About

Within the scope of their activities, all entities working in favor of Green Energi Utama and on its behalf comply with rules under this Code of Conduct.

In particular, the Recipients of the code of ethics (hereinafter the “Recipients”) are:

• Organ Perusahaan (organ administratif, Dewan Audit, serta badan Perusahaan lainnya (badan administratif, Dewan Auditor, serta pihak yang sebenarnya mempunyai wewenang untuk mendelegasikan, mengambil keputusan, dan/atau mengendalikan Perusahaan, terlepas dari kewenangan yuridis/yang ditugaskan kualifikasi formal).
• Employees (employees, executives, self-employed, sub- contractors, internees and all parties working in the interest of the company organs and the employees, jointly the “Collaborators”).
• Advisors, suppliers of goods and/or services, commercial partners, agents and all those carrying out an activity to the benefit of the company (hereinafter the “Third Parties”).

The Addresses shall stick to the laws and regulations in force, therefore harmonising their project, management and operation conduct to the rules of behaviour, principles and ethical values under this Code of Ethics.

As a matter of fact, the Code of Ethics is enforced with relation to all activities carried out on behalf of Green Energi Utama both in Indonesia and whenever necessary abroad, in this case taking into account any cultural, social, and economic diversity of the countries where the company could work.

The addresses shall hold behaviors consistent with the respect of values and principles of Green Energi Utama, they must be familiar with and implement.

LEGALITY

Green Energi Utama acknowledges as fundamental principle the respect of laws and regulations in force. Recipients shall be bound to the provisions of the legal systems the work in the performance of their activities.

HONESTLY

Dalam hubungan internal dan eksternal, penerima berperilaku transparan, berintegritas, dan jujur, serta tidak boleh mengejar kepentingan pribadi dan/atau perusahaan yang tidak hanya melanggar undang-undang dan Perjanjian Kerja Bersama Nasional, namun juga Kode Etik dan modelnya.

FAIRNESS

The behavior and activities of the addressers must be inspired by the highest principles of fairness, also in their relation with colleagues, suppliers, customers and more generally, with all those with whom they come in contact in the performance of their functions. This principle, in addition to compliance with the provisions under the model, the policies, and practices, implies that situations of discrimination and conflict of interest must be avoided.

TRUST

Green Energi Utama believes that mutual trust is a prerequisite for effective and profitable business relationships, both within the company and outside.

SHARING

Perusahaan berupaya untuk memainkan perannya secara penuh dalam merangsang pertukaran informasi, pengetahuan, pengalaman, dan keterampilan profesional baik di dalam Green Energi Utama maupun jika diperlukann di luar perusahaan.

TEAMWORK

Teamwork and collaboration in achieving the common goals guides the actions of the company, in the awareness that the success of Green Energi Utama is based in large part on the added value stemming from the synergy of people working in it.

Green Energi Utama involves the addressers in the company business, ensuring a working environment based on attention, listening, trust, and professional recognition. In order to enhance the skills of its human resources, the Company shall provide such resources with training, update and professional development tools.

RESPONSIBILITY

In the development of the corporate mission, the behaviour of Recipients must be responsible and attentive to the implications and consequences of their actions, also in the light of the Principles set out in this Code of Conduct.

IMPARTIALITY

In full compliance with the Principles inspiring the company action in the conduct of its business and activities, Green Energi Utama shall not accept any discrimination as to race, sex, religion, ethinicity, language and nationality of individuals. This also involves the application of the principle of equal opportunities in the management and daily operations of the company life.

TRANSPARENCY

Green Energi Utama in the conduction of business and to the benefit of the corporate life, strongly believe in the truthfulness, completeness and accuracy of information provided both inside and outside the company.

EXCELLENCE

Standards of effectiveness and efficiency must be pursued in every sphere of activity. Recipients shall ensure commitment and professional work in order to provide an excellence-oriented performance.

ENVIRONMENTAL POLICY

Green Energi Utama pays great attention to respecting the public interest and considers the environment and nature as fundamental values and a public good, to be protected and defended. To this end, Green Energi Utama is fully committed to tailoring its business to ensure compliance with these principles. Green Energi Utama productive activities are managed in strict compliance with the prevailing environmental laws and regulations.

COMPETITION AND FAIR DEALING

We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance, never through unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or including such disclosures by past or present employees of other companies is prohibited. Each employee and officer should endeavor to respect the right of and deal fairly with Green Energi Utama customers, suppliers, competitors and employees. No employee or officer should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other illegal trade practice. No employee or officer is permitted to engage in price fixing, bid rigging, allocation of markets or customers, or similar illegal anti-competitive activities.

To maintain Green Energi Utama's valuable reputation, compliance with our quality processes and safety requirements is essential. All inspection and testing documents must be handled in accordance with all applicable speculations and requirements.

