code of Conduct

The Company has prepared a set of code of conduct that addresses the preferred work ethics and business ethics to be referred to for every action to be taken by any individual within the Company. The Code of Conduct is also binding toall members of the Board of Commissioners and the Board of Directors, without exception.

This Code of Conduct is implemented to ensure that all elements of the Company adhere to the corporate regulations as well as other external regulations that are pertinent to its business. The formulation and implementation of this Code of Conduct has been in line with the good corporate governance practices. With 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 insider-trading 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 The Company’s 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 BOC, BOD, and all employees are committed toward 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 2020