Compliance & Feedback

CPG Compliance Policy

I. GENERAL PRINCIPLES

1. CPG attaches great importance to the implementation of an effective compliance policy at CPG and in relations with its partners.

2. Every person acting for, in the name or on behalf of CPG must respect, at any time, relevant national or international legislation, applicable regulations of Thammasat University, Thammasat University’s code of conduct and the following Code of Conduct of CPG.

3. CPG’s core principles are:

Accountability: CPG and its members are aware of their functional responsibilities and the trust of their partners. CPG assumes responsibility for any damage caused by its activities or by any of its members.

Merit: CPG strives for excellence and pursues its goals with diligence and dedication. Decisions and agreements at CPG or between CPG and third parties shall be made with due regard to merit and performance.

Partnership & Independence: CPG is a joint institute of four participating universities. It operates without undue external interference from third parties. All CPG members are trained and supported by CPG to this effect.

Transparency: CPG pursues its goals and performs its functions transparently. Its budget and financial dispositions are subject to external audits. CPG activities are open and accessible for the public.

Commitment: CPG supports internal and external actors in their efforts to promote ethics and integrity within CPG’s scope of activity.

Respect: Mutual respect and non-discrimination are key elements for the success of CPG’s work. CPG is committed to open exchange of ideas and opinions.

4. CPG’s policy, procedures, advice and research must be oriented along these core principles at any time.

5. CPG upholds its compliance policy when contracting with third parties or when recruiting new members.

6. All CPG members have the duty to respect this compliance policy and to promote a culture of compliance. Any issue related to this compliance policy must be addressed with due regard to the guidelines set out in this compliance policy.

II. CODE OF CONDUCT:

GENERAL REMARKS

1. All CPG’s members must keep in mind that any breach of the following rules will affect the CPG’s reputation and reduce the trust from its partners and the quality of its work.

2. A CPG member who breaches any of the following rules exposes himself or herself to sanctions that can lead to the removal of its function.

3. Every issue raised in relations to the following rules is compiled and published in an annual report.

PREVENTION OF CORRUPTION

4. A CPG member may be suspected of corruption if he or she accepts or demands, directly or indirectly, any undue advantage due to his or her or the third party’s position.

5. It is not a defense to claim that an undue advantage accepted or offered results from a custom in his or her home country or in his or her profession.

6. It is the policy of CPG to prohibit all members from soliciting or granting any undue advantage to any person having relations with CPG. In case of gifts, the CPG member involved must refer it to the CPG director and require the consent of the director to accept it.

7. Undue advantage includes anything of non-neglectable value, such as money, items or entertainment, that could affect a member’s objectivity in properly conducting the organization’s work, or that could motivate him or her to act to the detriment of CPG, or that could create the impression that CPG is not independent and impartial. This does not include small items such as food or drink provided for immediate consumption at events or on similar occasions.

8. CPG members must refer to the CPG director whenever they have the impression that someone tries to corrupt them. They are assured of CPG’s full support to properly address such situation.

CONFLICT OF INTEREST

9. A conflict of interest is a situation where there is a risk that the interests of CPG will compete with the personal interests of a CPG member, including the interests of his or her family, friends, a group in which he or she belongs or a person to whom he or she owes a favor. These are not necessarily financial interests.

10. When a member acts on behalf of CPG, he or she shall always give highest priority to the interests of CPG. Any form of favoritism, abuse of power and corruption is not permitted.

11. CPG members must report any risk of conflict of interest to the director at the earliest occasion possible.

12. CPG members must refer to the CPG director whenever they suspect the existence of a conflict of interest. They are assured of CPG’s full support to properly address such situation.

13. If necessary, a task must be withdrawn from a CPG member to avoid or to stop a situation of conflict of interest.

PREVENTION OF FRAUD

14. A CPG member may be suspected of fraud if he or she intentionally practices deception to cause damage (financial or other) to a person, a group or an organization. This includes the falsification, concealment and destruction of documents, the use of a false document or the unauthorized use of goods for personal benefit or for the achievement of a task.

15. CPG prohibits all members from behaving dishonestly and from using any dishonest method.

16. CPG members must refer to the CPG director whenever they suspect fraudulent or dishonest behavior at CPG or in relations with third parties. They are assured of CPG’s full support to properly address such situation.

MONEY LAUNDERING

17. Money laundering refers to actions which aim to conceal the identity, source, or destination of illicitly-obtained money.

18. CPG commits itself to acquire and use funds in total clearance and transparency. It also makes sure that third-party sources of its funding follow the same standards.

19. If there are reasonable grounds of suspicion of money laundering at a third party, CPG reserves the right to demand credible assurances before contracting. CPG does not engage with a third party if reasonable grounds of suspicion remain. CPG will decline any partnership or donation that could impact its integrity.

20. CPG members must refer to the CPG director whenever they suspect money laundering on the part of a CPG member or a third party with relations to CPG. They are assured of CPG’s full support to properly address such situation.

21. Any goods or money donated to CPG cannot be reclaimed in a different form or in the same form by the donor.

ROLES

Director: The CPG director is the reference point for compliance matters. He or she welcomes questions and concerns of CPG members without prejudice. He or she is responsible for addressing a compliance matter, taking into consideration information or advice from the CPG team. He or she dutifully examines any initiative to promote and improve the compliance policy. The director is also the public voice of the institute and shall reveal compliance issues with transparency either publicly or to the appropriate person.

Staff: CPG staff members, including interns and legal clerks, incorporate a compliance culture in their work and support each other in any compliance-related matter without prejudice. They shall report compliance concerns or issues to the director and help to implement and improve the compliance policy.

CONTACT

In case you have witnessed or taken notice of any inappropriate or wrongful behavior on the part of CPG, we would appreciate if you took the time and sent an email to the email address below. Emails sent to this address can be accessed only by our compliance officer and will be handled confidentially.

compliance@cpg-online.de

CPG is constantly striving to improve all its activities. If you have any feedback such as suggestions, complaints, or maybe even compliments, we would be honored if you took the time and let us know. We appreciate your feedback very much.