Table of Contents:

– Introduction
– Purpose
– Benefits
– Company Culture & Values:
  • Integrity
  • Respect
  • Competency
  • Passion
– Ethical Standards / Ethics of Conduct:
  • Ethics towards employees
  • Ethics towards the Company
  • Ethics towards Business Partners
  • Ethics towards the Public
  • Ethics towards Regulator
– Guidelines for Implementation & Application of the Company`s Code of Ethics
  • Steps for Implementation
  • Reporting of Code of Conduct Violations
  • Sanctions for Code of Conduct Violation
  • Statement of Compliance

INTRODUCTION

In principle, the Company`s code of ethics & business behavior is part of the Company`s internal regulations, which must be obeyed by all employees. The Company`s code of ethics can be used as standards and guidelines for all employees, including management, to carry out their daily work based on noble morals, honesty, transparency, and professional attitude. The Company`s code of ethics is also an essential element in implementing Good Corporate Governance (“GCG”) practices for the Company.

As a public company, the Company is responsible for meeting the expectations of shareholders and stakeholders. The application of Good Corporate Governance principles can encourage creating a corporate culture that is expected, either directly or indirectly, to increase corporate value.

Violation of the Company`s code of ethics & business conduct may be subjected to sanctions followingCompany Regulations.

PURPOSE

– As a practical guide and code of conduct for all Alakasa personnel who must be adhered to in interacting with all parties in order to develop a good relationship between the Company, Employees and Stakeholders.
– Manifesting good behavior as per g ethical standards that apply to all employees.
– As a behavior guide for all Company personnel who must be obeyed in carrying out all Company activities.
– Creating a harmonious relationship with stakeholders

BENEFITS

– Encourage the Company`s operational activities to be more efficient and effective, considering that the relationship with customers, communities, government, and other stakeholders has ethical standards that must be emphasized.
– Increase the value of the Company by providing assurance and protection to stakeholders in dealing with the Company.
– Increase Shareholders` assurance that the Company is managed professionally followingthe principles of GCG: transparent, accountable, responsible, independent/independent and fair to achieve the level of profitability expected by Shareholders and other Company Stakeholders.
– As a reference for each individual in carrying out the mission to achieve the Company`s Vision, and creating a work environment that supports the values of honesty, ethics and openness, to improve all employees` performance and productivity.

COMPANY CULTURE & VALUES

Company Vision:
To be a company with competency in the aluminum business from upstream to downstream.

Company Mission:
• To research business development from upstream to downstream in the aluminum business;
• To empower potential resources to support business development strategy;
• To attain professionalism through developing capabilities, upgrading of processes, operational and management system;
• To provide added value to shareholders, customers, employees, and the community.

Culture and Values of the Company

The Corporate Culture contains Company values which will serve as a code of conduct in achieving the Company`s goals, vision, and mission, which are as follows:

• Integrity Think, speak, act honestly and ethically

To create a conducive work environment, every employee must think, speak, act honestly and ethically. Having good integrity is a strong foundation for building trust

• Respect Be empathetic, listen to others, and give ethical responses

To build a balanced team, everyone must respect each other. A balanced team is a foundation for a synergized team.

A culture of respect or mutual respect between employees, both vertically and horizontally, will create a work climate that can trigger harmony and creativity and innovation among teams.

• Competency Having knowledge, skill and good attitude

To provide value and be able to work effectively, everyone must be competent in various aspects: technical, business, management and leadership.

Competency is a skill owned by every individual to carry out their duties and responsibilities in their work. Competence will include technical, and non-technical matters in one unit, including management, leadership and business competencies.

• Passion Involve and entirely responsible for each job

Passion is individual work motivation and enthusiasm to complete the job, which is a critical condition for every employee. Passion can be formed by assigning employees according to their talents, interests and competencies, combined with good interpersonal relationships.

ETHICAL STANDARDS / ETHICS OF CONDUCT

Ethics towards fellow employees

• Mutual respect and trust among fellow employees.
• Maintain integrity and take responsibility for what is said and done.
• Developing the existing potential through professional cooperation regardless of gender, ethnicity, religion, race and class.
• Maintain proper two-way relationships and communication by avoiding actions or words that blame, insult, threaten, harass or others.
• Appreciate differences of opinion and new ideas.

Ethics towards the Company

a. Conflict of Interest
Conflicts of interest arise when personal (including family) interests, social, financial, or political, clash with company interests so that they have the potential to interfere with objectivity in decision making.

