PT Telkom Landmark Tower’s Anti-Bribery Management System (ABMS)

PT Telkom Landmark Tower is committed to conducting all business activities with the highest integrity, transparency, and free from bribery practices, while ensuring continuous improvement in the implementation of the Anti-Bribery Management System (ABMS). This commitment is upheld through the following principles:

Prohibition of Bribery

The Company strictly prohibits all forms of bribery, whether direct or indirect, involving both internal and external parties. This prohibition includes:

  • Cash or fund transfers.

  • Goods, gifts, and facilities.

  • Gratuitous provision or acceptance of services.

  • Any other benefits or advantages that could improperly influence decision-making.

Compliance

The Company commits to comply with all applicable anti-bribery laws and regulations within Indonesian jurisdiction and the Telkom Group’s internal provisions. This includes.

  • Integrating such legal requirements into internal policies.

  • Ensuring all employees understand and adhere to relevant rules.

Policy Relevance

This policy serves as the primary guideline to:

  • Establish measurable anti-bribery objectives.

  • Conduct periodic reviews of these objectives.

  • Ensure consistent achievement of targets through relevant performance indicators.

Anti-Bribery Objective Framework

We are committed to environmental stewardship through prudent management of environmental impacts, pollution prevention, emission reduction, and efficient use of natural resources. All activities are grounded in sustainability principles and compliance with environmental regulations.

ABMS Compliance

The Company is committed to fulfilling all requirements of ISO 37001:2016, including:

  • Implementation of procedures for prevention, detection, and handling of bribery.

  • Provision of adequate resources and training.

  • Documentation compliant with international standards.

Good Faith Reporting

The Company encourages the reporting of suspected bribery under the principles of:

  • Good faith or reasonable belief.

  • Confidentiality of the reporter’s identity.

  • Protection against any retaliation or discrimination.

  • Availability of easily accessible reporting channels.

Continuous Improvement

The Company continuously enhances the effectiveness of the ABMS through:

  • Periodic bribery risk assessments.

  • Independent internal audits.

  • Comprehensive management reviews to determine corrective actions.

Authority and Independence of the Compliance Function

The AntiBribery Compliance Function (ABCF) is granted:

  • Full authority to oversee policy implementation.

  • Access to necessary information for compliance assessment.

  • Independence to provide recommendations without interference from interested parties.

Consequences of Non-Compliance

Any violation of this policy will result in sanctions commensurate with the severity of the offense, including:

  • Written warnings or disciplinary action.

  • Termination of employment for serious violations.

  • Legal action in accordance with applicable laws and regulations.