeholders.
AOT's Support Policy
AOT’s Anti-Corruption Policy establishes comprehensive guidelines governing all forms of external support, including political contributions and assistance to third-party organizations, ensuring full compliance with Group-Level Anti-Corruption standards. The policy mandates that any financial support provided must demonstrate complete transparency, undergo rigorous verification processes, and maintain strict alignment with clearly defined organizational objectives. These requirements are detailed in Anti-Corruption Policy Clause 3, which covers Charitable Contributions, Donations, and AOT’s protocols for both giving and receiving support, incorporating systematic processes for control, verification, approval, and ongoing review.
AOT upholds absolute political neutrality through its zero-contribution policy, maintaining no direct or indirect political financial support. This commitment is reinforced by Anti-Corruption Policy Clause 4, which explicitly prohibits both the acceptance and provision of facilitation payments
- Integrity in Work Performance
- AOT Regulation on Ethical Standards 2023 (B.E.2566)
- AOT Good Corporate Governance Handbook 2024
- AOT Corporate Governance Policy
- AOT Supplier Sustainable Code of Conduct
- Anti-Corruption Policy
- Procedures, Receiving complaints or whistleblowing of AOT
- Ethical and Disciplinary Performance Metrics for AOT Employees
- Human Rights Policy
- Occupational Health, Safety, and Working Environment Policy
- Principles and Guidelines on Conflict of Interest
- AOT Business Ethics Performance
- AOT Risk Management Manual 2024
- Policy on the Integration of Corporate Governance, Risk Management, and Compliance (GRC)
- Fair Operating Policy and Practices
- Sustainability Management Policy
- AOT Personal Data Protection Policy
Management Approach
AOT recognizes the potential risks related to violations of the Code of Conduct and corruption, therefore requires all employees and relevant business partners to strictly comply with AOT’s policies and practices throughout the value chain. This is to prevent any adverse impact on the Company’s image and stakeholder confidence.
The responsible units include the Corporate Secretary and Corporate Governance Department, and the Corporate Compliance and Anti – Corruption Department, which report their performance to the Corporate Governance Committee and the President. The implementation framework includes clear operational guidelines and communication channels, as outlined below:
Participation in the United Nations Global Compact (UNGC)
AOT has become a participant in the United Nations Global Compact (UNGC), which serves as the United Nations’ strategic policy initiative for sustainable development. The Compact encourages companies worldwide to voluntarily align their strategies and operations with ten universally accepted principles in the areas of human rights, labour, environment, and anti-corruption.
By adhering to these principles, AOT aims to embed responsible business practices into its operations and decision-making processes. The Company also seeks to promote concrete action in support of the United Nations Sustainable Development Goals (SDGs), with the overarching objective of fostering a more inclusive, sustainable global economy that balances economic, social, and environmental development.
Participation in the Collective Action Against Corruption (CAC)
AOT is committed to transparent business practices and ethical governance through its participation in the Collective Action Against Corruption (CAC), a private-sector initiative aimed at combating corruption through collaborative efforts. The Company is currently preparing certification documentation to join the Thai Private Sector Collective Action Coalition Against Corruption.
AOT actively engages business partners in anti-corruption efforts, developing strategies to promote CAC principles throughout its supply chain. The Company encourages suppliers and partners to adopt these standards, creating a transparent and responsible business network that ensures operational integrity and long-term sustainability across all airport operations.
AOT's Anti-Corruption Guidelines
AOT Fraud Risk Management
AOT adheres to fraud risk management guidelines according to AOT Risk Management Handbook 2024. The main responsible units include the Corporate Compliance and Anti – Corruption Department and the Risk Management Department. The risk management framework for fraud-related issues is outlined as follows: as follows:
| 1 Fraud Prevention Process |
2 Fraud Detection Process |
3 Fraud Response Process |
|---|---|---|
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Reception of Feedback and Complaints Related to Business Code of Conduct and Fraud
AOT has established procedures for receiving and responding to feedback, whistleblowing reports, and complaints related to business ethics and fraud as follows:
AOT’s Whistleblowing Procedure for Fraud and Misconduct Complaints
Whistleblowing Procedure for Fraud and Misconduct Complaints Flowchart
Monitoring Compliance with the Business Code of Conduct
The Corporate Compliance and Anti – Corruption Department and the Corporate Secretary and Corporate Governance Department serve as the key responsible units for monitoring compliance with AOT’s Business Code of Conduct. These departments ensure that ethical standards are upheld throughout the organization and oversee the handling of violations by implementing corrective and preventive measures to avoid recurrence. This is carried out in accordance with AOT’s whistleblowing and complaint handling procedures regarding fraud and misconduct.
Furthermore, AOT reports the outcomes of its monitoring activities to the President and the Board of Directors on a quarterly basis (four times per fiscal year).
Complaint Management: Upon receiving a complaint, the responsible unit conducts an initial screening to assess the clarity and sufficiency of the supporting evidence and testimony. Validated cases are then forwarded to the designated committee for review and resolution in accordance with AOT’s prescribed procedures. The entire process is to be completed within 30 business days.
