1. Our position

MediaTuig B.V., trading as New Way Work (“New Way Work” or “we”), has zero tolerance for bribery and corruption. We do not offer, promise, give, request or accept bribes, directly or through someone else, with public officials or with private parties. This applies in the Netherlands, in Indonesia and anywhere else we work. We would rather lose business than win it this way.

2. Scope and law

This policy applies to:

• MediaTuig B.V. and everyone who works for it;

• PT Starianti Administrative Center (“PT Starianti”), our editing team in Indonesia, and its employees when they work for us;

• contractors, agents and other partners who act on our behalf.

We share this policy with the contractors and partners who act for us and expect them to follow it.

Bribery is a criminal offence under the Dutch Criminal Code (Wetboek van Strafrecht), both when it involves public officials and between private parties, and under Indonesian anti-corruption law. Where this policy is stricter than the law, this policy applies.

3. What is not allowed

• Bribes: anything of value, such as money, gifts, favours, jobs or hospitality, offered or accepted to improperly influence a decision or to reward one.

• Indirect bribes: giving or paying through an agent, consultant, family member or any other intermediary.

• Facilitation payments: small unofficial payments to speed up or secure a routine action by an official, such as issuing a permit or a visa or passing an inspection. They are not allowed, even where they are customary or the amount is small.

• Political donations made on behalf of the company.

If someone demands a payment under a threat to a person’s safety, safety comes first. Report the payment to the founder immediately afterwards, so that we can record it and act on it.

4. Gifts and hospitality

Gifts and hospitality can be part of normal business relationships. They are allowed only if they are:

• modest in value and occasional;

• given or received openly;

• never cash or cash equivalents, such as vouchers;

• never intended or likely to influence a decision, and never offered or accepted while a decision involving the other party is pending, such as a quote, a contract or a hiring decision.

Customary small gifts, such as food at religious holidays, are allowed only within the rules above. Anything beyond a customary, modest and occasional gift needs the founder’s approval in advance and must be recorded, whether it is given or received. If the value or purpose is unclear, ask before accepting or offering it. A gift that does not meet these rules must be declined; if immediate refusal creates a safety concern, report it to the founder as soon as it is safe to do so.

We do not give gifts or hospitality to public officials.

5. Dealing with public officials

We deal with public officials in the Netherlands and in Indonesia, for example for permits, visas, registrations, tax matters and inspections. In those contacts:

• we pay only official fees, through official channels and against an official receipt;

• we do not pay to speed up a procedure, unless the authority offers an official, published fast-track fee;

• during inspections, we cooperate and give accurate information;

• if we use an agent or consultant, for example for visas or permits, we choose a reputable one, agree the fees in writing, ask for a breakdown of costs and require them to follow this policy.

6. Conflicts of interest

A conflict of interest arises when a personal interest could influence a business decision.

PT Starianti is a related company: it is owned by the founder’s family, and MediaTuig B.V. holds no shares in it. We disclose this relationship openly. Transactions between MediaTuig B.V. and PT Starianti are documented in writing and invoiced on a cost-plus basis, at arm’s length.

Anyone with a personal interest in a decision, for example because a relative applies for a job or a friend owns a supplier, discloses it to the founder and does not take that decision alone.

7. Books and records

We record every transaction accurately and completely, supported by an invoice or receipt. We do not keep secret or unrecorded funds, and we do not make false or misleading entries. We pay by bank transfer where possible; a cash payment always needs a receipt. We keep our administration for 7 years, as Dutch tax law requires.

8. Reporting a concern

If you are offered or asked for a bribe, or you suspect a breach of this policy, report it to info@newwaywork.nl or directly to the founder.

No one is disadvantaged for reporting in good faith, or for refusing to pay or accept a bribe, even if we lose business as a result.

We are a small company without a separate compliance department. If a concern involves the founder, you can also report it to the competent authorities in the Netherlands or Indonesia.

9. Consequences

We take breaches seriously. A breach can lead to disciplinary measures under the applicable employment law, up to dismissal, or to the end of a contract with a contractor or partner. Where a breach may be a criminal offence, we may report it to the authorities.

10. Review

The founder owns this policy. We review it at least once a year. The next review is due by September 2027.