As a professional organization we will always handle our activities – personal and business – with integrity. This means consistently being honest and doing what is right within the purview of the law, regulatory prescriptions and best practice.
1A. Conflict of Interest
A “conflict of interest” arises when you use your position to make a personal gain or benefit over and above what is defined in your employment agreement. The employees must ensure that your personal interests do not conflict with the interests of the business or our customers.
How to do it right
DO
- Ensure that your personal activities and interests do not conflict with your responsibilities to the Company
- Inform your direct manager or the Compliance Department if you feel you might have a potential conflict of interest
- Declare yourself, and update at any time, if you have personal investment in a business that you feel might have a potential conflict of interest.
- Check with your direct manager, Compliance Department, or Human Resources as to what is permitted and acceptable before taking any action
- Remove yourself from the decision-making process if you have potential conflicts
DON’T
- Do business on behalf of GS Group with a third party from which you or your family member might benefit from unfairly
- Invest in a supplier if you have any involvement in the selection, negotiation with or assessment of said supplier, or if you supervise anyone who has such a responsibility
- Invest in a customer if you are responsible for dealing with them or if you supervise anyone with such a responsibility
Remember! Sometimes, we are the vendor and our obligation to do well stays. Let’s maintain the same commitment of Ethics and Integrity in serving our partners, clients and customers as we expect from them.
1B. Fraud
Gunung Sewu Group is committed to maintaining the highest standards of ethics and integrity in the way we do business. Any act of fraud, bribery or corruption is not tolerated by GS Group, nor is any help given to people carrying out such acts.
How to do it right
DO
- Be Alert. Watch for suspicious activity that could undermine our reputation for doing business honestly and fairly. Regularly review our procedures and controls to ensure they are current
- Immediately report any attempts to offer or to get you to act in a way that could be disadvantageous to Gunung Sewu Group
- Be Cooperative with either Compliance’s investigation or law enforcement agencies and support the prosecution or disciplinary action where sufficient evidence exists
DON’T
- Intentional deception for personal gain and to cause harm, involves knowingly misleading the Company or any individuals to benefit oneself. This can include actions such as falsifying documents, misrepresenting information, or manipulating transactions to illicitly obtain money, goods, or services
- Never give in to pressure to do something that’s unethical and unlawful, for example: to falsify a document, manipulate information, intentionally record a wrong transaction and any other activities of the same nature
1C. Gift and Entertainment
Gunung Sewu Group commits to do business with ethics and integrity. Business gifts and entertainment to and from business partners build goodwill, and enhance business relationships. However common the practice of offering modest gifts, meals, hospitality, and entertainment is; it should never influence – or appear to influence – our business decisions in any way.
How to do it right
DO
- Always use good judgment. Ask yourself questions like: Will it compromise my business judgment or give the appearance of doing so? Will it tarnish Gunung Sewu Group’s reputation? Have I obtained all necessary approvals?
- Keep receipt. If you accept gifts, hospitality and entertainment that are extravagant or lack transparency or a legitimate purpose, tell your manager and document the details
- Ask for approvals. You generally need approval when you are offered or plan to give gifts and entertainment. Consult your managers and/or Compliance Department to be sure, obtain receipts and document the details
- Require any person or firm who represents GS Group (such as a consultant, agent, sales representative, distributor or contractor) to comply with this policy and the related laws
- Immediately report any attempts to offer you gifts and entertainment or to get you to act in a way that could be disadvantageous for GS Group
- Regularly review our procedures and controls to ensure they are current
DON’T
- Participate in any entertainment that is unsavory, sexually-oriented or otherwise violates our commitment to mutual respect
- Participate in any activity that you know would cause the person providing the gift and entertainment to violate their own employer’s standard
- Offer or provide a gift or anything of value to a government official that is illegal or would cause the official or employee to violate established ethics or rules governing his or her conduct
- Offer or provide a gift, entertainment or anything of value if it is:
- Illegal
- Cash or other monetary instrument
- A quid pro quo (Legally speaking, quid pro quo indicates an item or service that has been traded in return for something of value, usually when the proprietary or equity of the transaction is in question. Otherwise known as “you scratch my back, I’ll scratch yours.”)
