Ethics and Anti-Corruption Policy

1 | Introduction

The Company is committed to conducting its business activities with integrity, professionalism, transparency, and responsibility. This policy is intended as a guideline for ethical behavior and prevention efforts against all forms of corruption, bribery, gratification, extortion, conflicts of interest, and abuse of authority.

2 | Legal Basis

• Law No. 31 of 1999 in conjunction with Law No. 20 of 2001 concerning the Eradication of Criminal Acts of Corruption
• Law No. 13 of 2003 concerning Manpower
• Law No. 40 of 2007 concerning Limited Liability Companies
• OJK regulations regarding GCG and compliance (if a public company)
• International standards such as the UN Convention Against Corruption (UNCAC) and ISO 37001 (Anti-Bribery Management System)

3 | Scope

This policy applies to all:

• Directors and Board of Commissioners
• Permanent, contract, and intern employees
• Agents, distributors, vendors, partners, consultants, and other third parties involved in the company's activities, either directly or indirectly.

4 | Code of Ethics Principles

All company personnel are required to uphold the following values:

1. Integrity – Consistency between correct words and actions.
2. Transparency – Openness in communication and decision making.
3. Accountability – Responsible for the duties and authorities held.
4. Professionalism – Working based on the best standards and competencies.
5. Compliance – Complying with internal regulations and applicable laws.

5 | Prohibition of Corruption and Gratification Practices

All parties are prohibited from:

• Giving or receiving bribes, whether in the form of money, goods, facilities, or other forms.
• Abusing office for personal or group gain.
• Asking for, receiving, or giving gratification related to office and contrary to obligations or duties.
• Carrying out manipulative or unethical actions in the procurement of goods/services.
• Being involved in undisclosed conflicts of interest.

6 | Conflict of Interest

Every individual must:

• Avoid situations that may cause a conflict of interest.
• Report openly if they have family, business, or financial interests related to company decisions.
• Not using company information or assets for personal gain.

7 | Reporting Mechanism (Whistleblowing System)

• Reporting Channels: Official email, internal hotline, or complaint box
• Reporters can report confidentially and anonymously
• The company guarantees protection for reporters from all forms of intimidation or retaliation
• All reports will be verified and investigated objectively by the compliance team/ethics committee

8 | Sanctions for Violations

Violations of this policy will be subject to the following sanctions:

• Verbal/written warning
• Suspension of promotion, incentives, or facilities
• Termination of employment
• Reporting to legal authorities if it contains criminal elements

9 | Socialization and Training

• This policy must be socialized to all employees and third parties.
• Code of ethics and anti-corruption training must be conducted at least once a year, especially for procurement, finance, and top management functions.

10 | Policy Review

This policy is reviewed and updated at least every 2 (two) years or if necessary in accordance with changes in law and best practices.

CLOSING

With the establishment of this policy, all elements of the company are expected to be able to build an ethical work culture that is free from corrupt practices in order to realize a sustainable, trusted, and competitive company.

Sexual Harassment Policy

1 | Legal Basis

1. Law No. 12 of 2022 concerning Criminal Acts of Sexual Violence (TPKS)
2. Decree of the Minister of Manpower (Kepmenaker) No. 88 of 2023 concerning Guidelines for the Prevention and Handling of Sexual Violence in the Workplace
3. Law No. 13 of 2003 (jo. Job Creation Law) concerning Manpower.
4. Other relevant laws and regulations and international practice standards (ILOC190 – Violence & Harassment).

2 | Objectives

• To create a safe, dignified, and sexual harassment-free workplace.
• To establish procedures for prevention, reporting, investigation, protection, recovery, and enforcement of sanctions effectively and in favor of victims.

3 | Scope

Applies to all employees, contract workers, interns, consultants, contractors, suppliers, guests, and any party who is active in the company's work area, including events, business trips, and online interactions (e-mail, chat applications, etc.).

4 | Definition (referring to Kepmenaker88/2023 &UU12/2022)

Term	Brief Definition
Sexual Harassment	Any act of sexual nature, physical or non-physical, one-time or repeated, that causes someone to feel offended, degraded, insulted, and/or hurt.
Victim	The party experiencing sexual harassment.
Reporter	The victim, witness, or anyone who submits a complaint.
PPKS Team	The Team for Prevention & Handling of Sexual Violence formed by the company in accordance with Kepmenaker88/2023 (minimum 3 people, of various genders & positions).

5 | Policy Principles

1. ZeroTolerance – zero tolerance for any form of harassment.
2. NonDiscrimination & NoRetaliation – protection from retaliation or intimidation of the reporter/victim.
3. Confidentiality – the identities of the reporter & victim are strictly protected.
4. Victim Centred & DoNoHarm – prioritise the safety, dignity and needs of the victim.
5. Procedural Justice – fast, fair, transparent and balanced process.

 

6 | Company Commitments

• Prevent: assess risks, improve layout and post codes of conduct throughout the work area.
• Stop: immediately stop harassment once identified.
• Deal: provide 24/7 reporting channels, independent investigations and medical/psychological support.
• Take action: impose disciplinary sanctions up to and including termination of employment, or termination of contracts for third parties.

