Good Corporate Governance

004/SKD-Dir/BVT/X/2022  

Bvarta is committed to high ethical standards in all of our activities and compliance with applicable laws and regulations. All of the Company’s stakeholders must conduct business in an ethical and legal manner whether dealing with customers, vendors, distributors or each other. To foster an ethical culture and commitment to complying with the law, this Code of Ethics and Business Conduct (the “Code”) is designed to help all stakeholders understand their responsibility to set the highest business standards. 

All officers, managers, employees and contractors, consultants or other persons acting on behalf of Bvarta are expected to comply with our obligations. The following standards of conduct will apply at all levels of the organization. Any employee who violates, or fails to report a violation of these standards will be subject to disciplinary action, up to and including separation. Acts that are criminal acts can also be subject to fines and imprisonment for the perpetrators. 

This Code contains other Bvarta policies and procedures, including the Employee Handbook. This Code does not set out existing policies and procedures. 

Our principles 

Bvarta has an unwavering commitment to prohibiting and effectively responding to harassment, discrimination, misconduct, abusive conduct, and retaliation. To that end, Bvarta adheres to these following good corporate governance main principles:  

• Transparency: Transparency in the decision-making process and disclosure of material information about the Company. 

• Accountability : Commitment to provide optimal results for all stakeholders through clarity of functions and responsibilities of each position in the organization. 

• Responsibility : Clear responsibilities in terms of compliance with applicable laws and regulations. 

• Independency : Independent in managing the Company in a professional manner, free from conflicts of interest and influence of any party. 

• Fairness : Equal and fair treatment for all stakeholders. 

Bvarta’s Business Ethics are based on the Company’s corporate values: 

• Ambition: We have a strong desire to achieve our dreams through determination and hard work, be bold and just go. 

• Teamwork: We bring our passion and expertise to make things happen 

• Together: We achieve more through collaboration  

• Data driven: We trust the power of data in all that we do   

Our practice 

Bvarta personnel must comply with all applicable laws and regulations in Indonesia and every country where the Company conducts its business activities. 

In accordance with the Principles, all employees are expected to do their best to create a supportive work environment, where everyone has the opportunity to reach their full potential, and free from harassment, intimidation, bias and unlawful discrimination. 

Commitment to the Employees  

Bvarta values the diversity and contribution of employees in the success of its business activities, based on mutual trust and respect. Bvarta recruits, empowers and develops its people based on the current and future needs, qualifications and competencies required, and by paying attention to the welfare of employees according to the Company’s capabilities. 

Equal Opportunity Employment 

Jobs at Bvarta are based solely on individual merit and qualifications which are directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, gender, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or other characteristics protected by law. We also make all reasonable accommodations to fulfill our obligations under laws protecting the rights of persons with disabilities. 

Harassment, Discrimination, and Bullying 

Bvarta prohibits discrimination, harassment and bullying in any form – verbal, physical or visual, as discussed more fully in the Policy Against Discrimination, Harassment and Retaliation. If you believe you have been harassed, harassed or discriminated against by anyone at Bvarta, or by a partner or vendor of Bvarta, we strongly encourage you to immediately report the incident to your supervisor, Human Resources, or both. Similarly, supervisors and managers who become aware of the incident should immediately report it to Human Resources. Human Resources will promptly and thoroughly investigate any complaints and take appropriate action. 

Drugs and Alcohol 

Every Company stakeholders prohibited from being involved in the abuse of narcotics and illegal drugs, such as sales, production, distribution, possession and use. 

Safe and Healthy Workplace 

We are committed to a safe, healthy and violence-free work environment. Behavior that poses a risk to the safety, health or security of us or our visitors is prohibited. If you become aware of a risk to the safety, health or security of our workplace, you must immediately report it to the Bvarta compliance team. 

Compensation and Career 

Bvarta values each individual based on integrity, quality of performance, achievement of business targets, and cooperation. The Company encourages the Company’s people to pursue achievements with high motivation. The Company will provide continuous training and development facilities in order to provide full opportunities for every employee of the Company to achieve effectiveness in their duties and careers. The Company also provides a fair career development system, through an objective evaluation process of the competence and personality of every employee of the Company who has the potential to carry out greater duties and responsibilities. 

Protecting Proprietary and Confidential Information  

While working with Bvarta, employees may have access to intellectual property and confidential information relating to the Company, its employees and customers. All employees must protect Bvarta and its customers’ proprietary and confidential information from improper disclosure. Company employees must not accept confidential information from other persons or companies, or enter into confidentiality agreements for the benefit of others, without appropriate internal permission. 

All Bvarta employees sign “Trade Secrets, Proprietary Information and Invention Agreements” which, together with various laws, give Bvarta ownership of work developed by employees within their scope of work. Bvarta employees are required to cooperate with Bvarta to obtain any intellectual property rights that may be necessary to protect Bvarta’s rights in work products. 