The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships, not to gain unfair advantage with customers. No gift or entertainment should ever be offered, given, provided or accepted by any employee or officer, family member of an employee or officer, or agent unless:

• Is not a cash gift.
• Is consistent with customary business practice.
• Is reasonable in value.
• Cannot be construed as a bribe or payoff and does not violate any laws, regulations or applicable policies of any other party’s organization.

Please discuss with your manager any gifts or proposed gifts which you are not certain are appropriate.

PROTECTION & PROPER USE OF GREEN ENERGI UTAMA GRUP ASSETS

The corporate assets of Green Energi Utama consists of both physical material goods - such as computers, printers, equipment, vehicles, real estates, warehouse infrastructure, as well as intangible assets-such as confidential information, know-how, technical knowledge developed and disseminated by and to employees.

Safety - that is protection and conservation of those assets, is a key value for the protection of corporate interests. Each employee is personally responsible for maintaining this safety by complying and disclosing the corporate policy and regulations on this matter, and by preventing fraudulent or improper use of the company’s assets.

The co-workers who steal assets owned by the company - including documents, equipment, personal belongings of other employees, cash or other objects, misuse of the intellectual property of the company, shall be subjected to the measures permitted by law and established by the disciplinary system.

The use of the goods of the assets by the co-workers must be functional and exclusive in performing business activities or for purpose authorised by the relevant corporate functions, in compliance with the Policies and Practices.

ANTI-BRIBERY & CORRUPTION

All Employees must read and understand the company’s Anti-Bribery and Corruption Policy and attend any training provided by the Company. The Anti-Bribery and Corruption Policy is incorporated into and made a part of this code which means that it must be followed in the same way as the Code.

The company strictly prohibits giving facilitating payments to any private or government officials or employees, their agents or intermediaries in order to expedite or secure performance of any governmental action, or to gain any perceived or actual favor or disadvantage from any private or government entities. The Company must ensure that it and its directors, officers and employees fully comply with the laws governing bribes, unlawful payments and other corrupt practices.

ANTI-MONEY LAUNDERING

The Company pursues its business in full compliance with anti-money laundering regulations and with the provisions issued by the competent Authorities. To this end, it does not put in place operations that might be deemed suspicious in fairness and transparency terms.

The company’s relationships with trade counterparties, suppliers, partners, collaborators and consultants are based on the prior assessment of information available on their respectability and the lawfulness of their activity, so as to avoid any involvement in operations which can, even only potentially, favour the laundering of money from unlawful or criminal actions, and acting in full compliance with internal control procedures and anti-money laundering rules.

TRANSPARENCY OF ACCOUNTING

Green Energi Utama believes that transparency and keeping of accounting records according to the principles of truthfulness, completeness, clarity, precision, accuracy and compliance with the applicable law are the basic prerequisite for effective control.

For each operation an adequate supporting documentation must be kept on records to allow an easy accounting entry, the reconstruction of the operation itself and the identification of any responsibility. The budget should represent the economic, equity and financial situation of the company in a truthful, clear and complete way. Everyone must therefore cooperate to ensure that operating events are represented correctly and promptly in the accounts.

Each record shall reflect exactly what is shown by the supporting evidence. It is the responsibility of each Associate to ensure that the documentation can be easily traced and field according to logical criteria. Invoices must indicate the nature of the services or goods purchased and/or sold. Payments to “blacks funds”, or similar funds or accounts - meant as those for which no accounting entry was made for receipts and expenses - are illegal and forbidden.

COLLECTIVITY AND ENVIRONMENT

The company is aware of the social role it plays in the community and of the environmental aspects that interact with their activities on the territory and in the community.

As a matter of fact, Green Energi Utama in carrying out its activities, takes on its responsibility towards the community, inspired by the values of solidarity and dialogue with stakeholders.

The company holds and develops a relationship of trust and an outgoing dialogue with stakeholders with a view to informing and involving them in issues that affect them, where it is possible. As a part of its business, the company also focuses on environment protection and public health.

Finally, Green Energi Utama promotes social, economic, and occupational development in compliance with applicable standards and internationally recognised rights on the protection of fundamental rights, non-discrimination, child protection, prohibition of forced labor, health and safety at work, working hours and remuneration.

CONFIDENTIALITY

1. Employees must maintain the confidentiality of confidential information entrusted to them by the company or companies, including the company’s suppliers and customers, except when disclosure is specifically authorised by a supervisor or required by law, regulations or legal proceedings. Unauthorised disclosure of any confidential information is prohibited. You should consult the Legal Department if you believe you have a legal obligation to disclose confidential information.
2. Confidential information includes, amongst other things:

•  Any non-public information concerning the company’s business, financial performance and/ or results, prospects or potential corporate transactions.
• Any confidential non-public information provided by a third party and any personal information about the company's customers, agents and employees.

3. Employees are required to keep such information confidential during employment as well as thereafter, and are not to use, disclose or communicate it to third parties. By keeping such information confidential the company maintains the trust of its counterparties and its compliance with legal requirements.

