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:

1. 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.

2. 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.

3. 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.

4. 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.

5. 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]

In accordance with applicable labor regulations, the Company is committed to not employing underage workers and preventing forced labor. This commitment reflects the Company's dedication to protecting human rights (HR) and complying with all labor and human rights laws and regulations.

During the employee recruitment process, the Company ensures compliance with the minimum age requirement to prevent underage labor within the Company. Additionally, the Company requires every employee to sign an employment agreement only after fully understanding and agreeing to the terms and conditions of employment, ensuring that no forced labor is involved.

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

Occupational Health and Safety
The Company upholds work practices and procedures by applicable occupational health and safety standards. To that end, the Company carries out various initiatives, which are described as follows:

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 The Board of Commissioners Assessment [G-04]

The performance appraisal of the Board of Commissioners is carried out based on the implementation of the duties and responsibilities of the Board of Commissioners as a supervisor, provider of advice, suggestions and recommendations related to business activities carried out by the Board of Directors. In addition, each member of the Board of Commissioners is assessed based on attendance at internal meetings of the Board of Commissioners or joint meetings with the Board of Directors. The Shareholders carry out this assessment at the time of the GMS. The performance assessment is based on the following procedures and criteria:

1. Performance assessment procedure:
a. The Nomination and Remuneration Committee develops a performance measurement and evaluation system for the Board of Commissioners and submits it to the Board of Commissioners for approval at the General Meeting of Shareholders (GMS)

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

c. The performance evaluation results from the Nomination and Remuneration Committee are reported to the Board of Commissioners for review before being recorded in the Board of Commissioners meeting minutes

d. The Board of Commissioner performance report is presented as part of the Board of Commissioners supervisory duties report

e. Shareholders, through the GMS, assess the Board of Commissioners performance and decide whether to extend or terminate the tenure of its members

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

3. Assessing parties:
The assessment of the Board of Commissioners is conducted by a committee appointed by the Board of Commissioners, namely the Nomination and Remuneration Committee

Policy on The Board of Directors Assessment [G-04]

The performance assessment of the Board of Directors is carried out based on the implementation of the duties and responsibilities of the Board of Directors as the party responsible for implementing the Company's operations. Each Board of Directors is also assessed based on
attendance at internal Board of Directors meetings or joint meetings with the Board of Commissioners and the implementation of directives or recommendations given by the Board of Commissioners and the Audit Committee on the follow up to audit findings. The Shareholders carry out this assessment at the time of the GMS. The performance assessment is based on the following procedures and criteria:

1. Performance assessment procedure:
a. The Nomination and Remuneration Committee develops a performance measurement and evaluation system for the Board of Directors and submits it to the Board of Commissioners for approval at the GMS

b. The Nomination and Remuneration Committee conducts a performance evaluation based on predetermined criteria or indicators
c. The performance evaluation results from the Nomination and Remuneration Committee are submitted to the Board of Commissioners for review
d. The Board of Commissioners reviews the Board of Directors performance evaluation, considering the recommendations from the Nomination and Remuneration Committee
e. The Board of Commissioners presents the Board of Directors performance evaluation review to shareholders at the GMS

f. Shareholders, through the GMS, assess the Board of Directors performance evaluation report provided by the Board of Commissioners and decide whether to extend or terminate the tenure of the Board of Directors members

2. Evaluation criteria:
a. Board of Directors Performance Report
b. Attendance and engagement of the Board of Directors in meetings
c. Compliance with applicable laws and regulations
d. Follow up on audit findings from the Audit Committee, Internal Audit, and External Auditors

3. Assessing parties:
The performance assessment of the Board of Directors is initially conducted by the Nomination and Remuneration Committee, followed by the Board of Commissioners and the GMS as the final evaluators and decision makers

Training Policy for The Board of Commissioners & Directors [G-05]

To increase the competency and knowledge of the Board of Commissioners & Directors and in line with the Board of Commissioners & Directors development program, the Company always updates the knowledge of the Board of Commissioners & Directors through training activities, workshops, seminars, conferences or in the form of work visits and comparative studies (Benchmark) which is useful in improving the effectiveness of the Board of Commissioners & Directors functions.

Specific Criteria for Appointment of The Board of Commissioners [G-06]

The criteria for the appointment of the Board of Commissioners are based on the Board of Commissioners Charter and include:
1. Having good character, morals and integrity
2. Being legally competent
3. Never having been declared bankrupt
4. Never having been a member of a Board of Commissioners found guilty of causing a company to go bankrupt
5. Never having been convicted of a criminal offense that caused financial harm to the state and/or was related to the financial sector
6. Committing to compliance with laws and regulations
7. Possessing the knowledge and expertise required by the Company and the capital market
8. In addition to the above requirements, an Independent Commissioner must meet additional criteria in accordance with applicable regulations

In addition to the requirements mentioned above, an Independent Commissioner must also comply with additional requirements in accordance with the applicable regulations.

