Appendix I to Financial Services Authority Circular Letter No. 19/SEOJK.04/2018 on Investment Manager Governance Implementation Report

APPENDIX I
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
NUMBER 19 /SEOJK.04/2018
REGARDING
INVESTMENT MANAGER GOVERNANCE IMPLEMENTATION REPORT

SELF-ASSESSMENT WORKSHEET
INVESTMENT MANAGER GOVERNANCE IMPLEMENTATION REPORT

Explanation:
Self-assessment of Governance is conducted using Dichotomous and Discrete methods, namely there are indicators using a scoring type with Yes and No answers, and there are indicators using a scoring type with an application scale ranging from a score of 0 to 1, with the following provisions:
a. A checkmark (√) in the NB (Not Good) column is valued at 0: if the indicator is not fully implemented/fulfilled. b. A checkmark (√) in the IG (Insufficiently Good) column is valued at 0.25: if most of the indicator is not yet implemented/fulfilled.
c. A checkmark (√) in the FG (Fairly Good) column is valued at 0.5: if part of the indicator is implemented/fulfilled.
d. A checkmark (√) in the G (Good) column is valued at 0.75: if most of the indicator is implemented/fulfilled. e. A checkmark (√) in the VG (Very Good) column is valued at 1: if the indicator is fully implemented/fulfilled. f. A checkmark (√) in the Yes column is valued at 1: if the indicator is fully implemented/fulfilled. g. A checkmark (√) in the No column is valued at 0: if the indicator is not fully implemented/fulfilled.

I. Implementation of Duties and Responsibilities of the Board of Directors
A. Governance Structure a b c d e

1. The number of Board of Directors members is at least 2 (two) people. Yes No

All Board of Directors members meet the requirements of integrity, financial reputation, competence and expertise in the Capital Market field (have passed the competency and propriety assessment). Yes No
3. All Board of Directors members have individual licenses
as Securities Company Representatives. Yes No

4. One of the Board of Directors members has an individual
   license as an Investment Manager Representative. Yes No
5. All Board of Directors members are appointed through the GMS
   including the extension of the Board of Directors' term of office. Yes No 6.
   The determination of the number and composition of the Board of Directors has regard to the provisions of the Financial Services Authority Regulations, the condition of the Investment Manager, diversity of knowledge, experience and/or expertise required, and effectiveness in decision-making. VG G FG IG NB
6. All Board of Directors members reside in Indonesia. Yes No

Board of Directors members, either individually or together, do not hold shares exceeding 20% (twenty percent) of paid-up capital in another Investment Manager. Yes No 9. The majority of Board of Directors members do not have financial relationships and/or family relationships up to the second degree with other Board of Directors members, and/or with Board of Commissioners members and/or shareholders of the Investment Manager. VG G FG IG NB 10. The Investment Manager has a binding guideline for all Board of Directors members which at least contains legal basis, description of duties, responsibilities and authority, meeting policies and reporting and accountability. Yes No 11. Board of Directors members do not hold concurrent positions as Directors in other companies except for concurrent positions allowed in capital market legislation. Yes No

B. Governance Process a b c d e
12.
Board of Directors members are able to implement the competencies they possess in the execution of their duties and responsibilities. VG G FG IG NB 13. The Board of Directors carries out management with good faith, prudence and full responsibility in accordance with applicable legislation, the Articles of Association, and Board of Directors guidelines and acts independently for the interest of the Investment Manager. VG G FG IG NB 14. Board of Directors members do not grant general power of attorney to third parties resulting in the transfer of tasks and day-to-day functions of the Board of Directors. Yes No
15. The Board of Directors ensures that Governance is implemented effectively in the Investment Manager. VG
G FG IG NB
16.
The Board of Directors forms committees and/or units supporting the Board of Directors in order to support effectiveness in the execution of tasks and ensure that committees and/or supporting units carry out their tasks effectively. VG G FG IG NB
17. The Board of Directors provides accurate, relevant, and timely data and information to the Board of Commissioners. VG
G FG IG NB
18. The Board of Directors establishes policies and strategic decisions through Board of Directors meeting mechanisms. VG
G FG IG NB
19. The Board of Directors holds meetings at least 1 (one) time
every 2 (two) months. Yes No
20.
Board of Directors members attend at least 75% (seventy five percent) of the total number of Board of Directors meetings in a year, whether physically present, via circular resolution or via teleconference. Yes No

Decision-making in Board of Directors meetings is carried out based on consensus, in the event that consensus is not reached, decision-making is carried out based on the majority vote, or in accordance with provisions. Yes No 22. Every decision taken by the Board of Directors can be implemented and is in accordance with policies, guidelines, and work rules. VG G FG IG NB 23. The Board of Directors follows education and/or training on a continuous basis to assist in the execution of their duties. VG G FG IG NB 24. The Board of Directors is able to avoid shareholder intervention related to the operational activities of the Company. VG G FG IG NB 25. Board of Directors members do not abuse their authority for personal, family, and/or third-party interests. Yes No 26. Board of Directors members do not take and/or receive personal benefits from Investment Manager activities whether directly or indirectly other than lawful income and other facilities established by the GMS. Yes No 27. The determination of Board of Directors remuneration takes into account: VG G FG IG NB a. Remuneration applicable in the industry and scale of the Investment Manager's business; b. The duties, responsibilities, and authority of Board of Directors members are linked to the achievement of goals and performance of the Investment Manager both in the short term or in the long term;
c. Performance targets or the performance of each
Board of Directors member; and/or

• d. Balance between fixed and variable allowances.
  C. Governance Outputs
  a b c d e

28. The Board of Directors is accountable for the execution of
    their duties to shareholders through the GMS.
    VG
    G FG IG NB

Accountability of the Board of Directors for the execution of their duties is accepted by shareholders through the GMS. Yes No 30. Results of Board of Directors meetings are recorded in meeting minutes and documented well, including clear disclosure of dissenting opinions that occur in Board of Directors meetings. VG G FG IG NB
31. Results of Board of Directors meetings are distributed to all Board of Directors members. VG
G FG IG NB
32.
There is an increase in knowledge, expertise, and ability of Board of Directors members in the management of the Investment Manager, demonstrated among others through improved performance of the Investment Manager, resolution of problems faced by the Investment Manager, and/or achievement of results in accordance with stakeholder expectations. VG G FG IG NB 33. Board of Directors members are fully responsible for the truthfulness of the content of the Investment Manager's financial report. Yes No
34. In the Governance Implementation Report, the Board of Directors has disclosed at least:
VG
G FG IG NB a.
Execution of duties and responsibilities of Board of Directors members. b. Share ownership of Board of Directors members in the relevant Investment Manager, other Investment Managers, and Financial Service Institutions other than Investment Managers.

