WORKING WITH CUSTOMERS AND BUSINESS PARTNER

A. Business Partner relationships
B. International Trade Controls(ITC) laws
C. Money laundering prevention
D. Privacy

1A. Business Partner relationships
GS Group’s relationships with suppliers are based on lawful and fair practices. We expect our suppliers to meet high labor standards for their employees, treat them fairly, provide safe and healthy working conditions and uphold environmental standards. This is to ensure that our business partner relationships will not damage our reputation and its long-term business sustainability. We also require our business partners to sign an agreement/undertaking not to bribe our employees.

What does it mean for me?

DO

DON’T

  • comply with applicable laws and
    government regulations covering
    business partner relationships
  • ensure you are familiar with and follow
    government acquisition regulations when
    purchasing materials and services for
    fulfilling government contracts
  • choose business partners who comply
    with local requirements relating to labor
    standards, the environment, and health
    and safety through open and competitive
    bidding
  • safeguard “personal data” obtained from
    business partners
  • safeguard GS Group’s confidential
    and proprietary information with a
    confidentiality agreement; safeguard any
    business partner-provided information
    protected by a confidentiality agreement
  • engage in direct business with a business
    partner owned or managed by a relative
    or close friend without disclosing it to
    management
  • place orders with a business partner if
    you believe they may need to breach
    existing laws or supply standards to
    complete it
  • enter into any supplier agreement or
    contract if there are potential conflicts
    in business partner selection such as
    accepting improper gifts or other items of
    value
  • accept business with a business partner
    whose facility’s conditions are unsafe
    or those who ignore environmental
    standards
  • entrust “personal data” or confidential
    information to business partners without
    ensuring that they have appropriate
    technical, physical and organizational
    measures to prevent unauthorized access
    or use
​  

1B. International Trade Control (ITC) laws​
International Trade Control (ITC) laws affect the transfer of goods, services and technology across national borders. These laws apply to GS Group’s operations beyond the shipping of products. Exchanges of information across national boundaries, including e-mail and web access, are subject to trade controls.

 What does it mean for me?​

Do

DON'T

  • follow relevant ITC regulations in the
    area in which you operate, along with
    your business’s own ITC procedures, as
    they relate to the import and export of
    goods, technology, software, services and
    financial transactions
  • report all relevant information to your
    import manager to ensure accurate and
    complete import declarations
  • check the export classification of the
    product, software or technology prior
    to export to determine whether special
    authorization is required
  • screen your transactions against all
    applicable rules that restrict transactions
    with certain sanctioned countries, persons
    and prohibited end-users
  • screen all of your business partners,
    suppliers and parties involved in your
    international transactions against
    government provided watch lists
  • cooperate with any restrictive trade
    practice or boycott that is prohibited or
    penalized under foreign or applicable
    local laws
  • ignore or take for granted any acts
    that suggest your customer may be
    attempting to evade ITC laws
  • accept evasive, reluctant or otherwise
    unsatisfactory answers from a customer
    to questions about end-use, end-user,
    delivery dates or delivery locations
  • get involved with parties or activities
    suspected of any connection with the
    development of biological, chemical or
    nuclear weapons, or ballistic missiles
  • conduct transactions involving an
    embargoed country, a citizen or
    representative of an embargoed country
    or an individual or entity subject to
    government sanction
  • accept an invoice on imported goods
    where the price shown does not reflect
    the full value, the description of the goods
    is not complete, or the country of origin is
    not correctly identified
  • accept or process any payment to the
    exporter or benefit the exporter in a way
    that is not stipulated in the invoice price
    or otherwise reported
  • take or accept transfer pricing between
    related parties that fail to cover
    appropriate costs and profits
  • use an import tariff classification that
    does not accurately describe the
    imported goods.
  • accept or allow the designation of GS
    Group as the importer of record (party
    responsible for an importation) without
    maintaining necessary processes to
    comply with import laws
  • allow the entry of goods under a
    preferential duty program (North
    American Free Trade Agreement [NAFTA],
    etc.) without supportive procedures
    assuring compliance with the program’s
    requirements
 

1C. Money laundering prevention​
People involved in criminal activity – e.g., terrorism, narcotics, bribery and fraud – may attempt to “launder” the proceeds of their crimes to hide them or make them appear legitimate. GS Group is committed to complying with all anti-money laundering and anti-terrorism laws worldwide. It will conduct business only with reputable customers involved in legitimate business activities and with funds derived from legitimate sources.

