Other Policies

OTHER POLICIES

Policy on Sexual Harassment and/or Non-Discrimination [S-08]

In an effort to create a safe, fair and supportive work environment for all employees, the Company has established the following policy regarding actions that violate moral norms and sexual harassment:

Prohibition of Inappropriate Behavior

The Company strictly prohibits all forms of conduct that can be categorized as sexual harassment, indecent behavior, or other actions that violate moral norms in the workplace. This includes acts that may be suspected as infidelity, whether between employees or with third parties who have a working relationship with the Company.

A Safe and Harassment-Free Work Environment

The Company is committed to maintaining a professional work environment that is free from sexual or unethical harassment and coercion, whether verbal, physical, or in the form of digital communication.

Protection for Female Employees

The Company provides specific protection for female employees who may be at risk of being in vulnerable positions towards inappropriate or unethical conduct, whether from superiors, colleagues, or external parties.

Reporting and Follow-Up Actions

Any employee who experiences or witnesses harassment or violations of moral conduct may report the incident to the HR department or a designated complaints unit. The Company ensures the confidentiality of the reporter and protection from any form of retaliation.

Sanctions and Firm Actions

Any violation of this policy will result in disciplinary action, including but not limited to written warnings, demotion, or termination of employment, depending on the severity of the offense.

Human Rights Policy [S-09]

The Company does not yet have a specific policy related to Human Rights in the workplace. However, employee management within the Company already complies with applicable Human Rights Laws, under which all employees are treated equally in accordance with fundamental human rights principles.

Policy on Child Labor and Forced Labor Prohibition [S-10]

As part of the Company’s commitment to upholding human rights and fair labor standards, the following policy is established:

1. Prohibition of Child Labor

The Company strictly prohibits the employment of children below the minimum age permitted by applicable labor laws and regulations. All employees must meet the legal working age requirements and be legally eligible to work.

2. Prohibition of Forced Labor

The Company does not tolerate any form of forced labor, including work performed under coercion, threat, or physical or psychological pressure. All employment relationships within the Company are voluntary and governed by lawful employment agreements.

3. Compliance with Laws

The Company complies with all applicable labor laws and regulations, including those that govern minimum working age, working hours, and employee rights.

4. Monitoring and Corrective Actions

The Company conducts regular monitoring to ensure that no child labor or forced labor practices occur across its operations or with its business partners. Any violation of this policy will be dealt with strictly in accordance with applicable rules and regulations.

Policy on Occupational Health and Safety and a Safe and Decent Work Environment [S-11]

Health

The Company strives to provide a comfortable and healthy work environment for all employees. To that end, the Company has implemented the following initiatives:

Providing BPJS Health and Private Insurance facilities (For permanent employees)
Provide handwashing facilities and hand sanitizers and urge parties who are in an unwell condition in the work environment wear masks
Clean the entire work environment of the Company or its Subsidiaries regularly

Work Safety

Occupational safety is a top priority that the Company considers for the convenience and continuity of the business activities being carried out. Several initiatives are carried out by the Company, namely:

Ensuring workspace, worker capacity, including adequate air circulation
Place a light fire extinguisher (APAR) in every workplace
Providing an emergency button (Fire alarm)
Establish evacuation routes and assembly areas
Maintain and care for electrical installations, installations of lightning distributors, installations of fire alarms and others as well
Provide a first aid kit equipped with accident-handling equipment

Policy on the Separation of the Chairman of the Board and the CEO [G-03]

The Company implements a policy to separate the roles of the Chairman of the Board and the Chief Executive Officer (CEO) as part of its commitment to Good Corporate Governance (GCG) principles. Under the Company’s organizational structure, the supervisory function is carried out by the Board of Commissioners, while the executive management function is performed by the Board of Directors.

This structure ensures a clear distinction between supervisory and executive roles, helping to avoid conflicts of interest and enabling an effective check-and-balance mechanism in strategic decision-making. The position of Chairman of the Board is held by a member of the Board of Commissioners, who is responsible for providing direction and oversight of the Board of Directors’ performance, while the CEO role is held by the President Director, who leads the day-to-day operational management of the Company.

By separating these two roles, the Company upholds supervisory independence and reinforces accountability and transparency across all business activities.

Policy on Board of Commissioners Assessment [G-04]

The performance assessment of the Board of Commissioners is based on the execution of their duties and responsibilities as supervisors, advisors and providers of suggestions and recommendations related to the business activities carried out by the Board of Directors. In addition, each member of the Board of Commissioners is evaluated based on their attendance at internal meetings of the Board of Commissioners or joint meetings with the Board of Directors. This assessment is carried out by the Shareholders during the General Meeting of Shareholders (GMS). The performance evaluation is conducted based on the following procedures and criteria:

1. Performance Evaluation Procedures:
a. The Nomination and Remuneration Committee designs the performance evaluation system for the Board of Commissioners and proposes it to the Board of Commissioners for GMS approval

b. The Nomination and Remuneration Committee conducts the performance evaluation based on predetermined criteria or indicators

c. The results of the evaluation are reported to the Board of Commissioners for review before being documented in the meeting minutes

d. The performance report is presented in the supervision duties report of the Board of Commissioners

e. The shareholders assess the performance report during the GMS and decide whether the term of the member will be extended

2. Assessment Criteria:
a. Execution of supervisory duties and functions
b. Compliance with applicable laws and regulations
c. Attendance and participation in meetings

3. Evaluating Party:
The Nomination and Remuneration Committee, as appointed by the Board of Commissioners, conducts the assessment.