c. Financial relationships and family relationships
of Board of Directors members with Board of
Commissioners members, other Board of Directors members and/or Controlling Shareholders of the Investment Manager. d. Total remuneration and other facilities established by the GMS. 35. Non-disruption of Investment Manager operational activities and/or the existence of unfair benefits given to shareholders, resulting from shareholder intervention in the execution of the Board of Directors' duties. VG G FG IG NB Assessment Result a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

II. Implementation of Duties and Responsibilities of the Board of Commissioners
A. Governance Structure a b c d e
1.
All Board of Commissioners members meet the requirements of integrity and financial reputation (have passed the competency and propriety assessment), competence and expertise in the Capital Market field. Yes No 2. All Board of Commissioners members are appointed through the GMS, including the extension of the term of office of the Board of Commissioners. Yes No
3. The number of Board of Commissioners members of the Investment Manager
is at least 2 (two) people. Yes No
4.
The determination of the number and composition of the Board of Commissioners has regard to the provisions of the Financial Services Authority Regulations, the condition of the Investment Manager, diversity of knowledge, experience and/or expertise required, effectiveness in supervision, and providing advice to the Board of Directors. VG G FG IG NB
5. The number of Board of Commissioners members of the Investment Manager
does not exceed the number of Board of Directors members. Yes No

The majority of Board of Commissioners members do not have financial relationships and/or family relationships up to the second degree with other Board of Commissioners members, and/or with Board of Directors members and/or shareholders of the Investment Manager. Yes No
7. Have an Independent Commissioner. Yes No
8.
Independent Commissioners do not have financial, managerial, shareholding and/or family relationships with other Board of Commissioners members, Board of Directors and/or controlling shareholders or other relationships that could affect their ability to act independently. Yes No 9. The Board of Commissioners has a guideline binding on all Board of Commissioners members which at least contains legal basis, description of duties, responsibilities and authority, meeting policies and reporting and accountability. Yes No 10. Board of Commissioners members do not hold concurrent positions as Board of Commissioners in other Securities Companies except for concurrent positions allowed in regulations. Yes No B. Governance Process a b c d e 11. Board of Commissioners members are able to implement the competencies they possess in the execution of their duties and responsibilities. VG G FG IG NB 12. The Board of Commissioners obtains data and information that is complete, accurate, up-to-date, and timely from the Board of Directors. VG G FG IG NB

The Board of Commissioners carries out supervision against the execution of duties and responsibilities of the Board of Directors periodically and ad hoc and is carried out independently. VG G FG IG NB
14. The Board of Commissioners provides advice to
the Board of Directors and is carried out independently. VG G FG IG NB 15.
In the event that the Board of Commissioners makes decisions regarding matters established in the Articles of Association and/or applicable legislation, the decision-making concerned is carried out in its function as supervisor and advisor to the Board of Directors. For example: The Board of Commissioners is not involved in decision-making regarding operational activities of the Investment Manager, except in the case of providing funds to related parties and other matters established in the Articles of Association of the Investment Manager and/or applicable legislation in order to carry out supervisory functions. VG G FG IG NB 16. In order to carry out supervisory duties, the Board of Commissioners has directed, monitored, and evaluated the implementation of strategic policies of the Investment Manager. VG G FG IG NB 17. The Board of Commissioners forms committees in order to support effectiveness in the execution of tasks and ensure that the committee carries out its tasks effectively. VG G FG IG NB 18. In carrying out audit functions, the Board of Commissioners through Independent Commissioners reviews:
VG
G FG IG NB a. financial information to be issued by the Investment Manager to the Public and/or regulatory authorities

• b.
  independence, scope of assignment, audit service fees, expertise and experience, audit methodology, techniques and tools used, potential risks and evaluation results of the use of audit services, benefits of fresh eyes perspective that will be obtained through replacement of the Public Accountant, Public Accounting Firm and Audit Team from the Public Accounting Firm. c. plans and implementation of audits by the Public Accountant. d. implementation of compliance, risk management and internal audit functions of the Investment Manager. 19. The audit function carried out by the Board of Commissioners through Independent Commissioners evaluates the implementation of audit services for annual historical financial information by the Public Accountant and/or Public Accounting Firm at least through:
  VG
  G FG IG NB a. conformity of audit implementation by the Public Accountant and/or Public Accounting Firm with audit standards; b. adequacy of fieldwork time; c. assessment of the scope of services provided and adequacy of sampling; and d. improvement recommendations provided by the Public Accountant and/or Public Accounting Firm.

20. The Board of Commissioners supervises the
    implementation of Governance. VG
    G FG IG NB

The Board of Commissioners holds Board of
Commissioners meetings inviting the Board of Directors in the event there are findings indicating violations of Legislation. VG G FG IG NB
22. The Board of Commissioners holds meetings at least 1
(one) time every 3 (three) months. Yes No
23.
Board of Commissioners members attend at least 75% (seventy five percent) of the total number of Board of Commissioners meetings in a year, whether physically present, via circular resolution or via teleconference. Yes No 24. Decision-making in Board of Commissioners meetings is carried out based on consensus, in the event that consensus is not reached, decision-making is carried out based on the majority vote, or in accordance with provisions. VG G FG IG NB 25. Every decision taken by the Board of Commissioners can be implemented and is in accordance with policies, guidelines, and work rules that are in effect. VG G FG IG NB 26. The Board of Commissioners follows education and/or training on a continuous basis to assist in the execution of their duties. VG G FG IG NB 27. The Board of Commissioners is able to avoid shareholder intervention related to the execution of their duties. VG G FG IG NB 28. Board of Commissioners members do not abuse their authority for personal, family, and/or third-party interests. Yes No 29. Board of Commissioners members do not take and/or receive personal benefits from Investment Manager activities whether directly or indirectly other than lawful income and other facilities established by the GMS. Yes No

