Business Ethics Policy

Papaya Technologies Co., Ltd. (“The Company”) Business Ethics Policy, embodied in the following standards, is a guide to ethical decision-making. The standards in this Policy may be implemented, interpreted, or amended from time to time through written procedures or other compliance guidelines. This Policy is made available on the Company’s website: www.papaya.co.th/policies

Declaration of Intent

It is the Company’s policy to ensure the actions of the Company’s employees, contractors, directors and owners all operate at the highest level of ethical behavior.


The following standards of conduct will be enforced at all organizational levels. Anyone who violates them will be subjected to prompt disciplinary action, which may include dismissal for cause.

Business Ethics

Compliance with Laws, Rules and Regulations:
Employees and directors of the Company are required to comply with all applicable laws, rules and regulations. Employees are also responsible for honoring and abiding by the contracts that we have entered into with other parties, including intellectual property licenses, confidentiality agreements, contracts with our customers and suppliers, and undertakings and other commitments we may have with government authorities.
Conflicts of Interest:
A conflict of interest occurs whenever our personal interests interfere in any way with our ability to perform our jobs objectively and in the best interests of the Company. In order for the Company to carry out its business effectively, it must be assured of its employees’ undivided loyalty. Employees must therefore refrain from entering into relationships or transactions that might impair their judgment as to what is best for the Company. Even relationships that create the appearance of a conflict of interest should be avoided. Any employee who is presented with a transaction or relationship which could create a conflict of interest must bring the transaction or relationship to the attention of the Company and provide a full written disclosure of the circumstances surrounding the conflict.
No employee, officer or director of the Company may have a financial interest in any competitor, customer, distributor, broker, or supplier where the financial interest would be likely to influence, or appear to influence, his or her actions on behalf of the Company.
Gifts and Entertainment:
The acceptance of gifts and entertainment by employees and directors or members of their family may present a conflict of interest. While employees and directors are permitted to accept gifts of nominal value, they are prohibited from accepting anything that might influence their judgment on Company matters affecting the gift donor or that might be accompanied by any express or implied understanding that the gift recipient is in any way obligated to take some action which would benefit the gift donor to the detriment of the Company in exchange for the gift. Similarly, employees may accept entertainment, but only insofar as it is reasonable in the context of the business at hand and facilitates the Company’s interests. When practical and appropriate, hospitality should be reciprocated. Employees are strictly prohibited from soliciting gifts, gratuities or business courtesies for the benefit of any family member or friend.
Corporate Opportunities:
No employee of the Company, including its officers and directors, may pursue or undertake, for his or her own personal benefit or for the benefit of any other person or organization, any business venture, opportunity or potential opportunity which is in the Company’s line of business without first obtaining the Company’s consent. Employees, officers and directors of the Company owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.
Confidential Information:
All employees and directors have an obligation to safeguard confidential information about the Company and confidential information that our suppliers, customers, associated partners and contractors have entrusted to the Company. Employees and directors must remain conscious at all times of their obligation to protect confidential information against unauthorized disclosure.
Fair Dealing:
The Company is committed to having its employees deal fairly and honestly with the Company’s customers, suppliers, competitors and other employees.
Waivers of the Business Ethics Policy
Any request for a waiver of any standard of this Policy may be granted only by the Company. All employees and directors should be aware that the Company generally will not grant such waivers and will do so only when there is a compelling reason.

Anti-Bribery and Corruption Policy

Papaya Technologies Co., Ltd. (the “Company”) is committed to conducting business in an honest, transparent and just manner while taking all stakeholders into consideration. As such, to ensure that the Company has in place an appropriate policy outlining responsibilities and appropriate operating procedures to prevent corruption and bribery, as well as to ensure that all business decisions which may be at risk of corruption and bribery are considered and managed with proper deliberation, the Company has established in writing an “Anti-Bribery and Corruption Policy” to provide clear guidelines of conduct for all directors, executives and employees of the Company as they perform their duties.

