Code of Conduct

1. Background

PT FAP Agri Tbk hereinafter referred to as “Pthe company”, realizes the importance of implementing good corporate governance ( corporate governance/GCG) as one of the references for the Company to increase value and sustainable long-term business growth.

The trust of stakeholders (stakeholders) such as employees, customers, suppliers, creditors and other stakeholders is a very decisive factor for increasing value and continuity of activities the Company’s business. The image and reputation of the Company with the trust of stakeholders is closely related to the behavior of each individual in the Company in interacting with the stakeholders. The management of the Company in addition to complying with the applicable laws and regulations, each individual in the Company is also required to have a high awareness of carrying out good ethics such as being honest, fair, and trustworthy so that the trust of stakeholders can be obtained and in the end can strengthen the Company’s reputation.

Individuals in the Company in this Code of Ethics are all members of the Board of Directors, members of the Board of Commissioners, including all employees and supporters of the Company’s organs (hereinafter referred to as “Individuals of the Company”).

On this basis, the Company has compiled this Code of Conduct (COC) to be applied as a standard of behavior that must be obeyed by all individuals Company. This Code of Ethics is a series of commitments consisting of business ethics and work ethics for each individual of the Company based on the self-awareness of each individual of the Company to apply it at all times both inside and outside the work environment, and is structured to shape or create the behavior and work culture of the Company. that meet good ethical values, which are based on the basic principles of GCG to achieve the vision and mission of the Company.

This Code of Ethics should be dynamic and follow the development of the world, the environment, society and its surroundings, so that this Code of Ethics can be reviewed and changed according to these needs by always upholding ethical values good.

2. Foundation of Compilation

The preparation of this Code of Conduct is based on the following basic principles of GCG :

a. Transparency (Ttransparency): To maintain objectivity in conducting business, the Company must provide material and relevant information in a manner that is easily accessible and understood by stakeholders and presented in an accurate and timely manner. The Company must take the initiative to disclose not only issues required by laws and regulations, but also matters that are important for decision making by shareholders, creditors, and other stakeholders.

b. Accountability (Accountability): Responsible for the Company’s performance in a transparent and fair manner and for that the Company must be managed correctly, measurably, and in accordance with the interests of the Company while taking into account the interests of shareholders and other stakeholders. Accountability is a necessary prerequisite to achieve sustainable performance.

c. Responsibility (Responsibility): Comply with relevant laws and regulations and sound corporate principles and carry out responsibilities towards society and the environment so that business continuity can be maintained in the long term.

d. Independence (Independency): Manage the Company independently so that each organ of the Company does not dominate each other and cannot be intervened by other parties.

e. Fairness and Equality (Fairness): Pay attention to the interests of shareholders and other stakeholders based on the principles of fairness and equality.

3. Visi and the Company’s Mission

Vision : To be the Best Palm Oil Company from All Aspects.

Mission :

a. Carrying out Business Development by Paying Attention to Responsibilities

b. Increasing Company Profitability Through Effective and Efficient Management

c. Produce Quality Products and International Standards d. Developing Competent Human Resources

d. Developing Competent Human Resources

4. Corporate Values

The values adopted by the Company are as follows:

a. Integrity : Upholding the values and culture of the Company, Doing the right thing without being supervised, and only actions with words.

b. Commitment : Work with all my heart, sincerely and thoroughly, Caring / Care, and Loyal and Love to work and the Company.

c. Result : Creative and innovative thinking, Continuous improvement, and giving the best

5. Purpose and Purpose

Mean

The Code of Ethics is prepared to help each individual in the Company understand, appreciate, and have their own awareness to behave ethically in carrying out all activities in the Company based on GCG principles, behave well, create an environment work that upholds the values of honesty, openness, fairness, and trustworthiness and creates a healthy and comfortable working atmosphere within the Company’s environment, minimizing the opportunity for irregularities that are part of risk management so as to strengthen the Company’s reputation.

Goal
As a shared commitment to realize the vision and carry out the Company’s mission in a professional and business ethics manner.

6. Business Ethics and Company Work Ethics

6.1 Business Ethics

Business ethics in this Code of Ethics are values ​​and norms that serve as a reference for each individual of the Company to behave with business ethics based on GCG principles in carrying out their business activities so that they become part of the Company’s culture.

6.1.1 Conflict of Interest
Conflict of interest is a situation where a person because of his position or authority in the structure of the Company has a personal interest that can affect the implementation of the tasks mandated by the Company so that its implementation is not objective. With regard to the conflict of interest conditions, all employees need to:

a. Avoid conflicts of interest in any form and personally always prioritize the Company’s business interests above personal interests or other parties.
b. Disclosure if the employee has a competing or supplying business, or has the same business activities as the Company’s business activities.
c. Not conducting transactions and/or using company assets for self, family or group interests.
d. Not receiving and/or giving gifts and/or benefits in any form from customers, suppliers, and/or business partners related to their position in the Company. In the event that for one reason or another the employee is unable to refuse gifts and/or benefits from customers, suppliers and/or business partners, the employee concerned is obliged to report/disclose to his superiors.
e. Do not take advantage of the Company’s confidential information and business data for interests outside the Company’s environment.
f. Not exploiting and using the Company’s intellectual property rights that can harm the interests or hinder the development of the Company.
g. Not holding any position in the Company/institution that wants and/or is doing business with the Company or who wants and/or is competing with the Company.
h. Not giving preferential treatment to customers, suppliers, business partners, government or other parties beyond the policies set by the Company.
i. Disclosing and reporting any interests and/or activities outside the Company during working hours to their superiors to obtain permission.
j. Report to the leadership of the Company if you have family relationships with partners, competitors or suppliers of the Company’s activities and are willing not to be involved in the decision-making process.

