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Anti-Bribery and Anti-Corruption

SIP SHIELD ANTI-BRIBERY, ANTI-CORRUPTION, ANTI-COLLUSION, AND ANTI-GRATUITIES POLICY

This Policy describes the integrity standards that PT Beklen Royal Lestari (“Provider”) applies in connection with the Services and related commercial, procurement, support, and public-sector activities.

Anti-Bribery and Anti-Corruption Policy

Policy sections

  • 1. Purpose and Scope
  • 2. Definitions
  • 3. Zero-Tolerance Principle
  • 4. Prohibited Conduct
  • 5. Government and Public-Sector Dealings
  • 6. Gifts, Hospitality, and Business Courtesies
  • 7. Third Parties and Intermediaries
  • 8. Books, Records, and Controls
  • 9. Conflicts of Interest
  • 10. Reporting and Non-Retaliation
  • 11. Relation to Other Documents
  • 12. Changes to this Policy
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1. Purpose and Scope

1.1 This Policy applies to Provider’s directors, commissioners, officers, employees, contractors, consultants, agents, resellers, channel partners, subcontractors, and other persons acting for or on behalf of Provider in connection with the Services.

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2. Definitions

For purposes of this Policy:

“Customer” means any individual or legal entity subscribing to, purchasing, accessing, or using the Services.

“Services” means SIP Shield website access, dashboard, desktop agent, onboarding, support, maintenance, updates, and related services made available by Provider.

3

3. Zero-Tolerance Principle

Provider adopts a zero-tolerance approach toward:

a. bribery;

b. corruption;

c. kickbacks;

d. procurement collusion;

e. undisclosed conflicts of interest or nepotism; and

f. improper gratuities or unfair advantage.

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4. Prohibited Conduct

No person acting for or on behalf of Provider may directly or indirectly:

a. offer, promise, authorize, request, or accept any improper payment, gift, commission, rebate, favor, hospitality, travel, accommodation, employment opportunity, or other benefit to improperly influence a decision;

b. engage in bid-rigging, collusive tendering, sham competition, cover quotations, or price coordination;

c. use personal, family, political, or unofficial relationships to improperly influence selection, evaluation, award, or payment decisions;

d. disguise improper payments through false invoices, inflated commissions, sham consulting arrangements, or undocumented payments; or

e. retaliate against any person raising a good-faith compliance concern.

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5. Government and Public-Sector Dealings

In dealings with ministries, agencies, regional governments, SOEs, procurement working groups, evaluators, and public officials, Provider requires strict adherence to integrity standards.

Provider expects that:

a. no improper gift, payment, or favor shall be offered or provided;

b. tender submissions and declarations shall be truthful, complete, and not misleading;

c. any required integrity statement or Pakta Integritas shall be supported in good faith; and

d. actual, potential, or perceived conflicts of interest shall be disclosed where required.

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6. Gifts, Hospitality, and Business Courtesies

6.1 Gifts, hospitality, and business courtesies must never be used to improperly influence a decision.

6.2 Cash gifts, cash equivalents, vouchers, personal payments, and hidden reimbursements are prohibited.

6.3 Any permitted courtesy must be lawful, modest, proportionate, infrequent, and properly recorded.

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7. Third Parties and Intermediaries

7.1 Provider may be exposed to risk through the conduct of third parties acting on its behalf.

7.2 Resellers, consultants, agents, channel partners, and subcontractors are expected to comply with standards equivalent to this Policy.

7.3 No third party may be used as an indirect means to do something that Provider would be prohibited from doing directly.

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8. Books, Records, and Controls

Provider expects transactions, expenses, commissions, discounts, reimbursements, and payments to be accurately, completely, and truthfully recorded. False, misleading, or incomplete entries are prohibited.

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9. Conflicts of Interest

Actual, potential, or perceived conflicts of interest relevant to procurement, contract performance, reseller arrangements, or public-sector opportunities must be disclosed through appropriate internal channels.

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10. Reporting and Non-Retaliation

Concerns relating to this Policy may be reported to:

PT Beklen Royal Lestari

Email: help@sipshield.id

WhatsApp: +62 811-8049-911

Provider prohibits retaliation against any person who, in good faith, reports a concern, asks for guidance, or refuses to participate in conduct believed to be unlawful or unethical.

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11. Relation to Other Documents

This Policy should be read together with the SIP Shield Terms and Conditions, SIP Shield Ethics and Responsible Use Policy, and SIP Shield Information Security Policy.

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12. Changes to this Policy

Provider may amend this Policy from time to time. Updated versions become effective upon publication unless otherwise stated.

SIP Shield
PT Beklen Royal Lestari Jalan Raya Tapos No. 57 RT. 001 RW. 011, Depok, Indonesia 16457 NPWP: 1000 0000 1888 6649
WhatsApp: +628118049911 Email: help@sipshield.id
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