• Misusing company information / assets / resources for personal interest is not permitted.
• It is not permitted to directly or indirectly own of shares in suppliers, distributors, customers, or competitors.
• It is not allowed having”outside employment / second job” in suppliers, distributors, customers, or competitors.
• Transactions that have a conflict of interest with the company are not allowed. If the transaction cannot be avoided, then proactively do not involve yourself in the decision- making process.
• It is not allowed to have other activities that interfere with the company`s activities, except with the knowledge of the authorities.
• It is not allowed to take personal advantage of the “business opportunities” which could have become “business opportunities” for the company.
• It is not allowed for “direct family members” (parents-children, husband-wife, siblings) to work for the same company / department, which potentially can create a conflict of interest (e.g. superiors-subordinates, family working in the Personnel, Finance, etc.

b. Gift
Gifts (gratuities) are various forms of gifts not in the form of cash given or received by a company or employee. Gifts in the form of cash or cash equivalents as a means of business exchange are included in the category of bribery which is prohibited by law.
• Gifts can be given to the extent that they are within proper limits of their value, form and purpose (for example at birthdays, weddings, company inaugurations, etc.), and not violate the law with the approval of the authorities.
• It is not allowed to accept or ask for gifts of any kind, either directly or indirectly, from suppliers, distributors, customers or any party related to the company that has the potential to interfere with objectivity in decision making, except for promotional materials.
• The Authorized party must be notified various forms of giving which are impossible to refuse (honorarium, souvenirs, etc.)-.

c. Company Assets
Company assets are all property of the company both intangible form (including scrap & other non-productive assets) and intangible such as working time and intellectual property (copyrights, trademarks, trade names, proprietary information, etc.).
• It is the responsibility of every employee to use company assets effectively and efficiently, and to prevent them from damage, theft, abuse or other potential losses.
• It is the responsibility of every employee to maintain the company`s image.
• Accurate and complete documents must support every company transaction.
•It is not allowed for company assets to be used by parties outside the company except with the approval of the authorized party.

d. Documentation and Confidentiality of Information
Documentation is the process of recording, storing and maintaining the confidentiality of company data and information, up to its destruction if necessary.
• It is not allowed to hide, change, falsify or disguise any existing data or information.
• Document storage and destruction must comply with applicable regulations.
• It is the responsibility of each employee to maintain the confidentiality of information that he knows or entrusts to him, including information from third parties (customers, suppliers, etc.), both while the employee is still working at the company or after leaving the company.
• It is not allowed to discuss confidential information carelessly (precautionary principle)

e. Reporting of Violations
• Every employee is obliged to report every violation to his / her supervisor, if necessary, up to the highest management level or a designated party.
• All reports will be followed up to completion, and the identity of the reporter will be protected following the prevailing laws and regulations.

Ethics towards Business Partners

a. Customer
• In principle, the company conduet business based on- the strength of its products and services in terms of Quality, Cost, Delivery, Safety and Moral (QCDSM) and commitment to customer satisfaction.
• It is not allowed to give gifts as a means of business exchange, except in the form of “promotional materials”.
• Information about products and services, either verbally or through brochures, advertisements and other promotional materials, is conveyed clearly, truthfully and accurately, and does not give excessive expectations so as not to cause misinterpretation in the future that can damage the company`s image.
• The company provides the best service to all customers.

b. Supplier
• In principle, companies determine suppliers based on Quality, Cost and Delivery (QCD) factors.
• The Company must reject bribes from Suppliers or potential suppliers in an attempt to influence the Company`s decision.
• All purchases from Suppliers or sub-contractors must go through open tenders and only include reputable prospective Suppliers.
• The company prioritizes the use of affiliated company products following QCD requirements.

c. Distributor
• In principle, the company determines distributors based on the factors of distribution capability and financial capacity, service reputation, professionalism and integrity.
• The Company must reject bribes from distributors or prospective distributors in an attempt to influence the Company`s decision.

d. Creditors
• Choosing creditors who have a good reputation, and are free of Corruption, Collusion and Nepotism (KKN).
• Provide factual information about the use of funds to increase creditor trust.
• Fulfill the rights and obligations in accordance with the agreement between the Company and the creditor.

e. Principals
• The company respects the agreed upon in a professional manner
• Products and services marketed by the company are obtained and carried out legally and responsibly.

