A. BACKGROUND

Corruption is dishonest behavior carried out by an individual in the form of embezzlement or misuse of state, corporate, organizational, or other institutional funds for personal gain or for the benefit of others. Corruption can be committed by anyone who engages in dishonest actions, deviations, or fraud that result in harm to the company or corporation where the corrupt act is carried out.

In line with its commitment to implementing the principles of Good Corporate Governance, PT Pakuwon Jati Tbk (hereinafter referred to as the “Company”) has established a policy to prevent and eradicate corruption within the company in particular and in society in general.

 

B. PURPOSE AND OBJECTIVES
The purpose and objectives of establishing the Anti-Corruption Policy are to:

  1. Prevent acts of corruption by company employees that could cause both material and immaterial losses to the company.
  2. Raise awareness among all company employees to behave honestly, with discipline, integrity, and responsibility, and to refrain from legal violations that are inconsistent with the Company’s ethics, core values, or applicable laws and regulations.

 

C. TYPES OF CORRUPTION
The types of corruption include:

  1. Acts That Harm the Company's Finances
    Employees are prohibited from committing acts that may financially harm the company, such as:
    • Using company funds for personal gain or to enrich oneself.
    • Manipulating financial figures to create discrepancies in the amount of money the company should receive or disburse, with the discrepancy benefiting the individual or their group.
       
  2. Bribery
    Employees are strictly prohibited, either directly or indirectly, from giving, receiving, and/or promising any form of reward to any individual whether internal or external (vendor/contractor/business partner/supplier) with the intent to influence the recipient’s decision.
     
  3. Embezzlement
    The act of misappropriating money or valuable securities entrusted due to one's position or authority, allowing such items to be taken or embezzled by others, or assisting and facilitating such acts.
     
  4. Extortion
    Employees are prohibited from extorting others—whether internal or external (vendor/contractor/business partner/supplier)—through threats or coercion, forcing the other party to comply in order to get their work done.
     
  5. Fraudulent Acts
    Examples of fraudulent acts include:
    1. Marking up prices or expenses in a way that distorts the company’s income and expenditure.
    2. Providing assistance, opportunities, facilities, information, or engaging in criminal conspiracy to commit acts of corruption.
       
  6. Abuse of Authority and Position
    This includes misuse of power, opportunity, or company facilities entrusted due to one’s position or authority.
     
  7. Gratification
    Employees are prohibited from giving and/or receiving gifts or promises to/from any individual, whether internal or external (vendor/contractor/business partner/supplier).
     
  8. Violations of Laws
    Any act that violates legal provisions which explicitly define such violations as acts of corruption.

 

D. EFFORTS TO PREVENT CORRUPTION

Efforts to prevent acts of corruption are closely tied to the implementation of Good Corporate Governance principles, namely:

  1. Transparency
    In line with this principle, all work must be carried out in an open manner with nothing concealed, as secrecy can create opportunities for embezzlement and fraud. Transparency must be upheld from the very beginning of any process—starting from budgeting, project execution, to evaluation.
    This also applies when the company selects vendors/contractors/business partners/suppliers. In such cases, the vendors/contractors/business partners/suppliers must complete and sign an integrity pact form.
     
  2. Accountability
    Every task and behavior must comply with both internal company policies and applicable laws and regulations. To ensure no deviation, misconduct, or fraud occurs, regular evaluations and audits are conducted as a form of control and supervision over employee activities.
     
  3. Responsibility
    Each employee is obligated to carry out their duties with full responsibility. If, during an evaluation or audit, any deviation, misconduct, or fraud is discovered, the responsible individual must be held accountable for their actions.
     
  4. Independence
    Employees must maintain independence in performing their duties, not easily influenced by others, and must strictly adhere to company policies and applicable laws and regulations.
     
  5. Fairness
    The principle of fairness is applied to prevent manipulation or irregularities in every work process—for example, in budget planning, financial disbursements and receipts, and company expenses.
     
  6. Equity and Equality
    All company decisions must reflect fairness and equality to prevent dissatisfaction and social jealousy among employees, which could lead to fraudulent behavior by those who feel unfairly treated.

 

E. SANCTIONS
The company will impose sanctions on individuals who commit acts of corruption as follows:

  1. Impose fines exceeding the amount of the company’s losses, which must be paid by the employee who committed the act of corruption.
  2. Terminate the employment of the employee with dishonor.
  3. Report the act as a criminal offense to the appropriate authorities in accordance with applicable laws.

 

F. PUBLIC PARTICIPATION

In implementing anti-corruption measures, the company welcomes reports from the public, business partners, or suppliers who are aware of and/or feel harmed by an employee's actions, by providing accurate supporting evidence through the company’s Whistleblowing System.

There are two available channels for reporting suspected violations:

  1. Via the online form available at www.pakuwonjati.com
  2. Via letter addressed to:

    • Jakarta Office:
      WBS Report Management Team
      PT Pakuwon Jati Tbk
      Gandaria 8 Office Building, 32nd Floor
      Jl. Sultan Iskandar Muda (Arteri Pondok Indah)
      Kebayoran Lama, South Jakarta
       
    • Surabaya Office:
      WBS Report Management Team
      PT Pakuwon Jati Tbk
      Pakuwon City Mall, 5th Floor
      Jl. Kejawan Putih Mutiara No. 17, Surabaya