STRUCTURE AND MECHANISM OF CORPORATE GOVERNANCE

  1. All Heads of Work Units up to 2 (two) levels below are responsible for and set an example for their subordinates for the implementation of this Code of Conduct.

TYPES OF SANCTIONS FOR VIOLATION OF CODE OF CONDUCT

Every Pelindo People who is proven to have violated the Code of Conduct will be given sanctions in accordance with the applicable rules and regulations in the Company, through an disciplinary mechanism. Sanctions for employees who commit violations are determined by the Board of Directors after receiving a recommendation from the disciplinary team.

The Board of Commissioners and/or the Board of Directors will decide on the provision of coaching actions, disciplinary sanctions and/or other actions as well as prevention that must be carried out by direct superiors within the respective work units/disciplinary mechanisms. Sanctions for members of Board of Directors and Board of Commissioners who commit violations are decided by the Shareholders.

If a business partner or other Stakeholders commit a violation, the provisions as contained in the contract and other provisions governing this will be imposed. If it is related to a criminal act, it can be forwarded to the authorities.

Sanctions for violating the Company’s code of conduct after the merger refer to the types of punishment according to the respective legal levels of former Pelindo I, II, III, and IV. The level of punishment for sanctions for violating the code of conduct consists of light disciplinary penalties, moderate disciplinary penalties and severe disciplinary penalties.

NUMBER OF VIOLATIONS AND SANCTIONS IMPOSED

After the merger, there were 3 (three) violations of the code of conduct and have been given sanctions of heavy violations.

CORPORATE CULTURE

Descriptions related to Corporate Culture are presented in the Company Profile Chapter in this Annual Report.