Remuneration of the Board of Commissioners takes into account: VG G FG IG NB a. Remuneration applicable in the industry and scale of the Investment Manager's business; b. The duties, responsibilities, and authority of Board of Commissioners members are linked to the achievement of goals and performance of the Investment Manager both in the short term or in the long term;
c. Performance targets or the performance of each member
of the Board of Commissioners; and/or d. Balance between fixed and variable allowances.
31.
The Board of Commissioners provides sufficient time to carry out their duties and responsibilities optimally. VG G FG IG NB
C. Governance Outputs a b c d e
32.
The Board of Commissioners is accountable for the execution of their duties to shareholders through the GMS. VG G FG IG NB 33. Accountability of the Board of Commissioners for the execution of their duties is accepted by shareholders through the GMS. Yes No 34. Results of the audit function carried out by the Board of Commissioners through Independent Commissioners are in accordance with legislation and company policies. VG G FG IG NB 35. Results of the audit function evaluation carried out by the Board of Commissioners through Independent Commissioners regarding the implementation of audit services for annual historical financial information by the Public Accountant and/or Public Accounting Firm, legislation and company policies. VG G FG IG NB

Results of Board of Commissioners meetings are recorded in meeting minutes and documented well, including clear disclosure of dissenting opinions that occur in Board of Commissioners meetings. VG G FG IG NB
37. Results of Board of Commissioners meetings are distributed to
all Board of Commissioners members. VG G FG IG NB
38. There is an increase in knowledge, expertise, and
ability of Board of Commissioners members. VG G FG IG NB
39. In the Governance Implementation Report, the Board
of Commissioners has disclosed at least: VG G FG IG NB a. Execution of Board of Commissioners activities. b. Share ownership of Board of Commissioners members in the relevant Investment Manager, other Investment Managers, and Financial Service Companies other than Investment Managers. c. Financial relationships and family relationships of Board of Commissioners members with other Board of Commissioners members, Board of Directors members and/or Controlling Shareholders of the Investment Manager d. Remuneration and other facilities established by the GMS. 40. Non-disruption of Investment Manager operational activities and/or the existence of unfair benefits given to shareholders, resulting from shareholder intervention in the execution of the Board of Commissioners' duties. Assessment Result a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

III. Completeness and Execution of Committee Duties (if any)
A. Governance Structure a b c d e
1.
The Investment Manager has committees to support the execution of duties of the Board of Directors and/or Board of Commissioners Yes No
2. The committee structure consists of at least 1 (one) chairman and 2 (two) members. Yes No
3.
Each committee member has high integrity, ability, knowledge, experience, competence and expertise in the execution of duties. VG G FG IG NB
4. The majority of committee members are independent parties.
VG G FG IG NB
5.
The committee has a charter (charter) used as a reference in carrying out duties and responsibilities. VG G FG IG NB B. Governance Process a b c d e
6. The committee acts independently in
carrying out duties and responsibilities. VG G FG IG NB 7.
Committee meetings are held in accordance with the procedures contained in the charter (charter). The meeting is attended by the majority of committee members. VG G FG IG NB 8. Decision-making in committee meetings is carried out based on consensus, in the event that consensus is not reached, decision-making is carried out based on the majority vote, or in accordance with provisions. VG G FG IG NB
C. Governance Outputs a b c d e
9.
Results of committee meetings are recorded in meeting minutes and documented well, including clear disclosure of dissenting opinions that occur in the meeting. VG G FG IG NB

Each committee has provided recommendations to the Board of Directors and/or Board of Commissioners regarding duties and responsibilities. VG G FG IG NB 11. Each committee discloses in the Governance Implementation Report, at least: VG G FG IG NB a. Description of duties and responsibilities. b. Report on the execution of activities
c. Disclosure of independence.
d. Disclosure of meeting frequency policies and attendance levels of members in such meetings. Assessment Result a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0
IV. Risk Management Function
A. Governance Structure a b c d e

1. The Investment Manager has a risk management policy
   including risk management strategy. Yes No
2. Risk Management Strategy contains at least:
   a. identification of all risks that may arise in Investment Manager activities; VG G FG IG NB b. explanation regarding the causes of the emergence of such risks; VG G FG IG NB
   c. identification of the likelihood of such risks occurring;
   VG G FG IG NB d. explanation of the implications of the occurrence of such risks; and VG G FG IG NB e. steps that must be taken if such risks occur. VG G FG IG NB 3. Having an organizational structure and resources that are adequate and of quality to support the risk management function. VG G FG IG NB

The coordinator of the risk management function is a unit head, Board of Directors member or official at the level below the Board of Directors, and has a direct accountability line to the Board of Commissioners. Yes No 5. The coordinator of the risk management function has an Investment Manager Representative license from the Financial Services Authority and has work experience holding a managerial position at an institution operating in the Capital Market and/or financial sector for at least 3 (three) years. Yes No 6. The coordinator and employees carrying out the risk management function do not hold concurrent positions as Coordinator and employees in the investment and research function, trading function, and securities transaction settlement function and Investment Committee. Yes No 7. Board of Directors members acting as Coordinator of the risk management function do not hold concurrent positions as Coordinator of other investment manager functions. Yes No B. Governance Process a b c d e The Risk Management Function (Coordinator) is responsible among others:
8.
Formulating policies including strategy, to promote a risk management culture that is adapted to the size and complexity of the business as well as the capabilities of the Investment Manager VG G FG IG NB 9. Updating the risk management strategy, if: VG G FG IG NB a. there are changes and/or additions to Investment Manager activities; and/or b. there are new regulations and/or changes in Financial Services Authority Regulations or other related regulations.

10. Monitoring and reviewing the implementation of
    risk management strategy periodically.
    VG
    G FG IG NB
11. Monitoring overall risk position and per
    risk type.
    VG
    G FG IG NB

Identifying potential or significant risks that have an impact on the success of achieving the goals of the Investment Manager. VG G FG IG NB 13. Formulating and implementing steps for anticipation and efforts to reduce significant risks in accordance with risk management policies. VG G FG IG NB 14. Identifying matters related to risk management that require attention from the Board of Directors and Board of Commissioners. VG G FG IG NB
15. Ensuring human resource development
through training or education.
VG
G FG IG NB
16. Acting independently. VG
G FG IG NB
The Board of Directors is responsible for duties among others:
17.
Following up on the identification of matters related to risk management that require attention from the Board of Directors. VG G FG IG NB 18. Ensuring that organizational structure, infrastructure, and resources are adequate to support the risk management function. VG G FG IG NB
19. Enhancing the risk management culture of the Investment
Manager.
VG
G FG IG NB
The Board of Commissioners is responsible for duties among others:
20. Approving risk management policies including
strategy and risk management framework. VG
G FG IG NB