People unrelated to or outside of the company, such as third parties, including media and market professionals, securities analysts or securities holders, may ask you for information concerning the company. Unless approved by a supervisor or required by law, only authorised spokespersons may discuss internal company matters with, or disseminate internal company information to, anyone outside the company. All responses to inquiries with respect to the company must be made only by the authorised spokespersons. If your duties make it necessary for an employee to disclose such confidential information they may do so after an appropriate confidentiality agreement is in place. If you receive any inquiries of this nature, you must decline to comment and refer the inquirer to one of the company’s authorised spokespersons set out the company’ s disclosure policy.

COMMITMENTS AND OBLIGATIONS UNDER THIS CODE OF CONDUCTS

With a view to fully achieving purposes underlying the Code of Conduct, Green Energi Utama is committed to ensuring the adoption of all the initiatives that can guarantee:

• utmost dissemination of the code of Ethics to Recipients;
• periodical integration and update of the Code of Conduct in order to adapt it to any change in the reference values and relevant regulations;
• availability of any tool allowing a better understanding and clarification on the construction and implementation of the rules contained in the Code of Conduct;
• ascertainment of any information on the violation of this Code of Conduct and the implementation of times in case of ascertained violation in compliance with the rules in force;
• prevention of relation of any kind against people having taken steps to report any violations of the Code of Conduct or of reference rules.

Every Recipient must be aware of the rules contained in the Code of Conduct and in the reference rules governing the activity performed within the scope of every recipient function.

OBLIGATIONS TO THE EMPLOYEES

Every Employee being entrusted with operating responsibilities shall be obliged to:

• with their behaviour, to represent an example for their own and other employees;
• prompt employees to the respect of the Code of Conduct as well as raise issues relating to the rules;
• work to ensure that Employees understand that compliance with the Code of Conduct is an essential part of the quality of their work;
• carefully select, within their competences, Employees and Third Parties to prevent assignments being given to people who are not fully reliable on their commitment to observe the rules of the Code of Conduct;
• promptly report, according to the provisions contained in the model, any information provided by external Third Parties about possible violations of the Rules;
• adopt immediate corrective actions whenever required;
• prevent any type of retaliation against Employee who have taken steps to report violations of the Code of Conduct.

OBLIGATIONS TO THE COLLABORATORS

The Green Energi Utama collaborators, by virtue of their powers, in their contracts with third parties will take care of:

• duly inform them about commitments and obligations set forth in the Code Of Conduct;
• demand compliance with the obligations directly concerning their activities;
• adopt appropriate internal and, if authorised external actions in the vent of failure to comply with the obligations under the rules of the code of Conduct by any Third Party.

CONTROL ACTIVITY

The company policy at spreading at all levels a culture characterised by the awareness of individual and collective responsibilities, the existence of controls and a control-oriented attitude. The attitude towards controls must be positive since they contribute to improving efficiency.

Internal controls are all tools necessary or useful for addressing, managing and checking the company activities, with the aim of ensuring compliance with the laws and the policies and practices, protecting corporate assets, efficiently managing activities and providing accurate and complete financial and accounting data

Green Energi Utama described the controls which have specific relevance to the purposes of implementation of the model in the model itself. In any case, the responsibility for implementing an effective internal control system is shared at every level of the organisation; consequently all Employees, in their respective functions, are responsible for the definition and proper functioning of the control system.

Each employee shall be held responsible for the corporate assets (tangible and intangible) that are instrumental to the carried out activity. No collaborator may make improper use of assets and resources of the company or allow others to do so.

TRAINING PROCEDURES, AUDIT AND REGULAR REVIEW

The company is committed to ensuring that its employees are regularly trained, and that its compliance procedures generally are regularly audited and reviewed. Green Energi Utama will implement all the necessary procedures, to ensure and validate on a regular basis, the proper adherence of the Code by all employees, Directors and Officers.

An independent review, regarding the conformance of the Company’s transactions, business operations and employee responsibilities with the Code, will be performed on an annual basis. Results will be communicated directly to the Audit Committee, in order to identify the appropriate and necessary corrective actions.

Green Energi Utama guarantees equal opportunities to all employees, on the basis of professional competencies and individual skills, without any discrimination based on gender, age, religion, ethnicity, political belief and/ or trade union affiliation.

The company interprets its entrepreneurial role both in the protection of working conditions, and in the mental, and physical protection of the worker, by fully respecting their moral personality and preventing them from suffering unlawful conditioning or undue discomfort.

The company expats all its employees, at every level, to cooperate in maintaining a climate of mutual respect for the dignity, honor and reputation of each individual, and they will then intervene to prevent any interpersonal offensive and defamatory attitudes.