Prevention of Recurrence: Once an investigation confirms the veracity of the violation, AOT enforces appropriate disciplinary measures in accordance with applicable laws and internal regulations. These actions are taken to prevent the recurrence of similar incidents and to uphold the integrity of the Company’s ethical standards.
Reporting and Oversight: The responsible departments are required to report the results of monitoring activities, including any confirmed violations or absence thereof. In the event of a violation, updates on the status of screening and further investigations must also be included in the reporting process.
Channels for Submitting Feedback and Complaints Related to Business Code of Conduct and Fraud
Postal Mail: Address a letter to:
Director, Corporate Regulatory Compliance and Anti-Corruption Department, or President, or Director, Internal Audit Office, or AOT Board of Directors
Airports of Thailand Public Company Limited (AOT)
333 Cherdwutagard Road,
Si Kan Subdistrict, Don Mueang District,
Bangkok 10210, Thailand
Website: www.airportthai.co.th/th/แจ้งเบาะแสการทุจริต
(Online portal for reporting fraud or ethical misconduct)Walk-in (In-person Submission): Submit a written statement directly to the Corporate Compliance and Anti-Corruption Department
at AOT Headquarters Building.
Remark: In cases where the complaint concerns the Director of the Corporate Compliance and Anti-Corruption Department, the letter should be addressed directly to the President of Airports of Thailand Public Company Limited.
AOT will protect and take into consideration the safety and potential impact on the complainant, the source of information, and any individual involved, in accordance with AOT’s zero-tolerance policy. Disclosure will be made only when legally required during formal legal or investigative proceedings.
Independent Reporting Channel
In addition to illustrative diagram of the whistleblowing process flow, as a state-owned enterprise, several government agencies oversee the business, including the whistleblowing mechanism and its reporting channels. However, the whistleblowing mechanism is operated by the State Audit Office and the National Anti-Corruption Commission, which are government-affiliated but constitutionally independent oversight agencies or independent third parties. They provide mechanisms for those seeking reporting channels. Reports are submitted anonymously in the system to ensure confidentiality and prevent retaliation in each case.
Internal and External Audits
AOT has established comprehensive evaluation mechanisms for anti-corruption management, conducted by both internal and external entities. Internally, the Corporate Compliance and Anti-Corruption Department is responsible for monitoring and assessing the Company’s anti-corruption performance and reports directly to the President. In addition, the Internal Audit Office conducts independent audits and reports directly to the Audit Committee to ensure transparency and adherence to good governance principles.
Externally, anti-corruption performance assessments are carried out under the Integrity and Transparency Assessment (ITA) framework, administered by the Office of the National Anti-Corruption Commission (NACC). In fiscal year 2024, AOT achieved a score of 88.60 under this national integrity evaluation
Organizational Culture Promotion and Business Ethics Training Activities
AOT regularly organizes activities to promote business ethics, anti-corruption practices, and the reinforcement of corporate values on an annual basis. These initiatives include awareness campaigns, special lectures, study visits, and training programs, which are held at a minimum frequency of one activity per month, totaling at least 12 activities per fiscal year. The formats of these activities are as follows:
- AOT Anti-Corruption Day Project
- Executive-Level Communication on Anti-Corruption Policies
- Anti-Corruption Training Program: Integrated into the Operational Airport Training Curriculum, as well as Airport Management Programs at the basic, intermediate, and advanced levels.
- Educational Field Visit to the Anti-Corruption Museum (Office of the NACC)
- Special Lectures on Anti-Corruption Awareness: Delivered at AOT-managed airports to strengthen employee understanding and promote a culture of integrity.
- Training employees on the use of reporting channel.
Implementation
Appointment of the Business Ethics Committee
AOT’s Moral Organization Initiative Implementation
AOT places great importance on promoting morality and ethical values among its employees, in line with the concept: “Moral values develop people and strengthen organizations.” In Fiscal Year 2024, AOT appointed the AOT Moral Organization Steering Committee, along with working groups at the departmental and airport levels, to establish policy and oversee the implementation of moral initiatives in alignment with AOT’s defined objectives. A total of 14 departments and airports participated in the moral organization assessment program. The evaluation results were as follows:
Business Ethics Training
Training Curriculum Content Review
AOT arranged the training courses on corruption prevention and anti-corruption including the ethical promotion
in the core curriculum of AOT, with up-to-date contents given in the training courses as follows:
Airport Operation (AO)
Junior Airport Management (JAM)
Intermediate Airport Management (IAM)
These programs are mandatory for all levels of AOT employees. This ensures that business ethics training is systematically embedded across the organization, covering 100% of AOT personnel.
Special Lecture on Business Ethics and Anti-Corruption
AOT organized a special lecture entitled “Morality and Ethics in the Performance of Official Duties by Public Officers” on Thursday, August 15, 2024. The event was presided over by Mr. Kerati Kijmanawat, President of AOT, who formally opened the session. The event was also honored by Mr. Phantong Loykulnanta, AOT Board Director, who delivered a keynote address, and Ms. Siriwan Menaphot, an esteemed expert from the Office of the Civil Service Commission, who served as the guest lecturer.