21. Actively supervise the effectiveness of the implementation of the risk management function, including risk management policies.
    SB B CB KB TB

22. Ensure that the Board of Directors follows up on identifications of matters related to risk management that require the Board of Directors' attention.
    SB B CB KB TB

23. Evaluate and provide improvement recommendations regarding the implementation of the risk management function and policies.
    SB B CB KB TB

C. Governance Outputs a b c d e

24. Risk management policies, strategies, and implementation are able to minimize potential and significant risks within the Investment Manager.
    SB B CB KB TB

25. Able to provide direction for the Investment Manager in viewing influences that may arise in both the short term and long term.
    SB B CB KB TB

26. The Investment Manager does not conduct business activities outside the risk profile acceptable to the Investment Manager.
    Yes No

27. Follow-up on matters related to risk management that require the Board of Directors' attention has been implemented.
    SB B CB KB TB

28. There is an evaluation by the Board of Commissioners regarding the implementation of the risk management function.
    SB B CB KB TB

29. Reports on the implementation of the risk management function to the Board of Commissioners, namely:
    SB B CB KB TB a. Incidental reports. b. Periodic reports at least 1 (one) time per year.

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

V. Compliance Function
A. Governance Structure a b c d e

1. The Investment Manager has compliance policies or strategies.
   Yes No

2. Has a written charter containing the duties and responsibilities of the compliance function that binds the functions of the Investment Manager.
   Yes No

3. Has an adequate and qualified organizational structure and resources to support the compliance function.
   SB B CB KB TB

4. The coordinator of the compliance function has unrestricted access to other Investment Manager functions related to their duties to ensure compliance.
   SB B CB KB TB

5. Board of Directors members acting as the coordinator of the compliance function do not concurrently serve as coordinators of other Investment Manager functions.
   Yes No
   In the event the coordinator of the compliance function is not a member of the Board of Directors, the answer is Yes.

B. Governance Process a b c d e

The Compliance (Coordinator) function has duties and responsibilities including:

6. Act as a liaison officer with the Financial Services Authority (OJK).
   SB B CB KB TB

7. Formulate compliance policies and/or strategies.
   SB B CB KB TB

8. Update compliance policies and/or strategies if:
   SB B CB KB TB a. there are changes and/or additions to the Investment Manager's activities; and/or. b. there are new regulations and/or changes to Financial Services Authority regulations or other related regulations.

9. Ensure that compliance policies or strategies, as well as business activities conducted by the Investment Manager, comply with applicable laws and regulations.
   SB B CB KB TB

10. Formulate and submit an annual work plan for the compliance function to the Board of Commissioners, containing activities and the schedule for implementing compliance function activities.
    SB B CB KB TB

11. Disseminate and socialize compliance manuals, policies, procedures, and other information related to compliance to relevant parties within the Investment Manager's environment.
    SB B CB KB TB

12. Supervise and ensure the implementation of the business continuity plan according to the company's established policies.
    SB B CB KB TB

13. Ensure employees receive training and education related to compliance.
    SB B CB KB TB

14. Formulate and submit mid-year and annual reports on the implementation of the compliance function to the Board of Directors and Board of Commissioners.
    SB B CB KB TB

15. Submit incidental reports to the Board of Commissioners if there is a suspicion of violations of capital market laws and regulations committed by the Investment Manager and/or Clients, no later than 2 (two) working days from the discovery of the suspected violation.
    SB B CB KB TB

16. Act independently.
    SB B CB KB TB

The Board of Directors has duties and responsibilities including:

17. Approve compliance policies.
    SB B CB KB TB

18. Follow up on identifications of matters related to compliance that require the Board of Directors' attention.
    SB B CB KB TB

19. Ensure that the organizational structure, infrastructure, and resources are adequate to support the compliance function.
    SB B CB KB TB

The Board of Commissioners has duties and responsibilities including:

20. Actively supervise the effectiveness of the implementation of the compliance function, including compliance policies.
    SB B CB KB TB

21. Ensure that the Board of Directors follows up on identifications of matters related to compliance that require the Board of Directors' attention.
    SB B CB KB TB

22. Evaluate and ensure that the compliance function carries out activities in accordance with the annual work plan submitted.
    SB B CB KB TB

23. Evaluate and provide improvement recommendations regarding the implementation of the compliance function and policies.
    SB B CB KB TB

C. Governance Outputs
a b c d e

24. The number and level of violations of regulations decrease.
    SB B CB KB TB

25. Follow-up on matters related to compliance that require the Board of Directors' attention has been implemented.
    SB B CB KB TB

26. There is an evaluation by the Board of Commissioners regarding the implementation of the compliance function.
    SB B CB KB TB

27. The annual work plan for the compliance function has been formulated and submitted to the Board of Commissioners.
    SB B CB KB TB

28. Reports on the implementation of the compliance function to the Board of Directors and Board of Commissioners, namely:
    SB B CB KB TB a. Incidental reports. b. Mid-year reports.
    c. Annual reports.

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

VI. Internal Audit Function
A. Governance Structure a b c d e

1. The Investment Manager has an internal audit charter containing procedures or methods of implementation.
   Yes No

2. Has an adequate organizational structure to support the internal audit function.
   SB B CB KB TB

3. There are qualified resources in the internal audit work unit to complete tasks effectively.
   SB B CB KB TB

4. The coordinator of the internal audit function is a work unit leader, a member of the Board of Directors, or an official at a level below the Board of Directors, and has a direct reporting line to the Board of Directors, as well as to the Board of Commissioners.
   Yes No

5. Coordinators and employees implementing the internal audit function do not concurrently serve as Coordinators and employees in the investment and research function, trading function, securities transaction settlement function, and Investment Committee.
   Yes No

6. Board of Directors members acting as the coordinator of the internal audit function do not concurrently serve as coordinators of other Investment Manager functions.
   Yes No

B. Governance Process a b c d e

The Internal Audit (Coordinator) function has duties and responsibilities including:

7. Formulate and/or refine the internal audit charter periodically.
   SB B CB KB TB

8. Ensure the implementation of Investment Manager functions in accordance with written procedures/standard operating procedures.
   SB B CB KB TB

9. Create planning, control, and recording of all internal audit activity implementations.
   SB B CB KB TB

10. Implement internal audit/examination programs, both incidental and periodic, independently, objectively, and without limiting the scope and coverage of the audit.
    SB B CB KB TB

11. Conduct assessments of:
    SB B CB KB TB a. The adequacy of the Investment Manager's internal control system. b. The effectiveness of the Investment Manager's internal control system.

