Governance

The Company is fully committed to supporting the Government’s efforts to eradicate corruption in Indonesia. Therefore, the Company always strives to prevent all forms of corruption, whether committed by or involving the Company’s personnel. Anti-bribery and anti-corruption policies are a fraud prevention program in suppressing future fraud and the Company continues to comply with the applicable laws and regulations in the Republic of Indonesia. This is in accordance with the Law No. 31 of 1999 in conjunction with Law No. 20 of 2001 on Eradication of Corruption Crimes.

Every gift/receipt of money, equivalent to money, goods, rebates (discounts), commissions, interest-free loans, travel tickets, lodging facilities, travel tours, free medical treatment, receipt/provision of valuable guarantees or rights to land, employment, exemption from implementation other obligations or responsibilities, certain support or benefits, and other facilities of any value, whether received domestically or abroad, and which are carried out using electronic means or without electronic means that are carried out by the Company’s personnel related to their authority/position at the Company, is categorized as the “Gratification”, which may cause conflict of interest in the future. The Company has stipulated the provisions regarding this Gratification in Indocement Code of Conduct stating that the Company’s Personnel are not allowed to receive Gratification from other parties in any form. The Company will continue to maintain anti-corruption policies that aim to prevent material and immaterial losses that may interfere with the Company’s operation/business continuity by increasing the Company’s compliance and discipline with laws, regulations, and Indocement Code of Conduct, and supporting government programs to increase awareness of high ethical culture in carrying out the Company’s activities related to external parties, in this case, work partners and Government agencies that are related to the Company, by:

1. Not accepting any type of gratification that is known and shall be suspected that it is given to encourage to do or not to do something in its responsibilities or that is contrary to its obligations.
2. Complying with the limitation of giving or receiving gifts or hospitality, but still paying attention to the risk of corruption and the applicable laws and regulations, where:
   • Such matter rarely happens (once or twice per year per business partner);
   • Value is not significant, as stipulated in the Decision Letter of the Board of Directors;
   • It is given solely due to the company’s hospitality and normal business practices;
   • Accepting it is not a violation of law or regulation;
   • There is no reasonable possibility or conclusion that the decision to enter into a contract with another party is affected by the acceptance of such gift or hospitality.

The Company’s Anti-Corruption Policy is stated in the Indocement Code of Conduct for all Company Personnel in carrying out their duties to comply with the following matters:

1. Not taking action to enrich themselves or groups that can harm the Company;
2. Not abusing the authority, opportunities, or facilities of the Company for personal or group gain;
3. Not committing any forms of fraud or conspiracy;
4. Not offering, promising, authorizing, or giving permission, requesting or accepting for personal or group benefits in any forms;
5. Not blackmailing in any forms.

The Company will continue to run its business and/or work in a legal, ethical, honest, and professional manner and in line with the Company’s code of conduct and vision and mission. This practice will be applied to every activity carried out by the Company. Sanctions for Company personnel who are identified as having committed acts of corruption are punishments or strict consequences for violations committed either individually or in groups by:

1. Discharging the employee dishonorably;
2. Prosecuting the person responsible according to the applicable law in Indonesia.

One manifestation of the Company’s commitment to avoiding all forms of corrupt practices is by requiring
echelon 1 to 3 employees to attend e-c@mpus training, which consists of three modules, namely competition law, compliance basic, and preventing corruption. Through these training programs, the Anti-Corruption spirit can be embedded in the Company’s employees.