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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.

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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.

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

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Prohibition of Child Labor

In accordance with applicable labor regulations, the Company is committed to not employing underage workers. During the recruitment process, the Company ensures that all prospective employees meet the minimum age requirements.

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Prohibition of Forced Labor

Aligned with applicable labor regulations, the Company is committed to rejecting any form of forced labor. Every employee must sign an employment agreement after fully understanding and agreeing to its terms, as a preventive measure against forced labor practices.

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​Compliance with the Law

The Company adheres to all applicable labor laws and regulations, including those concerning minimum working age, working hours, and employee rights.

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Monitoring and Corrective Actions

The Company conducts regular monitoring to ensure that there are no practices of child labor or forced labor throughout its operations and among its business partners. Any violations of this policy will be dealt with firmly in accordance with prevailing regulations.

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

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Health​

  1. Providing BPJS Health insurance and private insurance facilities.

  2. Providing handwashing facilities and hand sanitizer, and ensuring that everyone in the workplace wears a mask.

  3. Regularly cleaning the Company's and subsidiaries’ work environments.

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​Workplace Safety

  1. Ensuring adequate workspace capacity and air circulation.

  2. Installing fire extinguishers (APAR) at every location.

  3. Providing emergency buttons (fire alarms).

  4. Establishing evacuation routes and assembly points.

  5. Maintaining electrical installations, lightning rods, fire alarm systems, and other safety systems.

  6. Providing first aid kits (P3K) equipped with accident-handling supplies.

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

 

The Company applies a policy separating the roles of Chairman of the Board and Chief Executive Officer (CEO) as part of good corporate governance (GCG) practices. Within the organizational structure, supervisory functions are carried out by the Board of Commissioners, while operational management is the responsibility of the Board of Directors.

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This structure clearly delineates supervision and execution roles to avoid conflicts of interest and to ensure a check-and-balance mechanism in strategic decision-making. The Chairman of the Board is held by a member of the Board of Commissioners responsible for guiding and overseeing the performance of the Board of Directors, while the CEO role is held by the President Director, who leads the Company’s daily operations.

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By separating these roles, the Company is committed to maintaining the independence of oversight while enhancing accountability and transparency across all business activities.

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Policy on the Evaluation of the Board of Commissioners [G-04]

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The Board of Commissioners' performance is evaluated based on their duties to oversee, advise, and recommend on the Company's business activities. Each member is also evaluated based on their attendance in internal meetings and joint meetings with the Board of Directors. Evaluation is conducted by the Shareholders at the General Meeting of Shareholders (GMS) based on the following procedures and criteria:

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Performance Evaluation Procedures:

  1. Developing Key Performance Indicators (KPIs) for the Board of Commissioners through performance evaluations, using a self-assessment system or other methods determined during Board meetings.

  2. Providing feedback and recommendations regarding the Directors' KPIs at the start of the working year.

  3. Evaluating each Commissioner’s performance and documenting it in Board meeting minutes.

  4. Reporting the Board of Commissioners' performance in the supervisory duty report.

  5. Designing a performance measurement and evaluation system for the Board of Commissioners to be submitted to the GMS.

  6. Proposing annual KPIs and targets for confirmation by the GMS.

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Evaluation Criteria:

  1. Annual KPIs must be established as management contracts.

  2. KPIs include financial aspects, customer focus, workforce, leadership, and other dynamic aspects.

  3. KPI achievement calculations are based on:

  • Auditor reports.

  • KPI development and assessment guidelines.

  • Comparisons between realized and targeted work programs.

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​Evaluator:

The evaluation is conducted by the Nomination and Remuneration Committee appointed by the Board of Commissioners.

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Policy on the Evaluation of the Board of Directors [G-04]

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The Board of Directors' performance evaluation refers to their execution of duties and responsibilities as the Company's operational controllers. Each member’s performance also considers their attendance at internal Board meetings and joint meetings with the Board of Commissioners. This evaluation is conducted by the Shareholders at the GMS.

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Performance Evaluation Procedures:

  1. 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 GMS approval.