12. Create records of all findings, conclusions, and recommendations from the implementation of internal audit activities.
    SB B CB KB TB

13. Formulate internal audit reports after the implementation of each internal audit to be submitted to the Board of Directors and Board of Commissioners.
    SB B CB KB TB

14. Develop human resources periodically and continuously.
    SB B CB KB TB

The Board of Directors has duties and responsibilities including:

15. Establish the internal audit charter.
    SB B CB KB TB

16. Ensure that the planning, control, and recording of all internal audit activity implementations are conducted effectively.
    SB B CB KB TB

17. Follow up on identifications of matters related to internal audit that require the Board of Directors' attention.
    SB B CB KB TB

18. Ensure that the organizational structure, infrastructure, and resources are adequate to support the internal audit function.
    SB B CB KB TB

The Board of Commissioners has duties and responsibilities including:

19. Approve the internal audit charter.
    SB B CB KB TB

20. Actively supervise the effectiveness of the implementation of the internal audit function, including internal audit policies.
    SB B CB KB TB

21. Ensure that the Board of Directors follows up on identifications of matters related to internal audit that require the Board of Directors' attention.
    SB B CB KB TB

22. Evaluate and provide improvement recommendations regarding the implementation of the internal audit function and policies.
    SB B CB KB TB

C. Governance Outputs a b c d e

23. No recurring findings from internal audit examinations.
    Yes No

24. No deviations in the realization of the Investment Manager's internal audit examination plan.
    SB B CB KB TB

25. Follow-up on matters related to internal audit that require the Board of Directors' attention has been implemented.
    SB B CB KB TB

26. There is an evaluation by the Board of Directors and Board of Commissioners regarding the implementation of the internal audit function.
    SB B CB KB TB

27. Reports on the implementation of the internal audit function to the Board of Commissioners, namely:
    SB B CB KB TB a. Incidental reports. b. Periodic reports at least 1 (one) time per year.

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

VII. External Auditors (Public Accountants (PA) and/or Public Accounting Firms (KAP))
A. Governance Structure a b c d e

1. There are external auditors registered with the Financial Services Authority to conduct audits of the Investment Manager's financial reports.
   Yes No

2. The assignment of audits to Public Accountants (PA) and Public Accounting Firms (KAP) must at least meet the following aspects:
   Yes No a. Capacity of the appointed PA and KAP. b. Legality of the work agreement including the scope of the audit.
   c. Public Accountant Professional Standards;

3. PAs, KAPs, and persons within the KAP providing services to the Investment Manager must meet the condition of independence during the Audit Period and Professional Assignment Period, as declared in the Statement Letter and submitted by the KAP to the Investment Manager, before the Professional Assignment Period begins.
   Yes No

B. Governance Process a b c d e

4. The appointment of external auditors must first obtain approval from the General Meeting of Shareholders (GMS), considering the proposal of the Board of Commissioners.
   Yes No

5. The appointed external auditors are able to work independently, meet Public Accountant Professional Standards, and the work agreement and audit scope established.
   SB B CB KB TB

6. The Board of Directors follows up on findings and recommendations from external auditors.
   SB B CB KB TB

7. The Board of Commissioners ensures that the Board of Directors follows up on findings and recommendations from external auditors.
   SB B CB KB TB

C. Governance Outputs a b c d e

8. External auditors act objectively so that audit results and management letters accurately reflect the condition of the Investment Manager.
   SB B CB KB TB

9. The scope of audit results is at least in accordance with the audit scope as regulated in the provisions.
   SB B CB KB TB

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

VIII. Conflicts of Interest and Transactions with Affiliated Parties
A. Governance Structure a b c d e

1. The Investment Manager has policies, systems, and/or procedures regarding conflicts of interest that bind every member of the Board of Directors, members of the Board of Commissioners, and employees of the Investment Manager in accordance with applicable laws and regulations.
   Yes No

2. The Investment Manager has policies, systems, and/or procedures regarding the administration, documentation, and disclosure of conflicts of interest.
   Yes No

3. The Investment Manager has policies, systems, and/or procedures regarding transactions with Affiliated Parties (individual Shareholders, members of the Board of Directors, members of the Board of Commissioners, employees/staff, and/or parties related to the Investment Manager) in accordance with applicable laws and regulations.
   Yes No

4. The Investment Manager has policies, systems, and/or procedures regarding the administration, documentation, and disclosure of transactions with Affiliated Parties.
   Yes No

B. Governance Process a b c d e

5. In the event of conflicts of interest and/or Affiliate transactions, members of the Board of Directors, members of the Board of Commissioners, and employees act in accordance with the policies, systems, and/or procedures owned.
   SB B CB KB TB

6. The Board of Directors takes follow-up action regarding violations of conflict of interest policies and/or transactions with Affiliated Parties.
   SB B CB KB TB

7. The Board of Directors evaluates and updates conflict of interest policies and policies on transactions with Affiliated Parties.
   SB B CB KB TB

8. The Board of Commissioners supervises the effectiveness of the implementation of conflict of interest policies and policies on transactions with Affiliated Parties periodically.
   SB B CB KB TB

9. The Board of Commissioners provides improvement recommendations to increase the effectiveness of the implementation of conflict of interest policies and policies on transactions with Affiliated Parties.
   SB B CB KB TB

C. Governance Outputs a b c d e

10. Results of handling conflicts of interest are disclosed and well documented.
    SB B CB KB TB

11. Results of handling transactions with Affiliated Parties are disclosed and well documented.
    SB B CB KB TB

12. There are no violations of conflict of interest policies.
    SB B CB KB TB

13. There are no violations of policies on transactions with Affiliated Parties.
    SB B CB KB TB

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

IX. Stewardship
A. Governance Structure a b c d e

1. The Investment Manager has policies related to monitoring activities against companies where the Investment Manager and its managed funds are invested.
   Yes No

2. The Investment Manager has policies related to engagement activities against companies where the Investment Manager and its managed funds are invested.
   Yes No

3. The Investment Manager has policies related to the use of voting rights over share ownership in companies, including procedures for using voting rights that consider the principles of prudence, independence, and the interests of client fund management.
   Yes No

