Definitions Used in this Policy
“Company” means PT Agra Energi Indonesia (PT AEI).
“Employees” includes management, permanent, temporary or contract staff, who may become aware of, or possess Confidential or Sensitive Information.
“Confidential or Sensitive Information” means any technical, financial, legal or other documentation regarding the Company’s activities, assets, business arrangements, financing etc. For the avoidance of doubt, any and all information produced, acquired, developed or maintained by the Company shall be treated as confidential and sensitive unless otherwise stated or specified by management.
PT AEI's management provides oversight and direction for the Company's operations. The management has given consideration to the needs of the business to adequately control its day to day operations and has approved and delegated certain signature authorities and approval guidelines. This policy serves to protect both the Company and its employees from unnecessary and unwanted financial, legal and reputational exposures associated with any communication.
It is the Company's intent that all transactions involving Confidential or Sensitive Information receive adequate review & approval from management.
PT AEI has developed this Communications Policy to ensure consistent and accurate disclosures regarding any technical, financial, legal or other documentation concerning the Company, its assets, business arrangements and financing. The policy applies to both Internal & External Communications and the following rules must be followed:
- Only management are allowed to comment publically on Company activities, results or other significant matters.
- No employee shall disclose publicly the names of investors in the Company.
- Unless required by the Government of Indonesia or other Persons, Bodies or Institutions identified by the Directors, the Company or its employees shall not disclose or provide any information publicly nor comment, affirmatively or negatively, on Company activities, results or any other matters.
- No Employee shall save information on flash disks or other portable media for removal from the Company’s premises without the formal written consent of a Member.
- No employee shall host or participate in, any public forums or link to electronic chat rooms or bulletin boards where information of any sort concerning the Company can be discussed or posted.
- All information obtained while under the employment of the Company remains property of the Company. All employees waive any and all rights to any information developed as an employee of the Company.
Access to Confidential Information
Employees shall be given access to confidential information on an “as needed” basis and must not disclose that information to anyone except in the ordinary course of business and only where everyone involved understands that it is to be kept confidential.
Employees must not discuss confidential information in situations where they may be overhead, or participate in discussions regarding decisions by others about investments, divestments or other corporate actions.
In all cases, Non-Disclosure Agreements (NDAs) or Confidentiality Agreements (CAs) should be signed with any party or person outside the Company before disclosing any Company information.
Certain external communications must receive particular attention due to their sensitive nature or content. Such communications may include, but are not limited to press releases, as well as correspondence or document submission to the Government and our joint venture partners.
Any press releases relating to operations and or other matters involving our joint venture partners, must also receive approval from those partners prior to release.
Where the Company determines that this policy has been violated and it is able to identify the individual employee or employees involved, the Company will take disciplinary actions. These actions may result in written sanctions, implementation of a probationary period or termination of employment. The Company is also entitled to pursue legal remedies through the courts.