Management of Conflict of Interest & Insider Trading

PROVISION ON INSIDER TRADING

Pursuant to the Decree No. 39.3/SK/WBP/PEN/2017 on Good Corporate Governance Guidelines:

• Conflict of interest is the difference of interests between the economical interests of the Company with the personal interests of the member of the Board of Directors, Board of Commissioners, or Shareholders.
• PT Waskita Beton Precast Tbk develops the conflict of interests policy ensuring that the Board of Commissioners, the Board of Directors and employees to prevent themselves from conducting transactions that contain any conflict of interest without prior approval form the Shareholders.
• Member of the Board of Commissioners and the Board of Directors must disclose any share ownership in other companies in a special register as required by the prevailing laws and regulations.
• PT Waskita Beton Precast Tbk will remind its employees, in all levels to be aware of the conflict of interest policy. Every employee must fully report and disclose every activity that contains any conflict of interest.
• All transactions that contain any conflict of interest between the Company and employees, member of the Board of Directors and the Board of Commissioners must be disclosed completely to the Shareholders.

Conflict of interest occurs if:

• Abusing the position for personal, family and other parties interest or benefit.
• Utilizing confidential information and business data of the Company for the interests outside of the Company.
• Serving a position in a competitor’s company and/or business partner or potential business partner of the Company that may cause conflict of interest.
• Has family relationship by blood up to the third degree and or marital relationship with Member of the Board of Directors and/or Member of the Board of Commissioners.
• In the discussion and decision-making that contains conflict of interest element, the relevant party is not allowed to participate.
• Has a business that is directly related with the Company’s activities.

In terms of operational sector, especially in goods and services procurement should not have conflict of interest, namely:

• Conflict of interest in goods and services procurement.
• Goods and services providers affiliated with the employees and/or the Board of Directors of PT Waskita Beton Precast Tbk.
• Goods and services procurement that is controlled by certain goods and services provider.

Implementation of conflict of interest in PT Waskita Beton Precast Tbk is significantly affected by:

• Leader’s commitment in the Board of Commissioners, the Board of Directors, Management or working groups of employees.
• Catalyst of the implementation and development of conflict of interest by the HR & GA Department.
• Dissemination to all employees.

Sanctions on conflict of interest violation

• Every employee that conducts conflict of interest violation will be sanctioned in accordance with the level, nature, and frequency of violation.
• Procedure of imposing sanction in accordance with the Company’s Regulations of PT Waskita Beton Precast Tbk.

Requirements for reporting on conflict of interest violation

• Every employee must report the conflict of interest violations to the HR & General Affairs Department.
• Every employee that reports alleged violation on conflict of interest must disclose his/her identity clearly.
• Confidentiality of the whistleblower identity must be maintained, except if it is necessary of the report follow up in accordance with the policy of the Company.
• No punishment is imposed on whistleblower in the event that such violation occurs, except that the related person is involved in the violation and/or the report is false.
• HR & General Affairs Department must follow up the report in accordance with the scope of its authority.
• HR & General Affairs Department must report to the Board of Directors to be followed up in accordance with the Company’s policy.