B. Governance Process a b c d e

4. The Investment Manager conducts periodic monitoring activities against companies where the Investment Manager and its managed funds are invested.
   SB B CB KB TB

5. The Investment Manager conducts engagement activities as a follow-up to the results of monitoring performed.
   SB B CB KB TB

6. The Investment Manager ensures that the use of voting rights is conducted considering the principles of prudence, independence, and the interests of client fund management.
   SB B CB KB TB

7. The Investment Manager ensures that policies related to monitoring, engagement, and the use of voting rights comply with applicable laws and regulations.
   SB B CB KB TB

8. The Investment Manager evaluates and updates policies related to monitoring, engagement, and the use of voting rights.
   SB B CB KB TB

C. Governance Outputs a b c d e

9. There are periodic reports on the results of monitoring against companies where the Investment Manager and its managed funds are invested.
   SB B CB KB TB

10. The Investment Manager has communicated to the relevant companies matters of concern regarding the companies' public information.
    SB B CB KB TB

11. Policies on the use of voting rights along with the results of voting rights given at each agenda proposed by the company have been disclosed on the Website.
    SB B CB KB TB

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

X. Business Plan
A. Governance Structure a b c d e

1. The Investment Manager has a Business Plan formulated annually, realistically, measurably, and sustainably.
   SB B CB KB TB

2. The Business Plan must at least cover the following information:
   Yes No a. Investment management services to be offered. b. Client and/or investor targets in accordance with the products to be offered.
   c. Managed fund targets.
   d. Percentage of revenue contribution from each product against the company's total revenue. e. Product distribution methods to be offered. f. Product sales methods to prospective clients and/or investors.

3. The Business Plan is fully supported by Shareholders, which can be seen from the Shareholders' commitment and efforts to strengthen the Investment Manager's capital.
   SB B CB KB TB

B. Governance Process a b c d e

4. The Investment Manager formulates the Business Plan considering:
   SB B CB KB TB a. the Investment Manager's strategic plan; b. internal and external factors that can affect the sustainability of the Investment Manager's business;
   c. the principle of prudence; and
   d. the implementation of risk management.

5. The Business Plan is formulated by the Board of Directors and approved by the Board of Commissioners or GMS as determined in the articles of association.
   Yes No

6. The Board of Directors is responsible for ensuring the implementation of the Business Plan.
   SB B CB KB TB

7. The Board of Directors socializes the Business Plan to:
   SB B CB KB TB a. Shareholders of the Investment Manager b. All levels of the organization within the Investment Manager.

8. The Board of Commissioners is responsible for supervising the implementation of the Business Plan.
   SB B CB KB TB

C. Governance Outputs a b c d e

9. The Business Plan and its realization have been socialized by the Board of Directors to all employees/staff.
   SB B CB KB TB

10. There are no significant deviations between the Business Plan and its realization.
    SB B CB KB TB

11. The realization of the Business Plan impacts the sustainability of the Investment Manager's business.
    SB B CB KB TB

12. The Business Plan, including changes to the Business Plan, is submitted to the Financial Services Authority in accordance with Financial Services Authority provisions.
    SB B CB KB TB

13. There is a report on the realization of the business plan presented comparatively with the business plan previously submitted to the Financial Services Authority.
    SB B CB KB TB

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

XI. Business Ethics
A. Governance Structure a b c d e

1. The Investment Manager has policies, systems, and procedures in accordance with applicable laws and regulations regarding behavior in conducting business activities.
   Yes No

2. The Investment Manager has policies, systems, and procedures in accordance with applicable laws and regulations regarding the Know Your Customer (KYC) principle.
   Yes No

3. The Investment Manager has a special work unit or assigns an official as the person in charge of implementing the Know Your Customer (KYC) principle.
   Yes No

4. The special work unit or official as the person in charge of implementing the Know Your Customer (KYC) principle has adequate capability and authority to access all client data and other related information.
   SB B CB KB TB

5. The Investment Manager has a code of ethics formulated by the Board of Directors and Board of Commissioners, applicable to all members of the Board of Directors, members of the Board of Commissioners, and employees/staff, as well as supporting organs owned by the Investment Manager, which at least contains:
   Yes No a. Company values. b. Principles of implementing the duties of the Board of Directors, Board of Commissioners, employees/staff, and/or supporting organs owned by the Investment Manager must be conducted in good faith, with full responsibility, and prudence. d. Handling of code of ethics violations. e. Accountability for the imposition of sanctions for code of ethics violations.

B. Governance Process a b c d e

6. The Board of Directors ensures that business activities run in accordance with business ethics and behavior in conducting business activities based on applicable laws and regulations.
   SB B CB KB TB

7. The Board of Directors ensures that the implementation of the Know Your Customer (KYC) principle is carried out in accordance with the Know Your Customer (KYC) principle policy.
   SB B CB KB TB

8. The Board of Directors ensures that all employees related to the implementation of the Know Your Customer (KYC) principle have participated in training related to the implementation of the Know Your Customer (KYC) principle periodically.
   SB B CB KB TB

9. The special unit or official as the person in charge of implementing the Know Your Customer (KYC) principle conducts identification, verification, monitoring, and comprehensive evaluation of clients.
   SB B CB KB TB

10. The code of ethics is socialized to all employees/staff of the Investment Manager.
    Yes No

11. In the event there is a suspicion of code of ethics violations, the Board of Directors, Board of Commissioners, employees/staff, and/or supporting organs owned by the Investment Manager report through the violation reporting system.
    Yes No
    If there is no suspicion of code of ethics violations, answer "Yes".

C. Governance Outputs a b c d e

12. There are no violations of applicable laws and regulations regarding behavior in conducting business activities.
    SB B CB KB TB

13. All employees of the Investment Manager have implemented the Know Your Customer (KYC) principle and complied with the code of ethics.
    SB B CB KB TB

14. All code of ethics violations have been handled well.
    SB B CB KB TB

15. Monitoring and evaluation results of the implementation of the Know Your Customer (KYC) principle are well documented.
    SB B CB KB TB

Assessment Results a x 1 b x 0.75 c x 0.5 d x 0.25 e x 0

XII. Violation Reporting System and Client Complaint System
A. Governance Structure a b c d e

1. The Investment Manager has a violation reporting system policy.
   Yes No

2. The violation reporting system policy must at least contain:
   Yes No a. Systematics of the violation reporting process. b. Types of violations that can be reported.
   c. Method of submitting violation reports.
   d. Protection and confidentiality guarantees for reporters. e. Handling of violation reports. f. The party managing the handling of violation reports. g. Results of handling and follow-up of violation reports. h. Periodic evaluation by the Board of Directors and Board of Commissioners regarding the violation reporting system policy.