Bvarta requires that all third party software, data, images or other materials installed on its computer equipment and mobile devices be properly licensed. To ensure compliance of all employees with Bvarta’s copyright policies, all obligations imposed by vendors of software, data, images or other third party proprietary materials and by law must be complied with at all times. 

Shareholders 

Shareholders Bvarta strives to create sustainable growth based on the principles of good corporate governance, which provides optimal benefits to its shareholders. Bvarta always discloses current, fair, objective and timely information regarding its business activities and performance. 

Business Partners 

Business Partners Bvarta builds and implements mutually beneficial business relationships with all business partners. We strive to ensure that our business partners adhere to the Bvarta Business Ethics.  

Innovation 

Bvarta continues to promote innovation as an important component of its business expansion to meet customer needs through responsible scientific research and development activities, as well as through the implementation of product safety standards. Bvarta respects intellectual property rights. 

Commitment to the Environment 

Bvarta is committed to carrying out efforts to prevent and control environmental pollution, as well as efforts to preserve the environment. Bvarta strives to use natural resources wisely. Bvarta actively participates and forms partnerships with other parties in environmental conservation. 

Business Competition 

Bvarta conducts its business based on the principle of fair competition in accordance with applicable regulations. We see competition as a challenge to improve the Company’s performance. 

Business Integrity 

Bvarta individuals may not accept gifts of any kind that may influence their decision making. Bvarta individuals must not give any gifts that may influence decision making. Any occurrence of these conditions must be reported to their respective supervisors. Bvarta submits financial statements that fairly disclose all transactions based on applicable accounting principles. 

Conflicts of Interests 

Bvarta prohibits employees from engaging in any activity that, or may appear to be, a conflict of interest with the employee’s duties at Bvarta. Each employee is expected to avoid situations where personal or family interests actually or potentially conflict with the interests of Bvarta. Employees must declare in writing to Human Resources any recruitment of close relatives or associates, in addition to the financial interest the employee or employee’s relatives or close associates have in any competitor, customer or supplier to Bvarta. Employees who are elected or appointed to public office, or external boards with organizations related to or affiliated with Bvarta’s competitors, customers, suppliers or partners must also disclose this position to Human Resources. 

Social/Political Activities 

As citizens of the Republic of Indonesia, the Company’s personnel have the freedom to take part in social and/or political processes. In exercising these rights, the Company’s Personnel are responsible for maintaining office facilities or other matters relating to the Company’s identity from any interference, and avoiding abuse of position and authority to influence other Company personnel in exercising their political rights. Any participation in this activity is personal and cannot represent the Company. Every statement, stance and action that reflects the Company’s position, must be approved by the Board of Directors. Expenditures in the form of donations on behalf of the Company, for social and/or political activities, must be approved by the Board of Directors. 

Compliance to Bvarta’s Business Ethics  

The Board of Directors is responsible for ensuring that the principles of Bvarta’s Business Ethics are communicated, understood and implemented by all Bvarta individuals. Bvarta’s Business Ethics is implemented in stages to ensure the commitment of all Bvarta individuals. The Board of Commissioners and Board of Directors are assisted by the Audit Committee and Senior Management oversees the implementation of Bvarta’s Business Ethics. The Board of Directors encourages Bvarta individuals to report any violations or suspected violations of Business Ethics through available channels, and ensure the confidentiality and protection of whistleblowers. 

Reporting Mechanism  

Bvarta establishes a Governance Compliance Team to follow up violation reports or suspected violations against the Business Ethics. The Team is chaired by the Independent Director with the support of the Internal Audit, Legal, Human Resource, Corporate Secretary and Corporate Communication functions, as well as other appointed third parties. 

The Governance Compliance Team documents all submitted reports and the respective follow up actions as a source of organization learning to improve the Company’s business processes and strengthen its internal control. The Governance Compliance Team submits periodical reports to the President Commissioner/President Director. 

All procedures for reporting violations are listed in document 019/SKD-Dir/BVT/VIII/2022 

 

Introduction 

Thank you for visiting Bvarta (“We,” “Our,” or “Us”). This Privacy Policy serves as our notification to you regarding how we protect, collect, and manage your Personal Data in accordance with applicable laws and regulations. 

We are highly committed to upholding the principles of data management with full integrity. This Policy applies to all visitors, users, and individuals accessing our website and services. It does not cover the practices of third-party services or websites beyond our control. 

By accessing or using this site, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. 

