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64 Super Turtle Public Company Limitedthe Company divides the group of stakeholders into (a) the group of stakeholders within the organization which includes shareholders, investors, and employees and (b) the group of stakeholders outside the organization which includes customers, business partners, creditors, competitors, community, society and environment. Disclosure and Transparency The Company places importance on the disclosure of the Company%u2019s information and memorandum, both financial and non-financial, to be equally accessible by the shareholders, investors, analysts, those interested in investment in the Company%u2019s securities, and other stakeholders through various channels, such as the SET disclosure system and the Company%u2019s website. Information and memorandum shall (a) be disclosed accurately, completely, sufficiently, clearly, and in a timely manner both in Thai and English, and correspond to relevant laws and regulations, (b) be prepared in careful and transparent manner with concise and easy understanding language, and (c) be updated on regular basis. In the past year, the Company disclosed its information in compliance with the SET%u2019s and the SEC Office%u2019s regulations. The Company did not face any cases of being fined, accused, or subject to legal action by the SEC Office or the SET regarding violations of equal treatment of shareholders in the matters such as share repurchases, preventing shareholders from communicating with each other, and undisclosing information that could have a significant impact on the Company or other shareholders. In addition, the Company also engaged in meetings with investors and analysts to disseminate and clarify information about its business operations.19.2 Code of ConductThe Company realises the importance on business operations and management with ethics and morality by taking into account the rights of stakeholders. Therefore, the Company has provided the Code of Conduct as frameworks and guidelines for the Company%u2019s directors, executives, and employees (collectively, the %u201cPersonnel%u201d) to adhere and follow. The Company shall review the Code of Conduct on an annual basis. The Code of Conduct covers the following topics:1. Anti-corruption2. Confidentiality and Protection of Personal Information3. Respect for Human Rights4. Use of IT Systems 5. Intellectual Property6. Anti-Money Laundering7. Political Activities8. Conflict of Interest9. Occupational Health and Safety 10. Trading of Securities11. Treatment of Shareholders and Investors12. Treatment of Customers13. Treatment of Employees14. Treatment of Business Partners15. Treatment of Competitors16. Treatment of Creditors17. Treatment of Community, Society and Environment18. Treatment to Government Sector and Regulators19. Whistleblowing20. Disciplinary ActionsThe details of Code of Conduct can be considered on the Company%u2019s website under Code of Conduct section. The Company realises the importance of both internal and external participation in corporate governance, therefore, provides channels for all stakeholders to contact or express concerns or complaints should there be any breach or case of possible breach of the Corporate Governance Policy and Code of Conduct, or any other policies of the Company including rights abuses.The Board of Directors established a mechanism for handling complaints and whistleblowing as stipulated in the Code of Conduct and the Whistleblowing and Protection Measures which areparts of the Anti-Corruption Policy. This mechanism aims to build and gain trust with whistleblowers and complainants. It covers complaints and whistleblowing channels, protective measures for the whistleblowers, confidentiality, procedures upon receipt of whistleblowing or complaints and disciplinary actions. The details could be summarised as follows.Reporting and Whistleblowing Channels1) The Contact Us page on the Company%u2019s website at https://www.superturtle.co.th2) Via email:%u2022 To the Board of Directors and the Company Secretary Office at bod@superturtle.co.th, or%u2022 To the Audit Committee and the Internal Audit Department at ac@superturtle.co.th3) By post or by hand to the Board of Directors via the Company Secretary Office or the Audit Committee via the Internal Audit Department, at the Company%u2019s head officeIntroduction Nature of Business Business Performance Corporate Information Corporate Governance Financial Report Attachment