Code of Conduct

Commitment to Enforcing the Company Code of Ethics

To ensure the effective implementation and enforcement of the Company Code of Ethics, all Company Personnel are committed to conducting business operations with integrity, professionalism, transparency, and accountability in accordance with the principles of the Company Code of Ethics. This commitment is demonstrated through:

1. Statement of Compliance with the Code of Ethics

All Company Personnel are required to comply with and demonstrate their commitment to the Company Code of Ethics by signing the Statement of Compliance with Business Ethics and Work Ethics annually.

2. Anti-Fraud Commitment

All Company Personnel are required to declare their Anti-Fraud Commitment annually as a demonstration of their commitment to preventing and refraining from fraudulent activities in carrying out their duties and responsibilities. The Anti-Fraud Commitment also serves as one of the indicators in employee performance assessment.

3. Anti-Gratification Commitment and Gratification Declaration

a. All Company Personnel are committed to not accepting, soliciting, or giving Gratification in connection with their position, duties, and/or responsibilities.

b. The Board of Commissioners and its Supporting Organs, the Board of Directors, Band I Officials, and Band II Officials are required to sign the Anti-Gratification Commitment annually.

c. All Company Personnel are required to submit an annual Gratification Declaration regarding Gratification received or not received, in accordance with the applicable provisions.

4. Conflict of Interest Declaration

All Company Personnel are required to submit an annual Conflict of Interest Declaration and disclose any potential Conflict of Interest that may affect objectivity in carrying out their duties and making decisions.

5. Integrity Pact

The Integrity Pact represents a commitment to conducting business processes with honesty, transparency, objectivity, professionalism, and accountability, while rejecting all forms of fraud, corruption, bribery, gratification, collusion, nepotism (KKN), and Conflict of Interest. The Integrity Pact is applied to certain business processes, particularly those involving third parties and/or having potential fraud and bribery risks, in accordance with the applicable Company policies and procedures.

6. Whistleblowing Management System (WBMS)

Any suspected violation of the Company Code of Ethics may be reported through the Whistleblowing Management System (WBMS) available within the Company. All reports will be followed up in accordance with the applicable mechanisms and provisions. Where an investigation confirms a violation of the Company Code of Ethics, the responsible party will be subject to sanctions in accordance with the Company's applicable policies and regulations.