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SFL Anti-Corruption Policy DDQ52
SFL Anti-Corruption Policy DDQ52
Thank you for considering to engage in business with Seal for Life Industries (“SFL”). To move forward
with a business relationship with your company, it is the policy of SFL to conduct a due diligence review,
which includes the completion of the Information Questionnaire. Additional information may be required.
1) Basic Information
Mr.Cherdsak Tangsomboon/ RL THI CORPORATION LIMITED.
YOUR NAME AND YOUR COMPANY’S NAME
4) Registration Information. Please provide your commercial registration number(s) or business license number(s), if any, below:
COMMERCIAL REGISTRATION NO.0105529018237 ___________________________________
_______________________________________
_______________________________________ ___________________________________
_______________________________________ ___________________________________
What is the name of the organization or Government agency issuing the commercial registration(s) or license(s) listed above:
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5) Please identify the names, titles, and business addresses (if different from your company headquarters) of individuals who are
the executive management (officers and/or directors) of your business.
6) Please identify the names, titles, and business addresses (if different from your company headquarters) of key employees who
will be involved in conducting business with SFL.
7) For non-publicly traded companies, please provide the names and addresses of the entities and/or individuals who are the
beneficial owners of your company (e.g. shareholders, partners, members, etc.).
8) Please provide the names and addresses of companies that are currently affiliated with your company (e.g. parent, subsidiary,
and affiliated companies).
DYR ENGINEERING AND CONSTRUCTION CO.,LTD. AFFILIATED COMPANIES THAILAND.
COMPANY RELATIONSHIP ADDRESS
For any company identified in response to Question 8 above, please describe the role, if any, that the identified company will have
with respect to SFL.
________________________________________________________________________________________
________________________________________________________________________________________
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9) Region. Please identify the country or countries in which you operate or are authorized to do business:
________________________________________________________________________________________
________________________________________________________________________________________
10) Business Partners. For any country in which your company intends to engage a business partner that will have any role with respect to
SFL, please identify the business partner, the country in which the business partner will operate, and the business partner’s role with
respect to SFL.
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
For purposes of the remainder of this questionnaire, please consider the term “Principal” to mean any of the
individuals listed above in response to Questions 5 and 6.
11) For the past five years, have any of the Principals in your business been employed by, or had any official duties for, any
government agency?
Yes ___ No ___
If the answer is Yes, please indicate the person’s title and government agency:
NAME TITLE
DESCRIBE DUTIES
12) Please state whether any Principal has family, business, or other ties with a foreign official or agency.
Yes _____ No _____
If the answer is Yes, please identify the Principal, the nature of those ties and the name or title of the foreign official or agency.
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
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13) Do you have any employees who meet with foreign officials/government employees on your behalf (the term “employee” means
any person whom you pay for assisting you in performing your business)?
Yes _____ No _____
If the answer is Yes, please list each such employee(s) and the nature of their ties with the foreign official or employee.
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
14) Do any of the Principals in your business currently hold any office or position in any political party or are they candidates for
any political office?
Yes _____ No _____
If the answer is Yes, please identify the Principal, the political party and position held or sought.
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
15) Does your company provide any products or services to governments or state owned enterprises?
Yes ____ No _____
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
16) Please identify any foreign officials, agencies or political officials that your company may have dealings with in relation to the
contemplated business relationship with SFL.
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
17) Do your company and its parent, subsidiary, and affiliate companies have business ethics and anti-bribery policies that
address compliance with international and/or U.S. anti-bribery laws?
Yes _____ No _____
18) In the past five years, has any officer, director, employee, partner, member or shareholder of your company either self-
reported or responded to an inquiry by any anti-corruption enforcement agency regarding your company’s business practices,
including questions regarding payments to a foreign official?
Yes _____ No _____
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If the answer is Yes, please provide details:
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
MR.CHERDSAK TANGSOMBOON
PRINT NAME SIGNATURE
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ANTI-CORRUPTION COMPLIANCE
THIRD PARTY CERTIFICATION
Mr.Cherdsak Tangsomboon
I _____________________________________________ [name], a duly authorized representative
RL THAI CORPORATION LIMITED.
of _____________________________________________(“Certifier”), do hereby certify and confirm to
Seal for Life Industries and its affiliates (“SFL”) for and on behalf of Certifier, that:
Distributor
(2) Certifier will perform the following services for SFL, ____________________, in the
following countries and territories (“Territory”):
South East Asia Territory
a. _____________________________________________________________________
Thailand
b. _____________________________________________________________________
(3) Certifier will comply with all laws, regulations, rules, decrees, and other directives applicable
to it and to SFL, including the bribery and corruption prevention laws of the United States and the Territory,
including but not limited to the U.S. Foreign Corrupt Practices Act.
