CORPORATE POLICY

WHISTLEBLOWING SYSTEM

PT CAPITAL FINANCIAL INDONESIA Tbk

I. PURPOSE

Facilitating employees and other external parties so that they can submit reports about alleged unlawful behavior and unethical conduct in the work environment;
Protect whistleblowers from internal and external parties;
Detect early violations.

II. HOW TO SUBMIT VIOLATION REPORTS

Delivering official letters addressed to Personnel with a copy to the Directors and Board of Commissioners, by direct delivery, sent via facsimile, or by post to the Company:

By e-mail: wbs@capitalfinancial.co.id
Delivered to the official address.

PT CAPITAL FINANCIAL INDONESIA Tbk

 Jamsostek North Tower 5th floor, JL. Gatot Subroto Kav. 38 Jakarta Selatan 12710 – Indonesia

Telp : + 62 21 270 82002

Fax :   +62 21 270 82001

III. MADE IN REPORT

Acts that can be reported (violations) are acts that are in the view of the reporter in good faith are the following acts:

Corruption;
Fraud;
Dishonesty;
Acts that violate the Collective Labor Agreement
Unlawful acts (including theft, use of violence against employees or leaders, extortion, drug use, harassment, other criminal acts);
Violations of taxation provisions, or other legislation (environment, mark-ups, under invoices, employment, etc.);
Violation of the Company's Code of Ethics or violation of norms of decency in general;
Acts that endanger occupational safety and health, or endanger the security of the Company;
Acts that can cause financial or non-financial losses to the Company or harm the interests of the Company;
Violations of the Company's standard operating procedures (SOP), mainly related to the process of procurement of goods and services, the provision of benefits and remuneration.

IV. ACCEPTANCE OF REPORTING

The Company accepts every Report of Violation submitted by:

Employee;
The supplier;
Customer;
Investor;
The bank; and
all other stakeholders, both internal and external.

V. PROTECTION FOR REPORTERS

The Company will protect the reporter by guaranteeing the confidentiality of the reporter's identity and the contents of the report submitted unless required to be disclosed under the law. False reports may be subject to sanctions following Company regulations and/or applicable laws.

VI. THE HANDLING OF COMPLAINTS

 Complaint handling procedure:

If the violation complaint is related to the employee, the investigation team is led by the Head of Personnel; if the violation complaint is related to the Board of Directors, then the investigation team is led by the Board of Commissioners;
Every complaint is followed up by an investigation team consisting of at least an internal audit unit;
The investigation team will investigate by looking for evidence from both the reporter and related parties;
The results of the investigation will be reported to the President Director and/or the Board of Commissioners;
If a violation is proven, then it is followed up by the Personnel and/or Legal section following applicable regulations.

VII. CLOSING

This Violation Reporting System Policy takes effect after it is signed;
If there is a change in the Articles of Association of the Company relating to the material of this Policy, then this Policy Reporting System of Violations can be revised following applicable regulations.

Set in Jakarta

On July 18, 2016