7 | Prevention Efforts

• Routine socialization of policies & case examples at least twice a year.
• Mandatory training:
• New employees (orientation).
• Annual refresh training for managers, HR, and PPKS Team.
• Annual risk assessment by HSE & PPKS Team; results reported to the Board of Directors.
• Safe room design: adequate lighting, CCTV in public areas,

8 | Reporting Mechanism

1. Channels: toll-free phone, dedicated email, internal application, closed complaint box.
2. Accessibility: available in Bahasa Indonesia & English; visual guide for workers with disabilities.
3. Response Time:
• Registration & confirmation of receipt ≤2 working days.
• Initial investigation ≤5 working days.

9 | Handling Procedures

Steps	Definition	Responsible Person	Max Time
Triage	Validation of completeness of report, assessment of victim safety risk.	PPKS Team	2 working days
Investigation	Collection of evidence, interviewing witnesses (privacy guaranteed).	Certified Investigator	14 working days
Recommendation	Report of findings & proposed sanctions/remediation to Senior PPKS Team Leader	PPKS Team Leader	3 working days
Monitoring	Evaluation of effectiveness of remediation & re-prevention.	HR & PPKS Team	Sustainable

10 | Victim Protection & Recovery

• Recovery leave with full pay according to medical recommendations.
• Free psychological counseling and/or legal assistance.
• Temporary transfer (at the victim's request) without harming career.

11 | Sanctions

• Light: written warning, warning letter.
• Medium: demotion, suspension of promotion/bonus.
• Severe: dishonorable dismissal, criminal reporting (Law 12/2022).
• Third party: termination of contract & blacklisting of suppliers.

Human Rights Policy

1 | Legal Basis & International References

1. United Nations Guiding Principles on Business and Human Rights (UNGPs) – especially the Protect, Respect & Remedy pillar.
2. Universal Declaration of Human Rights (UDHR, 1948).
3. Eight ILO Core Conventions ratified by the Republic of Indonesia:
• Conventions 29 & 105 – Forced Labour/Abolition of Forced Labour
• Conventions 87 & 98 – Freedom of Association & Collective Bargaining
• Conventions 100 & 111 – Equal Remuneration & Non-Discrimination
• Conventions 138 & 182 – Minimum Age & Elimination of the Worst Forms of Child Labour
4. National laws & regulations related to employment, human rights and sustainability.

2 | Objectives

• Establish the company’s commitment to respect, protect and promote human rights throughout its operations and supply chain.
• Standardize human rights due diligence procedures and remedy mechanisms in accordance with the UNGPs.

3 | Scope

Applies to all employees, directors, commissioners, suppliers, contractors, subcontractors, distributors, agents, and other business partners acting on behalf of the company at each location of operation.

4 | Policy Principles

1. Responsibility to Respect – not causing or contributing to human rights violations.
2. Human Rights Due Diligence – identifying, preventing, mitigating, and being accountable for human rights risks.
3. Stakeholder Engagement – meaningful consultation with employees, local communities, and vulnerable groups.
4. Access to Remedy – providing effective, safe, and non-retaliatory grievance and redress mechanisms.
5. Non-Discrimination & Equality – upholding the dignity and rights of every individual regardless of race, religion, gender, sexual orientation, disability, age, or other status.
6. Transparency & Accountability – regular and open reporting of human rights performance.

5 | Core Company Commitments

1. Decent Work & Freedom of Association; ensuring freedom of association, the right to collective bargaining, and fair working conditions.
2. Prohibition of Forced & Child Labor; zero tolerance for all forms of forced labor & exploitation of children.
3. Safety, Health, and Environment; providing a workplace that is physically and mentally safe, in accordance with the ILO SafeWork principles.
4. Decent Wages & Hours; fair and decent wages, timely payment, and working hours & overtime according to regulations.
5. Non-Discrimination & Equal Opportunity; selection, remuneration, promotion, and career development based on competence and performance.
6. Rights of Indigenous Peoples & Local Communities; respecting rights to land, resources, culture, and free, prior, informed consent (FPIC) for new projects.
7. Data Protection & Privacy; processing personal data lawfully, proportionally, and transparently.

6 | Governance & Responsibility

Level	Main Responsibilities
Board of Commisioners	Strategic oversight of human rights policy implementation & performance.
Board of Directors	Target setting, resource allocation, integration of human rights into business strategy.
Sustainability/Human Rights Committee	Coordination of due diligence, risk evaluation, reporting, and remediation.
HR Function, Procurement	Operational implementation, supplier audit, training.
All Employees & Partners	Comply with policies, report violations, and support a culture of respect for human rights.

7 | Grievance & Redress Mechanism

• 24/7 Grievance Channel (phone, email, app, physical mailbox) available in Indonesian & English.
• Procedure:
1. Receipt & registration <2 working days.
2. Investigation & verification of facts <14 working days.
3. Determination of remediation actions: restitution, restoration, rehabilitation, or sanctions.
4. Communication of results to the reporter with confidentiality protection & prohibition of retaliation.

8 | Sanctions & Firm Actions

• Violations by employees: written warnings up to termination of employment.
• Violations by suppliers/contractors: warnings, mandatory improvement plans, or contract termination.
• Reporting to relevant authorities if the alleged violation is criminal.