Supplier Code of Conduct

018/SKD-Dir/BVT/VIII/2022

Bhumi Varta Technology is committed to complying with all laws and regulations that apply to our company in a manner consistent with the highest professional and ethical standards. As a Bhumi Varta Technology supplier, you play a role in helping us achieve these goals. We created this Supplier Code of Conduct to communicate the minimum standards that all Bhumi Varta Technology suppliers are expected to conduct themselves when providing goods or services to our system. Please note Bhumi Varta Technology organizations or departments may establish guidelines that are more restrictive than those described in this document. As a supplier, it is your responsibility to share this Supplier Code of Conduct with all personnel who may be involved in conducting business activities with Bhumi Varta Technology.

Health Safety and Quality
  • Process safety: Suppliers are required to comply with applicable laws, regulations, and safety standards regarding the management and maintenance of production processes in each country where you operate.
  • Product safety: Suppliers are required to comply with applicable product safety laws (including product labeling and handling requirements) in each country where you operate. Supplier is required to provide applicable documentation, containing all information relevant to security (e.g. product information, security data sheet/MSDS, etc.)
  • Product quality: Suppliers are required to provide high-quality, safe and effective goods and services in accordance with applicable laws, regulations and quality standards or contract-approved quality requirements and standards in each country in which you operate.
  • Product control: Suppliers are required to ensure that the number of each product is traceable, so that in the event of a product failure or recall by the manufacturer, the relevant product can be removed from use.
Legal Compliance, applicable Laws, and Business Ethics
  • Legal Compliance: Suppliers are required to comply with all laws and regulations, contractual agreements in each country where you operate.
  • Cooperative with Regulators: Suppliers are required to inform Bhumi Varta Technology if contacted by Regulators regarding Supplier’s business dealings with Bhumi Varta Technology, and must keep Bhumi Varta Technology up-to-date on regulatory inquiries, audits, reviews or investigations.
  • Corruption and Bribery: Suppliers are prohibited from engaging in any form of corruption such as bribery, giving or receiving of inappropriate benefits, regardless of whether they are given directly, through intermediaries either to private officials or public authorities. Prohibited in particular is the giving of funds (bribery, receipt of profits) and acceptance (passive bribery, receipt of profits) of donations intended to provide an illegal advantage.
  • Conflicts of Interest: Suppliers must avoid all conflicts of interest or situations where there is a potential conflict of interest in any of their business transactions. If there is a relationship (for example, employment, investment or other relationship) between members of the board of commissioners and directors, employees, or business partners of Bhumi Varta Technology and a supplier that conflicts, or may appear to conflict, with the business interests of Bhumi Varta Technology, the supplier must notify the Bhumi Varta Technology in the shortest possible time.
  • Fair competition: Suppliers are required to comply with applicable laws and regulations to maintain fair competition, including provisions on unfair competition and antitrust laws.
  • Intellectual Property: Suppliers are required to respect the intellectual property rights of others including but not limited to the intellectual property rights of Bhumi Varta Technology, and not to misuse or illegally use the intellectual property of others.
  • Privacy & Data Protection: Suppliers are required to handle and disclose personal data and confidential information obtained during business transactions with Bhumi Varta Technology, only when permitted and directed by Bhumi Varta Technology and as required by Applicable Law. Suppliers are obligated to protect personal data and confidential information from unauthorized and unlawful use, disclosure, access, loss, alteration, destruction and destruction.
  • Political Activities: Suppliers are prohibited from making political contributions or giving gifts to candidates for public office, elected officials, political parties or committees on behalf of or as representatives of Bhumi Varta Technology or in connection with any business dealings with Bhumi Varta Technology. Suppliers are prohibited from representing Bhumi Varta Technology’s political views. Suppliers are prohibited from lobbying government officials on behalf of or on behalf of Bhumi Varta Technology or in connection with any business dealings with Bhumi Varta Technology or using Bhumi Varta Technology resources for political activities.
Human Rights
  • Wages & Hours: Suppliers are required to comply with applicable standards, laws and regulations.
  • Discrimination: Suppliers are required to treat all employees equally and fairly by providing a work environment that prohibits any form of unlawful discrimination.
  • Forced labor: Suppliers are prohibited from practicing any form of forced labor, including convict forced labor, bonded labor, debt labor, slavery, or any form of human trafficking, corporal punishment or ill-treatment in accordance with applicable laws and regulations in your country operate.
  • Underage labor: Suppliers are required to comply with the minimum age requirements set by the applicable laws and regulations of the country in which you operate.
  • Human Trafficking & Modern Slavery: Suppliers are prohibited from engaging in, abetting or tolerating modern slavery, human trafficking, or forced, bonded or involuntary labor.
  • Safe and healthy workplace: Suppliers are required to comply with applicable health and safety laws and regulations in each country where you operate.
Gifts, Entertainment and Hospitality
  • Suppliers are prohibited from offering or giving and receiving or soliciting any gifts, entertainment or hospitality for any reason that could improperly influence decisions or impair objectivity more than Rp 200.000 in relation to business dealings with Bhumi Varta Technology.
  • Suppliers are prohibited from accepting or providing any gifts or favors to or from current or former government officials or commercial parties more than Rp 200.000 for or on behalf of Bhumi Varta Technology.
  • If any Bhumi Varta Technology member asks for any gifts, entertainment, or hospitality, suppliers shall report to Bhumi Varta Technology governance team.
Sustainability
  • Governance: Suppliers are required to practice responsible business practices with good governance and take appropriate steps to minimize, reduce and prevent unwanted or adverse environmental, economic and social impacts in all respects of their business activities, and ensure sustainable business performance.
  • Environmental Management: Suppliers are required to maintain an appropriate environmental management system for the protection and preservation of the environment.
  • Information Technology Security: Suppliers must ensure their information technology security standards meet Bhumi Varta Technology’s requirements to maintain and protect information, including physical and electronic assets, as well as prevent and effectively deal with any cyberattacks.
Consequences of Violation

