Anti-Bribery and Corruption Policy Qualification

Questionnaire

APPENDIX J - Anti-Bribery and Corruption Policy

PURPOSE AND SCOPE

PT. Hexindo Gemilang Raya and its Partners willingly comply with antibribery

and corruption laws and regulations including the U.S. Foreign Corrupt Practices

Act (FCPA) and the UK Bribery Act. These standards are minimum standards

that apply to all employees, Directors and Board of Directors, PT. Hexindo

Gemilang Rayas CEO, all members of PT. Hexindo Gemilang Rayas

Management Team and Contractors / Suppliers / Consultants that work with or

on behalf of or are associated with PT. Hexindo Gemilang Raya.

ANTI-BRIBERY & CORRUPTION POLICY

This Policy was created to state PT. Hexindo Gemilang Rayas zero tolerance

approach to bribery and to provide direction to assist in the prevention of bribery

and corruption. No PT. Hexindo Gemilang Raya supplier, contractor or consultant

may pay, offer or promise to pay, or authorize payment of money, money

equivalent, gifts or anything else of value, in any amount, to any person or

company whether a public official or private person or company, in order to

secure improper performance of duties or functions with PT. Hexindo Gemilang

Raya or, in the case of a public office, with any intention to gain influence for a

business advantage in the performance of official functions. A public official is

defined as all elected or appointed officials, candidates for political office,

consultants with governmentowned or controlled companies, officials in political

parties or anyone acting on behalf of a public international organization.

No PT. Hexindo Gemilang Raya supplier, contractor or consultant may receive or

solicit to receive payment of money, money equivalent, gifts or anything else of

value, in any amount, from any person or company in connection with the
 Anti-Bribery and Corruption Policy Qualification
Questionnaire

performance of services on behalf of PT. Hexindo Gemilang Raya other than the

contractually established fee for services rendered and legitimate expenses to

be reimbursed in connection with the performance of such services.

SUPPLIERS, CONTRACTORS OR CONSULTANTS

PT. Hexindo Gemilang Raya can be held liable for the actions of our suppliers,

contractors, or consultants in the conduct of business dealings with public or

private organizations or officials. PT. Hexindo Gemilang Raya can be held

responsible for suppliers, contractors or consultants accepting or giving of

bribes, and PT. Hexindo Gemilang Rayas failure to take adequate steps to

prevent such intermediaries from participating in bribery. PT. Hexindo Gemilang

Raya will not do business with a supplier, contractor or consultant if they are not

committed to doing business without bribery. Any supplier, contractor or

consultant that does business on PT. Hexindo Gemilang Rayas behalf must

conduct business with PT. Hexindo Gemilang Rayas high level of integrity and

must carry out business fairly, honestly, and openly.

Any PT. Hexindo Gemilang Raya employee seeking to establish a business

relationship with a supplier, contractor or consultant must, prior to engaging the

party, perform a risk assessment using PT. Hexindo Gemilang Rayas Anti-

Corruption Due Diligence form to determine the level of risk.

ASKING QUESTIONS AND & REPORTING INCIDENTS OR

CONCERNS

Every PT. Hexindo Gemilang Raya Supplier, Contractor or Consultant is

encouraged to ask questions regarding this Policy. Every Supplier, Contractor or

Consultant must promptly report any bribe, solicitation or offer of an improper

payment or advantage. You may ask questions or make a report to a PT. Hexindo

Gemilang Raya Ethics & Compliance Manager at (+62 2130434000) or visit PT.
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Questionnaire

Hexindo Gemilang Rayas office at Graha Ortus Lantai 4 - 7, Jalan K.H. Wahid

Hasyim No.4-4A, Kebon Sirih, Menteng, Jakarta Pusat 10340 for additional

information. All interaction with PT. Hexindo Gemilang Raya will be treated in a

confidential manner within the limits of the law.

CONSEQUENCES OF POLICY VIOLATION

Any Contractor, Supplier or Consultant found to be in violation of this

Policy will be subject to disciplinary action, including termination of

contract, reporting to the appropriate government agencies as well as

any other legal rights and remedial actions available to PT. Hexindo

Gemilang Raya.

Signature:___________________________ Date:___________________

Name:

Title:

Company: