Company Code Of Conduct

As a company that is built on reputation and integrity, shareholders and customers’ perception plays an important role in determining the Company’s progress. Therefore, the responsibility of all the elements in the Company at every level is to protect the reputation and demonstrate to stakeholders that the Company has high integrity and upholds ethics in carrying out every activity.

Acting with integrity is not just abiding by the law. It is more than that, as it calls for some effort to safeguard the reputation of the Company by acting honestly and treating co-workers, customers and business partners with dignity.

Continuous implementation of Corporate Ethics would shape the corporate culture which manifests itself as the Company’s values. Corporate Ethics that are applicable in the Company are stipulated in the Company’s Code of Conduct.

Corporate Ethics Contents

The Code of Conduct contains general guidelines on relationships of employees with the Company, colleagues, customers, shareholders, Government, and the community.

The entire management and employees must have the commitment to read and comprehend the Code of Conduct as the basis for acceptable behavior in the Company. Hence, employees are expected to have a better understanding of how to behave and act in order to implement the Company’s vision, missions, and philosophy.

The Code of Conduct includes:

1. Business integrity is in compliance with the applicable regulations.
2. Not making false statements and false claims which is primarily related to marketing and negotiations, including costs and expenses, review of specific projects and reporting.
3. Avoiding conflict of interests, particularly in relation to shares ownership, either directly or indirectly, insider trading, using the  Company’s assets for personal interest, doing other work outside the Company that could potentially interfere with productivity and providing information that benefits others.
4. Giving/receiving gifts, as stipulated by the Company’s policy, such as it should not be in the form of cash or vouchers and valued not more than Rp500,000.
5. Not receiving or giving any form of bribe.
6. Not committing fraud such as cheating, embezzling, piracy, misappropriation of assets, transfer of cash and others.

Integrity Commitment

The Company has implemented the GCG principle on the commitment of integrity. This policy is about managing commitment and for the entire organization to execute GCG principles, Code of Conduct, the prudent principle and internal control in operating the business.

In order to maintain a consistent and sustainable implementation of the integrity commitment, the Company through the Compliance and Business Process Improvement unit is currently performing a review on Ethical and Behavioral Guidelines as well as Corporate Governance Guidelines. The Company will be conducting the socialization and distributing those Guidelines to all employees in 2015.

Employees and Industrial Relations

The Company focuses on the quality development of its human resources to improve competencies and capabilities in a professional manner. The Company always prioritizes occupational safety and health (K3) and Community Development, assesses business competition and manages stakeholders effectively.

Relationship with Business Partners

Policies in managing relationships with customers, suppliers, and creditors, stipulated the need to establish mutually beneficial cooperation and safeguarding the Company’s reputation by upholding good corporate governance principles of fairness, transparency, accountability, independence and business ethics.

Relationship with Employees and Government Officials

The Company established policies to develop and maintain good relationships and effective communication to all levels in the government that have the authority on the Company’s operations. Employees should wherever possible avoid the misuse and/or perform actions that are prohibited by laws and compliance.

Code of Conduct Statement applicable at All Levels of the Organization

The code of conduct is applied equally to all employees at all levels. Through the implementation of the code of conduct, all employees are expected to maintain credibility and the public’s trust of the Company that has thus far is known for its good reputation and is trusted.

Corporate Ethics Socialization and Enforcement to Employees

In order to effectively implement the code of conduct, the Company has formed a team consisting of the Corporate Secretary as the Team Leader, Internal Audit Manager, HRD Manager and all General Managers (GM) for the socialization, implementation, and evaluation on its implementation on a regular basis.

Socialization is given to all employees in all divisions or departments, including the Company’s subsidiaries. Comprehensive socialization is expected to encourage employees to conduct proper behavior that will be the foundation for all of the Company’s activities in conducting its business.

Corporate Culture

In general, corporate culture is established from the Company’s core values which becomes the basis for the Company’s management and its business units’ in conducting activities. But in practice, corporate culture is also expected to be the guideline for all employees in conducting their duties and responsibilities in order to achieve the Company’s goals. The Company’s main values that are expected to become the corporate culture are:

• Honesty, loyalty, and dedication

• Assertiveness and amiability

• Cooperation and synergy

• Fairness

• Humanity