Code of Ethics

Code of Conduct

The Company is required to be trustworthy and ethical in running its business operations. Therefore, the Company prepares the Code of Conduct which will always be cultivated by all of the Company’s workforce.

The Company’s Code of Conduct consists of :

1. Introduction;

2. Vision, Mission, and Corporate Values;

3. Business Ethics;

   1. The Company’s Ethics to Employees;

   2. The Company’s Ethics to the Government;

   3. The Company’s Ethics to Shareholders;

   4. The Company’s Ethics to Consumers/Customers;

   5. The Company’s Ethics to Business Partners;

   6. The Company’s Ethics to Business Competitors;

   7. The Company’s Ethics to Creditors/Investors

   8. The Company’s Ethics to Good/Service Providers;

   9. The Company’s Ethics to Surrounding Communities and the Neighborhood;

   10. The Company’s Ethics to Mass Media;

   11. The Company’s Ethics to Subsidiaries.

4. The Company’s Commitment and Work Ethics; and

5. Enforcement of the Company’s Code of Conduct.

The application of the Code of Conduct applies to all employees, both from non – staff, staff, supervisor, manager, general manager, to the level of Board of Directors and Board of Commissioners. The dissemination of implementing the Code of Conduct is delivered since the employees joined the Company, at the time of education/training, and also delivered through the Company’s internal sites.

Whistleblowing System

The whistleblowing system is one of the Company’s inherent supervision methods to control its internal environment in a consistent and sustainable manner. This system provides a formal channel for employees and standardizes the process of expressing aspirations that help the Company to annihilate any kind of existing or potential violation. The implementation of this system helps to actualize the GCG professionally.

Scope

The scope of the Company’s whistleblowing reporting system is as follows :

1. Describe all aspects needed to establish and implement a whistleblowing reporting system as a a forum for governance of whistleblowing reporting; and

2. This whistleblowing reporting system applies to the Company’s internal interest which include all employees, Board of Directors and Board of Commissioners.

Objectives

The Company’s whistleblowing reporting system aims to :

1. Help the Company in increasing the work productivity through eradicating all forms of violation and potential violation;

2. Reduce the Company’s losses through early prevention as a form of follow-up from reporting through various whistleblowing reporting channels;

3. Improve the image and reputation of the Company holding good GCG;

4. Create an increasingly conducive climate and encourage all employees to report on issues that may cause financial or non-financial losses, including those that may corrupt values and image of the Company;

5. Simplify Management to deal efffectively with all forms of reports of violation and potential violation; and

6. Protect the confidentiality of the whistleblower’s identity and maintain the security of reported information managed in a special database.

Mechanism of Conveying and Handling the Whistleblowing

The reporting mechanism uses a special scheme submitted to the relevant Head of Department and copied to the Company’s Internal Audit Unit and the Human Resources and General Affairs Department of the Company and each of the Subsidiaries, using email facilities or applications provided to facilitate the process.

The procedure for handling violation reporting is outlined below :

1. Reporting format

   • Reporting of violations must be submitted in writing and must include the identity of the employee (for external parties accompanied by a photocopy of ID card and phone number) and include the chronolgy of events and if possible provide supporting evidence; and

   • The Company will not follow up anonymous reports or letters.

2. Violation or potential violations that may be reported include:

   • Corruption;

   • Fraud;

   • Money laundering;

   • Insider dealing;

   • Acts that violate the law (including theft, use of violence against employees or leaders, extortion, drug use, harassment, acts of other criminal categories;

   • Violation of tax provisions, or other laws and regulations;

   • Violation of the Company’s Code of Conduct or Company Values or violations of courtesy norms in general;

   • Actions that harm the work safety and health, or harm the security of the Company;

   • Actions that may cause financial and/or non-financial losses to the Company or loss of the Company’s interests;

   • Violation of all Company policies, including but not limited to Company regulations, standard operating procedures (SOPs) along with their implementation instruction; and

   • Others that support th creation of good corporate governance.

Protection for Whistleblowers

The whistleblowing system is part of efforts to implement the Code of Conduct. Therefore, the Company is committed to providing and guaranteeing the protection of whistleblower, either from within or outside the Company’s environment., so that complaints are not inhibited and whistleblowers can feel safe. With tihis commitment, it is expected that all people will be motivated to be open and courageous to inform violations in a factual and honest manner.