The Company has developed and implemented the Whistleblowing System through the Policies and Procedures concerning the Implementation of Whistleblowing Policy. The Whistleblowing System is intended to build loyalty to the Company and create conducive working environment. This is done by whistleblowing towards matters that may cause financial or non-financial losses to the Company, including those with the potential to damage the Company’s reputation and image.

WBS Socialization

The Regulation and Implementation on Whistleblowing System is disseminated and evaluated in a sustainable manner to all employees of the Company. The Whistleblowing System advancement/refinement is periodically conducted for sustainability based on the Company’s business development.

The Company has taken the following steps:

1. The Company constantly conducts socialization, implementation and evaluation on Whistleblowing System.
2. The socialization activity is carried out in a sustainable manner to the Company’s internal or external parties. The socialization for the internal party focuses on instilling an understanding, awareness and requirements to implement consistent GCG. The socialization to the external party is intended to instill an understanding of the Company’s applicable frameworks in accordance with GCG principles.
3. Whistleblowing System is consistently implemented with full commitment from all elements of the Company and supported by the other stakeholders.
4. The Company evaluates the Whistleblowing System. The evaluation is intended to acknowledge and measures the appropriateness of Whistleblowing System according the Company’s needs as well as the effectiveness of implementation programs. Based on the results, improvement and development of Whistleblowing System and its implementation programs are conducted in a sustainable manner.

Types of Violation that Can Be Reported

Actions that can be reported include but are not limited to:

1. Stealing, embezzling, abusing, and/or damaging the Company’s assets.
2. Corruption, collusion, and nepotism.
3. Bribery and/or taking/giving gifts (gratification).
4. Conflict of interest.
5. Violations of the Company’s regulations, code of
   conduct, and applicable laws and regulations.
6. Other actions that adversely impact the Company,
   directly or indirectly, on monetary or reputation.

The whistleblower provides an early indication with accountability, covering:

1. Problem or action being complained
2. Parties involved
3. Location of incident
4. Time of incident
5. Chronology of incident
6. Other details

Submission of Violation Report

Submission of the Company WBS Violation Report is set forth in Whistleblower Policies and Procedures, as follows:

1. Anyone may report alleged irregularities or breaches of law that may harm the Company, its customers, shareholders, employees, investors, or the public at large.
2. Reporting may be submitted in writing, by phone, or in person. However, it is recommended that it be made in writing. This way, the issues conveyed can be well understood
3. Every individual is encouraged to reveal his or her identity, although not an obligation.
4. All reports should be sent directly to all or one of the members of the Whistleblower Committee.
5. In the event that the report is submitted via email, it is recommended to use the title ‘Whistleblower Company’ to simplify identification.
6. Although a Whistleblower is not expected to prove the validity of the allegations, the whistleblower must provide a strong case supporting his or her concern of a violation/ alleged offense.

WBS Management

The management of the Company’s WBS is carried out by the Internal Audit Unit, in collaboration with the HR and/or Legal team. Upon incoming complaints, the Internal Auditor will look for evidence either through the whistleblowers or through related parties when a regular audit or investigative audit is conducted. Audit results and audit investigations are submitted to the President Director and the Audit Committee. If a violation is proven, then the HR and/or Legal team will handle it further in accordance with applicable regulations.

Reporting Media

Complaints for alleged violations of the code of conduct can be reported via email at wbs.kapitalindonesia@ mncgroup.com.

Whistleblower Protection

To maintain stability and conducive environment, Whistleblowing System shall provide whistleblower with the protection. The protection to the whistleblowers covers the following:

1. Independent, free and confidential reporting facilities;
2. Whistleblowers’ identity confidentiality guarantee;
3. Protection against retaliation from the Offenders or the Company as well as the other protections within the ability of the Company;
4. Protection guarantee provided by the Company’s Whistleblowing Officer to the Whistleblowers.
5. The protection on the retaliation from the Offenders as well as other means of protections within the Company’s ability.