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Anti-Gratification Policy 

Last Updated May 29, 2021

1. Introduction and Purpose:

a. PT Global Asia Sinergi (the Company) is committed to maintaining the highest standards of ethics, integrity, and transparency in all its business activities.
b. The purpose of this Anti-Gratification Policy is to prevent and prohibit any form of gratification, bribery, or corrupt practices within the Company.
c. This policy aims to ensure that all employees, contractors, suppliers, and business partners of the Company adhere to the principles of fair competition, honesty, and legality.

2. Definitions:

a. Gratification: Refers to the giving, receiving, or solicitation of gifts, money, favors, benefits, or any other form of advantage to influence or reward a decision, action, or business transaction.
b. Employee: Refers to all permanent and temporary staff, officers, directors, agents, consultants, contractors, and any individual engaged by the Company in any capacity.

3. Prohibition of Gratification:

a. The Company strictly prohibits its employees from directly or indirectly offering, soliciting, accepting, or receiving any form of gratification, whether for personal gain or to influence any business decision.
b. Employees shall not engage in any activity that may create a conflict of interest or compromise the Company's reputation, including accepting gifts, entertainment, or favors that may influence their impartiality or judgment.
c. It is strictly prohibited for employees to make, authorize, or facilitate payments or benefits to public officials, government entities, political parties, or their representatives, in violation of applicable anti-corruption laws and regulations.

4. Compliance with Laws and Regulations:

a. All employees must comply with all relevant anti-corruption, anti-bribery, and anti-gratification laws and regulations applicable in the jurisdictions where the Company operates.
b. The Company will provide appropriate training and resources to ensure employees understand their legal obligations and the consequences of non-compliance.


5. Reporting and Whistleblowing:

a. Employees are encouraged to report any suspected or actual incidents of gratification, bribery, or corrupt practices to the designated compliance officer or through a confidential reporting mechanism.
b. The Company guarantees protection from retaliation for whistleblowers and ensures that all reports will be promptly and thoroughly investigated.

6. Consequences of Non-Compliance:

a. Any employee found in violation of this policy may be subject to disciplinary action, up to and including termination of employment, as well as legal consequences in accordance with applicable laws.
b. The Company reserves the right to pursue legal remedies against individuals or entities involved in gratification, bribery, or corrupt practices, seeking restitution and damages as permitted by law.


7. Training and Awareness:

a. The Company will provide regular training programs to raise awareness about the risks and consequences of gratification, bribery, and corruption.
b. Training will focus on identifying and preventing situations that may lead to gratification, promoting ethical decision-making, and ensuring compliance with this policy.

8. Monitoring and Review:

a. The Company will periodically review and assess the effectiveness of this policy, making necessary updates to ensure alignment with evolving legal requirements and industry best practices.
b. The policy will be communicated to all employees, contractors, suppliers, and business partners, and made readily available through appropriate channels.

This Anti-Gratification Policy applies to all employees and stakeholders of PT Global Asia Sinergi and serves as a guide for ethical behavior. Compliance with this policy is mandatory, and failure to comply may result in serious consequences for both individuals and the Company.

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