This policy is established as the company’s commitment to conducting business ethically, transparently, and responsibly. It aims to prevent, detect, and address all forms of corruption within company activities. This policy is also designed to protect the company’s reputation and ensure compliance with applicable laws and regulations.
Objectives of Implementing the Anti-Corruption Policy
The anti-corruption policy is a crucial strategy implemented by the company with the primary goal of creating an environment free from corruption, bribery, and gratuities. Therefore, the implementation of the Anti-Corruption Policy is highly relevant and important for the company. The objectives of this policy are:
- Preventing Material (Financial) and Non-Material (Reputation) Lossesthat could threaten the company’s business sustainability.
- Enhancing Corporate Compliancewith laws, regulations, and ethics. With higher compliance, the company can maintain its integrity and stakeholder trust.
- Raising Ethical Awareness, which is a critical aspect within the organization to ensure ethical work interactions with external parties.
Thus, the implementation of the Anti-Corruption Policy is not only aimed at protecting the company from potential losses and legal violations but also at fostering a high-integrity work culture and supporting the creation of a corruption-free business environment.
Definitions
- Corruption:Any form of abuse of power for personal or group gain, including but not limited to bribery, gratuities, nepotism, collusion, embezzlement, or other misuse of authority that violates laws and business ethics.
- Bribery:Giving, receiving, or requesting anything of value to influence business decisions or an individual’s actions in an official capacity.
- Gratuity:Any form of gift, money, facility, or service received by someone in connection with their position or job.
Scope
This policy applies to:
- All company employees, including senior management.
- Business partners, vendors, suppliers, contractors, and other third parties.
- All business activities, including procurement of goods and services, IT service provision, client relations, marketing, project management, and interactions with government and regulatory authorities.
Legal Basis
This policy is based on applicable laws and international anti-corruption standards, including but not limited to:
- Law No. 31 of 1999 on the Eradication of Corruption Crimes, as amended by Law No. 20 of 2001.
- Law No. 11 of 1980 on Bribery Crimes.
- Regulations from the Corruption Eradication Commission (KPK)regarding gratuity prevention.
- International standards such as ISO 37001:2016 Anti-Bribery Management System.
Key Principles
- Zero Tolerance:The company enforces a zero-tolerance policy against any form of corruption.
- Integrity:All parties must act honestly, professionally, and uphold the company’s reputation.
- Transparency:All transactions and activities must be clearly documented and available for audit.
- Legal Compliance:All company activities must comply with applicable laws and regulations.
- Accountability:Every individual is responsible for their actions and must ensure compliance with this policy.
Policy Guidelines
1. Prohibition of Corrupt Practices
All employees, business partners, and third parties are prohibited from:
- Giving or receiving bribes in any form.
- Manipulating data for personal or group benefit.
- Offering gratuities or gifts that could influence business decisions.
2. Conflict of Interest Management
Employees must:
- Identify and report potential conflicts of interest to their direct supervisor or the Compliance Department.
- Avoid situations where personal or financial relationships may influence business decisions.
- Not use their position in the company for personal or family gain.
3. Giving and Receiving Gifts
All forms of gifts or entertainment provided or received must:
- Have a reasonable value and not influence business decisions.
- Not be in the form of cash or cash equivalents.
- Be reported to the Business Process Quality Assurance Departmentfor further evaluation.
4. Unauthorized Sale of Goods
- Employees are prohibited from selling used/spare parts without authorization and company approval, as this may impact business operations and company reputation.
- Employees are prohibited from selling bonus items received from distributor/principal/vendor purchases, as this may also impact business and company reputation.
4. Violation Reporting (Whistleblowing)
The company provides a secure and confidential reporting channel for suspected corruption cases through a dedicated email: feedback@pemmz.com.
The company guarantees:
- Protection for whistleblowersagainst any form of retaliation.
- Prompt follow-upon reported cases.
Consequences
Identifying and addressing corruption is a critical step in maintaining integrity, fairness, and trust in the company’s work environment. The consequences for individuals or groups involved in corrupt practices reflect the company’s seriousness in addressing violations and serve as a deterrent for future violations. The company will impose penalties on individuals or groups violating the Anti-Corruption Policy through the following measures:
- Termination:Corrupt practices are a serious offense and may result in immediate dismissal of employees involved. Termination ensures that individuals who violate the anti-corruption policy are removed to protect the company’s integrity.
- Significant Financial Penalties:Those involved in corruption may face financial penalties to recover potential losses and serve as an adequate deterrent.
- Legal Action:Corrupt acts often involve serious legal violations. Therefore, authorities may decide to prosecute individuals or groups involved, subjecting them to legal proceedings in accordance with the laws of the Republic of Indonesia.
- Internal Sanctions:In addition to external penalties such as termination and prosecution, the company may impose internal sanctions, including temporary suspension, salary reduction, or revocation of certain rights for those involved in corruption.
- Rehabilitation:In certain cases, the company may provide opportunities for individuals involved to participate in rehabilitation or ethics training programs. This aims to help them understand the negative impact of corruption and encourage positive behavioral changes.
- Public Announcement:The company may choose to publicly announce actions taken against individuals or groups involved in corruption to send a strong message that corruption will not be tolerated.
- Cooperation with Authorities:The company may collaborate with anti-corruption institutions or law enforcement agencies in investigating corrupt activities, demonstrating its commitment to supporting law enforcement and justice.
These consequences are expected to serve as a strong and effective deterrent against corruption within the company, supporting a high ethical culture and setting a strong example of the importance of integrity in all aspects of the company’s operations.