Any violation of the principles contained in the Bhumi Varta Technology Supplier Code of Conduct is a fundamental violation of the contract by the provider of goods/services. In the event of non-compliance, Bhumi Varta Technology has the right to request corrective action to be carried out within a reasonable period of time determined by Bhumi Varta Technology. In the event of failure to meet deadlines or if there is a serious violation of the principles and requirements set out in this Code, Bhumi Varta Technology have the right to terminate the partnership without notice and Bhumi Varta Technology have the right not to pay.

Inquiries & Reporting

Suppliers are obliged to provide all information for the initial assessment and fully be part of the self-assessment. Suppliers are also required to provide other available information demonstrating compliance with the Bhumi Varta Technology Supplier Code of Conduct. Bhumi Varta Technology has the right to monitor its implementation through audits. Suppliers are required to immediately inform Bhumi Varta Technology if there is an incident that is contrary to the principles of the Bhumi Varta Technology Supplier Code of Conduct.

Whistleblowing Policy

019/SKD-Dir/BVT/VIII/2022

The Company is committed to creating a clean and accountable environment. Therefore, the Company implements a violation reporting system. The Whistleblowing System is a mechanism to avoid and reduce violations, which include but are not limited to work ethics (code of ethics), Articles of Association, agreements with external parties, company regulations, and laws and regulations in force in the country.

The Company always carries out its operational business activities based on the principles of Good Corporate Governance (GCG), in addition to complying with relevant legal guidelines and policies.

The Whistleblowing system allows the possibility to act as an early detection of possible problems due to a violation. Complaints obtained from the reporting mechanism need attention and follow-up, in the form of imposing appropriate consequences in order to provide a deterrent effect for violators.