Specific Criteria for Appointment of The Board of Directors [G-06]

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

1. Having good character, morals and integrity
2. Being legally competent
3. Never having been declared bankrupt
4. Within 5 prior to appointment and during tenure, has never served as a member of the Board of Directors who was found guilty of causing a company to be declared bankrupt
5. Never having been convicted of a criminal offense that caused financial harm to the state and/or was related to the financial sector
6. Committing to compliance with laws and regulations
7. Possessing the knowledge and expertise required by the Company and the capital market

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

The Company has a Code of Ethics, which functions as a standard of behavior and serves as a guide for all Company employees in conducting business activities, so that they remain in line with GCG principles. The currently prevailing Code of Ethics in the Company is as stipulated in Company Regulations, an agreement which must be signed by every employee upon their joining the Company.

Key Points of the Code of Ethics

The Code of Ethics contained in Articles 9 - 15 of the Company Regulations regulates, among others:
1. Obligation to Perform Duties
2. Work Regulations
3. Confidentiality of Position
4. Use of Company Property
5. Fire Hazard Prevention
6. Prohibition on Accepting Gifts
7. Concurrent Employment Outside the Company

Code of Ethics Dissemination

The dissemination of the Company’s Code of Ethics takes place automatically at the point of recruitment, upon the signing of the work contract by an employee. In addition, the Code of Ethics is regularly socialized in various Company activities and through the website.

Fair Treatment of Shareholders Policy [G-08]

The Company is committed to implementing the principle of fair and equal treatment for all shareholders as an integral part of Good Corporate Governance implementation. In practice, the Company consistently ensures that every shareholder, whether the majority or minority, receives equal protection of their rights in accordance with the prevailing laws and regulations as well as the Company’s Articles of Association. This commitment is reflected through the provision of equal access to material and relevant information in an accurate, timely, and transparent manner, without discrimination or any treatment that may prejudice certain parties. Accordingly, the Company seeks to foster a fair relationship climate, maintain shareholders trust, and ensure that every corporate decision and action consistently considers the interests of all shareholders in a balanced manner.

Multiple Roles & Conflict of Interest Policy for The Board of Commissioners [G-09]

The provisions regarding multiple positions held by the Board of Commissioners are regulated in the Board of Commissioners Charter, which allows members to hold more than one position under the following conditions:
1. A member of the Board of Commissioners may concurrently serve as a member of the Board of Directors in no more than 2 publicly listed companies or issuers
2. A member of the Board of Commissioners may concurrently serve as a member of the Board of Commissioners in no more than 2 publicly listed companies or issuers
3. If a member of the Board of Commissioners does not concurrently serve as a member of the Board of Directors, they may hold a position as a member of the Board of Commissioners in up to 4 publicly listed companies or issuers

4. A member of the Board of Commissioners may concurrently serve as a member of up to 5 Committees in publicly listed companies or issuers where they hold a position as a member of the Board of Directors or Board of Commissioners
5. If an Independent Commissioner serves on the Audit Committee, they may only be reappointed to the Audit Committee for 1 additional term
6. Holding multiple positions is permitted only if it does not violate the Company's Articles of Association and applicable regulations

Ethics in Avoiding Conflicts of Interest

To avoid conflicts of interest arising from multiple positions and to uphold independence and professionalism, each member of the Board of Commissioners must adhere to the following ethical principles:
1. A Commissioner must avoid situations where their personal interests may conflict with their obligations to the Company
2. A Commissioner who has a conflict of interest or a potential conflict of interest with the Company must immediately report it to the President Commissioner and other members of the Board of Commissioners, providing all relevant information in the report. The President Commissioner must also share relevant information regarding the conflict of interest with the Board of Directors
3. Any transaction in which a commissioner has a conflict of interest must be approved by the Board of Commissioners and comply with applicable regulations regarding affiliated parties and/or conflict of interest transactions
4. A Commissioner with a conflict of interest must not be involved in the decision making process related to that conflict

Multiple Roles & Conflict of Interest Policy for The Board of Directors [G-09]

The provisions regarding multiple positions held by the Board of Directors are regulated in the Board of Directors Charter, which allows members to hold more than one position under the following conditions:
1. A member of the Board of Directors may serve on a maximum of 1 other Issuer or Public Company
2. A member of the Board of Commissioners may serve on a maximum of 3 other Issuers or Public Companies

3. A Committee member may serve on a maximum of 5 Committees at Issuers or Public Companies where they also hold a position as a member of the Board of Directors or the Board of Commissioners

Ethics in Avoiding Conflicts of Interest

To prevent conflicts of interest arising from multiple positions and to uphold independence and professionalism, each member of the Board of Directors must adhere to the following ethical principles:
1. Each member of the Board of Directors must always avoid situations where their personal interests may conflict with their duties within the Company
2. Each member of the Board of Directors must immediately report any conflict of interest or potential conflict of interest with the Company to the President Director and other members of the Board of Directors, providing all relevant information in the report
3. A Director with a conflict of interest must not be involved in the decision-making process related to the matter in which they have a conflict of interest