As a company committed to upholding integrity, professionalism, and transparency, the Company has established a Code of Conduct as the ethical foundation for all organizational elements. This guideline not only serves as a reference for employees in performing their daily tasks but also reflects the core values upheld by the Company. By consistently implementing the Code of Conduct, the Company aims to foster a harmonious work environment, enhance its reputation, and ensure compliance with applicable laws and regulations. Below is an explanation of the key points of the Code of Conduct, efforts to disseminate it, and a management statement supporting the implementation of these guidelines.

CODE OF CONDUCT GUIDELINE PRINCIPLES

The Company’s Code of Conduct is established as a guide for all employees to carry out their duties and responsibilities professionally and with integrity. This Code aims to:

  • Institutionalize the values of the Company based on international standards.
  • Promote accountability and transparency across all levels of the organization.
  • Ensure compliance with all applicable laws and regulations.

This Code of Conduct applies to all employees without exception. Any violation of this Code will result in disciplinary action in accordance with the Company’s regulations, which may include termination of employment if necessary.

Anti-Corruption and Anti-Bribery
As part of its commitment to ethical business practices, the Company strictly prohibits any form of corruption and bribery. In this context, “gift” is defined as any additional offering in the form of goods or services that have material value and are related to the Company’s business activities. Prohibited gifts include:

  • Gifts given or received in relation to one’s position, including promises of future gifts or additional benefits.
  • Gifts received indirectly, for example, through family, relatives, or third parties.
  • Gifts that violate ethical standards, create a conflict of interest, or are considered inappropriate.
  • Monetary gifts or items equivalent to money, regardless of the amount.

The Company provides exceptions for reasonable gifts, such as banquets of appropriate and reasonable value, as well as gifts in the form of goods or services that have no material value. Any employee who receives gifts outside these exceptions must immediately report it by completing a Gift Receipt Declaration Form.

The gift, along with the declaration form, should be submitted to the Human Resources Division (HR), which will decide on the appropriate course of action in accordance with the Company’s policies. In certain cases, exceptions to this policy may only be granted with approval from the Board of Directors.

Conflict of Interest
Employees are required to avoid situations that may create, or appear to create, a conflict of interest between their personal interests and professional responsibilities at the Company. This policy is designed to safeguard integrity and objectivity in all actions and decisions taken by employees. If a decision must still be made, it is mandatory to prioritize the interests of the Company and to disclose the conflict of interest in every decision.

Confidentiality
The Company mandates that all employees protect the confidentiality of information related to the Company’s business activities. Data, documents, and assets such as source code, flowcharts, and operating procedures must not be taken out, copied, or disseminated without official permission from the Company. Additionally, employees are required to maintain the confidentiality of customer information entrusted to the Company.

Violations and Sanctions
Any violation of the Code of Conduct will result in disciplinary action as outlined in the Company’s regulations. The sanctions can range from a warning to termination of employment, depending on the severity of the violation.

By understanding and adhering to this Code of Conduct, all employees are expected to help maintain the Company’s reputation, perform their duties with full responsibility, and continuously contribute to the achievement of the Company’s goals.

DISSEMINATION AND ENFORCEMENT

To ensure effective implementation, the Company undertakes various measures to ensure that every employee understands and adheres to the Code of Conduct, including:

Orientation for New Employees
All new employees are required to study and understand the Code of Conduct during their initial orientation.

Annual Declaration
Each year, employees must complete and sign a Disclosure Statement as a commitment to comply with the Code of Conduct.

Internal Communication Channels
The Company utilizes various internal communication platforms to disseminate information about the Code of Conduct, ensuring it reaches employees at all levels.

Sanctions for Violations
Violations of the Code of Conduct are addressed firmly in accordance with Company regulations. Sanctions include verbal warnings, warning letters, compensation for damages, and termination of employment (dismissal).

MANAGEMENT STATEMENT ON THE CODE OF CONDUCT POLICY

The Company’s management emphasizes that the Code of Conduct applies universally to all parties within the Company, including the Board of Directors, Board of Commissioners, management, employees, and subsidiaries without exception. These guidelines reflect the corporate culture, founded on principles of equality and fairness.

Additionally, as part of its anti-corruption policy, management ensures that transparency and integrity are embedded in all aspects of the Company’s operations. By consistently implementing the Code of Conduct, the Company aims to uphold a positive reputation and foster sustainable performance improvements.