COMPLIANCE WITH LAWS

A variety of laws apply to the Corporation and its operations. It is the Corporation’s policy to comply with all applicable laws, including employment, discrimination, health, safety, competition, securities, banking and environmental laws. No Green Energi Utama Representative has authority to violate any law or to direct another Green Energi Utama Representative or other person to violate any law on behalf of the Corporation. Each Green Energi Utama Representative is expected to comply with all such laws, as well as rules and regulations adopted under such laws.

Violations of laws may subject an Green Energi Utama Representative to individual crime of civil liability, as well as to discipline by the Corporation. Such individual violations may also subject the corporation to civil or criminal liability or the loss of reputation or business.

Many of the laws applicable to the corporation and Green Energi Utama Representatives are complex and fact specific. If any Green Energi Utama Representative has questions concerning a specific situation, he or she should contact the Compliance Officer before taking any action.

No director, officer or employee may purchase or sell any company securities while in possession of material non-public information regarding the company, nor may any director, officer or employee purchase or sell another company’s securities while in possession of material non-public information regarding that company. It is against Company policies and illegal for any director, officer or employee to use material non-public information regarding the company or any other company to:

• obtain profit for himself or herself;
• directly or indirectly “tip” others who might make an investment decision on the basis of that information.

Green Energi Utama Representative should refer to the Corporation’s insider Trading Policy for more details.

RULES OF CONDUCT IN THE RELATIONSHIP WITH THE EMPLOYEES

Human resources are fundamental components for the company’s life. The dedication and professionalism of employees represent fundamental values and conditions to achieve the Company’s goals. The processes for managing Green Energi Utama are designed and implemented in the spirit of the values described under the satisfaction of human resources and to the team spirit.

Proses pengelolaan Green Energi Utama dirancang dan dilaksanakan dengan semangat nilai-nilai yang dijabarkan berdasarkan kepuasan sumber daya manusia dan semangat tim.

PERSONNEL SELECTION POLICIES

The selection of employees is exclusively made on the basis of the competencies and professional skills of the candidates with regard to the roles that, according to Green Energi Utama, need to be covered. Moreover, with this in mind, the company shall select employees with full respect of the principle of equal opportunities, without discrimination of any kind and avoiding any form of favoritism or patronage.

EMPLOYEE TREATMENT

Green Energi Utama undertakes to create a happy working environment in which everyone can work in full respect of the laws, principles, and shared ethical values. The company ensures the confidentiality of information, in relation to Third Parties. Green Energi Utama guarantees equal opportunities to its employees and treats them with respect and dignity in the frame of the provisions set forth by the law of our legal system and any amendments thereto. Each employee is supposed to take note of existing Policies and Practices in Green Energi Utama and the model.

HEALTH AND SAFETY

Green Energi Utama attaches utmost importance to the protection of health and safety at work, having as its objective not only its compliance with the specific regulation on this matter but also its constant attention so as to continuously improve work conditions.

The company thus acts in accordance with the rules of force on safety and hygiene at work, and carries out its business in technical, organisational and economic conditions that ensure suitable prevention of accidents and a healthy and safe working environment. All recipients are required to pay utmost attention to the performance of their duties, acting strictly in accordance with all safety and prevention measures put in place to avoid any risk for themselves and their collaborators and colleagues.

The responsibility of all recipients toward their collaborators and colleagues requires their utmost care for the prevention of hazards. All recipients must abide by the instructions and directives given by the company’s safety managers.

BEHAVIOUR IN THE WORKPLACE

In accordance with the ethical principles forging its activity, Green Energi Utama protects the physical and moral integrity of its employees, ensuring them working conditions that respect the dignity of the person. As part of the environment relationship, the relationships between the employees, at all levels of responsibility in the organization, will be inspired by mutual fairness, respect and politeness. In keeping with the dignity of employees, the superiors will base their relationships with the employees reporting to them upon the utmost fairness and respect.

Green Energi Utama shall not admit in the workplace any offensive behaviors.

HARASSMENT

Green Energi Utama commits so that no internal or external working relationships result in harassment, such as:

• creating an intimidating or hostile working environment or isolating workers or groups of workers;
• creating unjustified interference with the execution of another’s work performance;
• hindering other colleagues’ individual professional perspectives merely for reasons of personal competitiveness.

The Company shall not accept nor tolerate sexual harassment, such as:

• subjecting important decisions for the working life of the Recipient to the acceptance of sexual favors;
• usulan untuk membangun hubungan antarpribadi, yang dibuat meskipun ada rasa tidak suka yang tersurat atau terlihat jelas, yang sehubungan dengan situasi spesifik, dapat mengganggu ketenangan penerima dengan implikasi obyektif pada kinerja kerja mereka.

It should be pointed out that sexual harassment of any kind shall be severely punished, even by taking disciplinary measures.

