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

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.

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

A. COMPANY PROFILE

1. PT Bhumi Varta Technology

PT Bhumi Varta Technology (BVT) was founded in 2018 and has become a leading provider of location and business intelligence software in Indonesia. BVT maps all types of big data and uses machine learning for predictive analytics to help businesses of all types make better decisions. Our various modules can assist with site selection, market planning, logistics, insurance risk, asset management, environmental profiling and many other site-related matters. Our data includes more than 6 million Points of Interest (POI) in Indonesia, more than 300 thematic data (age, gender, religion, etc.) and data from 138 million mobile devices, showing people’s traffic and behavior data Furthermore. We not only have the most data, we use it and visualize it in the best way

Vision

The #1 geospatial technology and data analytics enabler in Indonesia.

 Mission

“Help businesses make informed and strategic decisions using geospatial technology, big data analytics, and custom solutions. We are committed to data integrity and continuous innovation.” 

 

PT Bhumi Varta Technology

Foresta Business Loft 3, Jl. BSD Boulevard Utara No.19, Lengkong Kulon, Pagedangan, Tangerang, Banten 15331.

Phone : (021) 53169492 

Email : [email protected]

Website : https://www.bvarta.com

 

2. Organizational structure

 

3. Business process

 

B. MANAGEMENT SYSTEM

1. Scope of Application

The implementation of the Management System by the company includes the following 2 management systems

1. 1. Quality Management System ISO 9001:2015
   2. ISO 27001:2022 Information Security Management System

The implementation was carried out on

Process	:	Provision of LOCATION Intelligence, LOCATION Enterprise, and LOCATION Insights software
Dept	:	All departments according to the organizational structure and employees involved
Website	:	bvarta.com
Application	:	According to the product
Dashboard	:	According to the product
Physical Location	:	Foresta Business Loft 3,  Jl. BSD Boulevard Utara No.19, Lengkong Kulon, Pagedangan, Tangerang, Banten 15331

 

2. Exception of Application

All requirements contained in the implementation standard will be carried out by the company with the exception

Standard : ISO 9001:2015 Clause : 8.3 Design and Development

 

3. Organizational Context

Organizational context is a general description of the situation and conditions related to the company which is taken into consideration in making decisions. Organizational context is the way a company views its business environment which can be a risk and opportunity in the company’s development.

The company assigns personnel for

1. 1. Seeking Information Security information related to threats and technological developments.
   2. Follow the development of the service business by participating in forums, associations and meetings.
   3. Keep abreast of local and national regulations.

 

4. Regulatory Compliance

Compliance with regulations is one of the requirements in implementing ISO 9001 Quality Management System and ISO 27001 Information Security Management.

The method of fulfilling regulations can be seen in the procedures that are made to ensure that all relevant regulations can be fulfilled. The company also determines the personnel responsible for compliance with regulations that must be implemented

 

5. Risk management

Risk management is the starting point in mapping and identifying the processes required by the company. Risk management is one way of managing the company

Risk Management is adjusted to the object of risk in accordance with the implemented management system,

System	object	Risk Object
ISO 9001:2015	Stop	Quality, process, performance, standards, regulations
ISO 27001:2022	Information Security	Information, standards, regulations

The company makes procedures to manage the company’s operational risk as a way to get a continuous improvement process

 

6. Quality and Information Security Policy and Goals

Company Policy is a policy set by the company in implementing management system requirements. The company’s target is the performance target/goal/direction set in the process of implementing the management system. Policies and objectives will be communicated internally and externally and reviewed periodically

Both of these consider the scope, regulations / standards, as well as the risks faced by the company

Information Quality and Security Policy can be seen in Appendix 1: Company Policy

Quality and Information Security Targets can be seen in Appendix 2: Company Goals

 

7. Management System Description

The objective of implementing a management system is to achieve a continuous improvement process by using the PDCA pattern to comply with the requirements and control objectives set by the requirements

Plan – Determination / Planning

As a basis for the implementation of the management system, several things will be determined as a guide in its implementation, such as:

• • Establishment of a documentation system in documented information procedures
  • Determination of the scope of the system and its implementation
  • Identify the organizational context
  • Determination of policies and targets
  • identification of risks and opportunities
  • Determination of other documents as rules / operational procedures as needed

Do – Execution

The implementation of the process is carried out by implementing all the documents specified in the daily work

Check – Check

Examination is carried out by conducting internal audits within a certain period. Internal audit is carried out by personnel who have the ability to conduct audits so that they can achieve the desired goals, namely meeting the requirements

All internal (and external) audit results will be reported to top management as part of the improvement process

Act – Repair

If there are findings, corrective actions are taken so that the implementation process can continue according to the requirements

To ensure the certainty and continuity of the management system, a management review process is carried out as part of a continuous improvement process

8. Management System Document Structure

The document structure of the Management System is based on the following document levels

• • Level 1 : Policy / Policy

The stipulations that are decided contain rules and procedures for activities with scope in more than one particular division/dept/section

• • Level 2 :  Prosedur / Procedure / Standard Operation Procedure

The stipulations that are decided contain rules and procedures for activities within the scope of one particular division/dept/section

• • Level 3 : Work Instructions / Work Instructions / Standards

Decisions that are decided contain the management of activities or parameters that become supporting documents or stand alone

• • Level 4 : Form / Form

Filling format that contains a value / description which is evidence of the implementation of the system

9. Communication

Communications carried out both internally and externally are controlled according to need. The implementation of communication goes by identifying executors, methods and communication media used to ensure the purpose of communication

Internal and external communications must meet the appropriate information security requirements.

10. Operational

Every operational process of the company is carried out in accordance with policies, procedures, work instructions and proven implementation in a predetermined format. Each work unit has a performance that is determined by the company’s goals/targets and is reported to management in accordance with the provisions.

 

11. Audit Internal

Implementation of internal audit aims to review the differences between management system requirements that are implemented with the documentation and implementation. Internal Audit is the company’s effort to implement a continuous improvement process

The process is carried out periodically at least once a year by appointing certain personnel to carry out inspections of the company’s operational activities

 

12. Management Review

Management review is carried out in accordance with the input and output requirements contained in the management system requirements. Management review is carried out every period which is carried out after the internal audit process.

Performance reports, operational conditions and internal audit results along with constraints, suggestions and improvement plans are discussed in the implementation of management reviews.

Who we are

Our website address is: https://bvarta.com

 

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