Overview

Anti-Bribery & Anti-Corruption Policy

Anti-Bribery & Anti-Corruption Policy

PT Divistant Teknologi Indonesia (trading as "Divistant")


Last Updated: February 24, 2026


1. Introduction & Commitment


PT Divistant Teknologi Indonesia ("Divistant") has a zero-tolerance approach to bribery and corruption. We are committed to conducting business ethically, transparently, and in full compliance with all applicable anti-bribery and anti-corruption laws, including:

  1. Indonesian Anti-Corruption Law: Undang-Undang Nomor 31 Tahun 1999 jo. UU No. 20 Tahun 2001 tentang Pemberantasan Tindak Pidana Korupsi
  2. Indonesian Anti-Gratification: As regulated by the Komisi Pemberantasan Korupsi (KPK)
  3. International standards: Including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act (FCPA), where applicable to our international business activities


This policy applies to all Divistant employees, officers, directors, contractors, consultants, agents, and any third party acting on behalf of Divistant.


2. Definitions


  1. Bribery: Offering, promising, giving, accepting, or soliciting an undue advantage of any value (financial or non-financial) to influence the actions of an individual in a position of trust or authority.
  2. Corruption: The misuse of entrusted power or position for private gain, including but not limited to embezzlement, fraud, extortion, and abuse of office.
  3. Gratification (Gratifikasi): As defined under Indonesian law, any gift, reward, or benefit received by a public official or civil servant in connection with their position, unless reported to the KPK within 30 working days.
  4. Facilitation Payment: An unofficial payment made to secure or expedite routine actions by government officials. Divistant prohibits facilitation payments.


3. Prohibited Conduct


All Divistant personnel are strictly prohibited from:

  1. Offering, promising, or giving any bribe, kickback, or improper payment to any person, whether in the public or private sector
  2. Accepting or soliciting any bribe, kickback, or improper benefit
  3. Making facilitation payments of any kind
  4. Using company funds, assets, or resources for any corrupt purpose
  5. Creating or maintaining inaccurate financial records to conceal bribery or corruption
  6. Engaging third parties or intermediaries to perform any of the above acts on Divistant's behalf


4. Gifts, Hospitality & Entertainment


We recognize that modest gifts and hospitality can be a normal part of business relationships. However, they must never be used to improperly influence decisions. The following guidelines apply:


Permitted:

  1. Modest gifts of nominal value (not exceeding IDR 500,000 per occasion) that are customary in business relationships
  2. Reasonable business meals and hospitality with a clear business purpose
  3. Company-branded promotional items


Prohibited:

  1. Cash or cash equivalents (gift cards, vouchers) of any amount
  2. Gifts to or from government officials or their family members
  3. Lavish or extravagant entertainment, travel, or accommodation
  4. Any gift given with the intent to influence a business decision or outcome
  5. Gifts during active procurement, bidding, or tender processes


All gifts and hospitality above IDR 250,000 must be reported and recorded in the company's gift register.


5. Dealings with Government Officials


Special care must be taken in all interactions with government officials (pejabat publik/penyelenggara negara). Additional requirements include:

  1. Prior approval from management is required before offering any hospitality to government officials
  2. All interactions must be documented and transparent
  3. Political donations or contributions on behalf of Divistant are strictly prohibited
  4. Employees must not use personal relationships with government officials to gain unfair business advantages for Divistant


6. Third Parties & Business Partners


Divistant may be held liable for the corrupt actions of third parties acting on its behalf. Therefore:

  1. We conduct due diligence on all agents, consultants, contractors, and business partners before engagement
  2. Contracts with third parties include anti-bribery and anti-corruption clauses
  3. We monitor third-party activities and require compliance with this policy
  4. Any red flags identified during due diligence or ongoing monitoring are investigated promptly


7. Charitable Donations & Sponsorships


Divistant supports charitable causes and community initiatives. However, all donations and sponsorships must:

  1. Be made for legitimate charitable purposes and not to gain improper business advantages
  2. Be transparent, properly documented, and approved through the appropriate channels
  3. Not be directed to organizations with ties to government officials involved in decisions affecting Divistant


8. Record Keeping & Financial Controls


Divistant maintains accurate books and records that reflect all transactions:

  1. All payments and receipts are accurately recorded with supporting documentation
  2. Financial controls are in place to prevent and detect improper payments
  3. Regular audits are conducted to ensure compliance
  4. Off-the-books accounts or transactions are strictly prohibited


9. Reporting & Whistleblowing


If you know of, suspect, or are asked to participate in any form of bribery or corruption, you must report it immediately through:

  1. Your direct supervisor or manager
  2. Our secure Whistleblowing Channel
  3. divistant.com/contacts


All reports are treated confidentially. We guarantee that no one will face retaliation, demotion, harassment, or any adverse consequences for reporting concerns in good faith. See our Whistleblower Policy for full details on protections and processes.


10. Consequences of Violation


Violations of this policy are treated with the utmost seriousness and may result in:

  1. Immediate disciplinary action, up to and including termination of employment
  2. Termination of business relationships with third parties
  3. Reporting to relevant law enforcement authorities
  4. Civil and criminal liability under applicable laws


Under Indonesian law, corruption offenses can carry penalties of imprisonment up to 20 years and fines up to IDR 1 billion.


11. Training & Awareness


Divistant provides regular anti-bribery and anti-corruption training to all employees, with enhanced training for personnel in higher-risk roles. All employees are required to acknowledge their understanding of and commitment to this policy.


12. Contact Information


For questions about this policy or to report concerns:

  1. General Inquiries: divistant.com/contacts
  2. Whistleblowing Channel: divistant.com/whistleblowing
  3. Company: PT Divistant Teknologi Indonesia, Jakarta, Indonesia