Circular Letter of the Financial Services Authority Number 17/SEOJK.05/2014 Concerning the Report on the Implementation of Good Corporate Governance for Insurance Companies, Sharia Insurance Companies, Reinsurance Companies, and Sharia Reinsurance Companies

To:

1. Insurance Companies;
2. Sharia Insurance Companies;
3. Reinsurance Companies; and
4. Sharia Reinsurance Companies
   at their respective locations.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 17/SEOJK.05/2014

CONCERNING

THE REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE FOR INSURANCE COMPANIES, SHARIA INSURANCE COMPANIES, REINSURANCE COMPANIES, AND SHARIA REINSURANCE COMPANIES

In accordance with the mandate of Article 79 paragraph (3) of Financial Services Authority Regulation Number 2/POJK.05/2014 concerning Good Corporate Governance for Insurance Companies (State Gazette of the Republic of Indonesia Year 2014 Number 71, Supplement to the State Gazette of the Republic of Indonesia Number 5526), it is necessary to regulate the form and structure of the report on the implementation of good corporate governance for insurance companies, Sharia insurance companies, reinsurance companies, and Sharia reinsurance companies in this Circular Letter of the Financial Services Authority as follows:

I. GENERAL PROVISIONS

1. Company means insurance companies, Sharia insurance companies, reinsurance companies, and Sharia reinsurance companies.

2. Insurance Company means general insurance companies and life insurance companies.

3. Sharia Insurance Company means Sharia general insurance companies and Sharia life insurance companies.

4. Reinsurance Company means a company that conducts reinsurance business as referred to in the laws concerning insurance.

5. Sharia Reinsurance Company means a company that conducts Sharia reinsurance business as referred to in the laws concerning insurance.

6. General Meeting of Shareholders, hereinafter abbreviated as GMS, is the general meeting of shareholders as referred to in the laws concerning limited liability companies for Companies in the form of a limited liability company or equivalent to the GMS for Companies in the form of a cooperative or joint venture legal entity.

7. Board of Directors is the organ of the Company that performs the management functions as referred to in the laws concerning limited liability companies for Companies in the form of a limited liability company or equivalent to the Board of Directors for Companies in the form of a cooperative or joint venture legal entity.

8. Board of Commissioners is the organ of the Company that performs supervisory and advisory functions as referred to in the laws concerning limited liability companies for Companies in the form of a limited liability company or equivalent to the Board of Commissioners for Companies in the form of a cooperative or joint venture legal entity.

9. Independent Commissioner is a member of the Board of Commissioners who is not affiliated with shareholders, members of the Board of Directors, other members of the Board of Commissioners, and/or members of the Sharia Supervisory Board, namely does not have financial, managerial, shareholding, and/or family relationships with shareholders, members of the Board of Directors, other members of the Board of Commissioners, and/or members of the Sharia Supervisory Board or other relationships that can influence their ability to act independently.

10. Sharia Supervisory Board is a part of the Company's organ that conducts business activities based on Sharia principles that performs supervision over the implementation of insurance and reinsurance business to ensure compliance with Sharia principles.

11. Good Corporate Governance for the Company, hereinafter referred to as Good Corporate Governance, is the structure and process used and applied by the Company's organs to improve the achievement of business results objectives and optimize company value for all stakeholders, particularly policyholders, insured parties, participants, and/or parties entitled to benefits, in an accountable manner and based on laws and regulations as well as ethical values.

12. Financial Services Authority is an independent institution free from the interference of other parties, which has the functions, duties, and authorities for regulation, supervision, examination, and investigation as referred to in Law Number 21 of 2011 concerning the Financial Services Authority.

13. Executive Head of Insurance, Pension Fund, Financing Institutions, and Other Financial Service Institutions Supervision, hereinafter referred to as Executive Head of Non-Bank Financial Industry Supervision, is a member of the Financial Services Authority Commissioners who is tasked with leading the implementation of supervision of non-bank financial service institutions.

II. REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

1. Companies are required to prepare a report on the implementation of Good Corporate Governance at the end of each fiscal year.

2. The report on the implementation of Good Corporate Governance as referred to in item 1 consists of at least:
   a. transparency of the implementation of Good Corporate Governance; b. self-assessment of the implementation of Good Corporate Governance; and
   c. action plan.

III. TRANSPARENCY OF THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

1. Transparency of the implementation of Good Corporate Governance as referred to in Roman numeral II item 2 letter a includes at least the disclosure of all aspects of the implementation of Good Corporate Governance principles.

2. The aspects of the implementation of Good Corporate Governance principles as referred to in item 1 are as follows:
   a. Disclosure of the implementation of Good Corporate Governance includes at least:

1. Implementation of duties and responsibilities of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board, consisting of:
   a) number, job titles, criteria, date of appointment by the GMS, term of office, nationality, and domicile of members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board; b) duties and responsibilities of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board; c) concurrent positions of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board; d) training for the Board of Directors, Board of Commissioners, and Sharia Supervisory Board; e) implementation of activities and recommendations of the Board of Commissioners and Sharia Supervisory Board; and f) frequency of Board of Directors meetings, Board of Commissioners meetings, and Sharia Supervisory Board meetings that have been held, at least covering:
   (1) number of meetings held in 1 (one) year;
   (2) number of meetings attended physically and/or via teleconference, video conference, or other electronic media facilities; and (3) attendance of each member at each meeting.