All of the Company’s stakeholders can submit the report to the Company’s GCG Compliance Team through media letters addressed to the Company’s Head Office or to email [email protected] or through website www.bvarta.com in the violation reporting section.

WHISTLEBLOWING MECHANISM

The company provides several important things in terms of reporting violations:

  1. The Whistleblower may provide information regarding the identity of the Whistleblower (name, home/office address, telephone number that can be contacted or without providing anonymous data);
  2. The Whistleblower can provide information on violations (theft, corruption, fraud, gratification, bribery, conflict of interest, fraud, violation of the company’s code of ethics, other criminal acts), the person or party who is reported or suspected to be involved, the amount or value of the Company’s loss if it can be determined, the place and time of the incident, and explanation of the occurrence, chronology and availability of evidence that supports reports in the form of documents, photos, recordings, CCTV, SMS, and others.
PROTECTION AND REWARD TO WHISTLEBLOWER

The company is obliged to guarantee the safety of the reporter in relation to threats/actions obtained due to reports of violations and confidentiality as well as to provide a proper sense of security to the reporter and/or witness to violations and criminal acts that occur within the Company’s internal environment. Protection for whistleblowers is also applied to the manager of the violation reporting system, the party conducting the investigation, and the party providing information related to the complaint. If the violation is proven to be true, the whistleblower will be awarded a maximum of IDR 2 million.

WHISTLEBLOWING HANDLING MECHANISM

The violation management mechanism is as follows:

  • The GCG Compliance Team is responsible for:
    • Receive proceedings of violations;
    • Reviewing or examining the initial indications for 30 (thirty) days on the complaint/disclosure and summarizing it;
    • Same with External Investigators to conduct similar investigations on the substance of the complaint/disclosure of the work with the acknowledgment of the Board of Directors, Management or the Company and/or causing widespread and/or no longer monitored losses through the Internal Audit Unit;
    • Report the impact of internal and external investigations to the President Director or President Commissioner.
  •  The President Director or President Commissioner decides matters relating to the report on the results of the Company’s GCG Compliance Team, which consists of:
    • Whistleblowing cases are closed, if not proven;
    • Provide sanctions in accordance with applicable regulations, if proven and related to administrative actions;
    • Forward the violation case to a legal investigation, if proven and related to a general crime or corruption. In this case, the person in charge of the Company coordinates with the legal department to ensure there is sufficient evidence.
PARTIES IN CHARGE OF WHISTLEBLOWING

The Company authorizes the GCG Compliance Team to handle complaints of violations. The GCG Compliance Team is directly responsible to the President Director.

For reporting click here : Whistleblowing Form

Contract Management Policy and Procedures

006/SKD-Dir/BVT/IX/2022

Definition and Purpose

Bhumi Varta Technology is committed to quality, hence having a Contract Management policy is an integral part of its operations in keeping tracks of its exposures, to both suppliers and customers alike, in commercial, financial and last but not the least, intellectual property (including clients’ data). Therefore, it is in BVT’s interests to implement and put in place a Contract Management Policy. The purpose of this Contract Management Policy is to provide a clear and standardised approach to managing and administering contracts for goods, services and works purchased with the other party.

Contract Management enables BVT and other party(ies) to meet their obligations at an agreed cost and quality by monitoring and referencing the contract throughout its lifecycle. Circumstances may change over the life of a contract, so contract management also involves managing changes and variations in terms of scope, terms and prices.

Scope

This policy and procedure shall apply to all contracts and other documents which are legally binding with the exclusion of employment contracts (contracts of service) made in relation to Bhumi Varta Technology employees. This policy and procedure will apply to a contract until contractual obligations have concluded mutually between and by the parties involved.

Responsibility
  • Responsible for pre-contract actions required by this process.
  • Conduct inspections of the other party against the contract to assess the suitability of that party as a party to the contract, unless the other party is generally considered to have a sound reputation and financial position.
  • Ensure contracts comply with Bhumi Varta Technology’s legislative obligations and policies including data protection act and privacy.
  • Introduce yourself to the contractual obligations of all parties to the contract.
Procedures

Step 1: Request or Initiation

Step to request a new contract or perhaps the review of an existing contract.

