VSTECS is committed to conducting business with integrity, honesty, and transparency. As part of this commitment, the Company prohibits bribery, corruption, and violations of trade laws and regulations in all aspects of its operations.

VSTECS Anti-Bribery and Anti-Corruption Compliance Policy outlines the principles, standards, and procedures that govern the Company's efforts to prevent bribery, corruption, and trade violations.

This guidance in no way modifies or negates any of the employee obligations under the Company Code of Business Conduct and Ethics or the respective agreements with contractors, agents, or partners.

Objective:

VSTECS adopts and implements this policy that supports its commitment to continuously improve its corporate governance practices. This is in conjunction with the Company’s Code of Business Conduct and Ethics, Policies on Gift Giving/Bribery and Corruption, and other related policies.

Rationale:

VSTECS highly upholds the value of honesty and integrity in conducting business. It adopts a zero-tolerance policy to bribery and corruption. All forms of bribery and corruption are not acceptable and will not be tolerated by the Company.

All employees must not act corruptly or conduct any business dealings that include any form of bribery or corruption or any act that may be construed as being or an attempt to such acts and must ensure that any third party acting on the company’s behalf complies with this policy.

Coverage:

This policy applies to all employees, officers, directors, contractors, agents, and representatives acting on behalf of PT ECS Indo Jaya, regardless of their location or role within the organization.

Definition of Terms:

Corruption – misuse of public or professional power for personal gain

Bribery – offering, giving, soliciting, or receiving of any item of value as a means of influencing the actions of an individual holding a public or legal duty, which act constitutes a crime to both offer or and the recipient (e.g., giving an expensive gift to a bank manager to secure a loan)

Facilitation Payment – small bribe made to expedite the performance of a routine or necessary action to the benefit of the party making the payment. (e.g., a business paying a customs official to release held goods)

Payoffs – the act or occasion of giving of or receiving money or material gain especially as a compensation or a bribe

Kickbacks – a form of negotiated bribery in which a commission is paid to the bribe- taker in exchange for services rendered.

Prohibited Conduct:

Zero Tolerance Approach to Bribery and Corruption

VSTECS and its employees or any third party it engages with or that acts on its behalf are mandated to strictly comply with the Anti-Bribery and Anti-Corruption Policy and Laws based on both local (Indonesia Anti-Corruption Laws & Practices) and international laws and practices.

• Neither the company nor its employees or any third party acting on its behalf shall participate in any act whether directly or indirectly offering, giving, requesting, or receiving any gift or payment which is or maybe construed as being, or an attempt to influence decisions related to the Company’s business or for personal gain.
• No employee or any third party acting on the company’s behalf shall make or receive any improper payments to or from any individual, government official, organization - corporate or otherwise.
• Neither the Company nor its employees, any third party acting on its behalf may participate in any of the following acts of corruption: extortion, fraud, insider dealing, money laundering, facilitation payments, payoffs, and kickbacks
• Hospitality or gifts may be offered and received only in the normal course of business and will not generate any actual or perceived conflict of interest or affect the decision making of either party. Any hospitality or gift should not be excessive or regular and should be in accordance with the Company’s Policy on Gifts and Incentives.
• The Company shall conduct sufficient due diligence when entering into arrangements or agreements with vendors, customers, resellers, partners, joint venture partners, contractors, or agents to ensure that they do not engage in or practice acts of bribery or corruption and to periodically monitor their performance and compliance with such policy on anti-bribery and anti-corruption.
• Any demand for or offer of a bribe must be immediately rejected and reported to the Compliance Officer as referred to in the Company’s Code of Business Conduct and Ethics.

Trade Compliances

The Company prohibits engaging in business transactions with individuals, entities, or countries located outside of Indonesia territory except under specific circumstances approved by the principal. Any concerns or discrepancies must be reported for further investigation.

Reporting and Investigation

• Employees are encouraged to report any suspected violations of this policy or applicable laws to the Compliance Officer as referred to in the Company’s Code of Business Conduct and Ethics
• The Company will promptly and thoroughly investigate all reported violations of this policy. Investigations will be conducted impartially, confidentially, and in compliance with applicable laws and regulations.

Non-Compliance Consequence

• Non-compliance to the above policies and guidelines shall be subject to an administrative sanction per Company policy on Code of Business Conduct and Ethics.
• Employees may also be subject to legal consequences, including fines, penalties, and legal proceedings, for violations of anti-corruption, anti-bribery, and trade compliance laws and regulations.

Conclusion

VSTECS is committed to maintaining the highest standards of ethical conduct and legal compliance in all aspects of its operations. All employees have a responsibility to uphold the principles outlined in this policy and to conduct themselves with integrity, honesty, and transparency at all times.