The Company is committed to upholding integrity and ethics in every aspect of its operations. As part of this commitment, the Company provides a transparent and effective whistleblowing mechanism to ensure that any suspected violations can be reported safely, without fear of retaliation. This mechanism also aims to encourage good-faith reporting of violations and to ensure proper handling of every report received.

WHISTLEBLOWING PROCEDURE

The Company has established a transparent and effective reporting mechanism for parties wishing to report suspected violations, whether by Company employees or third parties affiliated with the Company. Reporting is open to anyone directly or indirectly connected with the Company, including external parties who feel aggrieved or wish to report suspected violations. Reports can be submitted via email to whistleblowing@mpc.id.

The Company reminds that all reports submitted by whistleblowers must be made in good faith and should not constitute personal grievances. Whistleblowers are required to attach supporting evidence, such as documents related to the reported transaction or violation. Types of suspected violations that may be reported include corruption, collusion, nepotism (KKN), fraud, dishonesty, gratuities, breaches of internal guidelines and/or policies, deviations from business and work ethics, violations of laws and regulations, disclosure of Company secrets, and other actions that could harm the Company in the future.

WHISTLEBLOWER PROTECTION

The Company provides robust protection for whistleblowers who submit reports in good faith. This protection includes safeguarding the whistleblower’s identity and shielding them from any negative consequences that may arise as a result of their report, such as dismissal, demotion, harassment, discrimination of any kind, and adverse entries in their personal file. This protection is granted with the understanding that the whistleblower is not involved in fraudulent activities related to the reported issue. The purpose of this protection is to ensure that whistleblowers can report suspected violations without fear of retaliation.

WHISTLEBLOWING HANDLING PROCEDURE

The Company applies a clear and systematic procedure for handling each reported violation received through the whistleblowing system. The Company is obligated to accept reports regardless of whether the whistleblower’s identity is disclosed. The Violation Complaint Management Team (VCMT) will verify incoming reports and determine whether further investigation is warranted. This verification process must be completed within a maximum of 14 (fourteen) business days from the date of receipt.

If the report is deemed valid, the Violation Investigation Team (VIT) will conduct a thorough investigation, to be completed within a maximum of 60 (sixty) days. For cases where the reported individual is not at the Board of Directors level, the investigation will be conducted by the Head of Internal Audit and at least two additional designated VIT members. In cases involving members of the Board of Directors, the investigation will involve two VIT members and one Board member who is not implicated in the report. Proven violators will be processed in accordance with Company regulations and/or applicable legal processes.

WHISTLEBLOWING MANAGER

The Violation Complaint Management Team (PPP Team) is responsible for verifying received reports and deciding whether further investigation is necessary. Next, the Violation Investigation Team (IP Team) is responsible for investigating verified reports, conducting thorough investigations, and processing violations according to applicable regulations.

If a member of either the PPP or IP Team is reported for suspected violations, they are excluded from all verification and investigation processes. In certain situations, if an IP member is unable to participate in an investigation, another team member of at least the Division Head level or equivalent may step in as a replacement.