Company’s Code of Ethics

PT Sinar Mas Multi Finance (“the Company”) declares that all decisions and actions taken on behalf of the Company have followed the highest standards of personal and professional integrity in all aspects of action and in accordance with the applicable provisions and laws, Code of Ethics and Code of Conduct, other policies and procedures used or implemented by the Company.

This Code of Ethics is prepared and made in the Company’s Regulations as a standard or norm of ethical or appropriate business conduct and personal conduct that applies to: employees (permanent employees, contracts, outsourcing), directors, Board of Commissioners, committees of the Company and parties who cooperate with the Company or parties representing the Company either directly or indirectly to comply with the applicable code of ethics.

It is very fundamental for the Company’s sustainable success to maintain and maintain on an ongoing basis personal and professional integrity as well as ethics including trust, honesty, morality, objectivity, fairness and respect for others both in the workplace and outside the workplace.

Code of Conduct

The Company’s Code of Conduct summarizes the principles, policies and regulations governing the Company’s activities that must be obeyed by all employees and other parties who work with the Company or who represent the Company directly or indirectly.

The Company expects all levels of the Company to act in accordance with high standards of personal and professional integrity in all its activities and to follow all the Company’s policies and applicable laws and regulations. All are obliged to reject all forms of compromise both for personal interests and for the interests of the Company that can damage the integrity. By accepting a position in the Company, each person is aware that they must be responsible for compliance with the law, Code of Ethics and Code of Conduct as well as the Company’s internal policies.

This Code of Ethics and Code of Conduct applies to all levels of the Company, including the Board of Commissioners, Audit Committee, Directors, Employees, Non-Permanent Workers/Outsourcing, Independent Contractors, Advisors, Consultants and other parties who cooperate with the Company, or who represent the Company directly or indirectly. All are responsible for understanding this policy and/or its supplemental policies.

QUESTIONS, CONFLICT AND EXEMPTION/LENIENCY

If there are any questions about this policy and/or its additional policies, if any, it should be discussed with their superiors, the Head of the Compliance Work Unit, Legal, Human Resources, Compliance Director or other Directors.
If there is a conflict between this Code of Ethics and Code of Conduct with applicable laws or other policies of the Company, or if you have any questions regarding the interpretation of the applicable law, you should immediately contact the official in the Legal Department or the Compliance Work Unit. Broadly speaking, if there is a conflict between internal policies, then stricter policies will apply.
Exemptions or waivers of the applicable Code of Conduct and Code of Conduct may only be granted by the Compliance Director or other Directors. Exemptions or relaxations from the Code of Ethics and Code of Conduct for the Board of Directors can only be granted by the Board of Commissioners. The application for exemption or leniency must be submitted by the Board of Directors concerned immediately to the Board of Commissioners in writing with a copy to the Audit Committee stating the Code of Ethics and Code of Conduct for which the exemption or leniency is requested.
Exemption or relaxation of applicable legal provisions cannot be granted.

This Code of Conduct does not constitute or should not be construed as an employment contract for a specific period of time or an employment guarantee.

RESPONSIBLE

a. Obligations in the Company’s business/business

Carry out business in an open and honest manner.
Maintaining the Company’s reputation in front of anyone, including not limited to the media and giving the best effort to meet the interests of the Customer.
Maintain relationships with customers so that they can create a good and sustainable investment climate.
Building trust from Key Stakeholders.
Not to act to persuade and influence the Customer to transfer his funds from the Company and/or its Affiliates to the Company and/or its Affiliates with the same or different types of products.
Not to influence, persuade or direct the Customer to change the specifications of the Company’s financial products without first explaining to the Customer about the losses that may be suffered by the Customer due to the use of such funds.
Do not receive funds directly from the Customer and immediately inform the Customer to deposit through the Company’s account.
Not utilizing asset ownership (e.g., land, buildings located adjacent to the Company’s business operations) to influence future decision-making.
Not to use business ownership (e.g., business entities or shops owned by private employees) to transact with the Company without going through the procedures set by the Company.
If the employee has a business entity or personal entrepreneur, the employee is required to report to HRD and update the data by filling out the form provided by HRD.
Employees are not allowed to carry out activities in connection with the employee’s personal enterprise during working hours.

