README

Financial Separation Policy

Document Control Information

• Document Title: Financial Separation Policy
• Version: 1.0
• Effective Date: 01 January 2026
• Document Owner: Direktur Organisasi
• Initial Implementation Date: 01 May 2025

1. Purpose and Scope

1.1 Purpose

This policy establishes standards and procedures for maintaining appropriate financial separation between PT Inovasi Teknologi Pembelajaran (the “Company”) and its non-profit research division, Teknologi Pendidikan ID (“EDTECH-ID”). These standards ensure transparency, accountability, and compliance with legal and ethical requirements pertaining to the operation of a for-profit entity with an integrated non-profit research division.

1.2 Scope

This policy applies to all financial activities, resources, and operations that involve both PT Inovasi Teknologi Pembelajaran and EDTECH-ID. It governs all employees, leadership, contractors, and partners who engage in financial activities related to either entity.

2. Organizational Financial Structure

2.1 Legal and Financial Relationship

PT Inovasi Teknologi Pembelajaran is the legal entity that houses EDTECH-ID as a dedicated non-profit research division. While operating under the same legal umbrella, EDTECH-ID maintains functional financial independence for research and grant management purposes.

2.2 Financial Officers and Responsibilities

• Chief Financial Officer (CFO): Oversees financial operations of both entities
• EDTECH-ID Financial Manager: Responsible for day-to-day financial management of EDTECH-ID
• Financial Compliance Officer: Ensures adherence to this policy and relevant regulations
• Independent Auditor: Reviews financial separation compliance annually

2.3 Oversight Mechanisms

• Finance Committee: Reviews financial reports quarterly
• Board of Directors: Approves annual budgets and financial plans
• Research Advisory Committee: Provides input on EDTECH-ID financial priorities

3. Financial Systems and Accounts

3.1 Separate Accounting Systems

• EDTECH-ID shall maintain a separate accounting module or system
• Chart of accounts shall clearly distinguish between Company and EDTECH-ID activities
• Financial reports shall be generated separately for each entity

3.2 Banking Arrangements

• EDTECH-ID shall maintain dedicated bank accounts for all research-related funds
• Grant funds shall be deposited into EDTECH-ID-specific accounts
• Account signatories shall include at least one independent EDTECH-ID representative
• Transfers between Company and EDTECH-ID accounts shall require documented justification

3.3 Financial Software and Access

• Access to financial systems shall be role-based and appropriately restricted
• Audit trails shall be maintained for all financial transactions
• Separate financial dashboards shall be maintained for each entity

4. Budget Development and Resource Allocation

4.1 Annual Budget Process

• EDTECH-ID shall develop an independent annual budget
• Budget must be approved by both EDTECH-ID leadership and Company leadership
• Budget shall clearly identify research priorities and funding sources
• Budget shall specify any resource sharing between entities

4.2 Cost Allocation Principles

• Direct costs shall be assigned to the entity that incurs them
• Shared costs shall be allocated based on documented usage or benefit
• Allocation methodologies shall be consistent, transparent, and reasonable
• Allocation methodologies shall be reviewed annually

4.3 Shared Resources and Services

• Office space, equipment, and infrastructure costs shall be allocated by square footage or usage
• Staff time shall be allocated based on documented time records
• Technology and software costs shall be allocated based on licenses or usage
• Administrative services shall be charged based on documented support levels

5. Grant and Donation Management

5.1 Grant Application Process

• Grant applications shall clearly identify EDTECH-ID as the research entity
• Applications shall disclose relationship to PT Inovasi Teknologi Pembelajaran
• Grant budgets shall accurately reflect all direct and indirect costs
• Pre-submission review shall verify compliance with this policy

5.2 Grant Fund Management

• Grant funds shall be deposited into EDTECH-ID-specific accounts
• Expenditures shall follow funder requirements and this policy
• Regular reporting shall be provided to funders and oversight bodies
• Grant closeout shall include financial reconciliation

5.3 Indirect Cost Recovery

• Indirect cost rates shall be calculated based on actual costs
• Recovered indirect costs shall be allocated to support EDTECH-ID operations
• Indirect cost calculations shall be documented and transparent
• Indirect cost rates shall be reviewed annually

6. Procurement and Expenses

6.1 Procurement Procedures

• Separate procurement processes shall be maintained for each entity
• Shared procurement shall document allocation methodology
• Vendor relationships shall be managed to avoid conflicts of interest
• Capital equipment shall be clearly assigned to appropriate entity

6.2 Expense Approval and Reimbursement

• Expense approval shall follow entity-specific approval chains
• Shared expenses shall require documentation of allocation methodology
• Expense reports shall be coded to appropriate entity
• Travel expenses shall be allocated based on purpose of travel

6.3 Contracts and Agreements

• Contracts shall clearly identify the contracting entity
• Shared contracts shall specify cost allocation methodology
• Contract review shall include verification of appropriate entity
• Contract database shall track entity responsibility

7. Financial Reporting and Transparency

7.1 Internal Reporting

• Monthly financial reports shall be generated for each entity
• Quarterly consolidated reports shall include separation analysis
• Leadership shall receive entity-specific financial dashboards
• Exception reports shall highlight potential separation issues

7.2 External Reporting

• Annual financial statements shall clearly distinguish entity activities
• Grant reports shall reflect EDTECH-ID-specific financials
• Public disclosures shall maintain appropriate entity separation
• Tax filings shall accurately reflect entity operations

7.3 Transparency Measures

• Financial separation policy shall be publicly available
• Cost allocation methodologies shall be documented and accessible
• Annual impact reports shall include financial transparency section
• Stakeholder questions about financial separation shall be addressed promptly

8. Compliance and Audit

8.1 Compliance Monitoring

• Quarterly self-audits of financial separation
• Random transaction testing for proper entity assignment
• Regular review of cost allocation implementations
• Compliance dashboard with key separation metrics

8.2 External Audit Requirements

• Annual external audit of financial separation
• Audit scope to include cost allocation methodology review
• Management response required for any separation findings
• Audit results review by Finance Committee and Board

8.3 Non-Compliance Procedures

• Process for reporting separation concerns
• Investigation procedures for potential separation issues
• Remediation requirements for identified problems
• Documentation of lessons learned and policy improvements

9. Policy Exceptions and Amendments

9.1 Exception Process

• Exceptions require written justification
• Approval required from both entity leaders and Finance Committee
• Documentation of exception rationale and duration
• Regular review of active exceptions

9.2 Policy Amendments

• Annual policy review process
• Amendment proposals from any stakeholder
• Finance Committee review and recommendation
• Board approval for substantive changes

10. Training and Awareness

10.1 Staff Training Requirements

• Initial training for all financial staff
• Annual refresher on financial separation
• Role-specific training on separation responsibilities
• Documentation of training completion

10.2 Awareness Program

• Regular communication about separation importance
• Easy access to policy documents and procedures
• Clear contact information for separation questions
• Recognition for separation compliance excellence

Appendices

• Appendix A: Cost Allocation Methodology
• Appendix B: Account Structure and Coding
• Appendix C: Financial Separation Checklist
• Appendix D: Exception Request Form
• Appendix E: Shared Resource Agreement Template

Approval

This policy has been approved by:

Rengga Prakoso Nugroho Direktur Organisasi 01 May 2025