Business Ethics

Importance

Airports of Thailand Public Company Limited (AOT) conducts its business with a strong commitment to ethical principles, integrity, transparency, and social responsibility, ensuring that its operations are auditable and free from any acts that may constitute corruption, bribery, or misconduct in any form.
As a state enterprise with a significant role in the country’s economic and social development, AOT places great importance on conducting business ethically across all dimensions, including respect for human rights, fair labor practices, environmental stewardship, and good corporate governance. This commitment aims to build trust among all stakeholder groups and to ensure alignment with state enterprise ethical standards as prescribed by relevant laws 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.
To ensure comprehensive ethical governance in business operations, AOT has established relevant policies, criteria, and guidelines addressing key ethical issues. These serve as reference frameworks for operational practices, oversight and monitoring, as well as communication with stakeholders, as presented in the table below.

ตารางนโยบาย

Ethical Issues	Relevant Policies
Bribery & Corruption	Anti-Corruption Policy AOT Good Corporate Governance Handbook 2025 Section 5.14: Code of Conduct on the Acceptance of Gifts, Assets, or Any Undue Benefits Principles and Guidelines on Conflict of Interest AOT Supplier Sustainable Code of Conduct
Discrimination	Human Rights Policy AOT Good Corporate Governance Handbook 2025 5.4 Employee Code of Conduct Section 5.4.3.6 Employees shall treat one another with respect, dignity, and equality, without discrimination based on gender, age, race, religion, nationality, opinion, disability, or any other status. 5.6 Code of Conduct on Relations with Customers and Service Providers Section 5.6.2 AOT personnel are required to carry out their duties with dedication and commitment, strictly complying with all applicable terms and conditions relating to customers and service providers. They shall perform their responsibilities with a service-minded attitude, free from bias, and with fairness and equality. In addition, they must safeguard the confidentiality and protect the interests of customers and service users, without imposing unfair conditions or misusing any information for personal gain. 5.7 Code of Conduct on Relations with Business Partners, Competitors, and Creditors/Debtors Section 5.7.1 Partnership Relations 5.8 Code of Conduct on Responsibility toward Employees Section 5.8.8 Treat employees with fairness and courtesy, respecting individuality, human dignity, and human rights. Discrimination based on gender, age, race, nationality, religion, beliefs, political opinions, or disabilities is not permitted.
Confidentiality of Information	AOT Personal Data Protection Policy AOT Good Corporate Governance Handbook 2024 5.15 Code of Conduct on Confidentiality 5.16 Code of Conduct on Securities Transactions and Use of Insider Information
Conflict of Interest	Principles and Guidelines on Conflict of Interest AOT Good Corporate Governance Handbook 2025 5.13 Code of Conduct on Related-Party and Conflict of Interest Transactions
Antitrust/Anticompetitive practices	Fair Operating Policy and Practices AOT Good Corporate Governance Handbook 2024 5.7 Code of Conduct on Relationship with Business Partners, Competitors and Creditors and Accounts Receivable Section 5.7.2 Relations with Business Partners and Competitors 5.18 Code of Conduct on Procurement of Supplies Section 5.18.7 Invitations for suppliers to submit quotations must be conducted in a manner that ensures fair competition among all suppliers.
Insider Trading/Dealing	AOT Good Corporate Governance Handbook 2025 5.15 Code of Conduct on Confidentiality 5.16 Code of Conduct on Securities Trading and Use of Inside Information
Environmental, Health and Safety Management	Sustainable Development Management Policy Occupational Health, Safety, and Working Environment Policy AOT Good Corporate Governance Handbook 2025 5.9 Code of Conduct on Social, Community and Environment Responsibilities
Whistleblowing / Complaints	Procedures, Receiving complaints or whistleblowing of AOT*
IT Security	AOT Good Corporate Governance Handbook 2025 5.17 Code of Conduct on the Use of Information and Communication Technology (ICT)

* 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 an integrate corporate governance, risk management, and compliance (GRC) policy 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 sets out clear guidelines regarding political contributions or support to any agencies or organizations (Group-Level Anti-Corruption), requiring full transparency and auditability of all financial processes and ensuring that such activities are carried out strictly in accordance with their stated objectives (Anti-Corruption Policy, Clause 3: Charitable Donations, Giving and Receiving Support by AOT, which are subject to control, review, approval, and verification procedures).
However, AOT maintains political neutrality, as demonstrated by political contributions amounting to THB 0 (no political contributions), both directly and indirectly (Anti-Corruption Policy, Clause 4: AOT’s policy on non-support of facilitation payments).

