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Whistleblowing System

In 2015 the Company began to establish a Wistleblowing System by adopting the whistleblowing system guided by Interra Resource Limited as the holding Company.

The Company regularly notices to all employees and its subsidiaries to observe Whistleblowing System, including report any fraud (if any).

Whistleblowing System is a communication line of the employee in reporting incidents that are suspected to be associated with fraud action. Crime, violation of company regulation and code of ethics violations involving employees of the Company and/or parties who have a relationship with the Company.

Implementation of a consistent and firm policy will be one of the efforts to maintain continuing clean business practices, compliance with laws and regulations and uphold ethics.

The existence of Whistleblowing System is expected to encourage employees to report violations without fear of becoming a victim, discrimination, or having loss. With this whistleblowing policy. It is also expected to encourage the check and balances of all parties in order to raise awareness for all parties in the Company of not committing fraud, violate and abuse of authority.

SUBMISSION ON VIOLATION REPORTS

Submission on violation reports can be done through a dedicated phone line direct to the top management.

PROTECTION FOR WHISTLEBLOWERS

The Company committ to provide protection to the whistleblower to foster security and encourage the whistleblower to not be afraid of reporting violations. Protection to the whistleblower will be given in the forms as follows: 1. Protection of the confidentiality of the whistleblower’s identity, including the information that can be used to contact the whistleblower; 2. Protection of retaliation from the reported party or other parties who have interests in the occurrence; 3. Protection from the pressure, employee rights, lawsuits, asset and physical actions.

COMPLAINT HANDLING

The Company ensures that all violation report should be followed up in a good order. Recurrent and systemic violations will be reported to the relevant officials who have the authority to make improvements.

COMPLAINT HANDLER

The whistleblowing system in the Company is managed by the Internal Audit Unit. This unit will periodically check very incoming reports for follow-up.

COMPLAINT HANDLING RESULT

Whistleblowing implementation is considered effective as a means for disclosure of fraud. Following a complaint, the report will be explored by the internal audit team related to the possibility of violations and fraud elements. During 2018, the Company did not received any complaint or fraud reporting from employee or other parties.

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