Introduction
PT Eclectic Consulting is committed to maintaining the highest ethical standards and vigorously enforcing the integrity of its business practices. Wherever we operate, we abide by all applicable national and international laws. We will not engage in any form of bribery or corruption — including the facilitation of tax evasion — either directly or indirectly.
This policy references the FCPA (Foreign Corrupt Practices Act), the UK Bribery Act, and Indonesian Law No. 31/1999 jo. Law No. 21/2001 on the Eradication of Corruption Crimes.
Scope
This policy applies to all employees including the Board of Directors. It also applies to all agents, representatives, and subcontractors acting on Eclectic's behalf.
Key Definitions
Bribery
Giving or promising something to someone with the intention of persuading them to act contrary to their authority or public obligation. Both the giver and the recipient are equally liable.
Corruption
Can include bribery, facilitation payments, or other improper business practices — essentially the misuse of entrusted power or office for private gain, whether in the public or private sector.
Facilitation Payments
Small bribes to officials to speed up routine governmental transactions. Eclectic prohibits facilitation payments entirely, even if they are local practice or custom.
Kickbacks
Arise when a third party pays part of their fees to the individual who gave them a contract or business advantage. This is strictly prohibited.
Gifts and Hospitality
Any form of gift, hospitality, reward, benefit, or incentive received or offered. Must be declared and documented properly.
Supporting Documents
This policy must be read together with the Business Code of Conduct and the Whistleblower Policy. Any breach or suspected breach must be reported under the Whistleblower Policy.
For questions, contact your line manager, local HR Manager, or email compliance@eclectic.co.id.