6.1.2 Giving and Accepting Gifts, Bribes and Donations
Bribery is an act of giving or promising something to someone and/or a government official that will influence decisions related to his position, including doing or not doing something in his position that is contrary to his obligations. The forms of bribes can be in the form of, but not limited to, money, gifts, goods or other forms that are rewards. Each employee is not allowed to:

a. Giving or receiving bribes that can influence decisions or direct someone to give or receive bribes.
b. Offering services for the purpose of obtaining personal gain in violation of predetermined rules.
c. Providing more facilities to other parties in exchange for personal gain
d. Accepting illegal gifts or gifts or the purpose of giving that is not justified from any party who wants, will and/or is having a business relationship with the Company.
e. Taking other actions that can be categorized as bribery according to the provisions and applicable laws and regulations.

Prizes can be in the form of money or its equivalent, namely checks, vouchers, bilyet giro, goods in other forms given by or to a person and/or government official because of their position:

a. Every employee is not allowed to accept and give gifts in any form that can influence decision making that violates existing provisions.
b. In order to maintain or maintain business relationships, the Company may incur expenses that can be accounted for at the expense of the Company, among others: religious holidays, official anniversary celebrations, farewell to Company officials and expressions of sympathy.
c. Assistance to third parties in the form of goods must include the logo/name of the Company.

6.1.3 Compliance with Legislation
a. Each individual of the Company must implement the laws and regulations of the Company.
b. Each individual in the Company maintains a healthy, harmonious and constructive relationship with legislators (regulators) and other relevant agencies from the central government and regional governments, and must avoid the practice of Corruption, Collusion and Nepotism (KKN) in

7 Maintaining the Company’s Good Name

The reputation and good name of the Company is always attached to the behavior of each individual of the company, because every individual of the company must always include:

a. Maintain and maintain good ethical behavior within the work environment with the Company and outside the work environment with the Company.
b. Care and maintain the good image and reputation of the Company.
c. Committed and consequently applies the Company’s ethics including this Code of Ethics, Company policies, Company Regulations and/or applicable laws and regulations.

8. Anti-Corruption and Anti-Money Laundering

The Company always applies the principles of GCG in carrying out its business activities and complies with the prevailing laws and regulations, including regulations regarding prohibition of taking actions or being involved in KKN, and money laundering ( money laundering) or facilitating any such KKN or money laundering activities. Any violation of the provisions of this regulation may result in criminal or civil sanctions in accordance with the applicable laws and regulations.

9. Inside Information

Each individual of the Company is obliged to protect and maintain the confidentiality of the Company’s Confidential Information and therefore is prohibited from using and/or disclosing Confidential Information for any purpose or interest, other than for the benefit of the Company’s business activities. All information available within the Company that is not in the public domain is the Company’s Confidential Information which must be protected and kept confidential by every individual of the Company.

10 Political Activities

The Company’s Code of Conduct guarantees all employees to be able to exercise their right to the opportunity to channel their political aspirations. The Company does not make political contributions and is not affiliated with any political party. Against political activities, all employees.

a. Do not take advantage of names, assets and opportunities for certain political purposes
b. Not on behalf of the Company or contributing on behalf of the Company to any political party.
c. Do not make misunderstandings, engagements, statements either directly or indirectly which shows that the Company has an attachment to any political party.
d. Every activity to channel political aspirations must be done outside of working hours and does not use the Company’s attributes.
e. Not holding positions in political parties or political activities that will interfere with their duties in the Company.
f. Not carrying out political activities, either directly or indirectly within the Company.

11. Enforcement and Reporting

a. All departmental leaders or superiors are responsible and set an example for their subordinates for the implementation of this Code of Ethics.
b. The implementation of the Code of Ethics is the commitment and responsibility of all the Company’s Individuals. In the event of a violation or deviation, each individual of the Company is required to report the violation through:
1. Corporate Secretary (Corporate Secretary).
2. The Company’s superiors.
3. Complaints contact at number (WA): +62 812-8046-2100
4. Board of Commissioners.
5. Suggestion box available
c. The reporting as referred to above must be carried out in good faith and is not a personal complaint against a certain Company policy.
d. The reporting format must clearly state the identity accompanied by relevant supporting evidence. The recipient of the report and the Company must keep the identity of the reporter confidential.
e. The Company is obliged to accept and ensure that reports of violations of the provisions of this Code of Ethics are processed fairly and in a timely manner.
f. The Company is obliged to guarantee the confidentiality of the identity and protection of every individual of the Company who reports a violation of the provisions in this Code of Ethics.
g. Sanctions in accordance with the rules and regulations that apply in the Company will be given to every individual of the Company who violates the provisions of this Code of Ethics.
h. Sanctions for employees who violate this Code of Ethics are decided by the Company’s Board of Directors.
i. Sanctions for members of the Board of Commissioners and Board of Directors who violate the Code of Ethics are decided in the General Meeting of Shareholders.

12. Closing

This Code of Ethics is provided as a guide for each individual of the Company and must be disseminated to all the Individuals of the Company. By the leadership of the Company for the following purposes:

a. Can be understood by all Company Individuals
b. Growing the awareness of the Company’s Individuals to implement it
c. Instilling the principle that the Code of Ethics is an integral part of business practices and performance appraisal of all the Company’s Individuals.

If there is any doubt regarding the implementation of the provisions of the Code of Ethics, each individual of the Company in the Company may consult with his superior or the Department appointed by the Company.