• Deal honestly and accurately with clients, candidates, suppliers and stakeholders.
• Do not falsify CVs, invoices, timesheets, payroll records or other business documents.
• Do not make misleading statements regarding qualifications, services, certifications or client relationships.
• Protect company and client assets and use them only for authorized purposes.
• Escalate suspected fraud, misconduct or material compliance concerns.

Magma Tech Solution Co., Ltd. prohibits bribery and corruption. Personnel must not offer, promise, give, request or accept an improper payment or benefit intended to influence a decision or obtain an improper advantage.

• Cash or cash-equivalent benefits intended to influence a decision are prohibited.
• Gifts and hospitality must be reasonable, legitimate, transparent and consistent with law and client rules.
• Employees must disclose or seek approval for gifts or benefits where required.
• Facilitation payments are prohibited unless legally required and properly documented.
• Charitable or political contributions must not be used to obtain an improper business advantage.

• Actual, potential or perceived conflicts should be disclosed to management or HR/compliance.
• Personal relationships must not improperly influence recruitment, procurement, hiring, compensation or client decisions.
• Confidential company or client information must not be used for personal benefit.
• Magma Tech Solution Co., Ltd. will compete fairly and will not participate in collusive or anti-competitive arrangements.
• Commercial quotations and proposals should be prepared independently and accurately.

• Access information only when required for assigned responsibilities.
• Do not disclose client or company confidential information to unauthorized persons.
• Use approved systems and storage locations for business information.
• Protect passwords, credentials, devices and access tokens.
• Report suspected loss, unauthorized access or disclosure promptly.
• Respect client and third-party intellectual property, software licenses, source code and proprietary materials.
• Return or securely dispose of confidential information when no longer required, subject to retention requirements.Artificial Intelligence (AI) and Technology Use: AI tools and digital technologies may be used for legitimate and authorized business purposes only. Personnel must not enter, upload, disclose or otherwise expose confidential client information, personal data, candidate CVs, employee records, payroll details, passwords, access credentials or other restricted information to public or unauthorized AI tools or platforms.

Any AI-generated content intended for business or client use must be reviewed by an appropriate person for accuracy, reliability, appropriateness, potential bias, confidentiality and intellectual property considerations. Personnel remain responsible for the content they create, review, approve or share, including content generated with AI assistance.

AI and digital tools must not be used to create, manipulate or distribute misleading, discriminatory, fraudulent, harmful or unauthorized content, or in any manner that violates applicable laws, contractual obligations, client policies or Company requirements.

Magma Tech Solution Co., Ltd. will handle personal data in accordance with applicable privacy laws and contractual requirements. Where Thailand’s Personal Data Protection Act (PDPA) applies, relevant processing activities should follow applicable requirements.

• Collect only information reasonably required for legitimate business purposes.
• Use personal data only for authorized purposes.
• Restrict access to personnel with a legitimate business need.
• Apply appropriate technical and organizational safeguards.
• Control data sharing with clients, vendors and subcontractors through appropriate agreements.
• Manage suspected personal-data incidents through the applicable incident-management process.

• Do not discriminate in recruitment or employment on characteristics protected by applicable law.
• Do not use forced labour, trafficking, slavery or coercive employment practices.
• Do not use child labour contrary to applicable law.
• Do not tolerate harassment, bullying, intimidation or retaliation for good-faith reporting.
• Provide equal opportunity and fair treatment.
• Respect lawful employee rights to associate and communicate workplace concerns.

• Employees and consultants should receive written terms appropriate to their engagement.
• Working hours, rest periods, leave and compensation should comply with applicable law and contractual requirements.
• Payroll information must be processed accurately and subject to review and approval.
• Employment and payroll records must be maintained securely.
• Employees should not be subject to unlawful deductions or disciplinary practices.
• Maintain appropriate onboarding and offboarding processes.