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 10 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
Establish business ethics and related policies Conduct fraud risk assessment Communicate and provide training to employees Set employee indicators for ethical conduct, linked to compensation Verify backgrounds of employees and third parties to prevent conflicts of interest and raise concerns Implement robust internal controls and fraud detection mechanisms	Provide a mechanism for reporting fraud and whistleblowing Monitor and detect fraud-related risks	Define the internal investigation process Establish measures to address identified fraud incidents Specify disciplinary actions and responsibilities Provide guidelines for disclosing corruption-related information

The Fraud Risk Assessment (FRA) Manual serves as the primary framework for operations across the organization. The scope of fraud covered under this framework encompasses three main types of fraud, namely:

Asset misappropriation, involving intentional acts to obtain benefits for oneself or others;
Fraudulent reporting, including both financial and non-financial reporting; and
Corruption, including the giving and/or receiving of bribes, conflicts of interest, coercion or solicitation of undue benefits, and facilitation payments.

AOT’s fraud risk, management process covers the prevention, detection, and response to fraud throughout its operational processes. This process is used as a basis for assessing risks within operations, particularly in high-risk areas or processes. It encompasses processes related to procurement, contract management, finance, and interactions with external parties. In addition, AOT has established systematic, comprehensive, and risk-aligned anti-corruption measures, as outlined below:

Conducting annual fraud risk assessments covering all organizational units and integrating the results with the enterprise risk management process;
Establishing Key Risk Indicators (KRIs) and conducting quarterly monitoring to serve as early warning mechanisms and support proactive risk management;
Implementing internal controls and clear segregation of duties in high-risk operational processes;
Conducting background checks on employees and external parties, including suppliers, contractors, and service providers—particularly new business partners—through transparent transaction oversight and third-party screening both prior to and throughout the business relationship. These processes assess credibility, financial status, reputation, potential conflicts of interest, and any past involvement in corruption cases, as part of efforts to mitigate fraud risks arising from business partners;
Providing independent whistleblowing mechanisms with whistleblower protection, accessible to both employees and external parties; and
Establishing clear and fair investigation procedures, corrective measures, and disciplinary actions.

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
Email: anti-corruption_center@airportthai.co.th
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 the whistleblowing process illustrated in the diagram, as a state enterprise, Airports of Thailand Public Company Limited (AOT) is subject to oversight by several public sector agencies that also provide mechanisms and channels for whistleblowing. These mechanisms are administered by the State Audit Office of the Kingdom of Thailand and the National Anti-Corruption Commission, both of which are independent constitutional bodies or independent regulatory authorities/third parties.
These agencies provide channels for individuals to submit whistleblower reports. All reports are submitted through systems that allow anonymity in order to maintain confidentiality and ensure protection against retaliation in all cases.

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 2025, AOT achieved a score of 94.50 under this national integrity evaluation

Organizational Culture Promotion and Business Ethics Training Activities

AOT regularly organizes activities to promote business ethics, anti-corruption and bribery 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

In 2025, Airports of Thailand Public Company Limited (AOT) continued to promote integrity, ethical conduct, and anti-corruption practices through various activities and initiatives aimed at enhancing knowledge, understanding, and awareness of integrity among employees at all levels. These efforts also focus on fostering a strong organizational culture grounded in the principles of good corporate governance in a sustainable manner.

Employee training on anti-corruption and business ethics.

