Corporate Governance

OBJECTIVE

This code of conduct sets out regulations of the Company that shall be followed by all its employees with a purpose to .

  • Institutionalize corporate values based on global best practices.

  • Continually enhance accountability and transparency

  • Act according to the prevailing laws and regulations.

CORPORATE POLICY

This code of conduct is applicable to all of the company’s employees without exception. Any violation to this code of conduct may result in disciplinary actions towards the employee including from the company. Details of disciplinary actions are provided in policy on Disciplinary Actions and Procedure.

Each of Company’s employees shall on an annual basis (or more often as deemed necessary by the Company’s Board of Directors) fill in and sign the Disclosure statement as attached to this Code of Conduct or as may be amended from time to time.

Approved by:

PT Asia Sinergi Solusindo

Okto Fready Nainggolan
President & CEO

a. Employees must not give or receive any gifts or other favors for personal benefit, whether in the form of cash, non-cash, services, or any other personal benefit. This prohibition applies to interactions with customers, suppliers, contractors, brokers, or any other parties with a business relationship with the Company. Gifts and favors include promises for future gifts and favors, as well as those given indirectly through family, relatives, or third parties.

b. Specifically, employees must not give or receive any gifts or favors to or from public officials anywhere in the world.

c. All gifts and favors received directly or indirectly by any employee must be reported and turned over to the Company’s Human Resources Division. These will be used for the benefit of all employees, with Human Resources determining their disposition.

Exemptions to this rule apply for the following:

  • i. Gifts such as calendars, planners, and work-related meals with a monetary value of Rp. 300,000 or less.
  • ii. Samples given to the Company or individual employees with no sale value or a value of Rp. 100,000 or less.

d. All employees must promptly disclose in writing the receipt or offer of any gifts and favors, including exempted items, to the Company’s Human Resources Division.

e. Any exceptions to the above policy require approval from the Company’s Board of Directors.

Each employee must avoid situations where their personal interests conflict or could potentially conflict with their work responsibilities. This includes, but is not limited to:

a. Nepotism: Applicants who have close family relationships with existing employees (parents, grandparents, spouse, children, siblings, in-laws) should be handled carefully to avoid favoritism.

b. Contracts with Personal Connections: Employees cannot award contracts or work to companies owned, managed, controlled by, or otherwise connected to themselves or their family members.

c. Financial Interests in Business Partners: Employees cannot have a financial interest (except for publicly traded shares) in the Company’s customers, suppliers, contractors, brokers, or other business partners.

d. Competing Businesses: Employees cannot operate, control, or own another business that might compete with the Company.

e. Misuse of Company Assets: Employees cannot use Company assets for personal, family, or friend’s benefit beyond authorized benefits.

f. Self-Dealing: Employees must prioritize the Company’s interests over their own personal gain.

g. Moonlighting: Employees must disclose if they hold a position in another company (not affiliated with the Company).

h. Disclosure and Approval: If an employee faces any of these situations, they must report it to Human Resources.

  • For all situations, the Company’s Board of Directors must provide approval.

  • Employees at or above the Board of Directors level require approval from the Company’s Board of Commissioners.

a. Protecting Company Information: All employees must safeguard confidential information related to their job and responsibilities.

b. No Unauthorized Disclosure or Removal: Employees cannot share, disclose, or remove any company documents or correspondence (physical or electronic, including emails) without permission.

c. Protecting Company Operations: Employees must keep information about company activities confidential. This includes things like equipment, systems, and procedures.

d. Protecting Customer Information: Employees must protect confidential information provided by customers according to the customer’s standards.

e. Ongoing Obligation: The duty to protect confidential information continues even after an employee leaves the company.

f. Annual Disclosure: Employees must annually (or more frequently if required) complete and sign a Disclosure Statement regarding their adherence to this confidentiality policy. This statement may be updated from time to time.

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