Whistle Blowing System

WHISTLEBLOWING SYSTEM

Whistleblowing System (WBS) is a mechanism developed by the Company in order to create a safe reporting system that prioritizes the principles of confidentiality and protection for whistleblowers. WBS provides a means for anyone to report any allegations of illegal, immoral behavior or other practices within the Company that are illegal and deviate from the Company’s Code of Conduct or applicable law.

Any person who feels restless or sees something that is not in accordance with the Code of Conduct/applicable law/a violation of the rules can:

• Submit their complaint through the compliance channel (complaint contact),
• Discuss findings of violations with their superiors at work,
• Discuss with the compliance officer.

Information that can be reported through the Whistleblowing System includes:

1. Acts of fraud, fraud, corruption, collusion/bribery, extortion,
2. Acts that violate the law, the Company’s Code of Conduct, Company Regulations and applicable Standard Operating Procedures (SOP),
3. Ethical violations, and
4. Other violation of behavior that has the potential to cause harm to the Company.

To support the follow-up steps, the whistle-blower should explain about:

• What was the violation (what)?
• Who are the parties involved (who)?
• When did the violation (when) occur?
• Where did the violation occur (where)?
• And how chronologically these violations can occur (how)?

WHISTLEBLOWING SUBMISSION

The whistleblower (internal or external) is required to submit a clear and accountable report to be proven, considering the following matters:

• To mention the reported violation briefly and clearly,
• To mention the name and work unit of the reported and involved persons,
• To state the clear timing and place of the violation,
• To state the clear and complete chronology of the events, if necessary, to attach evidence of violation to accelerate investigation.

Handling Mechanism of Whistleblowing System

WHISTLEBLOWING HANDLING AND PARTIES MANAGING COMPLAINTS

The person in charge of WBS is the Internal Audit Unit. Each incoming complaint will be managed by Internal Audit Unit for further action. In following up on violation reports, Internal Audit Unit can also coordinate with other relevant units. Regarding whistleblower protection, the Company guarantees the confidentiality of information and identities and provides protection for the whistleblower.

WHISTLEBLOWER PROTECTION

The Internal Audit Unit, as the managing party of WBS, guarantees whistleblowers. The whistleblower is allowed not to provide his/her identity, but if he/she provides his/her identity, this compliance channel will be able to report the results to the complainant or request additional information if needed.

The Company guarantees the confidentiality of information and identity as well as provides legal protection to the whistleblower for reports that have been properly verified.

WHISTLEBLOWING RECEIVED AND RESOLVED IN 2023

Throughout 2023, there were 4 reports filed through the Whistleblowing System (WBS) that have been followed up on and resolved. Individuals found in violation were subjected to sanctions in accordance with the Company's regulations.