(4) Neither I, the undersigned, nor any officer, director, stockholder, employee, representative or
agent of Certifier has provided, offered to provide, or agreed to provide, or will during the course of
Certifier’s relationship with SFL, provide, offer to provide, or agree to provide any loan, gift, donation,
payment, or other items of value directly or indirectly, whether in cash or in kind, to or for the benefit of
any foreign official and/or foreign political party, to obtain or retain business or to secure any improper
advantage for SFL.
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(5) Neither Certifier nor any officer, director, owner or controlling shareholder, employee,
representative, or agent of Certifier is a foreign official1, or an agency or arm of, or entity owned or
controlled by, a non-U.S. government. Further, neither Certifier nor any officer, director, owner or
controlling shareholder, employee, representative, or agent of Certifier has any contractual relationship
with a foreign official, or an agency or arm of, or entity owned or controlled by, a non-U.S. government,
including a contract of employment, a contract to provide consultancy, technical, or advisory services, or
any other association or agreement for which payment or other items of value are exchanged.
(6) Should Certifier learn of any instances of the prohibited activities described in Paragraph 4, or
if there are any changes in the ownership, control, or relationships of Certifier as described in Paragraph
5, it will immediately advise SFL by telephone, electronic mail, or in writing.
(7) Certifier, its employee, directors, and any of Certifiers’ agents involved by or at the direction of
Certifier in performing services on behalf of SFL have received a copy of, have read and understood, and
shall comply with SFL’s Anti-Corruption Policy as amended from time to time.
(8) Certifier acknowledges that it is responsible for ensuring that all employees, directors, and
agents retained by Certifier to complete work on behalf of SFL comply with the legal and regulatory
obligations of the countries in which Certifier does business and with applicable laws including but not
limited to the U.S. Foreign Corrupt Practices Act.
(9) Certifier agrees that it will sell all products purchased from SFL in compliance with all
applicable U.S. export control requirements, including, without limitation, the requirements of the Export
Administration Regulations (EAR) and the statutes, regulations, and Executive Orders administered by the
U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). Certifier expressly assumes
responsibility for determining all applicable U.S. export control requirements, including for determining
whether, in any case, any license is required to be obtained in connection with the exportation of any SFL
products from the United States. Certifier also agrees that it will comply with all import and other laws,
rules, and regulations, as applicable, of the country(ies) in which it will sell SFL products.
1
A “foreign official” for purposes of the FCPA includes the following: (i) an officer or employee of a foreign government or a
governmental department, agency or instrumentality; (ii) a foreign political party, a party official or candidate for political
office; (iii) an officer or employee of a foreign government or state-owned or -controlled entity or company; (iv) a member of a
foreign military; (v) an officer or employee of a public international organization (such as the United Nations or the World
Bank); or (vi) any person acting in an official capacity for or on behalf of any of the foregoing. Employees and representatives
of government-owned oil and gas companies or government-affiliated port authorities should be considered and treated as
foreign officials.
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(10) Certifier agrees to provide SFL with (a) prompt access to its books and records as necessary in
SFL’s judgment to confirm Certifier’s compliance with these obligations, and (b) such additional
certifications of its compliance with laws and regulations as SFL may from time to time reasonably request.
(11) Certifier agrees that, should SFL reasonably determine at any time during the relationship
between Certifier and SFL, that any of the responses, information, or statements provided to SFL or in
response to SFL’s request for access to Certifier’s books and records is or has been incorrect incomplete,
inaccurate, untruthful, or misleading, SFL has the right to terminate its relationship with Certifier without
notice and without liability or obligation of any sort accruing to SFL.
(12) Certifier understands and agrees that, should SFL at any time reasonably determine that
Certifier has or had a record of non-compliance with the legal and regulatory obligations set forth herein
or with the obligations of applicable laws, SFL may terminate any relationship with Certifier without
notice and without liability or obligation of any sort accruing to SFL.
MR.CHERDSAK TANGSOMBOON
_______________________________________________________________________________
PRINT NAME SIGNATURE
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