VIOLENCE

In accordance with the ethical principles forging its activity, Green Energi Utama protects the physical and moral integrity of its employees, ensuring them working conditions that respect the dignity of the person. As part of the environment relationship, the relationships between the employees, at all levels of responsibility in the organization, will be inspired by mutual fairness, respect and politeness. In keeping with the dignity of employees, the superiors will base their relationships with the employees reporting to them upon the utmost fairness and respect. Green Energi Utama shall not admit in the workplace any offensive behaviors.

CHILD LABOR

Green Energi Utama does not resort to the use of child or forced labor, nor has it entered into or entered into contracts with any Third Parties (Suppliers, Subcontractors, etc.) resorting to it. The company ensures that its services are not performed by persons who have been denied the opportunity to receive an education and to live a proper life as determined by Children Rights.

CONFLICT OF INTERESTS

Seluruh karyawan dalam hal apapun harus menghindari segala situasi dan kegiatan yang dapat menimbulkan konflik dengan kepentingan perusahaan, bahkan berpotensi menimbulkan konflik, atau yang dapat mengganggu kemampuan mereka untuk mengambil keputusan yang tidak memihak demi kepentingan terbaik Green Energi Utama dan sepenuhnya kepatuhan terhadap Kode Etik ini. Oleh karena itu, situasi apa pun yang dapat menimbulkan atau menimbulkan konflik kepentingan harus segera dilaporkan kepada atasannya atau bila perlu, kepada Dewan Pengawas. Secara khusus, seluruh karyawan diwajibkan untuk menghindari konflik kepentingan antara kegiatan ekonomi pribadi dan tugas yang dipercayakan kepada mereka di departemen tempat mereka berada. Konflik dapat terjadi dalam banyak hal, antara lain sebagai berikut:

• Economic and financial interests of the employee and / or their family in the activities of suppliers, customers and competitors.
• Using one’s position in the company or information acquired during their work so as to create a conflict between their personal interests and corporate interests.
• Conducting business, of any kind, directly or indirectly, as a subordinate or autonomously, at customers, suppliers and competitors.
• Working, in any capacity, for a competitor, customer or supplier while employed by the company.
• Accepting gifts or more than modest value or receiving personal documents or other benefits as a result of your position in the company from a competitor, customer or supplier.
• Competing with the company for the purchase or sale of property, services or the other interests.
• Directions business to a supplier owned or managed by, or which employs a relative or friend.
• Having an interest in a transaction involving the Company, a customer or supplier (other than as an employee, officer or director of the company and not including routine investments in publicity traded companies).
• Receiving a loan or guarantee of an obligation as a result of your position with the company.
• Accepting money, favour or benefits from persons or companies that have or intent to start business relations with Green Energi Utama.
• Anything that would present a conflict for a director, officer or employee would likely also present a conflict if it is related to such persons’s family members or other close personal connections.

Situations involving a conflict of interest may not always be obvious or easy to resolve. You should report actions that may involve a conflict of interest to the General Counsel. The company shall ensure that all recipients do not find themselves in a position of conflict of interest in order to ensure the public trust and confidence in them as well as its actions beneficiaries.

CORPORATE OPPORTUNITIES

Employees, officers and directors are prohibited from taking for themselves business opportunities that arise through the use of corporate property, information or position. No employee, officer or director may use corporate property, information or position for personal gain and no employee, officer or director may compete with the company.

Competing with the company may involve engaging in the same line of business as the company, or any situation where the employee, officer or director takes away from the company opportunities for sales or purchases of products, services or interests. Sometimes the line between personal and company benefits is difficult to draw, and sometimes there are both personal and company benefits in certain activities. Directors, officers and employees who contend to make use of company property or services in a manner not solely for the benefit of the company should consult beforehand with the CEO and the General Counsel.

OUTSIDE ACTIVITIES/ EMPLOYMENT AND CIVIC/ POLITICAL ACTIVITIES

Segala kegiatan di luar tidak boleh mengganggu waktu dan perhatian Perwakilan Green Energi Utama secara signifikan dalam menjalankan tugasnya untuk Perusahaan dan tidak boleh memberikan dampak buruk terhadap kualitas dan kuantitas pekerjaan mereka. Selain itu, Perwakilan Green Energi Utama tidak boleh menyiratkan sponsor atau dukungan Korporasi terhadap aktivitas luar apa pun yang bukan merupakan urusan resmi Korporasi dan dalam keadaan apa pun Perwakilan Green Energi Utama tidak boleh mengambil peluang bisnis yang dimilikinya atau anggota keluarganya ditemukan atau disediakan berdasarkan posisi mereka di Korporasi.

Selain itu, jika diizinkan oleh paragraf berikut atau oleh Dewan, Ketua Tata Kelola Perusahaan, dan Komite Nominasi atau Pejabat Kepatuhan, tidak ada karyawan Perusahaan yang boleh melakukan layanan untuk atau memiliki kepentingan finansial di entitas mana pun yang atau untuk sepengetahuan karyawan tersebut dapat menjadi vendor, klien atau pesaing Korporasi.

