According to Financial Services Authority Regulation No. 33/POJK.04/2014 dated December 8, 2014 (POJK 33/2014) regarding the Board of Directors and Board of Commissioners of Issuers or Public Companies, the Company establishes a Code of Conduct for all its members of the Board of Commissioners, Board of Directors, and all employees.

In order to ensure the Code of Conduct is adhered to and implemented, the Company requires all employees to instill corporate values consistent with global standards, increase accountability and transparency, and comply with all applicable laws and regulations.

Upon its implementation, the Company’s employees are required to avoid giving or receiving gifts from other parties, avoiding activities that may result in a conflict of interest with their position and work, as well as protecting important data and information about the Company.

The Code of Conduct must be enforced by all employees without exception. Supported by the principles of Good Corporate Governance (GCG) which have been described in detail in the Corporate Governance Policy section. This Code of Conduct provides equal rights for all stakeholders. The Code of Conduct also reflects the corporate cultural values ​​that serve as guidelines for the Board of Directors, Board of Commissioners, management, and all employees in carrying out all their daily duties and obligations. This also applies to interactions among employees, stakeholders, third parties, and local officials.



This Code of Conduct sets out the Company’s regulations of the Company that all its employees shall follow with the purpose to:

  1. Institutionalize corporate values based on global best practices
  2. Continually enhance accountability and transparency
  3. Act according to the prevailing laws and regulations

Corporate Policy

This code of conduct is applicable to all of the Company’s employees without exception. Any violation of this code of conduct may result in disciplinary actions towards the employee including dismissal from the Company according to provisions of the Company’s Regulations.

  1. Gifts and Other Favors

Every employee is not allowed because of his/her position and work to give, request or receive gifts and other gifts for personal interests, both in cash and non-cash, services and other personal interests, which are given directly or indirectly to and/or from buyers, suppliers, contractors, brokers or any other parties who have business relationships with the Company.

Every gift and other favor in any form whatsoever received directly or indirectly by any of the Company’s employees must be reported and turned over to the Company’s Human Resources Division. The Company’s Human Resources Division will determine the use of the gift.

2. Conflict of Interest

Each of the Company’s employees shall avoid situations where his/her personal interests have or may have a conflict of interest with his/her position and job at the Company, including:

  • Applicants who have family relatives with employees.
  • Employee who is granting contracts or work to companies owned by and/or having a conflict of interest with such employee and/or his/her family.
  • Employee who is having a financial interest in the Company’s customers, suppliers, contractors, brokers or any other parties that have business relationships with the Company.
  • Employee who is operating, controlling and or owning another business that may have a conflict with the Company’s interests.

3. Information Confidentiality

  • Each of the Company’s employees shall keep and secure any confidential information related to the job and responsibilities in the Company.
  • Each of the Company’s employees shall not own, disclose, or take out any copy or document related to data, documentation without company permission.
  • Each of the Company’s employees shall keep confidential information related to the Company’s activities.
  • Each of the Company’s employees shall keep confidential information given by the customers to the Company.


The Company’s Code of Conduct applies universally to all employees at all levels and levels of the organization. In enforcing the Code of Conduct, the Company disseminates the Code of Conduct through information facilities, as well as publication media which can reach all employees within the Company.


The Company takes disciplinary action against employees who are found to have violated the Code of Conduct, which may include dismissal from employment. This compliance shall be governed by the provisions of the Company Regulations as follows:

  1. Verbal Warning
  2. Written Warning Letter (I, II, and III)
  3. Compensation
  4. Termination (PHK)


Explanations about the Anti-Corruption policy and program in the Company are disclosed in the Company’s Code of Conduct.