Policy on Board of Directors Assessment [G-04]

The performance assessment of the Board of Directors is based on the execution of their duties and responsibilities in managing the Company's operations. Each Director is also evaluated based on their attendance at internal meetings or joint meetings with the Board of Commissioners, and on the implementation of directions or recommendations from the Board of Commissioners and Audit Committee concerning audit findings. This assessment is conducted by the Shareholders at the GMS. The assessment follows the procedures and criteria below:

1. Performance Evaluation Procedures:
a. The Nomination and Remuneration Committee designs the performance evaluation system for the Board of Directors and proposes it to the Board of Commissioners for GMS approval

b. The Nomination and Remuneration Committee conducts the evaluation based on established criteria or indicators
c. Evaluation results are submitted to the Board of Commissioners for review
d. The Board of Commissioners reviews the evaluation with consideration of the Committee's recommendations
e. The Board of Commissioners submits the review to the shareholders at the GMS

f. Shareholders evaluate the Board of Directors' performance report and decide on the extension of their term

2. Assessment Criteria:
a. Performance reports of the Board of Directors
b. Attendance and participation in meetings
c. Compliance with applicable laws and regulations
d. Follow-up on audit findings (Audit Committee, Internal Audit, and external auditors)

3. Evaluating Party:
Initial evaluation is conducted by the Nomination and Remuneration Committee, followed by the Board of Commissioners and the GMS as the final evaluators.

Training Policy for Directors & Commissioners [G-05]

To improve the competencies and knowledge of the Board of Commissioners and support their development programs, the Company continuously enhances the knowledge of the Board through training, workshops, seminars, conferences, or benchmarking visits that support effective functioning.

Specific Criteria for Appointment of Commissioners [G-06]

The criteria for appointing the Board of Commissioners are based on the Board Charter and include:

- Good character, morals and integrity
- Legal competence
- Never declared bankrupt
- Never served on a Board of Commissioners found guilty of causing a company's bankruptcy
- No criminal conviction related to financial loss to the state and/or financial sector
- Commitment to compliance with laws and regulations
- Possession of knowledge and expertise required by the Company and capital market
- Independent Commissioners must meet additional requirements in accordance with applicable regulations

Specific Criteria for Appointment of Directors [G-06]

The criteria for appointing the Board of Directors are based on the Board Charter and include:

- Good character, morals and integrity
- Legal competence
- Never declared bankrupt
- Within five years prior and during the term, never served as a Director found guilty of causing a company's bankruptcy
- No criminal conviction related to financial loss to the state and/or financial sector
- Commitment to compliance with laws and regulations
- Possession of knowledge and expertise required by the Company and capital market

Code of Ethics & Anti-Corruption Policy [G-07]

The Company upholds a Code of Ethics as a behavioral standard and guideline for all personnel to align with GCG principles. The Code of Ethics is detailed in Articles 9-15 of the Company Regulation and must be signed by all employees upon joining. Details are available on the Ethics Policy page.

Fair Treatment of Shareholders Policy [G-08]

The Company enforces strict insider trading policies for all employees. Non-public information that could affect the Company’s share price is kept confidential until officially disclosed via authorized regulatory platforms. Employees with sensitive information are prohibited from trading the Company’s shares directly or indirectly. The Board of Commissioners, Directors, and employees are committed to upholding the Company’s Integrity Pact and strategic policies to ensure sustainable growth. This is regulated in Article 11 of the Company Regulation on Position Confidentiality, which includes:

- Employees must keep all Company-related secrets
- Employees may not store, show, or take confidential records/documents outside the office without explicit approval
- Upon termination, all documents must be returned to their supervisors

Multiple Roles & Conflict of Interest Policy [G-09]

The Board Charter regulates multiple roles, allowing Directors to hold more than one position with the following conditions:

- A Director may serve on the Board of 1 other Public Company/Issuer
- A Commissioner may serve on the Board of up to 3 other Public Companies/Issuers
- A Committee member may serve on up to 5 Committees in Public Companies/Issuers where they are also a Director/Commissioner

Ethics to Avoid Conflict of Interest:

- Directors must always avoid situations where personal interests conflict with Company duties
- Directors must report actual or potential conflicts to the President Director and other Board members, along with full disclosure
- Directors with conflicts of interest must not participate in decision-making on the related matter