3. The Investment Manager has a policy for handling Client complaints.
   Yes No

4. The Client complaint handling policy must at least contain:
   Yes No a. Systematics of the client complaint process. b. Timeframe for handling complaints.
   c. Handling of complaints.
   d. The party managing the handling of complaints. e. Results of handling and follow-up of complaints. f. Periodic evaluation by the Board of Directors and Board of Commissioners regarding the client complaint handling policy.

5. The Investment Manager has a work unit or person in charge for the implementation of the violation reporting system and client complaint handling.
   Yes No

B. Governance Process a b c d e

6. The work unit or person in charge for the implementation of the violation reporting system and client complaint handling acts independently.
   SB B CB KB TB

7. Suspected violations committed by members of the Board of Directors, members of the Board of Commissioners, and/or employees/staff of the Investment Manager are handled objectively and promptly in accordance with established policies.
   SB B CB KB TB

8. Client complaints are handled objectively and promptly in accordance with established policies.
   SB B CB KB TB

C. Governance Outputs a b c d e

9. The Investment Manager documents and maintains records of:
   SB B CB KB TB a. Violations committed by members of the Board of Directors, members of the Board of Commissioners, and/or employees/staff of the Investment Manager. b. Client complaints.
   c. Steps taken and to be taken.
   d. Resolution status of violations committed by members of the Board of Directors, members of the Board of

Commissioners, and/or employees of the Investment Manager. e. Status of customer complaint resolution.
10. Mediation for the resolution of customer complaints is carried out properly. SB B CB KB TB
Assessment Result a x 1 b x 0,75 c x 0,5 d x 0,25 e x 0

XIII. Information Disclosure
A. Governance Structure a b c d e

1. The Investment Manager has policies and procedures regarding reporting procedures related to financial and non-financial conditions.
   Yes No
2. The Investment Manager has a reliable information system supported by competent human resources to prepare financial and non-financial reports:
   SB B CB KB TB
3. The Investment Manager has a website containing information at least including:
   Yes No a. General information. b. Information for customers.
   c. Corporate governance information.

B. Governance Process a b c d e
4. The Investment Manager submits financial and non-financial reports to the Financial Services Authority (OJK) and/or other Stakeholders in accordance with regulations.
SB B CB KB TB
5. The Investment Manager submits product information to customers in accordance with OJK regulations on Transparency of Investment Manager Product Information, including:
SB B CB KB TB

• No. Assessment Criteria/Indicator Response
  a. Written information regarding Investment Manager products that meets the minimum requirements as determined. b. Investment Manager staff (Customer Service and Marketing) have explained product information to customers.
  c. Product information provided corresponds to actual conditions.
  d. The Investment Manager informs customers of any changes to product information. e. Product information is clearly readable and understandable. f. The Investment Manager has product information services that are easily accessible to the public.

6. The Investment Manager submits information on customer complaint procedures and dispute resolution to customers in accordance with OJK regulations on Customer Complaints and Mediation in the capital market.
   SB B CB KB TB
7. The Investment Manager periodically updates and validates information on the Website.
   Yes No

C. Governance Output
a b c d e
8. Financial and non-financial reports have been submitted completely and on time to the Financial Services Authority (OJK) and/or other Stakeholders, including:
Yes No a. Periodic Financial Reports. b. Activity Reports.
c. Annual Accountant's Report on Adjusted Net Working Capital.
d. Corporate Governance Implementation Report.
9. Products issued, customer complaint procedures, and dispute resolution have been submitted to Investment Manager customers.
SB B CB KB TB
10. Information contained on the Investment Manager's website is accurate and up-to-date.
SB B CB KB TB

Assessment Result a x 1 b x 0,75 c x 0,5 d x 0,25 e x 0

Established in Jakarta on 18 December 2018
EXECUTIVE HEAD
CAPITAL MARKET SUPERVISOR, signature
HOESEN

c. completeness and execution of committee tasks if committees exist;
d. risk management function; e. compliance function; f. internal audit function; g. external auditor; h. Conflict of Interest and transactions with Affiliated Parties;
i. Stewardship;
j. Business Plan; k. business ethics;
l. violation reporting system and Customer complaint system; and
m. information disclosure.

4. Self-assessment is documented in a worksheet containing a set of questions to assess the quality of Corporate Governance implementation.

5. The questions contained in the worksheet as referred to in item 4 are integrated into 3 (three) aspects of Corporate Governance assessment, namely:
   a. assessment of Corporate Governance structure, aimed at viewing the adequacy of the structure and infrastructure of Corporate Governance so that the implementation process of Corporate Governance principles produces outputs consistent with the expectations of Investment Manager Stakeholders. Included in the Corporate Governance structure are the Board of Directors, Board of Commissioners, Committees, and functions within the Investment Manager. Included in the Corporate Governance infrastructure are the policies and procedures of the Investment Manager and the main tasks and functions (job descriptions) of each position within the organization; b. assessment of Corporate Governance process aims to assess the effectiveness of the implementation process of Corporate Governance principles supported by the adequacy of Corporate Governance structure and infrastructure, thereby producing outputs consistent with the expectations of Investment Manager Stakeholders; and
   c. assessment of Corporate Governance output aims to assess the quality of Corporate Governance outputs that meet the expectations of Investment Manager Stakeholders, which are the result of the implementation process of Corporate Governance principles supported by adequate structure and infrastructure.

6. The assessment criteria for Corporate Governance structure, process, and output are interrelated. For example, problems in the Corporate Governance structure, such as the absence of risk management, compliance, and internal audit functions, cause weaknesses in the Corporate Governance process in applying internal controls that deviate from regulations. Furthermore, these weaknesses in the Corporate Governance process will impact Corporate Governance outputs in the form of business activities outside the acceptable risk profile, violations of statutory regulations, and/or high levels of deviation in Investment Manager operations. Investment Managers must consider whether these weaknesses, especially recurring, material, and significant impacts on the Investment Manager currently and in the future.

