PT. Trust Finance Indonesia, Tbk is committed to implementing the Anti-Money Laundering and Prevention of Terrorism Funding programs in accordance with applicable laws and regulations, namely:

• Law of the Republic of Indonesia Number 8 of 2010 concerning Prevention and Eradication of Money Laundering Crimes.
• Law of the Republic of Indonesia Number 9 of 2013 concerning Prevention and Eradication of Terrorism Financing Crimes.
• POJK Number 12/POJK.01/2017 concerning Implementation of Anti-Money Laundering and Prevention of Terrorism Financing Programs in the Financial Services Sector.
• SEOJK Number 37/SEOJK.05/2017 concerning Guidelines for Implementing Anti-Money Laundering and Prevention of Funding Programs in the Non-Bank Financial Industry Sector.

The implementation of the Anti-Money Laundering and Combating the Financing of Terrorism program for Trust Finance Indonesia, Tbk is determined and actively supervised by the Board of Directors and Board of Commissioners which include:

1. Preparation of APU & PPT Standard Operational Procedure Policy which includes provisions:
1. Performing Customer Due Diligence (CDD) in order to identify customers including identification of beneficial owners and conducting Enhance Due Diligence (EDD) for debtors and beneficial owners who have high risk.
2. Appoint senior officials to approve or reject financing for high-risk debtors.
3. Monitoring and analysis to detect Suspicious Financial Transactions (TKM), Cash Financial Transactions (TKT) and report them to the Financial Transaction Reports and Analysis Center (PPATK).
4. Rejection of transactions and closing of business relationships.
5. Monitoring customer profiles and transactions as well as updating data.
6. Screening procedures for recruiting employees and monitoring employee profiles.
7. Administration of documents related to customer data and customer documents related to financial transactions with a period of 5 (five) years from the end of the contract.
2. Establishment of an Anti-Money Laundering and Counter-Terrorism Funding Unit at the head office which is under the Enterprise Risk Director. The unit handling the AML & CFT program has received training related to the Implementation of Anti-Money Laundering and Prevention of Terrorism Financing Programs.
3. Internal control:
   Implementation of the APU & PPT Program of PT Trust Finance Indonesia, Tbk based on risk (risk-based approach). The Board of Directors provides direction to the Internal Audit function to carry out compliance checks on the implementation of the APU & PPT Program.
4. Management information System:
   PT Trust Finance Indonesia, Tbk already has an information system that can identify, analyze, monitor, and provide reports effectively regarding the characteristics of transactions made by customers. The company has integrated the names registered in the List of Suspected Terrorists and Terrorist Organizations (DTTOT) issued by the authorities in the company's system, thus enabling the company to monitor the similarity/similarity of the identities of suspected terrorists to prospective customers. The system owned by the company has enabled the company to input or provide information regarding the job profile of prospective customers/customers who are included in the category of Politically Exposed Person (PEP).
5. Human Resources and Training
   To prevent the use of PT Trust Finance Indonesia, Tbk as a medium for money laundering involving internal parties, the company has carried out:
   1. Screening procedures for hiring new employees.
   2. Organizing training related to the APU & PPT Program for employees of PT Trust Finance Indonesia, Tbk both online (e-learning) and face to face

The implementation of the APU & PPT Program is carried out in all branch offices and head offices of PT Trust Finance Indonesia, Tbk and is reported by work units related to APU & PPT periodically to management.

Implementation of the APU & PPT Program
PT Trust Finance Indonesia, Tbk