This Code of Conduct (‘CoC”) is derived from PPLI needs to run business in line with good governance and high quality standard, to increase compliance of PPLI internal regulations and the applicable law and regulations, mutual beneficial working relations, and to create superior PPLI ethic and culture.

This CoC is prepared as a behavior reference to Commissioners, Directors and employees and business partners to achieve PPLI’s vision and mission.

This CoC is applied to:

1. All PPLI’s Employees and Directors
2. PPLI’s subsidiaries and affiliates in Indonesia
3. External party works for and on behalf of PPLI
4. Supplier or Third Party cooperate with PPLI

Vision
• PPLI intends to be the leading provider of environmental services in Indonesia, by using our highly qualified and experienced resources.

Mission
• PPLI is the premier provider of Integrated Environmental Waste Management Services in Indonesia, with commitment to minimize our customer’s environmental risks.

• Ethics and Integrity Commitment to act with integrity and honesty in all situation, and always try to do the right thing in guided by moral compass.
• Safety and Compliance Take responsibility of own safety and for those around us, follow procedure, and speak up and stop working if unsafe and non compliance conditions appear.
• Customer Focus Always understand customer needs and provide more than customer expectation through best effort.
• Quality Focus Always passionate to achieve high standard quality, striving for continous improvement for better result.
• Team Work Proud to be part of PPLI and commitment to help each other in order to achieve Company success.

a. Relations with Shareholders
PPLI tries to keep investment and guarantee fair result for its shareholders. PPLI commits to communicate honestly, accurately and periodically on the result achievement and business prospect to evaluate the investments. In providing the information and clear business description to its shareholders, PPLI will provide the information clearly, accurately and fairly, in compliance with the applicable regulations.

b. Relations with Customer
PPLI main priority is responsibility to satisfy customer’s need. PPLI will always try to understand customers’ need and place customers as number one for the services provided by PPLI.

c. Relations with Business Partners
PPLI commits to build quality relations with other companies to broaden its reach and influence and also its competitiveness in the industry. Relation based on trust is one of the most important aspects. PPLI always commits to keep its reputation. PPLI will not conduct business with those who are aware and continuously conflict with PPLI business ethic spirits. PPLI respects honest and open business relations as a way to build beneficial cooperation. PPLI procurement policies are referred to PPLI’s interest with the consideration to quality, price and service.

d. Relations with Government
As a company that is well and responsibly managed, PPLI is always in compliance with the applicable law and regulations in conducting its business, and provides accurate, clear and balance description on PPLI operational. PPLI commits to build constructive and harmonious communication with government.

e. Relations with employee
Knowledge, skills, and employee experiences are assets to the business development. Employee existence holds an important role in the business success. Thus, PPLI urges the creation of the spirit to respect and appreciate, and fairness and pride. PPLI hires an employee based on his/her capability to work and provide salary based on his/her performances, PPLI commits to provide safe and conducive working environment, and fight for the availability of same opportunity for career development. PPLI practices policy that allows employees to convey opinions openly in a respectful atmosphere.

f. Relations with Mass Media
Mass media, printed or electronic are main information and communication channels for PPLI and stake holders in obtaining data and information through the correct channel. Only authorized personnel is allowed to provide response to media. All employees has to give good image in all media appearances, and convey all questions from media to PPLI Public Relations.

g. Relations with Public
PPLI is a business entity that is responsible and actively support community through Corporate Social Responsibility (CSR) Programs, PPLI respects and cares about the environment. PPLI will try to realize the mutual benefits to encourage community empowerment creation. PPLI supports and encourages it employees to actively contribute to the community welfare creation.

h. Fair Treatment
Whomever having business with PPLI is entitled of fair treatment. This applies without considering the type of business with outside organization-buying, selling, receiving service or representing PPLI in any capacity.
In relations with marketing activities or services, PPLI’s employees are obliged to compete in a healthy way, effectively, maximally, and fair to all clients or suppliers.
Employees are also obligated to treat all suppliers fairly, where there is not any special treatment in determining suppliers, thus suppliers can compete in a healthy way.