 

Purposes 

We process your personal data for the following purpose: 

• Provide transparency regarding how Bvarta collects, uses, processes, stores, and protects personal data obtained through its website. 
• Ensure users understand their rights and how their personal data is handled in accordance with applicable laws, ethical standards, and best practices in data protection. 
• Define a transparent, lawful, and legitimate purpose for personal data processing related to Bvarta’s business operations and website functionality. 
• Safeguard the rights of users, including the right to access and delete personal data, and withdraw consent where permitted by law. 
• Support the security, reliability, and sustainability of website operations through responsible data governance. 
• Demonstrate Bvarta’s commitment to good corporate governance, transparency, and enviromental, social and governance (ESG) principles in data management.

Information We Collect 

Depending on how you interact with our website and services, we may collect the following types of data: 

A. Information You Voluntarily Provide 

We collect personal information when you submit our contact forms, register for newsletters, or communicate with us. This includes: 

• Identity Data: Name, username, and job title/position. 

• Contact Data: Email address, phone number, and company name. 

• Business Data: Industry type, business inquiries, or specific project requirements you share in message fields. 

B. Automatically Collected Data 

When you access our platform, technical information is collected automatically to ensure system performance: 

• Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, operating system, and platform. 

• Usage Data: Information about how you use our website, pages visited, access timestamps, and duration of sessions. 

• Location Information: We may collect general location data (based on IP address) to provide relevant content. 

> Note on Financial Data: We do not perform payment transactions on this website and do not collect financial information (such as credit card numbers or bank account details). 

Purpose of data Usage 

We process your personal data for the following purpose: 

• Responding to inquiries, requests, or communication submitted through our contact form. 

• Providing relevant information about our solutions and services. 

• Enhancing the security, performance, and functionality of the website. 

• Preventing misuse, security breaches, or unlawful activity. 

• We do not perform payment transactions on this website and do not collect any financial information. 

Data Retention Period 

We retain personal data only as long as necessary to fulfil the purposes set out in this policy or to comply with legal obligations. 

Legal Basis for Processing 

We process personal data based on: 

• Your consent, when you submit information through the contact form. 

• Legitimate interests, Including website maintenance, security, and operational functionality. 

• Compliance with legal obligations, when required by applicable regulations. 

Disclosure to Third Parties 

We do not sell or rent your personal information to any party. Data may only be disclosed: 

• When required by law, regulation, or lawful authority. 

• To protect the rights, property, and safety of Bvarta, users, or the public. 

• To trusted service providers who assist in website operations under strict confidentiality obligations. 

Your Data Rights 

Subject to applicable law, you may request: 

• Access to your personal data. 

• Correction of inaccurate or incomplete data. 

• Deletion of your personal data, where legally permitted. 

• Withdrawal of consent (without affecting prior lawful processing). 

• Requests may be submitted to our contact listed below.  

Sustainability Commitment 

Bvarta is committed to responsible and sustainable business practices, including: 

• Implementing digital efficiency measures to minimize unnecessary digital carbon impact. 

• Ensuring ethical, transparent, and responsible data handling. 

• Making business decisions aligned with long-term environmental, social, and governance (ESG) principles. 

• Partnering with organizations that uphold similar sustainability values. 

Changes to This Policy 

We may revise this Privacy Policy periodically to reflect operational, legal, or regulatory adjustments. Updates will be posted on this page with the latest effective data. 

 

Contact Information 

For privacy-related inquiries or data requests, please contact: 

Email: [email protected] 

Copyright 2026 Bvarta

All rights reserved. 

Published in Indonesia. 

By accessing or using any part of the Bvarta website, including its content and services, you acknowledge that you have read, understood, and agreed to these Terms of Use. This applies whether you are actively using the website or simply browsing it. 

If you do not agree with these Terms of Use, you must discontinue all access to and use of the Bvarta website immediately. Continued use of the website is permitted only if you accept and comply with these Terms of Use. 

1. Acceptance of TermsBy accessing the Bvarta website, you agree to be bound by these Website Properties Terms of Use (“Terms of Use”) between you and Bvarta, located at Foresta Business Loft 3, Jl. BSD Boulevard Utara No. 19, Lengkong Kulon, Pagedangan, Tangerang, Banten 15331.In these Terms of Use, the term “Services” refers to all offerings made available through the Bvarta website, including, without limitation, software applications; data, materials, and informational content; images, photos, animations, videos, audio, and music; text, scripts, and source or markup code; updates, enhancements, patches, and technical support provided upon request; web-based services; online communities and blogs; software or data delivered as a service (SaaS/DaaS); publicly accessible APIs or JavaScript libraries; documentation; and any other digital resources, information, or services provided individually or collectively through the Bvarta website.
2. Changes to Terms
   Bvarta may update, revise, or restrict access to any part of the Services at its discretion and without prior notice. Such changes may be made for various reasons, including compliance with applicable laws, updates to partner or platform policies, improvements in design or technology, or internal business and legal considerations. In addition, Bvarta may periodically amend or replace these Terms of Use, and any such changes may impact your ability to access or use the Services. 
3. Use of the Platform
   All Services and related content made available through the Bvarta website are provided subject to these Terms of Use. While certain Services may be accessible at no cost, they do not form part of the public domain unless explicitly stated otherwise. You are permitted to access, download, display, copy, and print the Services solely for internal use or personal, non-commercial purposes, unless otherwise specified. Any reproduction, distribution, or transmission of the Services for commercial use, in any format or through any method, whether electronic, mechanical, or otherwise, including copying, recording, or storage in any information system, is strictly prohibited without prior written authorization from Bvarta. 
4. User ResponsibilitiesYou are solely responsible for all actions, activities, and use that occur under your account, whether authorized by you or not. You agree to keep your account credentials confidential and secure at all times and not to share, disclose, or permit access to your account credentials to any third party. Any activity conducted through your account will be deemed to have been performed by you, and Bvarta will not be responsible for any loss or damage arising from unauthorized access resulting from your failure to safeguard your account information.
   