2. Implementation of duties of work units and committees that perform the Company's internal control functions, consisting of:
   a) implementation of duties of work units that perform the Company's internal control functions; b) implementation of duties of committees that perform the Company's internal control functions, consisting of:
   (1) Completeness and implementation of duties of committees formed by the Board of Directors, consisting of:
   i) structure, membership, and expertise of the committee; ii) duties and responsibilities of the committee; iii) frequency of committee meetings; and iv) committee work program and its implementation. (2) Completeness and implementation of duties of committees formed by the Board of Commissioners, consisting of:
   i) structure, membership, expertise, and independence of the committee; ii) duties and responsibilities of the committee; iii) frequency of committee meetings; and iv) committee work program and its implementation.

3. Implementation of compliance functions, internal auditors, and external auditors.
   The information to be disclosed is the performance of the compliance function, internal auditors, and external auditors, including:
   a) Compliance Function
   Implementation of compliance with regulatory provisions, including:
   (1) existence of a Board of Directors member who oversees the compliance function and work units or employees responsible to the respective Board of Directors member; (2) obligation to meet minimum own capital requirements; (3) financial health level, including solvency ratio, liquidity ratio, and investment adequacy ratio; (4) implementation of customer due diligence and reporting of cash financial transactions and suspicious financial transactions to the Center for Reporting and Analysis of Financial Transactions; and (5) ownership of work units or functions to handle and resolve complaints submitted by consumers. b) Internal Auditor Function Effectiveness and scope of internal auditor duties in assessing all aspects and elements of activities, including:
   (1) scope of audit work;
   (2) structure or position of the internal audit work unit; (3) independence of internal auditors; (4) description of work unit duties; (5) number of employees in the internal audit work unit; and (6) report on the results of internal audit duties. c) External Auditor Function Effectiveness of external auditor duties, including regarding the provision of all accounting records and supporting data required by external auditors, thereby enabling external auditors to provide their opinion on the fairness, compliance, and consistency of the company's financial reports with applicable audit standards.

4. Implementation of risk management, including internal control systems.
   Information that must be disclosed includes:
   a) active supervision by the Board of Commissioners and Board of Directors; b) adequacy of policies, procedures, and risk limit determinations; c) adequacy of risk identification, measurement, monitoring, and control processes; d) risk management information systems; and e) comprehensive internal control systems.

5. Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board.
   a) Disclosure regarding remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board includes at least:
   (1) remuneration in non-natura form, including salaries and other fixed income, such as benefits, stock-based compensation, tantiems, and other forms of remuneration; and (2) other facilities in natura or non-natura form, i.e., other variable income, including allowances for housing, transportation, health insurance, and other facilities. b) Disclosure of remuneration packages or policies in 1 (one) year includes at least:
   (1) remuneration packages and other facilities for members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board established by the GMS; (2) types of remuneration and other facilities for all members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board at least covering the number of Board of Directors members, number of Board of Commissioners members, number of Sharia Supervisory Board members, and the number of all remuneration policies and other facilities as referred to in letter a); and (3) number of Board of Directors, Board of Commissioners, and Sharia Supervisory Board members who received remuneration packages in 1 (one) year grouped by income level.

6. Company Strategic Plan, including:
   a) corporate plan covering the formulation of objectives and targets to be achieved by the company within a 5 (five) year period; and b) business plan describing the company's business activity plans within a 1 (one) year and 3 (three) year period.

7. Transparency of the Company's financial and non-financial conditions not yet disclosed in other reports.

8. Company functions outsourced to third parties.

9. Implementation of GMS authority, consisting of:
   a) implementation of annual GMS and extraordinary GMS and decisions resulting from each GMS; b) GMS announcement and summons process; and c) other matters still pending GMS approval.

10. Implementation of Independent Commissioner duties related to the protection of policyholders, insured parties, participants, and/or parties entitled to benefits, both regarding services and claim resolution, including reports on disputes currently being resolved in mediation bodies, arbitration bodies, or judicial bodies.
    This provision only applies to Insurance Companies and Sharia Insurance Companies.