i. Conflict of Interest
Conflict of Interest occurs when PPLI employee has interest other than PPLI’s interest that affects the decision making and resulting in PPLI failed to gain the best result. Decision and business conduct must be done based on PPLI main interest and not affected by kinship and personal consideration. Relations with PPLI stakeholders, in example suppliers, competitors, clients, cannot affect one’s responsibility and accountability to PPLI.
Employees are prohibited to accept material or immaterial thing, in any form, include but not limited to goods, money, rewards, commision, compensation/incentives, loan, grant, holiday facility and/or other benefits due to his/her position in PPLI that it could create conflict of interest.

j. Prohibition in giving and/or receiving Gifts,Gratification, Bribery, and other forms of Bribery.
Gratification is giving in a wider scope, consists of giving money, goods, discount, commission, soft loan, travel ticket, accommodation, medical expense and other facilities, both received in home country or abroad, electronically or non-electronically, directly or indirectly.
PPLI employees are prohibited to accept/give gratification to/from customers, suppliers and other business partners. Employee is obligated to report to management in regards to any situation related to accepting or giving gratification.
PPLI employees are prohibited to accept/ give bribery or promise to accept/give bribery, and not lead other to conduct bribery in PPLI environment or outside of PPLI, will not give/ offer directly or indirectly a gift or other unreasonable payment to a party outside of PPLI to gain benefit or special treatment in doing PPLI business transaction.

k. Public Statement
In general, employee is not allowed to give statement related to a certain issue or matter that is not part of his/her authority in the company.
PPLI believes that each external relations or communications by its employee with external party should be conducted in a careful manner, especially related to confidential data and information, or information that potentially can cause disruption or pressure that can harm PPLI development. Data or information provision to external party to fulfill obligation to the Country, legal proceedings and for PPLI interest as citizen, should obtain approval from the Directors or appointed officials and coordinate with the organization unit approved by PPLI.

l. Compliance to Laws & Regulations
Each employee should comply with the applicable laws and regulations. This includes the understanding on the Laws and Regulations in accordance with the employee’s obligation and responsibility and compliance with the applicable laws in the country, region or community where the employees work or originated.

m. Individual Responsibility
In implementing PPLI’s mission, moral and work ethic must be placed in the highest order. As PPLI’s representative, while doing our task, we have to always keep PPLI good name and reputation. Apart from relying on the periodic audit, PPLI will always nourish a conducive environment for the creation of responsibility and trust among PPLI employees.

n. Safety, Health and Good Working Environment
PPLI commits to protect Safety and Health of all PPLI employees. Thus everyone is responsible to create safe & healthy working environment. PPLI will try to provide safe and healthy working environment and avoid the impact to the damage of the environment.
List of activities that are not allowed to happen in PPLI that will create unconducive, unhealthy and unsafe working environment, included but not limited to:

• threat others;
• destructive behaviors;
• possession of weapons;
• use, distribution, sell or ownership of psychotropical drugs and other additive substances, unless previously approved by the applicable regulations;
• to be in PPLI working area influenced by drugs or alcohol;
• any form of harrasment at work place, between employee/supervisor and other employee (vertical relation), or between employee to other employee (horizontal relation), or between employer to contract worker or outsourcing worker, and between employee with client/third party; and/or
• work not incompliance with applicable health and safety regulations PPLI employees that are involved in prohibited activities above will be charged with disciplinary action that can lead to work termination.

o. Same opportunity for Work and Promotion
PPLI work environment should be free from race, skin color, religion, gender, ethnicity, age, personal incapability discrimination and other factors that can affect PPLI’s business interest. PPLI gives equal opportunities and fair treatment to all employees.

p. Use of PPLI assets properly
PPLI assets do not only include data and information, but also physical assets. PPLI information consists of intellectual properties that are the result of employee’s ideas and hard work. This also includes confidential data trusted to employees that are related with his/ her work.
Good management of significant data and information which are assets to PPLI will be one of supporting factor to PPLI business success.
Employees are responsible to manage data and information safely and effectively. Employees are trusted to use different type of PPLI assets to support PPLI’s interest. Lost, theft, oversight, waste of the assets can affect PPLI directly. Employees should be responsible to protect PPLI assets and ensure efficient use. All assets, information, equipment and sources can be used for business purpose only. The use of PPLI asset for personal interest is prohibited.

