Company Code Of Conduct

The Company has developed a Behavioral Guidelines as a Code of Ethics or Code of Conduct. The Code of Conduct serves as a standard behavior guideline for all Company’s employees in interacting with internal parties and external parties.

The Company’s Code of Conduct is introduced to all levels in the Company and written in the employee recruitment work contract that must be understood and signed by all employees. All employees are expected to conduct according to the Company’s values and implement the Code of Conduct in their daily activities.

The Company periodically evaluates the effectiveness of the Code of Conduct, and carries out disseminations to remind and emphasize the application of codes 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.

Code of Conduct Enforcement

The Company strives to achieve business success continuously which built upon the Company’s culture and human resources in accordance with GCG principles and the spirit of the Company’s Code of Conduct.

The Code of Conduct development is meant to be applied to all components of the Company:

1. Develop good behavior in accordance with high ethical standards for the corporation, the Board of Commissioners, the Board of Directors, and all employees.
2. Develop good relationships with external parties based on GCG principles and Code of Conduct.

The Company’s Code of Conduct shall be carried out consistently by the Board of Commissioners, Directors and all employees as a work culture in daily operational activities.

Code of Conduct Implementation and Enforcement

The application and enforcement of code of conduct is mandatory. Violations of code of conduct will be given disciplinary actions and will be handled by parties appointed by the Board of Directors. Every employee who is aware of a code of conduct violation must report to the party determined by the Board of Directors in handling GCG or direct supervisors.

Code of Conduct applies to all Company’s employees from the Board of Commissioners, Board of Directors, employees and other individuals related to the Company’s business. The successful implementation of code of conduct is the responsibility of all managers in the respective unit. To that end, all unit managers have a responsibility to provide an understanding of code of conduct practices to employees in their respective units.

Every member of the Company has a responsibility for the successful implementation of the code of conduct in daily activities. One form of the Company’s responsibility is the willingness of the Company’s employees to report on the actions of other employees or coworkers which are believed to constitute a violation of the code of ethics and convey any facts of the deviation. The Company provides strict and consistent sanctions
against violations of the Code of Conduct.

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:

1. Honesty, loyalty, and dedication
2. Assertiveness and amiability
3. Cooperation and synergy
4. Fairness
5. Humanity

Violations Sanctions

The types of sanctions against violations of the Company’s code of conduct are as follows:

1. Every employee who violates the Company’s code of conduct, violates the law or harms the Company will be subject to sanctions/actions from the Company through a warning or suspension or termination of employment carried out in accordance with the procedures of Law No. 13 of 2003 with the implementation guidelines in accordance with prevailing laws and regulations.
2. The Company determines the types of sanctions for violations in the following order:
   a. Oral Warning
   b. Warning Letters I, II, III
   c. Temporary Duty Exemption (suspension)
   d. Work Termination
3. Violation sanctions do not have to be given in the order above, but based on consideration of the type, frequency, intentional, weight and impact of the violation.
4. Each warning letter is valid for a period of 6 (six) months. If the Warning Letter is issued and has exceeded a period of 6 (six) months without the subsequent issuance of a warning letter or punishment, then the contents of the Warning Letter issued are deemed invalid.