b. Obligations in the Work Environment

1. Discipline

Comply with the Company’s Regulations and, or the Collective Labor Agreement along with all SOPs and policies and policies and regulations applicable in the Unitary State of the Republic of Indonesia (NKRI).
Carry out the main duties in accordance with the work targets that have been set in the Work Agreement, Work Agreement, Job Description and other duties set by the Company.
Devoting all one’s abilities to the Company, not working and binding oneself to third parties, both individuals and business entities or other institutions to obtain compensation, unless they have received written permission from the Company.
Use and maintain office facilities properly, including electronic devices such as laptops, software. systems and networks.
Wearing work clothes that have been determined by the Company with polite, clean and neat criteria while carrying out duties/work
Must carry out occupational health and safety policies at every opportunity and at all times. Using the Employee Identity Card/Employee Identity Card provided by the Company while in the work environment.
Creating a healthy and safe environment for all employees and vendors in the implementation of business activities in accordance with applicable norms and the Company’s values.

2. Behavior

Establish the Company’s values in carrying out work activities both inside and outside the work environment
Always base all actions on prioritizing the interests of the Company, in accordance with applicable rules and policies and not intentionally committing actions that violate the Company’s rules and policies.
Always underpinning all actions by prioritizing the interests of the Company, not prioritizing personal/ organizational/group profits.
Protect the Company’s assets/assets and not use the Company’s assets and assets (Physical and Intellectual) for personal interests.
Not doing Fraud and or that can be categorized as leading to an act of Fraud
Mutual respect and appreciation (tolerance) in the diversity of Ethnicities, Religions, Races and Inter- Groups within the Company.
Respect and respect each other among fellow employees and always be cooperative and willing to cooperate with other divisions.
Not to be a member of an organization prohibited by the Government, and not to carry out practical mass/religious/political organization activities that are not related to the interests of the Company within the Company
Uphold decency and avoid scandals among fellow workers as well as behave politely and maintain an atmosphere of brotherhood/familiarity in the work environment.
Avoid using physical violence, threatening, slandering or defamation and harassment in any form to fellow colleagues, which can interfere with the smooth running of work.
Avoid influencing or inviting other workers to do things that are contrary to the applicable Government Laws/Regulations.
Maintain themselves to be professional in work by avoiding direct or indirect family relationships with one of the Employees/Workers in the Company.
Declare to the Company that in a professional working relationship there is a direct or indirect family relationship with one of the Employees/ Workers in the Company. Declaration can be made by notifying HRD.
Declare to the Company if in a professional working relationship there is a direct or indirect family relationship with one of the Government agencies. Declaration can be made by notifying HRD.
When I am involved in the process, evaluation, creation, and implementation of public or operational services of the Company, I will disclose a “conflict of interest” related to such activities, my personal and family assets (in accordance with applicable provisions), and not participate in the decision-making, and for the resolution of the matter; I ask the boss who does not have a “conflict of interest” to be able to provide recommendations.
I am willing to provide information, both verbal and written, to the management of PT Sinar Mas Multifinance, if there is a complaint concerning myself or the organization under my responsibility.
Do not consume illegal drugs, drugs and the like or become a dealer.

c. Obligations in Eradicating Corruption/Embezzlement and Money Laundering Crimes

Supporting government and Company programs in eradicating Corruption/embezzlement and Money Laundering Crimes.
Supervise and implement Anti-Money Laundry by recognizing Customer/Know Your Customer (AML & KYC).
Will not commit criminal acts of money laundering, corruption/embezzlement and nepotism.
I am willing with my ability to provide assistance/ support to the discloser/witness who is concerned with the disclosure of bribery, KKN or the like under my authority or not under my authority
I am voluntarily willing to disclose matters that have been, are about to happen, in relation to the practice of bribery, KKN or the like under my authority or not under my authority. Any form of disclosure can be submitted through any of the contact persons.
With my ability and authority, I must carry out sanctions and incentives/disincentives for bribery disclosures/KKN or violators of the Integrity Pact under my authority in accordance with applicable regulations.

d. Obligations in Relation to Business Partners

Do not have a kinship or fraternal relationship either vertically or horizontally with any of the employees working for the Company in carrying out all forms of business transactions involving the Vendor.
Do not have shares in the Vendor who collaborates with the Company.
Committed to maintaining conflicts of Interest and will disclose conflicts of Interest that I know to the Company.
Committed to carrying out cooperation with Vendors in an open/transparent and honest manner, maintaining the Company’s reputation and building trust from stakeholders.