 What does it mean for me?​

DO

DON’T

  • follow your business’s rules concerning
    acceptable forms of payment
  • comply with all applicable laws and
    regulations that prohibit money
    laundering, the support and financing of
    terrorism, and that require the reporting
    of cash or suspicious transactions
  • collect and understand documentation
    about prospective customers, agents and
    business partners to ensure that they are
    involved in legitimate business activities
    and that their funds come from legitimate
    sources
  • learn the types of payments that
    have become associated with money
    laundering (for example, multiple money
    orders or travelers checks, or checks on
    behalf of a customer from an unknown
    third party)
  • deal with a customer, agent or proposed
    business partner who is reluctant to
    provide information, provides insufficient,
    false or suspicious information, or
    is anxious to avoid reporting on
    recordkeeping requirements
  • accept payments using monetary
    instruments that appear to have no
    identifiable link to the customer or have
    been identified as money laundering
    mechanisms
  • accept payments or early repayments of
    a loan in cash or cash equivalents by a
    customer or proposed business partner
    if there is suspicion that the fund is from
    money laundering-related activities
  • process orders, purchases or payments
    that are unusual or inconsistent with the
    customer’s trade or business
  • get involved in unusually complex deal
    structures, payment patterns that reflect
    no real business purpose, or unusually
    favorable payment terms
  • allow unusual fund transfers to or from
    countries unrelated to the transaction
    or those that are not logical for the
    customer
  • participate in transactions involving
    locations identified as secrecy havens or
    areas of known terrorist activity, narcotics
    trafficking or money laundering activity
  • get involved in transactions involving
    foreign shell or offshore banks, unlicensed
    money remitters or currency exchangers,
    or nonbank financial intermediaries
  • allow the structuring of transactions
    to evade recordkeeping or reporting
    requirements (for example, multiple
    transactions below the reportable
    threshold amounts)
  • grant requests to transfer money or
    return deposits to a third party or an
    unknown/unrecognized account

1D. Privacy
A growing number of countries are regulating the collection and use of consumers’ “personal data” (names, home and office contact information, etc.). Additionally, many countries regulate the personal data of company representatives in business-to-business transactions. GS Group is committed to handling personal data responsibly and in compliance with applicable privacy laws.

 What does it mean for me?​

DO

DON'T

  • obtain/process and use personal data for
    legitimate business purposes only
  • limit access to personal data to
    individuals who need it for a legitimate
    business purpose
  • use “anonymous” data (names removed)
    or “aggregated” data (summarized so as
    not to be identifiable) instead of personal
    data where appropriate or required
  • use care to prevent unauthorized
    access in the processing of personal
    data or accidental loss or destruction of
    personal data
  • learn and comply with the applicable
    laws and regulations of jurisdictions from
    which the personal data is collected and
    in which it is processed or used
  • store or keep personal data where
    there is inadequate access or security
    control, such as e-mailing or otherwise
    distributing personal data to a larger
    group than needed, or leaving printouts
    with personal data at a printer, copy
    machine or fax machine for others to see
  • allow the sharing of personal data with
    unaffiliated third parties such as vendors
    or suppliers who lack appropriate
    security safeguards or restrictions
  • permit the transfer of personal
    data between countries without
    first considering applicable legal
    requirements

 

Did you know?

Go Soei Kie (Dasuki Angkosubroto) was the founder of Gunung Sewu

Quick Fact#8

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