In order to make the Company as a sound Investment Manager, the Company has a Code of Ethics that will provide guidance on how the Company behaves in an ethical, credible and good governance manner in carrying out its business activities.

The principles implemented in the Company's Code of Ethics include independence, integrity, professionalism, prioritizing the interests of Investment Products, supervision of controls, adequacy of resources, asset protection of Investment Product, information disclosure, conflict of interest, protection against the risks of money laundering, terrorism financing, and proliferation for mass destruction weapons, and compliance.

The Company's internal procedures and policies will be referred to this Company's Code of Ethics and Internal Company is required to commit to implement the Company's Code of Ethics. The Internal Company includes the Board of Directors and the Board of Commissioners, as well as all employees of the Company.

Company has Risk Management Framework designed to increase awareness and vigilance towards risk management across all business lines or internal functions of the Investment Manager in the Company. Based on Risk Management Framework, risk governance structure implemented by the Company is 3 (three) lines Model that consists of 6 (six) Principles, as follows:

1. Governance
2. Roles of Governing Body
3. Management and First and Second Line Roles
4. Third Line Roles
5. Third Line Independence
6. Creating and Protecting Value

The structure of 3 (three) lines consists of:

1. First line. First line comprises front office and back office related to delivery of products and/or services to the clients. First line consists of Investment and Research Function, Dealing Function, Securities Transaction Settlement Function, Marketing and Customer Complaint Handling Function, Accounting and Finance Function, Human Resources Development Function, and Information Technology Function.
2. Second line. Second Line plays roles in providing assistance related to managing risk that focuses on the specific objectives of Risk Management, such as compliance with laws, regulations, and acceptable ethical behavior, internal control, security of technology and information, sustainability, and quality assurance. Second Line consist of Risk Management Function, Compliance and Legal.
3. Third line. Third line provides assurance and insight into the adequacy and effectiveness of governance and Risk Management. The one who plays this third line role is Internal Audit Function.

The risks managed by the Company include risks related to investment products and risks related to the Company as an Investment Manager. To carry out the risk management above, the Company develops a risk management strategy that is adjusted to the size and complexity, as well as the Company's capabilities.

Monitoring risk management and control within the Company is carried out regularly to minimize the Company's exposure to risk.

Performing the compliance function will assist in ensuring the Company's compliance with applicable laws and regulations, including in this case the Financial Services Authority Regulations, and internal procedures and policies, as well as the Company's Code of Ethics. As guidance in implementing this Compliance Function, Company has a Compliance Framework and Compliance Manual.

Company has also Internal Audit Charter to implement Internal Audit Function. The Internal Audit Function will ensure that the Company's operations are carried out in accordance with established procedures within the Company. Audit findings will be reported directly to the President Director and the Board of Commissioners.

The Company's Risk Management, Compliance and Internal Audit Functions are defined as part of the Company's organizational structure and have direct responsibility line to the Board of Commissioners, and act independently and have unlimited access to other Investment Manager functions related to the implementation of their duties.

To oversee the implementation of the Company's Risk Management, Compliance and Internal Audit functions, the Board of Commissioners has formed an Audit Committee headed by an Independent Commissioner, The duties of this Audit Committee are outlined in the Audit Committee Charter.

The Board of Directors is fully responsible for managing the Company on behalf of the Company in accordance with the aims and objectives of the Company, and for representing the Company, both inside and outside the court in accordance with the provisions of the articles of association. The duties and responsibilities of the Board of Directors are outlined in the BOD Charter.

The Board of Commissioners is responsible for carrying out general and/or special supervision in accordance with the articles of association and providing advice to the Board of Directors. The duties and responsibilities of the Board of Commissioners are outlined in the BOC Charter.

In addition to referring to the articles of association, in carrying out their duties and responsibilities, the Board of Directors and Board of Commissioners are guided by the applicable laws and regulations, including, but not limited to the Law regarding Capital Markets, Financial Services Authority Regulations concerning Implementation of Investment Manager Governance, Code of Conduct for Investment Managers, Implementation of Activities in the Capital Market Sector, Implementation of Anti-Money Laundering Programs, Prevention of the Financing of Terrorism, and Prevention of Funding for the Proliferation of Mass Destruction Weapons in the Financial Services Sector, Protection of Consumers and Communities in the Financial Services Sector, and its amendments and replacements there might be in the future.