Anti-Corruption Policy of PT. TRUST FINANCE INDONESIA, TBK

PT. Trust Finance Indonesia, Tbk (TFI) requires all members of the Board of Commissioners, Directors and employees to uphold fair business competition, values of sportsmanship and professionalism, and GCG principles, namely:⁣

1. Transparency
⁣One of the GCG principles that prioritizes aspects of information disclosure both in terms of the decision-making process as well as disclosure of material information that is relevant, accurate and timely to ensure the fulfillment of the rights of all Trust Finance Indonesia stakeholders. In practice, Trust Finance Indonesia already has a policy in terms of clarifying information whether open or closed, which is then used as a guide by all members of Trust Finance Indonesia to disclose/transparent information.⁣

2. Accountability
One of the GCG principles that emphasizes the clarity of functions, structures, systems and responsibilities of each organ of Trust Finance Indonesia so that all business and operational activities continue to run effectively and efficiently. Trust Finance Indonesia realizes that the principle of accountability requires all leaders to be accountable for their performance in a transparent and fair manner. Therefore, management has detailed roles and responsibilities of each organ of Trust Finance Indonesia and employees in a clear manner in accordance with the vision, mission, goals and strategies of Trust Finance Indonesia.

3. Responsibility
One of the GCG principles regulates that Trust Finance Indonesia always complies with applicable laws and regulations in carrying out every business activity and daily operations in order to create a healthy and conducive business climate. Trust Finance Indonesia is always committed to building conformity and alignment with applicable laws and regulations as well as sound corporate principles. ⁣ ⁣

4. Independence
One of the GCG principles prioritizes the implementation of the duties, obligations and authorities of each organ of Indonesian Trust Finance independently or without intervention from other parties. The principle of independence is needed, especially in terms of making decisions or determining management policies so that decisions are always made that are objective and free from conflicts of interest or pressure from any party. ⁣ ⁣

5. Fairness
One of the GCG principles is realized by not taking discriminatory actions to ensure the fulfillment of the rights of all shareholders and other stakeholders in accordance with applicable laws and regulations.⁣

The company is committed to creating and maintaining a healthy business climate, avoiding actions, behaviors or actions that may cause conflicts of interest, corruption, collusion and nepotism, and always prioritizing the interests of the company above personal, family, group or group interests.

In carrying out its business activities based on this commitment, TFI complies with Law Number 20 of 2001 concerning Amendments to Law No. 31 of 1999 concerning the Eradication of Corruption Crimes.

TFI regularly reports problems with customers to the Financial Transaction Reports and Analysis Center (PPATK).

The company's anti-corruption policy also includes, among other things, the implementation of transparency in the goods and services procurement system, as well as the giving and receiving of gifts by and for the company.

Giving and Receiving Gifts
Giving gifts is defined as all kinds of gifts by TFI or parties representing the company to certain parties, with the intention of influencing these parties so that they can benefit the company beyond the limits of fairness.

Acceptance of gifts is defined as all forms of acceptance by TFI or parties representing the company from interested parties, with the intention of influencing decisions by the ranks of the company in favor of the party giving the gift. There are company regulations regarding giving gifts, bribes and the like, giving to other parties as a sign of gratitude, gifts for religious holidays, souvenirs, and mementos in the form of goods or services.

In terms of receiving gifts, employees who receive gifts, regardless of value and in whatever form, must report to their direct supervisor. Receiving gifts from any party in the context of company promotions, tokens of thanks, gifts for religious holidays, souvenirs and mementos, can be accepted as an appropriate thing in daily life, provided that:

  1. Include the giving company's logo/name, which is part of the promotional activities of the giving company; And
  2. The gift is not made continuously by the same giver to the company, only three times a year maximum. Each individual who is part of TFI does not conduct discussions or provide internal company information that could create a conflict of interest or a negative image for the company.