The Company is dedicated to conducting its business operations with integrity and responsibility toward its stakeholders. It strongly emphasizes transparency, integrity, and compliance with laws and regulations, alongside adherence to the principles of good corporate governance and the business code of ethics. These guidelines define the scope and standards of behavior that all employees, including the Board of Directors and executives, must follow to align with ethical values.

All executives and employees are obligated to adhere to the Company’s Code of Ethics policy and manual to instill values of morality and accountability in the organizational culture. It is important for each executive and employee to behave with civility and consciousness, to consider the benefits and impacts of their actions on the Company’s stakeholders impartially and fairly, to conduct business with responsibility, and to establish a robust work system that prevents corruption through an internal audit system.

The Board of Directors delegates responsibility to the Corporate Governance and Sustainable Development Committee to establish policies, oversee implementation, and review the adequacy of anti‑corruption measures. This includes ensuring the effectiveness of internal control systems, complaint‑handling mechanisms, and appropriate whistleblower protection. Meanwhile, management and relevant functions are responsible for implementing these policies across the organization through the development of procedures, risk assessments, communication and training, compliance monitoring, and operational audits, to ensure that anti‑corruption measures are effectively applied throughout the organization.

The Company has announced policies and guidelines that are more suitable for the current business environment. These policies comply with generally accepted criteria and regulations, promoting and supporting ethical business operations. Additionally, the Company has published its manuals for Good Corporate Governance and a Code of Conduct along with other policies, on its website and intranet. This enables all members of the organization, including the Board of Directors, executives, and employees of the Company and its subsidiaries, to access and use them as guidelines for operations. Further to this, the Company has established AMATA’s Supplier Code of Conduct to ensure that its suppliers operate in accordance with the Company’s practices and standards. The Code encompasses key areas such as ethical conduct, legal compliance, anti-corruption, human rights, safety, and social and environmental responsibility. The Company publicly discloses the Supplier Code of Conduct on its website and requires suppliers to acknowledge and sign their commitment to adhering to these practices.

See more details about our Business Ethics and Anti-Corruption Policy

The Company has established clear guidelines for specific situations under its Anti‑Corruption Policy to prevent corruption risks in sensitive activities that may give rise to conflicts of interest, as follows:

1. Giving or Receiving Gifts, Hospitality, and Other Benefits

The Company requires that the giving or receiving of gifts, hospitality, or other benefits be carried out with caution, transparency, and in compliance with applicable laws, Company regulations, and appropriate business practices. Such actions must not be intended, nor perceived, as an inducement to influence improper actions or to obtain inappropriate business advantages.

• Acceptance of gifts or other benefits: Directors, executives, and employees must not accept gifts, services, hospitality, or other benefits from business‑related parties if such acceptance may influence decision‑making or give rise to conflicts of interest.
• Giving of gifts and hospitality: Gifts and hospitality may be provided only when there is a clear and legitimate business purpose, the value is appropriate and not excessive, and the action is not intended to induce government officials, business partners, or external parties to perform or refrain from performing improper acts.
• Approval and record‑keeping: Related expenses must be approved in accordance with the Company’s authorization matrix and properly recorded with complete and accurate supporting documentation to ensure transparency and auditability.

2. Charitable Donations and Sponsorships

The Company requires that charitable donations and sponsorships be conducted transparently, verifiably, and solely for public benefit, community development, or genuine social purposes. Such activities must not be used as a means to seek improper benefits or to conceal corruption in any form.

• Conducted in the name of the Company only: All donations and sponsorships must be made in the name of the Company, not in a personal capacity, and must not be linked to the personal interests of employees, executives, government officials, or decision‑makers related to the Company.
• Due diligence on recipients: The Company conducts appropriate due diligence on the status and credibility of recipients or beneficiary organizations, as well as on project objectives, to ensure legality and alignment with the Company’s policies.
• Documentation and follow‑up: All donations and sponsorships must be supported by complete and verifiable documentation, covering approval, payment, and the use of funds in accordance with the stated objectives.

3. Political Contributions and Political Involvement

The Company upholds political neutrality and has no policy of providing direct or indirect political support in exchange for business benefits or to obtain inappropriate operational advantages.

• No use of Company resources for political purposes: The Company does not provide financial contributions, assets, facilities, equipment, or other Company resources to political parties, politicians, election candidates, or political activities for political purposes.
• Protection of individual rights: The Company respects employees’ political rights as citizens within the legal framework. However, employees must not use the Company’s name, position, or resources in a manner that could imply the Company’s political support.
• Prevention of conflicts of interest: Employees must avoid any actions that may give rise to the perception that personal political involvement is connected to the Company’s business decisions.

In 2025, the Company did not make any political contributions, whether in monetary or non-monetary forms, to political parties, politicians, or election candidates. The Company did not contribute funds, assets, services, facilities, materials, equipment, or other resources to political activities, either directly or indirectly, in line with the principle of political neutrality set out in the Company’s Anti‑Corruption Policy.

The Company has integrated corruption risk assessment as part of its internal control system and enterprise risk management framework, with the objective of preventing and reducing the likelihood of corrupt practices across all business activities.

In 2025, the Company conducted corruption risk assessments covering 100% of its core operations in Thailand, totaling four operational units. These include the Bangkok Head Office, AMATA City Chonburi Industrial Estate, AMATA City Rayong Industrial Estate, AMATA Smart City Chonburi Industrial Estate, and AMATA City Chonburi 2 Industrial Estate, as well as subsidiaries under the Company’s operational control within the defined reporting boundary.

The Company applied the framework of the Thai Private Sector Collective Action Against Corruption (Thai CAC) to identify potential risk points across 14 business processes. In 2025, 10 processes were subject to in‑depth assessment, representing 71.4% of the total identified processes. Based on the assessment, the Company identified the following significant corruption‑related risks:

• Risks arising from interactions with government authorities, such as the risk of bribery or improper benefits to accelerate approvals for environmental impact assessments (EIA/EHIA), construction permits, and permit renewals.
• Risks related to land transfers, issuance of land title deeds, and land rights management.
• Risks associated with regulatory compliance and enforcement, including the risk of improper payments to avoid reporting exceedances of environmental pollution standards or to circumvent fines or legal actions in the event of environmental incidents.
• Risks in complaint management processes, which may involve the concealment of information or undue interference in the handling of complaints.

For the identified risks, the Company has established appropriate internal control measures, review processes, and checks and balances. This includes the application of technology to reduce reliance on individual discretion in high‑risk processes. Furthermore, the Company plans to expand in‑depth corruption risk assessments to cover the remaining four business processes within 2026, such as public sector‑related procurement and public‑private partnership projects, to ensure comprehensive coverage of all critical processes in a complete and systematic manner.