Code Of Ethics

Code of Conduct

The Company is committed to complying with the GCG not only as on organisation but also for all employees on an individual basis by providing them with a Code of Conduct that guides their daily activities and decision-making.

The Content of Company’s Code of Conduct

The Company’s Code of Conduct consists of 9 (nine) parts, namely:

• Occupational Safety
• The Use of Company’s Facility, Equipment and Resources
• Confidentiality
• Gifts
• Conflict of Interest
• Whistle Blowing
• Discipline
• Dismissal
• Policy Administration

The Company values diversity in the work environment based on mutual trust and respect for every employee at all levels. Based on this, the Company expects the employees to be responsible for its performance and reputation. Thus, the code of conduct applies to all organisational levels to create a safe and healthy work environment.

Code of Conduct Internalisation and Socialisation

The Company conducts socialisation and internalisation of the guidelines and implementation manual through regular announcements.

Sanction and Violation of Code of Conduct

The Company imposes sanctions for the violation of the code of conduct, with the aim of making the prevailing code of conduct understood and followed. Any concern on potential violation of the code of conduct shall be reported immediately for a follow-up action. The sanction imposed is based on the type of violation and the related breach.

Number of Code of Conduct Violation

During 2019 there were no cases of violations of the Code of Conduct committed by the Company's employees.

Whistleblowing Policy

As of the end of 2019, the Company’s whistleblowing policy follows the policy in its parent company, JAPFA Ltd., namely JAPFALERT. The Company believes that the policy has met all required functions and, therefore, there is no need to develop a separate system.

The Company encourages all employees, stakeholders and the public to report violations, suspected violations of the code of ethics or other illegal behaviors. Several reporting channels are available for use. Reports cannot be made anonymously. The Company guarantees that all reports submitted will be handled with the utmost confidentiality.

Reporting Scope

The types of violations that can be reported through JAPFALERT are as follow:

• Procedure and internal control principles (theft, misuse of asset or company’s facility, unfair competition, etc.).
• Accounting and financial principles (forgery of financial statement or account, fake invoice, fraud, etc.).
• Anti-Corruption regulation (bribery, kickback, unclear payment/benefit, etc.).

Submission of Violation Report

The submission of violation report can be made through:

• Normal communication channels, such as the Management, Human Resource Department, Legal Department.
• Or:  JAPFALERT website

The reporting person shall include his or her identity. To ease the identification process, the report shall include:

• Name of person who is allegedly involved in the violation or potential violation;
• Chronology of the incident;
• Time and location of the incident.

Protection for Whistleblower

The Company is committed to providing the whistleblower with protection to give the person a sense of security and encourage him or her to report any violations. The protection to the whistleblower takes the form of:

• Protection over the whistleblower's identity, including any information that can be used to contact the whistleblower.
• Protection from any retaliation from the violator or any other parties with a conflict of interest.
• Protection from any pressure, over the whistleblower’s right as employee, from any lawsuit, and loss of assets from physical action.

Handling and Managing Complaints

The Company guarantees that all violation reports will be followed up properly. Any violation reports will be immediately followed up by related parties. The whistleblowing policy at the Company is managed by the Internal Audit Unit. This unit will periodically check every report that comes in for follow up. If the employee commits violation, the former will be dealt according to Company policy.

Result of Complaints Handling

The Company considers the whistleblowing policy one of the most effective ways to disclose any fraud. Upon receiving any complaint, JAPFALERT Committee will investigate it to decide whether the violation and fraud have occured.

Total Complaints in 2019

In 2019, there was no complaint that was received and followedup by the Company.

Socialisation and Effort to Increase Whistleblowing Policy Quality

The Company continues to improve the quality of whistleblowing policy implementation, one of which is by disseminating information about the existence of Whistleblowing Policy by posting information about the policy on the bulletin boards in each unit.