7. Investment Managers must prepare data and information used as the basis for analyzing the adequacy and effectiveness of Corporate Governance principle implementation and document them properly. The data and information referred to include all reports and documents disclosed in Item IV.

8. Corporate Governance self-assessment is conducted using 2 (two) types of questions, namely dichotomous (questions with Yes or No answers) and discrete (questions with answers in the range from Very Good to Poor). The values for each answer are as follows:
   Dichotomous question type:
   a. check mark (√) in the Yes column has a value of 1: if the indicator has been fully implemented or met; or b. check mark (√) in the No column has a value of 0: if the indicator is not implemented or met at all. Discrete question type:
   a. check mark (√) in the VG (Very Good) column has a value of 1: the indicator has been fully implemented or met; b. check mark (√) in the G (Good) column has a value of 0.75: most of the indicator has been implemented or met;
   c. check mark (√) in the FA (Fairly Good) column has a value of 0.5: if part of the indicator has been implemented or met;
   d. check mark (√) in the PG (Poorly Good) column has a value of 0.25: if most of the indicator has not been implemented or met; or e. check mark (√) in the P (Poor) column has a value of 0: if the indicator is not implemented or met at all.

9. The description column in the worksheet must be filled with reasons, basis of implementation, or other additional information that must be disclosed to support the answer on the assessment factor indicators.

10. To obtain the value for each factor, the Investment Manager uses the following formula:
    Factor Value = (Sum of indicator values / Total indicators) x Factor weight x 100 Explanation:
    Factor Value: Result of dividing the sum of indicator values by the number of indicators and multiplied by the weight of each factor as determined in this Financial Services Authority Circular. Indicator Value: Sum of indicators met by the Investment Manager in each assessment factor. Total Indicators: Total number of indicators in each assessment factor. Factor Weight: Weight value for each assessment factor established in this Financial Services Authority Circular.

As an example:
Calculating the factor value for the execution of duties and responsibilities of the Board of Directors (structure: 11, process: 16, and output: 8) Investment Manager A answers as follows:
a. Structure:
From 11 indicators, the Investment Manager gives YES answers to 9 indicators, and NO answers to 2 indicators. b. Process:
From 16 indicators, the Investment Manager gives VERY GOOD answers to 10 indicators, FAIRLY GOOD answers to 4 indicators, and YES answers to 2 indicators.
c. Output:
From 8 indicators, the Investment Manager gives VERY GOOD answers to 6 indicators, and 2 YES answers. The calculation is as follows:
Factor Value = {[(1x9)+(0x2)]+[(1x10)+(0.5x4)+(1x2)]+[(1x6)+(1x2)]} x 20% x 100 = 17.71 Thus, the Corporate Governance factor value for the execution of duties and responsibilities of the Board of Directors is 17.71.

11. The weight of each factor is established as in the following table:
    No. Factor Weight (%)
12. Execution of duties and responsibilities of the Board of Directors 20
13. Execution of duties and responsibilities of the Board of Commissioners 20
14. Completeness and execution of committee tasks (if any) 2.5
15. Risk management function 7.5
16. Compliance function 7.5
17. Internal audit function 7.5
18. External auditor 2.5
19. Conflict of Interest and transactions with Affiliated Parties 2.5
20. Stewardship 2.5
21. Business plan 7.5
22. Business ethics 5
23. Violation reporting system and Customer complaint system 2.5
24. Information disclosure 2.5
    Total 100

Composite Score Rank Definition
90 – 100 Rank 1 Corporate governance is implemented very well where almost all or all corporate governance indicators have been met. 77 – 89 Rank 2 Corporate governance is implemented well where most corporate governance indicators have been met. 64 – 76 Rank 3 Corporate governance is implemented fairly well where some corporate governance indicators have been met. 51 – 63 Rank 4 Corporate governance is implemented poorly where most corporate governance indicators have not been met. ≤ 50 Rank 5 Corporate governance is implemented badly where almost all corporate governance indicators have not been met.

13. If the result of the self-assessment of Corporate Governance implementation yields a decimal value, the assessment result is rounded up if it is equal to or greater than 0.5.

14. If the Composite Rank is 4 or 5, the Investment Manager must compile and submit an action plan containing comprehensive and systematic improvement steps along with their implementation time targets to the Financial Services Authority (OJK).

15. The Financial Services Authority evaluates the self-assessment results conducted by the Investment Manager. If there is a difference between the Composite Rank resulting from the self-assessment and the results of the evaluation conducted by the Financial Services Authority, the Investment Manager must revise the self-assessment results of Corporate Governance implementation.

16. If the evaluation conducted by the Financial Services Authority over the self-assessment results conducted by the Investment Manager yields a Composite Rank of 4 or 5, the Financial Services Authority may request the Investment Manager to submit an action plan containing comprehensive and systematic improvement steps along with their implementation time targets.

VI. ACTION PLAN

1. The action plan as referred to in Item III item 3 is prepared to improve or perfect the implementation of Corporate Governance as a follow-up to the self-assessment results. The aforementioned action plan includes corrective actions required, completion targets/times, and obstacles/hindrances to completion if there are still deficiencies in the implementation of Corporate Governance.

2. Investment Managers must submit reports on the implementation of the action plan, no later than 10 (ten) working days after the completion target time of the action plan.

3. The Financial Services Authority may evaluate the action plans submitted by Investment Managers as referred to in item 1.

4. If necessary, the Financial Services Authority may request Investment Managers to adjust the action plan and resubmit the adjusted action plan to the Financial Services Authority for evaluation.

VII. PROCEDURE FOR SUBMITTING REPORTS ON CORPORATE GOVERNANCE IMPLEMENTATION

1. Investment Managers submit reports on the implementation of Corporate Governance signed by the President Director and Senior Commissioner, with the following provisions:
   a. the cover letter for submitting the Corporate Governance implementation report signed by the President Director is submitted in hardcopy format; and b. the content of the Corporate Governance implementation report is submitted in hardcopy and softcopy formats.

This copy is consistent with the original
Legal Director
Legal Department signed
Yuliana

2. The Corporate Governance implementation report as referred to in item 1 is submitted completely to:
   Financial Services Authority attn. Head of Capital Market Supervision Department 2A

VIII. CLOSING

This Financial Services Authority Circular takes effect on the date of determination.
Determined in Jakarta on December 18, 2018

EXECUTIVE HEAD
CAPITAL MARKET SUPERVISOR, signed
HOESEN