CODE OF CONDUCT
APPROVAL
Responsibilities Name Job Signature
Prepared by
Approved by
No. Revision : 00 Page’s 1 of 6
A Code of Conduct is a behavioral guide for the Corporation Staffs in carrying out their day-to-day
duties and official services and in establishing business relationship with customers, partners and
fellow workers.
The Code of Conduct is a behavioral guide to deal with Conflict of Interest, Confidentiality, Misuse of
Power, Insiders’ Behavior, Integrity and Accuracy of Corporation Data.
1. Conflict of Interest
A Conflict of Interest is a condition in which a Corporation Staff in carrying out his/her duties and
obligations has an interest outside the company’s interest, be it involves their personal interest,
family’s or other parties’ interest so the relevant Corporation Staff may miss out on the objectivity
in making decision and policy according to the power the Corporation has vested in him/her.
Therefore:
a. All Corporation Staffs shall be obliged to refrain from engaging in activity that may lead to a
conflict of interest. If a matter is unavoidable, then the relevant Corporation Staff shall be
obliged to report the matter to his/her immediate boss.
b. All Corporation Staffs shall be prohibited from approving and or asking approval for a
business investment, for:
1. Him/herself
2. His/her family
3. A company at which he/she or his/her family has an interest.
c. All Corporation Staffs shall be prohibited from working for another company, be they as
board of directors, employees, consultant or members of the board of commissioners,
except the relevant staff is assigned or at the written approval of the CORPORATION
Corporation. Specifically for member of the Board of Commissioners and Board of Directors,
the appointment to a position shall comply with the provision of regulating body on Good
Corporate Governance.
d. All Corporation Staffs shall be prohibited from becoming business partner, directly or
indirectly be they deal with goods or service for the CORPORATION Corporation.
e. All Corporation Staffs shall be prohibited from taking the Corporation goods for their
personal interest, family’s or outsider’s.
No. Revision : 00 Page’s 2 of 6
f. All Corporation Staffs shall only be allowed to make a transaction of investation and other
goods for their own interest as long as there is no conflict of interest, violation of insider
trading regulation and such other regulation.
2. Confidentiality
a. All Corporation Staffs shall be obliged to understand and maintain the confidentiality of any
information, be it information on customer or such other information in accordance with
prevailing provision.
b. All Corporation Staffs shall use any information they received only for Corporation activities,
and not for their personal benefit, family’s or activities outside the CORPORATION
Corporation.
c. In releasing information, each Corporation Staff shall act in accordance with the prevailing
provision.
d. To avoid any misuse, dissemination of customers’ information within the Corporation shall
be carried out carefully and only to those authorized.
e. All Corporation Staffs shall be prohibited from disseminating information to outside party
with respect to:
1. Corporation Activities with the Government of the Republic of Indonesia.
2. Corporation internal policy and working procedure (SOP).
3. Information System Management, Data and Report.
4. Data of employees, be they active or non-active.
5. Corporation business activity, including activity with customer and business partner.
Except at the approval of authorized Corporation official or instruction under prevailing laws
and regulation.
f. The obligation to keep special matters that must be treated confidential, shall continue to
apply to former Corporation employees.
3. Misuse of Position and Gratification
No. Revision : 00 Page’s 3 of 6
a. All Corporation Staffs shall be prohibited from misusing their power and taking advantage
either directly or indirectly, from knowledge they acquired from the Corporation business
activities for:
1. Personal benefit.
2. Family member’s benefit.
3. Other parties’ benefit.
b. All Corporation Staffs shall be prohibited from asking or receiving, permitting or approving
to receive gratification having to do with their position and are contradictory to their
obligation according to the prevailing laws and regulation.
This also includes asking or receiving, permitting or approving to receive a gift or reward
from a third party who got or try to get facility from the Corporation in the form of
investment facility, or other facility having to do with the Corporation operational activity.
Types of gratification and its reporting mechanism will be provided in a separate provision.
c. All Corporation Staffs shall be prohibited from asking or receiving, permitting or approving
to receive a gift or reward from a third party who got or try to get job having to do with
goods or service of the CORPORATION Corporation.
d. In the event of a customer, partner and other parties give a gift in the form of goods or such
other form at certain moments such as Hari Raya, certain celebration, goodwill, etc, if:
1. The effect of the receipt of the gift is believed to result in a negative impact and may
affect the Corporation decision, and
2. The gift’s price is unreasonable,
then the Corporation Staff who received the gift shall immediately return the gift along with
some decent explanation that Corporation Staff is not permitted to receive any gift.
e. In the event that the returning of the gift as referred to in the above item d is, due to a
certain reason, difficult, the Corporation Staff who got the gift must immediately report the
same to his/her boss for further action in accordance with prevailing laws and regulation.
f. In case of customer, business partner and other parties who give a promotional goods, then
as long as the effect of the receipt of the promotional goods is believed not to result in a
No. Revision : 00 Page’s 4 of 6
negative impact nor does it affect the decision of the CORPORATION Corporation, it is
possible for the Corporation Staff to have the promotional goods.
g. With respect to the procurement of goods and service from a third party for the purpose of
the Corporation service, the Corporation Staff shall attempt to find the best price at
maximum discount. The discount received must be recorded for the benefit of the
CORPORATION Corporation.
h. Corporation Staff shall be prohibited from using his/her position to borrow from customer
or got indebted to customer.
i. All Corporation Staffs shall be prohibited from taking the opportunity to use the Corporation
facility for their own benefit outside the facility the Corporation has provided for them.
4. Insiders’ Behavior
a. A Corporation Staff who has confidential information shall not be allowed to use the
information for his/her own benefit, family’s or other third parties’ by:
1. Influencing customer or individual or institution in making transaction with the
CORPORATION Corporation.
2. Disseminating the information to customer or individual or institution.
b. All Corporation Staffs shall be prohibited from using internal information to do transaction
of investment, except the information has been known the CORPORATION corporation.
c. All Corporation Staffs shall be prohibited from misusing their position and taking advantage
either directly or indirectly for their benefit, family member’s or other parties’ and/or
otherwise by influencing the process of a decision related to themselves.
d. Decision making for selling or purchasing assets and other service for the Corporation shall
be made by prioritizing the Corporation interest without any influence of any insiders.
5. Integrity and Accuracy of Corporation Data
a. All Corporation Staffs shall present accurate and accountable data.
b. All Corporation Staffs shall not be allowed to record and/or change and/or write off records,
with a view to make a transaction obscure.
c. All Corporation Staffs shall only be allowed to make a change or removal of data under
authority of authorized official, in accordance with the Corporation established procedure.
d. All Corporation Staffs shall not be allowed to manipulate any document.
No. Revision : 00 Page’s 5 of 6
6. Corporation System Integrity
a. All Corporation Staffs must, at all times, have a self-introspection and prevent the
Corporation from being implicated in a criminal act in the area of finance and investment
business.
b. All Corporation Staffs shall be obliged to have suspicion of an improper transaction and be
obliged to take preventive action in detecting any suspicious accounts that have been used
for such activities as money laundering, terrorism financing, corruption and other acts of
crime.
No. Revision : 00 Page’s 6 of 6