Karyawan Korporasi dilarang mengambil bagian dalam pekerjaan sampingan atau jabatan direktur apa pun tanpa persetujuan tertulis sebelumnya dari Chief Executive Officer atau Pejabat Kepatuhan, kecuali untuk pekerjaan kecil dan tidak terkait dan untuk jabatan direktur di dewan amal yang dalam setiap kasus tidak mengganggu pekerjaan kewajiban pegawai terhadap Perusahaan.

No employee of the Corporation may acquire securities of a customer, supplier or other party if ownership of the securities would be likely to adversely affect either the employee’s ability to exercise independent professional judgment on behalf of the Corporation or the quality of such employee’s work Green Energi Utama Representatives must always follow the Corporation’s other policies concerning the trading of securities, including those further described in this code.

Green Energi Utama Representatives are encouraged to participate in civic, charitable or political activities so long as such participation does to encroach on the team and attention they are expected to devote to their Corporation-related duties. Such activities are to be conducted in a manner that does not create an appearance of the Corporation’s involvement or endorsement.

DEALINGS WITH GOVERNMENT AND PUBLIC OFFICIALS

The Corporation strictly prohibits any payment to any public official that violates the laws of any jurisdiction in which the Corporation operates. The Corporation strictly prohibits any Green Energi Utama Representative from giving, offering, promising, demanding, soliciting or receiving, directly or indirectly, any bribe or improper payment, using corporate or personal funds, to or from public officials of any government or governmental agency for the purpose of obtaining or retaining business, or for any other reason. Any offer of, or request for, any bribe or improper payment must be reported to the Compliance Officer.

Korporasi dengan tegas melarang siapa pun untuk melakukan pembayaran apa pun jika orang tersebut mengetahui atau meyakini secara wajar bahwa seluruh, atau sebagian dari pembayaran tersebut akan ditawarkan, diberikan atau dijanjikan, secara langsung atau tidak langsung, kepada pejabat publik di pemerintah atau lembaga pemerintah mana pun untuk tujuan tersebut tujuan membantu Korporasi dalam memperoleh atau mempertahankan bisnis.

Public officials include, without limitation:

• Political parties or officials thereof, political candidates and elected or appointed representatives of any government or governmental agency holding a legislative, administrative or judicial position at any level.
• Orang yang melaksanakan tugas atau fungsi umum, termasuk orang yang dipekerjakan pada suatu dewan, komisi, korporasi, atau badan atau otoritas lain yang dibentuk untuk melaksanakan tugas atau fungsi atas nama pemerintah, atau sedang melaksanakan tugas atau fungsi tersebut dan seorang pejabat atau agen atau organisasi public
• Internasional yang dibentuk oleh dua atau lebih negara bagian atau pemerintahan, atau oleh dua atau lebih informasi publik internasional tersebut.

PUBLIC DISCLOSURES

The Corporation has an obligation in compliance with applicable laws to make full, fair, accurate, timely and understandable disclosure in its financial records and statements, in reports and documents that it files with or submits to securities regulatory authorities and in its other public communications.

In furtherance of this obligation, each Green Energi Utama Representative, in performing his or her duties, shall act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing one’s independent judgement to be subordinated, in order to ensure that to the best of his or her knowledge the Corporation’s books, records, accounts and financial statements are maintained and accurately and in reasonable detrial, appropriately reflect the corporation’s transactions, are honestly and accurately reflected in its publicity available reports and communications and conform to applicable legal requirements and the Corporation’s system of internal controls, including the Corporation’s Disclosure Policy.

GIFTS AND OTHER BENEFITS

It is not permitted to pay or offer, either directly or indirectly, gifts, payments, material benefits or other benefits of any kind to third parties, public officials or private individuals, to influence or compensate them for something they did or to obtain any advantage from them.

Commercial courtesy, such as gifts or hospitality are allowed if they are of limited value and do not compromise the integrity or reputation of Third party, and they cannot be construed by an impartial observer as aimed at obtaining undue advantages. This is always within the limits and subject to the provisions of the model, which is to be referred to. In any case, such expenses must always be duly authorised and documented, as per the provisions of the model. Moreover, should any employee receive either gifts or preferential treatments being not directly attributable to normal courtesy in relationships they must promptly notify the company, in compliance with the provisions of the model.

Third Parties are required to comply with the principles set forth in the Code of Conducts. Therefore every collaborator, in relation to their functions, will be responsible for:

• observe the principles, policies and practices for the selection and management of relations with Third Parties;
• only select qualified people and companies with good reputation;
• take into account information from any source about the opportunity to use certain Third Parties;
• promptly report in the manner prescribed by the Model on doubts violations of the Code of Conducts by any Third Parties.

In any case, the remuneration to be paid shall be exclusively commensurate with the performance indicated in the contract and the payments cannot be made to a person other than the contractor or in a third country other than that of the parties or the contract execution.

