Anti-Bribery and Anti-Corruption Policy

• To reinforce our group’s belief system and commitment to the highest levels of ethical behavior and compliance with laws and regulations and ensuring that no undue advantage is taken of any relationship.

• To ensure a clean and transparent environment for conducting business. To encourage ethical and competent Partners to engage with the group entities.

• To ensure that no factors other than merit play a role in;

✓ the selection of Partners or rates offered

✓ in verification of items received/consumed or

✓ in the quality of completed work or goods delivered.

• To ensure that Partners who seek to use non-ethical means to procure business or enhance profits are severely punished, along with any Associates of the group entities, who help such unethical Partners in furthering their goals.

1. Sentinel Tech Associates shall not accept any gift or favor or gratification, direct or indirect, from any Partner.

This includes personal events etc. given with an intention to influence the behavior in the giver’s favor but excludes gifts / hampers at time of festivals such as Christmas and Lebaran.

2. A Sentinel Tech Associate is not permitted to:

1. Work on behalf of any other ‘competitor’ individual / entity.

2. Receive professional compensation / remuneration / benefit from any other individual / entity in relation to business/work.

3. Have a financial interest (direct or indirect) in any entity which is a Partner (as defined above) of the company.

4. Pass information related to the company, which would generally not be available to an outsider, to any person who is engaged in any activity which could cause harm to the company, its business prospects and/or its Associates.

3. No Sentinel Tech Associate should engage or participate in any business activity which directly or indirectly involves his/her direct relatives (father, mother, siblings, children, spouse, spouse’s parents, spouse’s siblings) or any entity in which they have a financial stake.

In case such an instance comes up in the normal course of business, a Sentinel Tech Associate is expected to:

✓ Remove him/herself from the said matter completely.
✓ Inform the HOD, HR or GM, of such conflict of interest, in case he would like to continue dealing with the matter.

To prevent such conflicts of interest it is advisable that Sentinel Tech Associates discourage their direct relatives from having any business association with any of the group entities (unless such a direct relative is employed with the group).

4. Any attempt of any Partner to offer gratification to a Sentinel Tech Associate is required to be reported by the said Associate to their HOD with a CC email to [email protected] within 24 hours, specifying all relevant details including the name of the vendor, person involved from the Partner’s side and gift/favor/gratification offered.

Sentinel Tech Associates reporting such incidents may choose to keep their name anonymous if they so desire.

On investigation, if it is found to have merit and the company decides that an incident of violation of the Sentinel Tech policy has taken place, a ‘good citizen’s’ award of Rp1,000,000 shall be given to the concerned Sentinel Tech Associate (only those who had stated his/her name at the time of bringing the issue to the HOD).

5. Any Associate who learns that any other Sentinel Tech Associate or Partner is violating / attempting to violate the Sentinel Tech policy is required to report such incident, along with details of the Partner / Sentinel Tech Associate involved and context of the violation, to the HOD with a CC email to [email protected].

Sentinel Tech Associates reporting such incidents may choose to keep their name anonymous if they so desire. If the company finds merit in the issue and the company decides that an incident of violation of the Sentinel Tech policy has taken place, a ‘good citizen’s’ award of Rps. 1,000,000 shall be given to the concerned Sentinel Tech Associate, (only those who had stated his/her name at the time of bringing the issue to the company).

6. If any Partner or Sentinel Tech customer finds that he/she is being asked to provide gift or favor or gratification to a Sentinel Tech Associate, directly or indirectly, they should report such incident, along with all relevant details including name of Sentinel Tech Associate making such demand to [email protected].

Sentinel Tech shall ensure that any Partner reporting such an incident is not penalized for any reason whatsoever and investigation of the issues reported are done in a confidential manner, without jeopardizing the business interest of the Partner.

Process:

1. Sentinel Tech shall maintain complete confidentiality so that any Sentinel Tech Associate or Partner can approach Sentinel Tech in full confidence, without any 3rd party becoming aware.

2. Sentinel Tech will consider the merit of all issues / concerns / complaints received.

3. Sentinel Tech will deal with the issue and respond within 5 working days of receipt of the complaint / information.

4. Sentinel Tech will audit and carry out continuous and random checks of all locations where violations of this policy are most likely to occur. For any violations found, the Sentinel Tech Directors will send a dedicated team of 2-4 Associates to investigate further.

5. A pledge/undertaking to comply with this policy, in letter and spirit, will be required to be taken by all Sentinel Tech Associates at time of hiring or contract renewal. HR shall ensure that this policy is widely communicated to all Associates and at all locations of the company.

6. All Vendors/Partners should print and sign the undertaking attached in the Appendix below on their company letterhead in order to provide good or services to the Sentinel Tech entities.
   A copy of this letter should be kept on the Partners file at the Sentinel Tech entity they are dealing with.

7. Sentinel Tech Customers will not be required to become signatories, but this policy should be made known to them.

8. Whether a complaint/issue received is a violation of Sentinel Tech policy shall be decided upon by a 3-member Committee not related to the department in question.
   The findings of this Committee shall be binding on all concerned. The basis of decision followed by the Committee shall be reasonable proof and circumstantial evidence. Committee shall give its final decision in the matter no later than 14 days from the date of the matter being brought its attention by the Sentinel Tech/Audit.

In Cases where the Committee finds that violation of the Sentinel Tech policy has occurred:

1. In relation to the concerned Sentinel Tech Associate(s) who has tried to take/have taken benefit in violation of the Sentinel Tech policy:

1. He/she shall be immediately terminated from the services of the company, without any benefit of notice period.

2. All unpaid benefits (financial or non-financial) will lapse immediately.

3. Such instances shall be duly communicated within the company.

4. 2 x of all financial gratification received by said Associate on account of such violation, as estimated by the Committee, shall be recoverable from the said Associate.

5. The company will likely pursue police and/or legal action, based on the decision of the Board of Directors.

2. In relation to the Partner(s) (excluding Sentinel Tech customers) who have lured Sentinel Tech Associates to violate the Sentinel Tech policy and/or have facilitated such violations:

1. All existing relations with the said Partner (and all this subsidiaries) shall be terminated forthwith.

2. The said Partner (and all this subsidiaries) shall be placed on a ‘banned’ list for a period of 3 years from the date of such decision, during which said entity shall not be entertained in relation to any business of the company. The company may choose to extend this period indefinitely if the gravity of the violation so demands.

3. 3 x of all financial losses caused to the company on account of such violation, as estimated by the Committee, shall be recoverable from the said Partner and can be automatically deducted from the final pay check of the violator - the Partner shall comply with the same forthwith.

4. The company will likely pursue police and/or legal action, based on the advice of the company’s legal counsel.