AOT places strong emphasis on continuously enhancing knowledge, understanding, and awareness of anti-corruption and fraud prevention among employees at all levels. This is achieved through training programs and activities designed to foster an organizational culture rooted in integrity and aligned with applicable laws, regulations, and AOT’s anti-corruption policies.
The training programs cover key corruption-related issues, including bribery, conflicts of interest, and abuse of authority, while also promoting awareness of risk identification and appropriate conduct in operations. In 2025, AOT provided training to a total of 471 employees to enhance their understanding of preventive measures and compliance with the Company’s policies and requirements. Details of the training programs are as follows:

Airport Operation Program – 3 sessions, totaling 166 participants
Junior Airport Management Program (Entry Level) – 3 sessions, totaling 185 participants
Junior Airport Management Program (Intermediate Level) – 2 sessions, totaling 120 participants

In addition, AOT disseminated its Anti-Corruption Policy for 2025 to 100 percent of its personnel. The policy was also publicly disclosed through the website of AOT’s Corporate Compliance and Anti-Corruption Department.

Anti-corruption and business ethics communication.

AOT regularly develops and disseminates communication materials on anti-corruption and ethical conduct by coordinating with relevant units to communicate information through various AOT communication channels. These efforts include, for example, live broadcasts of International Anti-Corruption Day activities, the AOT ITAGC Connect program, and the monthly Integrity Boost initiative.
In addition, AOT has issued and disseminated an announcement on the “No-Gift Policy regarding the acceptance of gifts and other benefits during the New Year festival and on other occasions.” The content of this announcement has been integrated into AOT’s core employee training programs, including the Airport Operation Program and the Junior–Intermediate Airport Management Programs. AOT also seeks cooperation from its personnel to refrain from accepting gifts or other benefits from external individuals or organizations.
Furthermore, AOT has communicated this announcement to employees across the entire organization and all airports under its supervision, as well as to business partners, joint ventures, and subsidiaries, in order to raise awareness and ensure strict compliance.

Driving anti-corruption communication in collaboration with the public sector

AOT cooperates with the National Anti-Corruption Commission (NACC) to support the initiative to enhance Thailand’s Corruption Perceptions Index (CPI), particularly in the area of public communication. As part of this effort, AOT disseminates anti-bribery and anti-corruption campaign materials in the form of infographics and video clips through display screens at all six airports under AOT’s responsibility.
These activities aim to raise awareness among the general public, tourists, and both domestic and international investors, while also promoting the country’s image in terms of transparency through the role of airports as the “Gateway to Thailand.”

Ethics and integrity training: Leading AOT toward becoming an ethical organization

AOT organized a special lecture entitled “Ethics and Integrity: Leading AOT toward Becoming an Ethical Organization” on 26 February 2025. The event was presided over by Dr. Kerati Kijmanawat, President of AOT, and honored by a keynote lecture delivered by Dr. Suwit Rattanasukhon, a Judge of the Specialized Appeal Court.
The activity was attended by AOT’s senior management and employees and was live-streamed via AOTPR Facebook Live (closed group), enabling employees from all six airports under AOT’s supervision to participate. The program included a special lecture and an award presentation ceremony recognizing AOT departments and airports for their achievements in promoting ethical conduct.
The event aimed to enhance knowledge and understanding, as well as to instill ethical behavior in accordance with AOT’s Regulation on the Code of Ethics B.E. 2566 (2023), while supporting AOT’s development toward becoming an ethical organization characterized by transparent management and a zero-tolerance approach to corruption.

AOT Integrity Roadshow

Anti-Corruption Network Project (The X Team), Batch 3

AOT organized the prevention and anti-corruption network project (The X Team), Batch 3, for fiscal year 2025 during 27–29 August 2025 at The Zign Hotel, Pattaya, Chonburi Province. The project was attended by 60 employees from both the head office and regional operations.
The project was supported by speakers from the National Anti-Corruption Commission (NACC), who shared knowledge and experience in anti-corruption practices. Activities under the project included network building, team capability development activities, and workshops based on case studies. The objectives were to enhance knowledge on corruption prevention and to promote employee participation in building a strong anti-corruption network, thereby fostering an organizational culture aligned with the core value “5 Hearts of Pride (Integrity).”