INSIDER TRADING

All directors, key officers, employees, consultants, advisers of the company, and members of the immediate families of directors key officers who are living in the same household as the directors and key officers (The “Covered Persons” who have direct or indirect knowledge, from time to time, of material facts or changes in the affairs of the company, which have not been disclosed to the public, including any information likely to affect the market price of the Company’s shares, shall:

• Not trade in the Company’s securities directly or indirectly.
• Not communicate, directly or indirectly, such as material non-public information to any person until the material non-public information is disseminated to the public and two trading days have lapsed from the disclosure thereof to allow the market to absorb such information.

All Covered Persons shall be restricted form trading the Company's securities during the following blackout periods:

• Five trading days before and two trading days after the disclosure of the quarterly and annual financial results.
• Two trading days after the disclosure of any material information other than the above.

Information is deemed to be material non-public information if it has not been generally disclosed to the public and would likely affect the market price of the Company’s securities after being disseminated to the public or would be considered by a reasonable person as important, under the circumstances, in determining his/her course of action whether to buy, sell or hold the Company’s Securities.

As a general rule, information required to be disclosed under the result of the Securities and Exchange Commission and the Indonesia Stock Exchange should always be considered material in nature.

All directors, officers, and employees are required to report their trades on a quarterly basis to the Office of the Compliance Officer within fifteen calendar days from the end of each quarter.

The Corporation provides employees with access to e-mail, the internet, telephones and other forms of communication for business purposes, and while we understand the need for limited and occasional use of these tools for personal purposes, this use should not be excessive or be detrimental to the Corporation. The Corporation’s e-mail system, including e-mail accounts and addresses, are the property of the Corporation.

merugikan Korporasi. Sistem email Korporasi, termasuk akun dan alamat email, adalah milik Korporasi.

The Corporation has the right to access monitor and review communications conducted using the Corporation’s resources and employees should have no expectation of privacy when using these resources. Internet use must be conducted in a reasonable professional manner and must not impede on an employee's ability to perform his or her duties. Furthermore, as an example, accessing internet sites containing obscene or offensive material, or sending e-mails that are derogatory or harassing to another person or group of people or chain emails, is prohibited. Employees must be also vigilant to ensure that the network security is maintained.

The Corporation’s policies against workplace discrimination and harassment apply fully to employee use of e-email, the internet , telephone and other forms of communication.

Green Energi Utama Representatives should refer to the Corporation’s Social Media Policy for more information on how Green Energi Utama Representatives should conduct themselves online.

IT SYSTEMS

The company does business in full compliance with the rules in force on the use and management of information systems, which the recipients of this document are thus required to abide by.

Under no circumstances can computer and network resources be used for purposes that are contrary to mandatory provisions of law, to the public order or decency, and to perpetuate or induce the perpetration of offences, to damage or alter information systems and information of third parties (private or public entities) or to unlawfully obtain confidential information.

yang bertentangan dengan ketentuan wajib hukum, ketertiban umum atau kesusilaan, dan untuk

melanggengkan atau mendorong dilakukannya pelanggaran, untuk merusak atau mengubah sistem

informasi dan informasi pihak ketiga (badan swasta atau publik) atau diperoleh secara tidak sah

informasi rahasia.

No recipient can make audio-visual, electronic, paper or photographic recordings or reproductions of corporate documents, unless these activities fall within the ordinary scope of his/her duties.

PRIVACY PROTECTION

Green Energi Utama Protects the confidentiality of information and data relating to its employees, collaborators or third parties, collected by reason or on the occasion of business performance and each employee or collaborators is required to act in accordance with these principles.

ACCOUNTING RECORDS

Green Energi Utama complies with the rules on accurate, complete and transparent book-keeping accordance with the standards indicated by the applicable rules and the Accounting Principles currently in force. In accounting the Company’s management facts, its employees and collaborators are required to act strictly in accordance with the law in force and the Company’s internal procedures so that all operations are duly registered and authorised, assessable, and collaborators are required to act transparently towards the statutory auditors and to offer their utmost collaboration in their audit and control activities.

MANAGEMENT OF CONFIDENTIAL INFORMATION

Anyone who acquires inside, reserved and/ or confidential information in the performance of his/ her duties, is required to keep it confidential. Moreover, Confidential Information is communicated outside the Company only by authorised individuals, in accordance with the Company’s procedures and in any event with the rules in force and ensuring the party and contextual nature of the information given. In particular, any type of manipulation, use for economic purposes or direct or indirect investment, which finds its source in confidential information concerning the Company, is contrary to law and is thus strictly forbidden.

DATA BANKS

Each Employee is obliged to ensure the confidentiality required by the circumstances for each piece of news learners according to their working function. Green Energi Utama is committed to protecting the information concerning their employees, customers and Third Parties, generated or acquired inside and in business dealings, and to avoiding any misuse of this information.