Step 2: Contract creation & Authoring

The process to assemble a contract using existing and approved templates and clauses combined with a set of business rules. User is able to independently create contracts within the boundaries set by the legal team, in order to improve the speed and efficiency of the contract cycle time.

Step 3: Contract Negotiation & Review

Contract is shared with the counterparty and a negotiation process begins, so collaboration between internal and counter party is required. It is necessary to keep track of changes, control the latest version of documents, and audit trails for this process to run smoothly.

Step 4: Contract Approval & Execution

After the negotiation process is complete, it will be agreed by both parties to ensure that the agreement that has been made runs efficiently and effectively and all information shall be communicated in written format and with registered mail.

Step 5: Contract Performance & Analytics
Analyse and monitor how well the contracts that have been made are performing. The life cycle of a contract can last for several years and often involves many achievements and obligations, payments, rebates, discounts, etc.

Understanding, tracking, assigning and completing them is critical to achieving value in contracts. Equally important is assessing risk throughout the life cycle of a contract, as regulations change or business evolves, certain contracts may need to be changed to reflect the new environment.

Step 6: Contract Amendment

If there is a change/amendment to the contract, the amendment needs to be handled efficiently, without compromising existing processes or guidelines, and in written format agreed and addendum is to be added to the initial contract.

Step 7: Contract Expiry or Renewal

Have visibility or track of which contracts will expire or be renewed.

Code of Conduct

004/SKD-Dir/BVT/X/2022

Bhumi Varta Technology 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 Bhumi Varta Technology 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 Bhumi Varta Technology policies and procedures, including the Employee Handbook. This Code does not set out existing policies and procedures.

Our principles

Bhumi Varta Technology has an unwavering commitment to prohibiting and effectively responding to harassment, discrimination, misconduct, abusive conduct, and retaliation. To that end, Bhumi Varta Technology 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.

Bhumi Varta Technology’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

Bhumi Varta Technology 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 

Bhumi Varta Technology values the diversity and contribution of employees in the success of its business activities, based on mutual trust and respect. Bhumi Varta Technology 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 Bhumi Varta Technology 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

Bhumi Varta Technology 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 Bhumi Varta Technology, or by a partner or vendor of Bhumi Varta Technology, 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 Bhumi Varta Technology compliance team.

Compensation and Career

Bhumi Varta Technology 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 Bhumi Varta Technology, employees may have access to intellectual property and confidential information relating to the Company, its employees and customers. All employees must protect Bhumi Varta Technology 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 Bhumi Varta Technology employees sign “Trade Secrets, Proprietary Information and Invention Agreements” which, together with various laws, give Bhumi Varta Technology ownership of work developed by employees within their scope of work. Bhumi Varta Technology employees are required to cooperate with Bhumi Varta Technology to obtain any intellectual property rights that may be necessary to protect Bhumi Varta Technology’s rights in work products.

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

Business Partners

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

Innovation

Bhumi Varta Technology 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. Bhumi Varta Technology respects intellectual property rights.

Commitment to the Environment

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

Business Competition

Bhumi Varta Technology 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

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

Conflicts of Interests

Bhumi Varta Technology prohibits employees from engaging in any activity that, or may appear to be, a conflict of interest with the employee’s duties at Bhumi Varta Technology. Each employee is expected to avoid situations where personal or family interests actually or potentially conflict with the interests of Bhumi Varta Technology. 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 Bhumi Varta Technology. Employees who are elected or appointed to public office, or external boards with organizations related to or affiliated with Bhumi Varta Technology’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 Bhumi Varta Technology’s Business Ethics 

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

Reporting Mechanism 

Bhumi Varta Technology 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