• Provide a workplace that is reasonably safe and appropriate to the work performed.
• Identify and address relevant workplace hazards.
• Provide appropriate instructions or training where risks require it.
• Encourage timely reporting of workplace incidents and safety concerns.
• Take reasonable corrective action following reported incidents.

Recruitment

• Represent candidate qualifications and experience accurately.
• Protect candidate personal data.
• Obtain appropriate consent or authorization where required.
• Avoid discriminatory selection practices prohibited by law.

The Company prohibits forced labour, human trafficking, child labour contrary to applicable law, deceptive recruitment practices and unlawful worker-paid recruitment or placement fees. Original passports or identity documents must not be retained as a means of restricting a person’s freedom of movement. Identity documents may be handled temporarily only where necessary for an authorized administrative process, with appropriate safeguards and prompt return.

Secondment / Staff Augmentation

• Maintain appropriate contracts and assignment records.
• Clarify client and Magma Tech Solution Co., Ltd. responsibilities.
• Track assignment, timesheet and billing information.
• Protect client information and access.

Payroll

• Use documented payroll inputs and review/approval controls.
• Protect salary and personal information.
• Process statutory deductions and contributions in accordance with applicable requirements.
• Maintain payroll records for the applicable retention period.

Visa & Work Permit

• Provide accurate administrative information and documentation.
• Do not guarantee government approvals.
• Track relevant expiry dates and submissions.
• Protect passports, identity documents and personal information and handle them only as necessary for authorized administration.

• Maintain company registration, BOI-related documentation, and other applicable statutory records, and ensure compliance with relevant legal and regulatory requirements.
• Maintain corporate and tax records as required.
• Maintain employment and payroll records as required.
• Maintain documentation relating to immigration/work-permit services where applicable.
• Maintain contracts and material commercial records.
• Do not knowingly conduct business in violation of applicable law.

• Promote digital documentation and responsible use of resources.
• Reduce unnecessary paper and energy consumption where practical.
• Dispose of electronic equipment and waste through appropriate channels where applicable.
• Comply with environmental requirements applicable to operations.

Any public net-zero, emissions or formal sustainability commitment should be approved by management and supported by a measurable plan before publication.

• Select third parties based on legitimate business and capability criteria.
• Document key commercial and compliance responsibilities.
• Require confidentiality and data-protection obligations where applicable.
• Monitor material third-party performance and compliance.
• Address identified deficiencies and terminate relationships where material issues cannot be appropriately remediated.

Magma Tech Solution Co., Ltd. encourages employees, consultants and relevant stakeholders to raise good-faith concerns about suspected misconduct, legal violations, harassment, fraud, data incidents or other serious issues.

• Immediate Manager :- [Trina / Email: trina@magmatechsolution.com ]
• HR: [Email :- hr@magmatechsolution.com / siriporn@magmatechsolution.com ]
• Management / Compliance Contact: [Email – trina@magmatechsolution.com ]
• Confidential reporting channel: Not separately specified; concerns may be raised through the Management / Compliance Contact above.

Magma Tech Solution Co., Ltd. should not tolerate retaliation against a person who raises a concern in good faith. Reports should be handled confidentially to the extent reasonably possible and in accordance with applicable law.

Substantiated violations of this Code, company policies, applicable law or contractual obligations may result in proportionate corrective or disciplinary action, including counselling, warnings, additional training, restriction of access, removal from an assignment or termination of employment or engagement, subject to applicable law and the relevant agreement. Where a client assignment is affected, Management may coordinate appropriate action with the client.

• Management should periodically review this Code and supporting policies.
• Material compliance deficiencies should be documented and assigned for corrective action.
• For incidents, assess root cause, corrective action and prevention of recurrence.
• Retain and dispose of records according to applicable legal, contractual and company requirements.
• Support client audits or assessments with accurate evidence where contractual arrangements permit.

• I acknowledge that I have received/read the Magma Tech Solution Co., Ltd. Corporate Governance & Code of Conduct and understand that I am expected to comply with it and applicable laws and company policies.