5. Intellectual Property
   Requests related to copyright or other intellectual property matters, including permissions for uses not expressly permitted under these Terms of Use, may be submitted to Bvarta through a formal copyright request. Bvarta will review and respond to claims of alleged copyright infringement in accordance with applicable national intellectual property laws. “Bvarta”, the global logo, and any other branding displayed on the Bvarta website are trademarks, service marks, or registered trademarks of Bvarta. All other product names, logos, or marks appearing on the website are the property of their respective owners. Such marks may only be used with authorization from Bvarta or as otherwise allowed by law. Any unauthorized use of these marks constitutes a material violation of these Terms of Use. 
6. Termination
   
   These Terms of Use remain in effect unless and until they are terminated by either you or Bvarta in accordance with this section. Termination may occur only under the conditions outlined below. You may terminate these Terms of Use by taking both of the following actions: (a) submitting a written notice clearly stating your intention to terminate these Terms of Use to Bvarta’s legal department at Foresta Business Loft 3, Jl. BSD Boulevard Utara No. 19, Lengkong Kulon, Pagedangan, Tangerang, Banten 15331 (the “Termination Notice”); and (b) fully ceasing all access to and use of the Services on or before the date the Termination Notice is sent. Any continued access to or use of the Services after submitting the Termination Notice will be deemed your continued acceptance of these Terms of Use.   Bvarta may terminate these Terms of Use at its discretion if any of the following occur: 
   • You violate any provision of these Terms of Use, whether through action or failure to act; 
   • You breach any separate agreement with Bvarta relating to the use of Bvarta products or services; 
   • Bvarta discontinues or withdraws the Services to which these Terms of Use apply; or 
   • You (i) engage in, or are alleged to have engaged in, criminal conduct or activities involving illegal substances, moral misconduct, or felony offenses; (ii) participate in conduct or situations that result in public discredit, scandal, or ridicule, or that may reasonably offend the public or harm Bvarta’s reputation or the value of its association with you; or (iii) become the subject of publicly available information indicating past conduct described in points (i) or (ii). 
7. DisclaimersThe Bvarta platform is provided on an “as is” and “as available” basis, without any representations or warranties of any kind. Bvarta expressly disclaims all warranties, whether express, implied, or statutory, including but not limited to implied warranties of accuracy, reliability, merchantability, fitness for a particular purpose, non-infringement, availability, or uninterrupted operation.
   
8. Limitation of LiabilityTo the fullest extent allowed under applicable law, Bvarta will not be responsible for any indirect, incidental, special, consequential, or punitive damages. This includes, without limitation, any loss of profits, revenue, business opportunities, data, or other economic or intangible losses that may result from or relate to your use of, reliance on, or inability to use the Bvarta platform, services, or content.
   
9. Governing Law
   These Terms of Use, and any relationship, rights, or obligations arising between you and Bvarta in connection with them, shall be governed by and interpreted in accordance with the laws of the Republic of Indonesia. The application of any conflict of law principles that would result in the application of the laws of another jurisdiction is expressly excluded.
10. Dispute Resolution
    The parties agree to first seek to resolve any dispute, controversy, or claim arising out of or in connection with these Terms of Use through good faith discussions and negotiations. Each party commits to cooperating reasonably in an effort to reach a mutually acceptable resolution. If the matter remains unresolved after thirty (30) days from the date written notice of the dispute is provided, the parties may proceed with further dispute resolution steps as permitted under these Terms of Use.
11. FeedbackAny feedback, suggestions, ideas, comments, or requests for improvements that you voluntarily provide to Bvarta regarding its products or Services may be used, implemented, or incorporated by Bvarta for its business, operational, or commercial purposes at its discretion. Such use may occur without any obligation to provide compensation, credit, or notice to you, and without any restriction on Bvarta’s ability to exploit or modify the feedback in any manner.