  2. The Nomination and Remuneration Committee evaluates performance using pre-established criteria or indicators.

  3. The Committee submits the evaluation results to the Board of Commissioners for review.

  4. The Board of Commissioners reviews the Directors’ evaluations with consideration of the Committee's recommendations.

  5. The Board of Commissioners presents the Directors’ performance review results to the Shareholders during the GMS.

  6. The Shareholders assess the Board of Directors’ performance report and decide whether to extend the term of each Director.

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​Evaluation Criteria:

  1. Board of Directors’ Performance Report.

  2. Attendance and participation in meetings.

  3. Compliance with applicable laws and regulations.

  4. Follow-up on audit findings from the Audit Committee, Internal Audit, or external auditors.

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Evaluator:

The Nomination and Remuneration Committee acts as the initial assessor, while the Board of Commissioners and the GMS serve as the final evaluators and decision-makers.

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Policy on Training for Directors and Commissioners [G-05]

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To enhance the competence and insight of the Board of Directors and Board of Commissioners and to support development programs, the Company continuously updates their knowledge through training activities such as workshops, seminars, conferences, working visits, and benchmarking studies.

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Specific Criteria for the Selection of Commissioners [G-06]

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The criteria for the appointment of Commissioners, based on the Board of Commissioners Charter, include:

  1. Good character, morals, and integrity.

  2. Legal competence.

  3. Never declared bankrupt.

  4. Never found guilty as a Commissioner responsible for the bankruptcy of a company.

  5. No criminal convictions for acts harming state finances and/or related to the financial sector.

  6. Commitment to comply with regulations.

  7. Relevant knowledge and expertise in areas required by the Company and the Capital Market.

  8. For Independent Commissioners, additional requirements as per applicable regulations must also be met.

 

Specific Criteria for the Selection of Directors [G-06]

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

  1. Good character, morals, and integrity.

  2. Legal competence.

  3. Never declared bankrupt.

  4. Not found guilty within five years prior to appointment of causing a company’s bankruptcy.

  5. No criminal convictions for acts harming state finances and/or related to the financial sector.

  6. Commitment to comply with regulations.

  7. Relevant knowledge and expertise in areas required by the Company and the Capital Market.

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Policy on Code of Ethics and Anti-Corruption [G-07]

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Code of Ethics

The Company has established a Code of Ethics as a standard of behavior and guideline for all Company personnel in conducting business activities aligned with GCG principles. The Code of Ethics applies equally to the Board of Commissioners and the Board of Directors. Its formulation and implementation comply with best corporate governance practices.
The Company expects that the Code of Ethics will help maximize shareholder and stakeholder value while ensuring sustainable business growth. Key points of the Code of Ethics (articles 8–15) include:

  1. Employee rights;

  2. Employee obligations;

  3. Work regulations;

  4. Confidentiality obligations;

  5. Use of Company property;

  6. Prohibition on accepting gifts;

  7. Restrictions on holding external jobs.

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Anti-Corruption

The Company is committed to implementing clean and sound business practices by adopting an anti-corruption policy applicable to all personnel. This policy aims to foster a conducive work environment, raise awareness about the negative impacts of corruption, and promote good relationships with customers and business partners.
The anti-corruption policy outlines procedures for handling corruption cases, including strict action against employees found guilty of or involved in corrupt practices, in accordance with applicable laws.

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Policy on Fair Treatment of Shareholders [G-08]

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The Company enforces strict rules against insider trading for all employees. Non-public information that could affect the Company's stock price must remain confidential until formally disclosed via regulatory channels. Employees privy to sensitive information are prohibited from directly or indirectly trading Company shares.
The Board of Commissioners, the Board of Directors, and all employees are committed to upholding the Company’s Integrity Pact and implementing strategic policies to achieve sustainable growth.

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Policy on Dual Positions and Conflict of Interest [G-09]

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According to the provisions stated in the Board of Directors Charter:

  1. A Director may serve as a Director in a maximum of one other listed company.

  2. A Director may serve as a Commissioner in up to three other listed companies.

  3. A Director may serve on up to five committees in listed companies where they also serve as a Director or Commissioner.

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​To prevent conflicts of interest from multiple positions and to maintain independence and professionalism, each Director must:

  1. Avoid situations where personal interests could conflict with Company duties at all times.

  2. Immediately report to the President Director and other Board members any conflicts of interest or potential conflicts and provide all relevant information.

  3. Directors with conflicts of interest must abstain from decision-making processes involving matters related to the conflict.

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