ADDENDUM A - ANTI-CORRUPTION AND BRIBERY

POLICY

Entered into between:

TECEX
a division of VATit S.a.r.l, Reg No. RCS Luxembourg RCS B136 565, whose principal place
of business is situated at 14-16, Rue Philippe IIL-2340, Luxembourg
and

THE COMPANY
PT. Kreasi Internasional Fortuna whose principal place of business is situated at Mall

MGK Kemayoran Lt. 1 Blok B6 No. 6-7, South Gunung Sahari, Kemayoran, Jakarta

1. POLICY STATEMENT

It is our policy to conduct all of our business in an honest and ethical manner. We take a

zero-tolerance approach to Bribery and Corruption and are committed to acting

professionally, fairly and with integrity in all our business dealings and relationships

wherever we operate and implementing and enforcing effective systems to counter

bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in

which we operate. We remain bound by local and international laws.

2. DEFINITIONS

For the purpose of this Policy the below terms will have the following meanings:

“bribery” Bribery occurs when one person offers,

pays, seeks or accepts a payment, gift, favour, or a

financial or other advantage from another to

 influence a business outcome improperly, to induce

or reward improper conduct or to gain any

commercial, contractual, regulatory or personal

advantage. It can be direct or indirect through Third

Parties.

“business integrity” the application of TecEx’s core values of

honesty and a reputation for fair dealings;

“client/s” TecEx’s client/s;

“corruption” bribery, facilitation payments or other forms

of improper business practices;

“facilitation payments” small Bribes to officials in order to speed up

routine governmental and/or VAT payments and/or

transactions;

“kickbacks” when Clients, The Company or service

providers pay part of their fees to individuals who

advantage;

“policy” this Anti-bribery and Anti-corruption Policy;

“The Company” PT. Kreasi Internasional Fortuna or any third Parties

which include sub-contractors, entities or

 individual persons acting on behalf of The

Company, in any capacity whether or not employed

by The Company;

3. SCOPE

3.1. This Policy shall apply to all TecEx entities including The Company, employees,

its suppliers and directors.

3.2. This policy applies in all countries or territories where TecEx has entered into

agreement with The Company.

3.3. Where local customs, standards, laws or other local policies apply that are

stricter than the provision of this policy, the stricter rules must be complied

with.

4. PURPOSE

4.1. TecEx has adopted this Policy in order to ensure that:

4.1.1. The Company committed to maintaining the highest ethical standards

and Business Integrity of TecEx;

4.1.2. The Company adheres to the relevant Anti-Bribery and Anti-Corruption

laws and regulations where applicable;

 4.1.3. The Company does not engage in any practices which involve Bribery

and/or Corruption

5. POLICY

5.1. TecEx and The Company shall never offer, pay, solicit, accept Bribes or receive

kickbacks, in any form either directly or indirectly, including but not limited to,

Facilitation Payments from public officials and/or private individuals which The

Company interacts with or does business;

5.2. The Company may not offer to, or accept from, third parties, gifts, hospitality,

rewards, benefits or other incentives that could affect either party’s impartiality

or influence a business decision or lead to improper performance. Similarly,

such parties may not offer or accept cash donations.

5.3. The Company may offer and accept ‘reasonable’ and ‘proportionate’ gifts and

entertainment such as dinner, theatre tickets or tickets to sporting events. In

determining what is ‘reasonable’ and ‘proportionate’, The Company should

consider the value of the gift or the benefit. In all cases they must ensure that

the gift or benefit:

5.3.1. Is given as an expression of goodwill and not in expectation of a return

of a favour;

5.3.2. Is equal to the generally accepted standards for hospitality taking into

account the norms for the industry/ professional sector;

5.3.3. Is provided openly and transparency; and

5.3.4. Where applicable, complies with local laws and regulations.

 5.4. The Company must avoid situations or transactions in which their personal

interests could conflict or might be seen in conflict with the interests of TecEx.

5.5. TecEx and The Company must, at all times, comply with all applicable laws and

regulations.

6. MONITOR, REVIEW AND AMENDMENTS

6.1. TecEx will establish and put in place appropriate performance measures and

reporting systems to monitor performance against metrics and compliance with

the relevant policies, procedures and controls;

6.2. TecEx’s legal and compliance team will monitor the effectiveness and review the

implementation of this policy, regularly considering its suitability, adequacy and

effectiveness. Any improvements identified will be made as soon as possible.

THE COMPANY

Per: 27 December 2019

Name: Ian Sudiana

Title: Director

I have the authority to THE COMPANY.