q. Information and Intellectual Property Confidentiality
PPLI information are all kind of information/ data obtained or kept related to PPLI, included but not limited to any kind of intellectual property, material, data, report, research result, sample, business plan, computer data, standard operational procedure, client contact, email, letter, recording, and any information disclose or given by PPLI.
Each employee is obligated to keep and protect information and data confidentiality trusted by PPLI and his/her Clients, unless legally approved or obligated as per the applicable regulation. Confidential information includes PPLI data that cannot be disclosed due to possible used by competitors or other party that can disturb PPLI, Employees, Clients, or Suppliers.
Employees are not allowed either to use or spread data and information belongs to an ex- employee or other people or other institution to PPLI.
Employees are obligated to keep confidential data and information related to PPLI business. This obligation is still applied even though the employee is not bound by employment agreement with PPLI anymore, and when he/she resigns or retires, he/she is not allowed to bring copy of confidential data and information, or disclose them to others, ie. New Supervisor. If the confidential data and information needed to be disclosed, it should be consulted with PPLI appointed Legal.
Employess are expected to be discreet in managing and keeping either in softcopy nor hardcopy. Negligence in managing and keeping documents, that caused document to be scattered and read by a person who is not entitled nor responsible, sanction will be imposed.

r. Side Business
Each employee should be free from financial connection such as shareholders with any institution that has a potential to cause conflict of interest with PPLI. Said institution are not limited to business partners, suppliers, competitors, clients, family business or organizations that has different type of relation with the PPLI.
PPLI adopts policy that prohibited employee to be involved in the possession or management of certain business aside from PPLI interest. Exception can be done upon Director’s approval.

s. Private Commission
Each employee is prohibited, during their job tenure, to accept or try to get commision or personal benefit, discreetly or without PPLI consent, from every business partners, customers, client, contractors, suppliers, government officials, or other people related to PPLI in regards to every quotation and/or payment given.

t. Fraud and Theft
For every fraud, embezzlement, and theft occured in PPLI or in relations with PPLI, will be investigated, reported and after investigation punishment will be imposed accordingly in accordance with the applicable law and regulations.
Every incident suspected as fraud and theft should be reported immediately to PPLI or the appointed official.

Every PPLI employee is obliged to obey this CoC. During the implementation, there is a possibility that an employee will find violation done by other employee, business partners or other parties related to this CoC. Such incident occur, employees are suggested to discuss it with his/her superior or officials for this role: Human Capital

This CoC is aimed to the simultaneous and comprehensive implementation. Thus employees are expected to obey this CoC because of self awareness not because of coercion from outside. In the event of breach to this CoC, any employee shall report through the Helpline Services owned by PPLI.

PPLI expects that its business/ operations will run in a clean manner, thus employees are encouraged to actively participate in reporting any suspicion for any allegedly violation to CoC, PKB or PPLI Regulations, and applicable law and regulations known by PPLI employee and conducted by PPLI employee.

The report should be supported with relevant data and aimed for the benefit of PPLI, not with the aim to bring someone down. PPLI commits to facilitate the employees and other parties to channel their reports Helpline Services by using below channels:

Telephone : 087700072111
Fax : 021-4267293
SMS : 087700079111
Email : helpline_ppli@lawyerindo.com
Mailbox : PT Lawyerindo Integrasi Jasapro
Jl. Angkasa No.12AB, Kemayoran, Jakarta Pusat 10610

Report through Helpline Services is done with the anonymous, confidential and independent principles.

The scope of violation that can be reported thorugh Helpline Services are:
1. Corruption
2. Bribery
3. Conflict of Interest
4. Theft
5. Fraud
6. Violation to Laws and PPLI Regulations

The CoC of PPLI is a normative rules and a minimum standard that should be obeyed by every PPLI employees in conducting daily work. This CoC can be implemented together with other the regulations applicable in PPLI and/or other applicable regulations.

If there is any provision in this CoC conflicted with the applicable regulations then such provision in the CoC became void, and specific for that provision, the applicable regulation is considered replacing the specific provision of CoC.

This CoC may be amended in accordance with the needs of PPLI. While the revision is in the process, this CoC is still applicable until the new amendment is in force.

This CoC is distributed to all of PPLI employees to be understood and used in a proper manner.