Informasi, pengetahuan dan data yang diperoleh atau diproses oleh Karyawan selama bekerja atau menjalankan tugasnya adalah milik Perusahaan, dan tidak dapat digunakan, dikomunikasikan atau diungkapkan tanpa izin khusus dari atasan yang bersangkutan, baik selama hubungan kerja maupun pada akhirnya itu. Tanpa mengurangi larangan untuk mengungkapkan informasi mengenai organisasi dan cara produksinya atau menggunakannya sedemikian rupa sehingga menimbulkan kerugian bagi perusahaan, setiap Karyawan wajib:

• Acquire and process only those data required and adequate for the purpose of their membership function and in direct connection with their expertise.
• Sedemikian rupa sehingga mencegah pihak yang tidak berkepentingan memperoleh pengetahuan.
• Communicate the same data upon the express permission of the superior and, in any case, after ensuring that they can be actually disclosed in the specific case of data, ensure that there are no absolute or relative restrictions regarding the disclosure of information on the Third Parties and where appropriate, obtain their consent.
• Gather the data in a way ensuring that any party authorised to access then may easily get a picture as accurate, comprehensive and truthful as possible.

Green Energi Utama Representatives who observe, learn of, or, in good faith, suspect a violation of this code must immediately report the violation pursuant to the procedures for submission of complaints and concerns set out in the Corporation’s whistle policy. The Company does not tolerate acts of relation, including demotion, discharge, discipline, discrimination, harassment, suspension or threats, against any Green Energi Utama Representative who makes a good faith report of known or suspected acts of misconduct or other violations of this code.

WHISTLE BLOWING POLICY

As part of the Corporation’s commitment to the highest standards of corporate governance, the Corporation has established procedures for the receipt, retention and handling of complaints and concerns received relating to, among other things, alleged or suspected illegal activity or violations of this Code or a code of conduct of a subsidiary of the Corporation. Any such illegal activity of code violation must be reported promptly, as set out in the Corporation’s Whistle Blowing Policy.

This Code should be read in conjunction with the Corporation’s other related policy documents, including the Corporation’s Anti-Corruption and Anti-Bribery Policy, Gift and Hospitality Policy and Disclosure Policy. The Code supplements any contractual obligation any person may have under the terms of any agreements with the Corporation. This Code is not intended to create any contract (express or implied) with any person, including, without limitation, any employment or consulting contract, or to constitute any promise that a person’s employment or consulting arrangement will not be terminated except for cause.

APPROVAL AND AMENDMENT

The Code was approved and adopted by the Board. The Corporation is committed to reviewing and updating its policies and procedures on a continuing basis. This Code may be revised, changed or amended at any time by the Board, and amendment to the Code will be disclosed promptly to Green Energi Utama Representatives and will be disclosed publicly in accordance with applicable securities laws.

GENERAL POLICY REGARDING REPORT OF VIOLATIONS

Green Energi Utama Representatives who observe, learn of, or, in good faith, suspect a violation of this code must immediately report the violation pursuant to the procedures for submission of complaints and concerns set out in the Corporation’s whistle policy. The Company does not tolerate acts of relation, including demotion, discharge, discipline, discrimination, harassment, suspension or threats, against any Green Energi Utama Representative who makes a good faith report of known or suspected acts of misconduct or other violations of this code.

ADHERENCE TO CODE AND DISCIPLINARY ACTION

All Green Energi Utama Representatives have a responsibility to understand and follow this Code. In addition, all Green Energi Utama Representatives are expected to perform their work honestly and integrity in all areas not specifically addressed in this policy. The Corporation will discipline any Green Energi Utama Representative who violates this Code or related practices. The determination of the appropriate discipline will be made by the Chief Executive Officer in consultation with the Chairman of the Corporation’s Governance Committee or by the Board. Such discipline may include, among other things, written notice to the Green Energi Utama Representative that the Corporation has determined that there has been a violation, censure by the Corporation, demotion or reassignment, suspension with or without pay or benefits, or termination of the Green Energi Utama Representative’s relationship with the Corporation. Records of all violations of this Code and the disciplinary action taken will be maintained by the Compliance Officer and will be placed in the applicable Green Energi Utama Representative’s personnel file. The Corporation will notify and cooperate with the police or other governmental authorities regarding acts of Green Energi Utama Representatives involving violations of law. In addition, some violation may result in the Corporation bringing suit against employees or former employees to defend its rights vigorously.

CONSEQUENCES OF VIOLATION OF THE CODE BY CO-WORKERS, CONSULTANTS, AND THIRD PARTIES

Any violation of the Code of Ethics by collaborators, consultants or third parties acting under a contractual, non-employment relationship with the company, may lead, in accordance with the specific contractual clauses of their assignment, to termination of such relationship, subject to the Company’s claim for damages where such violation causes damages to the company even regardless of contractual termination.