AOT Anti-Corruption Day Project

AOT organized the selection of outstanding employees in integrity under the title “Integrity Role Model: AOT People of Integrity” for fiscal year 2025 on 18 June 2025. A recognition award ceremony honoring AOT’s valuable personnel was subsequently held on 1 July 2025. The project aimed to promote, recognize, and honor employees who demonstrate strong ethical conduct and integrity.
The employee who received the top award as the outstanding integrity role model “Integrity Role Model: AOT People of Integrity” was nominated for the “Transport Role Model” award for fiscal year 2025, with the award ceremony held on 29 September 2025. This reflects AOT’s commitment to recognizing and promoting ethical role models within the organization.

“AOT ITAGC Connect" Project

AOT organized the “AOT ITAGC Connect” program to promote knowledge and understanding of the Integrity and Transparency Assessment of Government Contractors (ITAGC) among AOT’s suppliers and contractors. The program was held at the AOT Auditorium, 2nd Floor, Head Office Building.
The program reflects AOT’s commitment to enhancing transparency in procurement operations, while strengthening suppliers’ understanding of the principles, data preparation methods, benefits of participating in the assessment, and good practices. The event was honored by Mr. Therdsak Ritthachoti, an expert from the National Anti-Corruption Commission (NACC), who served as a guest speaker. The program aims to enable suppliers and contractors to effectively apply this knowledge in their business operations and to jointly contribute to improving Thailand’s Corruption Perceptions Index (CPI) in the long term.

AOT Anti-Corruption Day "Hero to Zero" Project

AOT organized the AOT Anti-Corruption Day “Hero to Zero” Project for fiscal year 2025 on 22 September 2025 to demonstrate the organization’s commitment and firm intention to prevent and combat corruption. The event was attended by Mr. Apirat Chaiwongnoi, Chairman of AOT, together with Ms. Paweena Jariyathitipong, Senior Executive Vice President and Acting President, members of the Board of Directors, executives, and employees of AOT, who jointly participated in the activities and declared their commitment to anti-corruption efforts.
The event was honored by representatives from the Ministry of Transport, the National Anti-Corruption Commission (NACC), the Public Sector Anti-Corruption Commission (PACC), as well as AOT’s joint ventures and subsidiaries, who attended as witnesses. This reflects strong cooperation from all sectors in promoting transparency and good corporate governance.
In addition, AOT was honored by a special lecture delivered by Professor Emeritus Vicha Mahakun, Chairman of the Anti-Corruption Foundation of Thailand, on the topic “Public Participation in Corruption Prevention.” The lecture aimed to raise awareness of the role of all sectors in jointly preventing and addressing corruption in a sustainable manner. The event also featured activities to promote ethics and integrity, such as award presentations to winners of the contest to name AOT’s ethics promotion song and the anti-corruption video clip competition under the theme “AOT Does Not Tolerate Corruption.” Furthermore, educational exhibitions and campaign activities were organized to foster awareness and ethical consciousness in anti-corruption efforts, alongside promoting AOT’s “Five Hearts” core values as a sustainable organizational culture.

AOT places strong emphasis on promoting ethics and integrity among its employees, guided by the principle that “Ethics develop people and strengthen organizations.” In fiscal year 2025, a total of 14 units participated in the Ethical Organization Assessment, comprising 8 functional divisions and 6 airport units. The assessment results are as follows:

Ethical Promotion Level – 2 units
- Business Development and Marketing
- Engineering and Construction
Ethical Development Level – 1 unit
- Human Resources and Administration
Ethical Role Model Level – 11 units
- Digital Technology and Innovation
- Airport and Aviation Standards
- Corporate Strategy
- Accounting and Finance
- Regional Airports
- Suvarnabhumi Airport
- Don Mueang International Airport
- Chiang Mai International Airport
- Hat Yai International Airport
- Phuket International Airport
- Mae Fah Luang Chiang Rai International Airport

As a result of these achievements, the overall assessment of Airports of Thailand Public Company Limited (AOT) for 2025 was rated at the level of an Ethical Role Model Organization.

Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.

ทบทวนล่าสุด 27/02/2026