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The Company has a Code of Ethics that becomes a standard of conduct and serves as a guideline for all people of the Company in carrying out business activities, in order to be in line with the principles of GCG. The Code of Ethics applies to members of the Board of Commissioners and Board of Directors of the Company, without exception.

The formulation and implementation of this Code of Conduct has been in line with the Good Corporate Governance practices. Through this Code of Conduct, the Company wishes to deliver greater benefits to shareholders and all stakeholders alike, and thus ensure its long-term business sustainability.

Key Points of the Code of Conduct

The Code of Conduct stipulated in Articles 8–15 of the
Company Regulations governs, among others:
1. Employee Rights
2. Employee Obligations
3. Work Procedures
4. Confidentiality
5. Use of Company Assets
6. Prohibition from Receiving Gratification
7. Work Outside of the Company

Code of Conduct Dissemination
The Code of Conduct is disseminated automatically at the point of recruitment, upon the signing of the work contract by an employee.

Code of Conduct Implementation
The Company’s Code of Conduct, as described above, is binding on all the employees of the Company, including on all members of the BOC and the BOD.

Insider Trading

The Company enforces strict regulations against insidertrading on all employees. As such, non-public information that may affect the Company’s share price shall be considered confidential until the announcement is made by Company management through official platforms of the authorized regulators (Information Disclosure). Employees with sensitive information that may affect the Company’s share price and related rights shall not engage in direct or indirect transactions of those shares and other related rights. The Board of Commissioners, Board of Directors, and all employees are committed to upholding the Company’s Integrity Pact to the best of their abilities, along with the implementation of strategic policies, to achieve sustainable growth.

*Source : PT NFC Indonesia Tbk. Annual Report 2021

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