Ethics towards the Public

a. Investors / Shareholders
• The Company always respects and guarantees that the rights of Shareholders / Investors followingthe Company`s Articles of Association and other applicable regulations can be fulfilled in a transparent, fair, timely and smooth manner.
• The Company provides precise, actual, accurate and transparent information to shareholders / investors so that it can givea realistic picture of the Company`s financial condition and performance.
• The Company pays attention to and respects the directions and decisions of the Shareholders as long as they are in accordance with the Articles of Association and the prevailing laws and regulations.
• The Company applies a balanced treatment principle in providing the necessary information.

b. Competitor
• The company applies aggressive competition but healthy, ethical and following the prevailing laws and regulations.
• It is not allowed to deliberately take advantage of situations and conditions and misuse information to discredit competitors / competitors` products, whether in marketing, promotion or advertising activities so that it can be categorized as an act of unfair competition.
• It is not allowed to cooperate with competitors to regulate the market which may harm customers, leading to monopolistic, collaborative or cartel practices, for example controlling prices, allocating product types or market coverage, limiting the amount of production or sales.
• In a situation where a meeting or communication occurs between the company and competitors or customers, it is necessary to continue to act ethically and following applicable laws and regulations.
• It is not allowed to obtain information about Competitors illegally and contrary to the prevailing laws and regulations.

c. Mass media
• The company places the mass media as a partner, therefore it is necessary to build positive cooperation, mutual respect and benefit.
• The company adheres to the truth and disclosure of information followingthe journalistic code of ethics and the prevailing laws and regulations.

d. Environment and Society
• Attempt to make efforts to provide benefits and added value to the surrounding community.
• As much as possible to recruit workers from the environment around the company as far as they meet the existing requirements.
• Fostering harmonious relationships with government agencies and the surrounding community through related instruments.
• Always maintain the good name and reputation of the company through personal behavior outside the company and apply the precautionary principle in using company attributes.
• It is developing a work and living environment that is safe, clean and healthy in the company environment and around the company.

Ethics towards Regulators

a. Political Activities
• The company respects the right of every employee as an individual to participate in political activities.
• The company is politically neutral and does not take sides to certain political parties. For this reason, the company prohibits political activities in the company.
• Not allowed to use company facilities, including using company identities / attributes and recruiting employees when conducting political activities.
• Must not use power or position to influence the political views / activities of employees.
• Do not abandon duties and responsibilities in carrying out political activities.

b. Compliance with Laws and Statutes
• The company always acts in accordance with the prevailing statutes and regulations.
• The company respects the licensing and copyright rights owned by each business partner.

INSTRUCTIONS FOR IMPLEMENTATION & APPLICATION OF CORPORATE CODE OF CONDUCT

Implementation Steps

• Disseminate the contents of this Behavioral Ethics material to all levels of employees.
• Building a joint commitment, especially company leaders, to apply the contents of this Code of Conduct consistently.
• Provide role models, especially top management (“tone at the top”), as role models that all employees will follow.
• Phasing the application more realistically according to existing conditions.
• Regularly conduct refresher, counseling and ceremonial activities to strengthen determination in implementing the contents of this material
• Linking the application of this material to the employee`s performance appraisal, including the award program.
• Linking the application of this material to various company policies, including in Company Regulations along with sanctions for violations that occur.
Reporting Violations of the Code of Ethics
• Every employee is obliged to report every violation to his / her supervisor, if necessary, to the highest management level or a party appointed.
• All reports will be followed up to completion and the identity of the reporter will be protected followingthe prevailing laws and regulations.

Sanctions for Code of Conduct Violation

Violation of the Code of Ethics & Business Conduct of the Company will be subject to sanctions in accordance with Company Regulations, in the form of verbal and written warnings, stern warnings with the suspension to Termination of Employment depending on the level of violation and the results of the Company`s assessment of violations.

Compliance Statement Form:

STATEMENT OF COMPLIANCE AND COMMITMENT TO THE CODE OF CONDUCT AND BUSINESS ETHICS PT ALAKASA INDUSTRINDO TBK

I, the undersigned below:

Name : ………………………
Employee Number : ……………………….
Department : ……………………….
Position : ……………………….

Hereby declare:

1. Have received and read the Code of Ethics and Business Conduct of PT. Alakasa Industrindo Tbk;
2. Pledged to comply to all ethics stated in the Code of Ethics and Business Conduct of PT. Alakasa Industrindo Tbk;
3. Willing to be subjected to sanctions as stipulated in the Company Regulations as a result of not obeying and complying to the guidelines in this Code of Ethics & Business Conduct and not limited to accountability following applicable regulations within PT. Alakasa Industrindo Tbk and / or other laws and regulations.

Thus I give this statement consciously, without coercion from any party and am willing to bear all the consequences of violating this statement.

Jakarta, …… ………………. ……….

( _______________________)