e. Obligations in Receiving or Giving Gifts and Entertainment

Will not give gifts in the form of money in any amount either directly or indirectly.
Will not request or receive a gift in the form of money and goods with any value that is invalid, either legally or by Company Regulations.
All forms of gifts that have been received on the basis of Business Ethics (Religious Day Gifts or Company Birthdays) must be reported and submitted to HRD for further recording and distribution to all employees.
Will not accept or provide personal entertainment that may be suspected of causing a risk of adverse influence on the Company and/or certain parties.

f. Obligations in Maintaining Company Secrets

Protect information belonging to the Company, Customer and/or Vendor that is confidential and does not disseminate to anyone who is not entitled to receive such information unless ordered by the applicable laws in the Republic of Indonesia and/or with the permission of the information owner.
Protect personnel records from other parties (including the Company’s own employees) and not disseminate it to anyone who is not entitled to receive such information unless ordered by the applicable laws in the Republic of Indonesia and/or with the permission of the information owner.
Protecting the confidential information mentioned above is valid from the signing of the Statement Letter/Integrity Pact until after quitting the Company continuously or after no longer having a relationship with the Company unless ordered by the applicable laws in the Republic of Indonesia and/or with the permission of the information owner.

g. Obligation to Report Violations (Whistle Blower)

Report to the Company for violations of the Code of Ethics known to Employees/Employees and Agents.
It is mandatory to recognize, raise and resolve ethical issues immediately.
Cooperate with the Company in conducting investigations, regarding the possibility of or against acts of violation of the Code of Ethics.

IMPLEMENTATION & COMMITMENT TO THE IMPLEMENTATION OF THE CODE OF ETHICS FOR THE BOARD OF COMMISSIONERS, DIRECTORS ∧ EMPLOYEES

In accordance with the Code of Ethics and Code of Conduct of PT Sinar Mas Multifinance, the Company implements a code of ethics that applies to all levels of the organization, namely the Board of Commissioners, Board of Directors, Senior Officers and all employees of the Company. All of the Company’s ranks agree to commit that :

All decisions made and actions taken must be in accordance with the Code of Ethics, Code of Conduct, Company’s policies and all applicable laws and regulations.
Act with integrity and refrain from abusing the knowledge and opportunities obtained from their position in the Company. All must carry out their obligations and responsibilities in the Company with personal, professional and respectable integrity standards.
Every decision or action and the result must be appropriate/appropriate for all parties in the transaction and reasonable in terms of integrity and professionalism.
In acting and making decisions, both in relationships and on behalf of the Company, must be honest and trustworthy. Not directly or indirectly involved in or assisting in all fraud of any kind committed inside or outside the Company.
Have a commitment to treat a party with respect and support a harmonious relationship between colleagues/colleagues and leaders in the Company’s family. Refrain from any action either directly or indirectly influencing the auditor and/or other parties to manipulate information, or make false or misleading reports.
Prevent situations where personal interests conflict or are suspected to clash, with the interests of the Company or its customers. If there is or is suspected of a conflict of interest, it must disclose and report to the Director of Human Resources or the Director of Compliance.
Take all appropriate measures to protect the confidentiality of information that is not in the public interest about the Company and its customers obtained or related to its activities. Prevent unauthorized disclosure of such information unless required by applicable law or regulation or due to legal/regulatory proceedings.
Make complete and accurate reports and documents that will be submitted or submitted by the Company to regulators or authorized authorities.
All ranks of the Company are an inseparable part of the community and therefore must continue to understand/relate to societal values and follow/ comply with the provisions of the applicable laws.

DISTRIBUTION OF CODE OF ETHICS

The Company disseminates the code of ethics to the public through the Company’s Annual Report which can be downloaded through the Company’s website. Within the Company, the dissemination of the code of ethics to the public is conveyed through an employee network regulated by the Company’s Human Resources Department.

ENFORCEMENT & SANCTIONS FOR CODE OF ETHICS

Sanctions for Violations of the Code of Ethics are in the form of providing warning sanctions up to the termination of the status of Employees and/or Vendors based on the policies of the management and/or in the form of legal proceedings by following the provisions of laws and regulations and Company Regulations and/or applicable Collective Labor Agreements.