Corporate Governance

Code of Ethics

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.

Overview of Our Risk Management, Compliance and Internal Audit Functions

In performing the risk management function, the Company implements 3 (three) lines of defense against risks which include:

  1. First line: Business units
  2. Second line: Risk management and compliance unit
  3. Third line: Internal audit

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

Performing of 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.

The implementation of 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 resposibility 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.

In carrying out the Company's risk management, compliance and internal audit functions, the Company forms an Audit, Risk and Compliance Committee which has a responsibility line to the Board of Commissioners.

Guidelines for the Board of Directors and the Board of Commissioners

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 Board of Commissioners is responsible to carry out general and/or special supervision in accordance with the articles of association and providing advice to the Board of Directors.

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.