- Not recorded properly on the Company’s book or gift registry
1D. Insider trading and Market Abuse
GS Group employees have a legal duty to never use Company information that has not been made public for your own benefit, or for the benefit of others you know – for example, by selling or buying shares on the basis of price-sensitive information. Using information for your own benefit or for others is called insider trading and in almost all cases is a serious criminal offense. Other abuses of information such as disclosing sensitive material other than in the proper course of your employment (known as “market abuse”) may also result in serious criminal and/or civil penalties.
How to do it right
DO
- Maintain the confidentiality of Company information
- Consult with your manager or the Compliance Department before trading in the security or disclosing Company information
- Deal in other publicly traded companies’ shares
- Note that where your employment requires you to be in possession of nonpublic, price-sensitive information, you will be added to an “insider list” and notified by the Company secretary. You may not deal in the Company’s shares until you have been taken off the insider list
DON’T
- Talk about sensitive information regarding GS Group business or what you are working on with family and friends
- Convey information to anyone outside the Company unless it is necessary for the Company’s business activities
- Pass on non-public, price-sensitive information to other people or encourage others to deal in the Company’s shares on the basis of such information
- Buy or sell a security, asset or property because you heard about it at work and think the price will go up or down once it is publicly announced
1E. Political Activities
Gunung Sewu Group has no political affiliations and makes no political donations – we work with governments and parties around the world only on issues vital to the interests of our Group. All employees have the right to be politically active as long as you keep your work separate and remain professional around customers, colleagues, etc.
How to do it right
DO
- Make it clear when engaging in political activity or communicating in your personal social media that your political views and actions are your own and not those of Gunung Sewu Group
- Inform the Company when you are considering running for political office. This will help to avoid any potential conflict of interest
- Approach every conversation with Empathy and Open Mind. Remember that regardless of individuals political belief, we are united by a shared commitment to Collaboration.
DON’T
- Use Gunung Sewu Group’s funds, assets or facilities to support any of personal political activities, even wearing Gunung Sewu Group’s attributes
- Pressure another employee, customers or business partners to contribute or support or oppose any political candidate or party
- Solicit contributions or distribute political literature during work hours
- Make political or charitable contributions with the intent to improperly influence someone
1F. Social Media
Gunung Sewu Group recognizes the growing importance of social media and believes that it can be a great vehicle for communicating our passion and knowledge to the world. We understand that the lines between professional and personal online interactions can be blurry, but as the Ambassador of the Company, the employees should be aware that your online communications can affect not only millions of people, but also Our Reputation. And with that power comes additional responsibilities.
How to do it right
DO
- You are responsible for the content you publish. Always use common sense when engaging online. Your digital footprints are permanent. It can always be shared by other people
- When stating your own opinion, make that clear. You could add a statement, “These opinions are my own and not the opinions of my Company.”
- If you receive an inquiry regarding Gunung Sewu Group’s activities or positions on public issues, and you are not specifically authorized by the Executive Management to respond, refer the request to the right personnel. Ask your manager or Human Resources about that
- If you see something online that could be potentially harmful to Gunung Sewu Group, report it immediately to the right personnel, or when in doubt ask your Human Resources. Don’t respond to negative comments yourself, unless you are specially authorized to do so
- Be careful about sharing detailed personal information online. By protecting yourself, you protect the Company
- Always be respectful when engaging in online conversation. The online world is full of existing associates and potential clients of Gunung Sewu Group, and just like the “offline” world, we should be respectful in every conversation online as we do in our normal interaction
DON’T
- Disclose confidential business information about Gunung Sewu Group, our business partners and customers
- Make false statements or statements that might tarnish our reputation and violate the law
- Post anything that’s discriminatory or would constitute a threat, intimidation, harassment or bullying