Anti-Corruption Policy

Anti-Corruption Policy

The implementation of anti-corruption policies within the Company is a crucial response to the challenges faced by the Company in an increasingly complex and interconnected business environment. Corruption not only causes financial losses but also threatens the reputation, integrity, and sustainability of the Company. In the context of the evolving global business landscape, the implementation of anti-corruption policies is a proactive step to ensure that the Company operates with high ethical standards, complies with applicable laws and regulations, and supports government efforts in combating corruption. Furthermore, by adopting anti-corruption policies, the Company also builds trust and credibility among stakeholders, which can contribute to long-term growth and organizational success.

The purpose of implementing an Anti-Corruption Policy

Anti-corruption policy is a crucial strategy implemented by the Company, with the primary goal of creating a corruption-free environment. Therefore, the implementation of anti-corruption policies becomes a highly relevant and important step for the Company. The objectives of implementing an Anti-Corruption Policy are as follows:

• Preventing Material and Immaterial Losses: The anti-corruption policy's primary aim is to prevent both material (e.g., financial) and immaterial (such as reputation) losses that could threaten the Company's sustainability.
• Enhancing Compliance and Discipline: This policy is designed to enhance the Company's level of compliance with laws, regulations, and ethics. With higher compliance, the Company can maintain integrity and stakeholder trust.
• Supporting Government Initiatives: The anti-corruption policy also plays a role in supporting government programs aimed at preventing corruption in Indonesia. By participating in these efforts, the Company contributes to the maintenance of national integrity and economic stability.
• Enhancing Ethical Awareness: Another objective is to increase awareness of a high ethical culture within the organization. This is crucial for conducting work activities that involve interactions with external parties.

Therefore, the implementation of the Anti-Corruption Policy aims not only to protect the Company from potential losses and legal violations but also to cultivate a work culture characterized by high integrity and to support the government's agenda in creating a business environment free from corruption.

Types of Actions Classified as Corruption

Types of actions that can be categorized as corruption encompass various behaviors that contradict the Company's laws, regulations, and policies, involving Company employees, whether individuals or groups, who intentionally or unintentionally exploit their positions and authorities for personal or group interests, with the potential to harm the Company's financial integrity in the following ways:

• Abuse of Authority: This action occurs when someone uses the authority, opportunities, or resources available to them due to their position or status for personal or specific group gain. This includes making decisions that are not based on integrity or the Company's interests.
• Offering, Receiving, or Promising Bribes Corruption often involves giving, receiving, or promising bribes to officials or business partners, whether within or outside the Company. The aim is to influence their actions or decisions that contradict their duties or integrity of their positions.
• Misappropriation of Funds or Securities: This action includes embezzling money or securities held in trust due to someone's position in the Company. It can involve direct actions or allowing others to access or misappropriate those funds, ultimately harming the Company's finances.
• Giving or Receiving Gifts: Giving or receiving gifts or promises to or from individuals or entities, both within and outside the Company, considering the power or authority inherent in their positions, can be a corrupt act that undermines decision integrity and independence.
• Clear Violations of the Law: Corrupt actions can include clear violations of laws that explicitly state that the violation is an act of corruption. This includes actions involving bribery, abuse of power, or manipulation in business transactions that breach the law.
• Attempted Facilitation or Conspiracy: When individuals or groups attempt to plan or commit corrupt acts through attempted facilitation or conspiracy, this is also considered a serious form of corrupt behavior.
• Providing Assistance for Corrupt Acts: This includes providing assistance, opportunities, resources, or evidence that facilitates or supports corrupt acts by others. Such assistance can create an environment that supports corruption within or around the Company.

By identifying these types of corrupt actions, the Company can better develop effective anti-corruption strategies and policies to prevent, detect, and address any potential ethical violations that may occur.

Consequences for Engagement in Corruption

Identifying and addressing acts of corruption is a critical step in maintaining integrity, fairness, and trust in the Company's work environment. The consequences imposed on individuals or groups involved in acts of corruption reflect the Company's seriousness in addressing such violations and also aim to prevent similar violations in the future. The Company will impose penalties or consequences for violations of Company policies, especially anti-corruption policies, on individuals or groups in the following ways:

• Termination: Acts of corruption often serve as strong grounds for the dismissal of involved employees. Termination is a serious measure applied to remove individuals who have violated anti-corruption policies and jeopardized the Company's integrity.
• Significant Financial Penalties: In addition to termination, individuals or groups involved in corruption may face significant financial penalties. These fines are not only intended to compensate for any potential losses caused by corrupt actions but also serve as a substantial punishment and a deterrent for others.
• Legal Prosecution: Acts of corruption often involve serious legal violations. Therefore, authorities may decide to take legal action against individuals or groups involved. This may entail prosecuting them and bringing them to court in accordance with the laws applicable in the Republic of Indonesia.
• Internal Sanctions: In addition to external sanctions such as termination and legal prosecution, the Company can also impose internal sanctions. These may include temporary suspensions, salary deductions, or the reduction of specific rights for individuals involved in acts of corruption.
• Rehabilitation and Education: In some cases, the Company may provide individuals involved with the opportunity to participate in rehabilitation or ethics education programs. The aim of this measure is to assist them in understanding the adverse effects of corrupt actions and to encourage positive behavioral changes.
• Public Announcement: The Company may also decide to make a public announcement regarding the actions taken against individuals or groups involved in corrupt activities. This can be done to send a clear message to all employees and the public that corruption will not be tolerated.
• Collaboration with Authorities: The Company may choose to collaborate with authorities such as anti-corruption agencies or the police in investigating corrupt activities. This demonstrates the Company's commitment to supporting law enforcement and justice.

These consequences are expected to serve as strong and effective deterrents against corrupt actions within the Company and also support a culture of high ethics while setting a strong example regarding the importance of integrity in all aspects of the Company's operations.

The Participation of Employees and External Parties

The participation of employees and external parties is of utmost importance in the efforts to prevent and eradicate corruption within the Company. They can act as vigilant eyes and ears regarding potential allegations of corrupt activities within the Company's environment. Employees possess in-depth internal knowledge and have a vested interest in safeguarding the Company's reputation, while external parties can provide a different perspective on their interactions with the Company.

Through active engagement in reporting, both employees and external parties support the Company's efforts to swiftly detect and address alleged corruption, ensuring that the Company operates in accordance with high ethical standards. This helps create a culture that is transparent and free from corruption, bolstering the Company's integrity and operational sustainability. Employees and external parties can play a role in assisting the prevention and eradication of corruption by reporting information to the Company through the Whistleblower Reporting System via email at corpsec@arthavest.com.