The lecture was attended by AOT’s senior executives and staff at the AOT Headquarters Auditorium, with a live broadcast provided via AOT’s closed Facebook group (Aotpr) to ensure access for staff across all six airports. This initiative aimed to disseminate and promote awareness of the organization’s Code of Ethics, Ethical Standards, and Mechanisms for Ethical Compliance, serving as guiding principles for employee conduct. Furthermore, the event is part of AOT’s proactive approach to fostering a culture of integrity and preventing misconduct and corruption throughout the organization.
Anti-Corruption and Integrity Network Project: The X Team
AOT arranged the prevention and anti-corruption network project or The X Team (Class 2) of the fiscal year 2024 for 60 employees during 28 – 30 August 2024 at Ravindra Beach Resort and Spa, Chonburi Province. The program was lectured by guest lecturers from the Office of the National Anti-Corruption Commission (NACC), with an aim to create awareness on the importance of anti-corruption, enhance knowledge and consciousness as well as promoting the corporate culture. It also enhanced the effectiveness of AOT’s anti-corruption operations, fostering a strong internal network to support transparency, accountability, and good governance.
Other Projects and Activities (FY2024)
- AOT has communicated its top management’s policy by issuing the “No Gift Policy” announcement, which prohibits the acceptance of gifts or any other benefits during occasions such as the New Year festival. This policy has been communicated to all AOT employees across all airports, business partners, joint ventures, subsidiaries, and the general public to raise awareness of AOT’s firm commitment to anti-corruption practices.
- Business Ethics Programs
AOT Anti-Corruption Day Project
On Sunday 22 September 2024, AOT organized the activity “AOT Anti-Corruption Walk-Run 2024” to create awareness on the importance of anti-corruption and enhance knowledge and consciousness as well as promoting corporate culture against corruption. The activity was participated by 500 people in total, comprising Air Chief Marshal Manat Chavanaprayoon, Director and the Corporate Governance Committee’s member, Mr. Phantong Loykulnanta, Director and the Remuneration Committee’s member, Mr. Sompob Paksawan, Senior Executive Vice President (Regional Airports), AOT’s executives and employees, together with representatives from AOT’s subsidiary and associated companies, the Office of the National Anti-Corruption Commission (NACC), the Office of Public Sector Anti-Corruption Commission (PACC), the Anti-Corruption Operation Center (ACOC) of the Ministry of Transport, public and private agencies, as well as surrounding communities.
The objective of this project was to raise awareness and emphasize the importance of preventing and combating corruption, while promoting knowledge, a sense of responsibility, and a strong anti-corruption culture within the organization.
Honest People of AOT Program
On Tuesday 28 May 2024, AOT organized employee selection project to be awarded as Honest People of AOT for the fiscal year 2024, aiming to place importance on the promotion of good people and honor those who are good role models of integrity.
Transport Model People Award 2024
Mr. Anirutt Kumtavee, Director of Revenue Management and Development Division, Business Strategic Planning and Statistics Department, who was selected as an Honest People of AOT for the fiscal year 2023, received the “Transport Model People Award 2024” from Mr. Chayatham Phromsorn, Permanent Secretary of the Ministry of Transport. The award ceremony was held on September 23, 2024, at the Royal Coach Auditorium, Ministry of Transport. Mr. Krit Pakagij, Corporate Secretary, together with representatives from the Corporate Compliance and Anti – Corruption Department, also attended the ceremony.
This award is presented to individuals who demonstrate outstanding integrity and serve as exemplary role models for personnel within AOT and other agencies under the Ministry of Transport.
AOT Receives “Good Organization Award” for Promoting Integrity
AOT was selected to receive the “Good Organization Award” on April 4, 2024, at the Parliament House of Thailand. The award was organized by the Senate Committee on Religion, Morality, Ethics, Arts, and Culture and presented to public agencies, state enterprises, private sector entities, and civil society organizations whose leaders serve as role models and actively promote initiatives that cultivate moral values in society. Awarded organizations are also recognized for operating with transparency, integrity, and good governance. In fiscal year 2024, AOT submitted the “Person of Integrity – AOT Role Model” program for consideration, which was selected for this prestigious recognition.
Participation in the Integrity and Transparency Assessment (ITA) 2024
The Office of the National Anti-Corruption Commission (NACC) developed the Integrity and Transparency Assessment (ITA) as a proactive measure to prevent corruption and to promote transparency and integrity in public sector operations. The assessment also serves as a mechanism to raise awareness among government agencies.
AOT has participated in the ITA project since 2015. In the fiscal year 2024, AOT received an overall average score of 88.60, which falls within the “Pass” level.
Communication of Business Ethics Practices
AOT has developed and disseminated anti-corruption and fraud prevention communication materials in collaboration with relevant departments. These materials are distributed through the AOT Staff Application and other official communication channels.
