The Company has a Code of Conduct that regulates business ethics and work ethics for Allstars. The Code of Conduct serves as a guideline for Allstars in carrying out their activities in accordance with core values, fostering a strong corporate culture to accelerate the achievement of the Company’s vision and mission.

The Company’s Code of Conduct was established based on the Board of Directors’ Decree No. AAID/CEO-CORSEC/12-2018/023 dated December 7, 2018. The establishment of this Code of Conduct reflects the Company’s commitment to implementing corporate governance comprehensively to achieve long-term success.

Principles of the Code of Conduct

The formulation of the Company’s Code of Conduct is based on the Company’s core values and spirit, ensuring a positive influence in creating a conducive environment for Allstars and supporting the achievement of the Company’s vision and mission. The Company’s Code of Conduct consists of 3 (three) main sections:

1. Business Ethics
   Standards of conduct applied by the Company in interactions with stakeholders, which include:
   1. Compliance with Laws and Regulations;
   2. Concern for Employment, Occupational Health, and Safety (OHS);
   3. Equal Opportunity for Employees in Employment, Promotion, and Termination;
   4. Ethical Standards in Relations with Stakeholders;
   5. Ethical Standards for Management and Employees.
2. Work Ethics
   Application of values upheld by the Allstars in daily work interactions, including:
   1. Commitment of Allstars;
   2. Ethics in Maintaining the Company’s Reputation;
   3. Ethics in Maintaining Good Relations Among Employees;
   4. Ethics in Safeguarding Confidential Company Data and Information;
   5. Ethics in Maintaining and Utilizing Company Facilities;
   6. Ethics in Ensuring Workplace Safety, Security, and Environmental Health;
   7. Ethics in Recording Data and Reports;
   8. Ethics in Avoiding Conflicts of Interest.
3. Implementation and Enforcement of the Code of Conduct Commitment to implementation and boundaries that must not be violated in daily activities, which include:
   1. Socialization;
   2. Commitment and Responsibility;
   3. Reporting of Violations;
   4. Handling of Violations;
   5. Sanctions.

Code of Conduct Socialization and Enforcement

To ensure that the Code of Conduct is understood and adopted by Allstars in their daily activities, the Company conducts an internalization program consistently across all offices, including the Head Office and branch offices. The Company’s GCG Team is responsible for effectively and comprehensively disseminating the Code of Conduct to build commitment among all relevant stakeholders. The GCG Team may also coordinate with the People & Culture Department and the Internal Audit Division in carrying out this dissemination.

The dissemination of the Code of Conduct is carried out through employee orientation programs organized by the Company and periodic refreshers for Allstars. Additionally, the dissemination is also extended to the Company’s stakeholders to provide them with an understanding of the Company’s business and work ethics.

Code of Conduct Enforcement for All Organizational Levels

The Company requires every Allstars to commit to aligning themselves with the Company’s value system and work culture. Therefore, every Allstars are obliged to understand, internalize, and implement the Code of Conduct as a moral foundation, guiding their attitudes and ethical behavior. The Board of Directors and all Department Heads are responsible for ensuring that employees within their respective work units understand and implement the Code of Conduct to ensure its successful application.

Sanctions for Violations of the Code of Conduct

To ensure compliance with the Code of Conduct the Company imposes firm and consistent sanctions on the employees found to have committed violations, in accordance with applicable regulations. Sanctions for violations committed by the Board of Commissioners and/or Board of Directors are determined based on the Company’s Articles of Association and General Meeting of Shareholders (GMS) resolutions. Meanwhile, sanctions for employees are imposed in accordance with the agreements in the Company’s Regulations or applicable employment rules.

Reports of alleged violations by the employees must be accompanied by supporting evidence. Any reported violations will be followed up with further assessment or investigation to establish proof, determine the severity of the violation, and serve as a basis for disciplinary action or sanctions.

Throughout 2024, no violations of the Code of Conduct were committed by Allstars.

Code of Conduct