Guidelines for Good Conduct to Prevent Corruption and Bribery

(a) The Company recognizes the importance of distributing and providing knowledge, as well as developing understanding about the Anti-Bribery and Corruption Policy to all directors, executives, and employees of the Company.

(b) Employees of the Company must abide by the Anti-Bribery and Corruption Policy, ensuring that they have no part in corruption or bribery, whether directly or indirectly.

(c) Employees of the Company must not overlook or ignore incidents related to the Company that they witness which may be corrupt. Any such incidents should be reported to the employee’s manager or to the person responsible for such matters, and the employee must cooperate in any investigations of the facts.

(d) The Company shall provide safe channels of communication to allow employees of the Company to request advice, report wrongdoing, make suggestions, or submit grievances related to corruption and bribery. The Company shall ensure fairness and protection measures are afforded to any person filing a complaint or providing cooperation in reporting corruption and bribery.

(e) Employees of the Company who engage in corruption or bribery, in violation of this Anti-Bribery and Corruption Policy, shall face disciplinary measures as set by the Company’s regulations as well as legal action in line with relevant laws.

(f) The Company shall conduct regular monitoring and evaluation of the anti-bribery and corruption measures to ensure proper implementation of the Anti-Bribery and Corruption Policy.

Policies to Support Anti-Bribery and Corruption

Charitable donations
The donation of money or assets for charity, philanthropy and sponsorship must be conducted in a legal and transparent manner. There must be evidence that activities were conducted in line with a stated charity program, and any charitable donations must be undertaken with the aim of supporting the successful achievement of the program’s objectives and of creating true benefits for the society. Employees of the Company must take caution to ensure that charitable donations are not used as a method to avoid bribery, and are not involved in the mutual exchange of benefits with any particular individual or agency.
Sponsorships must be undertaken with the objective of developing the Company’s public relations, good image, and reputation only. Sponsorships must be undertaken in a legal and transparent manner, with evidence that the requestor of the sponsorship has engaged in the activity program as stated. Employees of the Company must take caution to ensure that sponsorships are not used as a method to avoid bribery and must be able to provide evidence that sponsorships or the provision of other benefits which can be ascribed a monetary value, such as accommodation and food, are not involved in the mutual exchange of benefits with any particular individual or agency.
Facilitation fees
The Company does not have a policy to provide any sort of facilitation fee to public officials or private sector employees to expedite any processes or ensure any outcomes outside of the Company’s normal business practices.
Gifts, entertainment and other expenses
The Company has established a policy for giving or receiving benefits which include assets, services, facilitation, or entertainment for business relations. Such exchanges must be conducted within the bounds of normal business custom and in accordance with relevant laws, be of an appropriate value, and must not be used as incentive for wrongdoing.


The Company’s procurement process must be honest, transparent, auditable, and in compliance with the laws.

Training and Communication

Employees of the Company

(a) The Company shall provide training and knowledge about policies and measures related to anti-bribery and corruption and/or other ethical issues to its directors, executives and Employees. It shall also provide an orientation for new Employees to raise awareness of the various forms of corruption and bribery, the risks resulting from engaging in corruption and bribery, as well as methods of reporting suspected or witnessed incidences of corruption or bribery.

(b) All Employees of the Company can access this Anti-Bribery and Corruption Policy via the appropriate channels such as email, the Company’s website, printed media, or announcement posters, for example, to ensure that employees of the Company have read and understood this Anti-Bribery and Corruption Policy.

Business representatives, business alliances, suppliers
The Company shall communicate the Anti-Bribery and Corruption Policy to advisors, agents, middlemen, business representatives, business alliances, suppliers, and associates for acknowledgement, and shall encourage all parties to adhere to the same standards of corporate social responsibility as the Company.

Disciplinary Actions

Employees of the Company who do not comply with the Company’s Anti-Bribery and Corruption Policy and measures shall face disciplinary action in line with the Company’s regulations which may include termination of employment in cases where the Company deems it necessary, and/or may face legal action.

Last Updated: This Terms of Service was last updated on 24th April 2023.