Reporting

ANTI-BRIBERY POLICY OF INDONESIA DERIVATIVE CLEARING HOUSE

Indonesia Derivative Clearing House in carrying out all activities of the Company to improve services and economic added value to committed Stakeholders:

Adhere to high moral values and compliance with laws and regulations and internal regulations related to the Anti-Bribery Management System in making decisions and carrying out actions;
Take a firm stance against all forms of Bribery to realize a clean, healthy, and correct management of the Company that is free from all forms of Corruption, Collusion, and Nepotism (KKN);
Take an active role in ensuring the implementation of the Anti-Bribery Management System, including by supporting the reporting of violations of anti-bribery policies in good faith without fear of retaliation in accordance with the applicable mechanisms at Indonesia Clearing Derivative House;
Make continuous improvements to the Anti-Bribery Management System in accordance with Company objectives;
Support the Anti-Bribery Compliance Function to act independently in monitoring implementation and reporting to the Board of Commissioners and Directors;
Willing to accept sanctions set by the Company if proven to have violated the anti-bribery policy.

Reporting Mechanism for Deviations, Violations and Gratuities to the Whistleblowing System (WBS) Team and Gratification Control Unit (GCU) of Indonesia Derivative Clearing House

As a form of support for the Indonesia Derivative Clearing House / KBI towards the eradication of corruption and in the context of implementing the Anti-Bribery Management System at KBI, we can convey the following:

All KBI personnel are prohibited:

Accepting Gratuities that are considered bribes from any party that has a relationship with their position, either directly or indirectly, which deviates from the provisions of KBI and applicable laws and regulations, unless the situation at that time does not allow the KBI Person concerned to refuse, namely:
1. 1. If KBI personnel do not know the implementation of the gift, the time and location of the Gratification, and do not know the identity and address of the Third Party providing the Gratification, and / or;
2. 2. If according to the reasonable logical judgment of the Recipient, the act of rejection can cause disruption of the business / partnership relationship between KBI and the Third Party, where the gift is not in the form of money and / or money equivalent regardless of the value of each Third Party.
Provide Gratuities that are considered bribes to any party either directly or indirectly that deviate from the provisions of KBI and applicable laws and regulations.

In an effort to control gratuities and provide a forum for reporting irregularities and / or violations that can be committed by KBI people, the Board of Directors has established a Whistleblowing System (WBS) Team and Gratification Control Unit (UPG) at KBI.

In the event of irregularities or violations committed by KBI people, reporting can be done with the following mechanism:

Reporting of Deviation or Violation by Employees, submitted in writing addressed to the WhistleBlowing System Team by way of:

(1) Submitting reports via email to the address: whistleblowing@ptkbi.com, or;
(2) Submitting reports via whatsapp (message & call) to the number 081181296999, or;
(3) Send the report by post / courier to the address:
Team Whistleblowing System
Indonesia Derivative Clearing House
Menara Danareksa 6th Floor Medan Merdeka Selatan No. 14 Central Jakarta 10110
The letter may only be opened by the Whistleblowing System Team;
(4) The report is accompanied by valid documents as evidence of irregularities or violations.
Reporting of irregularities or violations by the WhistleBlowing System Team, submitted in writing addressed to the President Director by way of:
(1) Send the report via email at dirut@ptkbi.com, or;
(2) Send the report by post/courier to the address:
President Director
Indonesia Derivative Clearing House
Menara Danareksa 6th Floor Medan Merdeka Selatan No. 14 Central Jakarta 10110
The letter may only be opened by the President Director;
(3) The report is accompanied by valid documents as evidence of irregularities or violations.

Reporting of Deviation or Violation by the Board of Directors, submitted in writing addressed to the President Commissioner by :
(1) Send a report by post/courier addressed to:
President Commissioner
Indonesia Derivative Clearing House
Menara Danareksa 6th Floor Medan Merdeka Selatan No. 14 Central Jakarta 10110
The letter may only be opened by the President Commissioner.
(2) The report is accompanied by valid documents as evidence of irregularities or violations.
Reporting of deviations or violations by the Board of Commissioners, submitted in writing addressed to the Whistleblowing System of the Ministry of SOEs by way of :
(1) Submitting reports through the Whistleblowing System website of the Ministry of SOEs which can be accessed through the address https://wbs.bumn.go.id/
(2) The report is accompanied by valid documents as evidence of irregularities or violations.
The reporter can send the report anonymously (without including identity). For whistleblowers who include an identity in their report, the WBS Team is obliged to maintain the confidentiality of the Whistleblower's identity and the KBI will implement the following:(1) Every whistleblower who reports legally has the right to legal protection from the KBI.
(2) The Company provides protection to every whistleblower who has good faith.
(3) The whistleblower's good faith is proven by the reporting submitted in accordance with the methods as stipulated in the Decree of the Board of Directors;
(4) Protection is given to the whistleblower against pressure, lawsuits, property, physical actions against the whistleblower;
(5) The whistleblower's right to protection is revoked if the whistleblower is proven to have committed false reporting.

Risk Management

Background Every business process of the company potentially contains risks that must be managed in an integrated and comprehensive manner by involving all KBI people on an ongoing basis. The company realizes that Risk Management is not to eliminate risk as a whole, but is a structured tool for managing risks that exist throughout the company's business processes in order to seek a balance between costs and benefits to be obtained. Risk Management must be embedded in every business process and function within the company so that it can become a risk culture. The scope of the company's Risk Management Policy is applied to all business processes and functions in the company, including the Board of Directors and all divisions in the company's organization, as well as new businesses / products in the company. Purpose and Objectives The purpose and objectives of the Risk Management Policy are:

Protect the company from significant risks that have the potential to interfere with the achievement of strategic and company-related goals and secure company assets including human resources, capital resources and company reputation.
Provide a consistent risk management framework for risks identified in business processes across all divisions.
Encourage management to act proactively to manage risk appropriately and at the same time become a source of competitive advantage and excellence in company performance.
Encourage every KBI person to be risk aware in managing the company's business as an effort to maximize company value and the achievement of shareholder wealth and meet the expectations of other stakeholders.

Risk Management Objectives

Creating awareness and concern for KBI people about the importance of risk management for the company;
Able to minimize the impact of significant risks that can hinder the achievement of company goals, secure assets and maintain the company's reputation;
Establishment of an enterprise risk management framework.

Risk Management Principles Risk management principles are the rules that must be adhered to in implementing risk management. The Risk Management Principles used by Indonesia Clearing Derivative House are as follows:

Commitment, the determination to achieve a set goal.
The System and Process approach identifies, understands and manages risk as a system and an integral part of the company's processes.
Transparency, all risks that may occur in every business process in the company are disclosed and listed in the company's risk profile so that there are no unidentified risks.
Integration and Comprehensiveness, the implementation of Risk Management needs to be integrated into the company's business processes, business decision making by all levels of management, and into the company's values and culture. The approach used in designing and implementing risk mitigation strategies covers all of the company's business processes.
Tiered responsibility, risk considerations are always inherent and must be an integral part of the management decision-making process at all levels of the company. The authority to make management decisions implies the authority to take a certain level of risk.
Balance between costs and benefits, in designing and implementing risk management, management must still take into account the balance between the costs that must be incurred and the benefits that might be obtained.
Continuous improvement, that the design and implementation of risk management must always be refined according to the needs of the company through increased competence and improved risk management systems.