11. Cooperation relationships between Insurance Companies and Sharia Insurance Companies with insurance agency companies marketing insurance products, including agent names, number of agents, agency certificate ownership, and agency cooperation agreements.
    This provision only applies to Insurance Companies and Sharia Insurance Companies.

b. Disclosure of share ownership of Board of Directors and Board of Commissioners members reaching 5% (five percent) or more of paid-up capital, covering the type and number of shares in:

1. The Company itself;
2. other insurance companies;
3. financial service companies other than insurance companies; and
4. other companies located domestically or abroad, including shares obtained through the stock exchange.

c. Financial and family relationships of Board of Directors members with other Board of Directors members, Board of Commissioners members, Sharia Supervisory Board members, and/or shareholders where the respective Board of Directors member serves.

d. Financial and family relationships of Board of Commissioners members with other Board of Commissioners members, Board of Directors members, Sharia Supervisory Board members, and/or shareholders of the Company where the respective Board of Commissioners member serves.

e. Highest and lowest salary ratio.

1. Salary refers to the rights of Board of Directors members, Board of Commissioners members, permanent employees, and non-permanent employees (including honoraries and outsourced personnel) received and stated in monetary form as compensation from the company or employer to employees established and paid according to a work agreement, consensus, or laws and regulations, including allowances for employees and their families for work and/or services performed.
2. Highest and lowest salary ratio, on the following comparison scale:
   a) ratio of highest and lowest employee salaries; b) ratio of highest and lowest Board of Directors member salaries; c) ratio of highest and lowest Board of Commissioners member salaries; and d) ratio of highest Board of Directors member salary to highest employee salary. The salaries compared in the salary ratio are the compensation received by Board of Directors members, Board of Commissioners members, and employees in the last month of the reporting year. Employees refer to permanent Company employees up to the executive level.

f. Implementation of investment governance, consisting of:

1. investment policies and strategies;
2. investment management, i.e., application of analysis of investment risks; and
3. outsourcing of investments to third parties, if any.

g. Number of internal fraud (internal deviations).

1. Internal deviation refers to deviations committed by Board of Directors members, Board of Commissioners members, permanent employees, and non-permanent employees (including honoraries and outsourced personnel) that can harm and endanger the continuity of business or the financial health of the Company;
2. Disclosure regarding internal deviations includes at least:
   a) number of internal deviations that have been resolved; b) number of internal deviations currently being resolved internally by the Company; c) number of internal deviations not yet attempted to be resolved; and d) number of internal deviations that have been followed up through legal processes.

h. Disclosure of other important matters, including at least:

1. resignation or dismissal of external auditors;
2. material transactions with related parties, i.e.:
   a) purchase, sale, or exchange of shares or assets with a value of 10% (ten percent) or more of company equity conducted with related parties in a single transaction or in a series of transactions; b) property leasing, management and service agreements, including cooperation for sharing of resources conducted with related parties; and c) reinsurance agreements and settlement of inter-company balances conducted with related parties;
3. insurance claims submitted by and/or against the Company with a value of 10% (ten percent) or more of the Company's own capital;
4. conflicts of interest currently ongoing and/or likely to occur; and
5. other material information regarding the Company related to Good Corporate Governance.

i. Legal issues.

1. Legal issues refer to civil and criminal legal problems faced by the Company during the reporting year period and whose legal processes have begun;
2. Disclosure regarding legal issues includes at least:
   a) number of legal issues that have received final and binding judgments; and b) number of legal issues still in the process of resolution in courts and alternative dispute resolution institutions for civil cases.

IV. SELF-ASSESSMENT OF THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

1. Companies are required to conduct self-assessments of the implementation of Good Corporate Governance periodically at least 1 (one) time in 1 (one) year.

2. The self-assessment of the implementation of Good Corporate Governance as referred to in item 1 is conducted based on the Good Corporate Governance guidelines and self-assessment checklists prepared by a committee formed by the government tasked with formulating good corporate governance policies.

3. The report on the results of the self-assessment of the implementation of Good Corporate Governance is an inseparable part of the report on the implementation of Good Corporate Governance as referred to in Roman numeral II item 2.

V. ACTION PLAN

1. Companies are required to prepare an action plan to improve or perfect the implementation of Good Corporate Governance as a follow-up to the results of the self-assessment. The aforementioned action plan includes corrective actions required and the completion time as well as obstacles or hindrances to completion, if there are still deficiencies in the implementation of Good Corporate Governance.

2. The action plan as referred to in item 1 is an inseparable part of the report on the implementation of Good Corporate Governance.

VI. FORM AND STRUCTURE OF THE REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

The form and structure of the report on the implementation of Good Corporate Governance are as stated in the Appendix which is an inseparable part of this Circular Letter of the Financial Services Authority.

VII. TIME FOR SUBMISSION OF THE REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

1. Companies are required to submit the report on the implementation of Good Corporate Governance for the current year to the Financial Services Authority no later than February 28 of the following year.

2. In the event that February 28 is a holiday, the deadline for submission of the report is the first working day after the aforementioned February 28.

VIII. PROCEDURE FOR SUBMISSION OF THE REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

1. Companies are required to submit the report on the implementation of Good Corporate Governance signed by the Board of Directors, Board of Commissioners, and Sharia Supervisory Board to the Executive Head of Non-Bank Financial Industry Supervision with the following provisions:
   a. the cover letter for submission of the report on the implementation of Good Corporate Governance signed by the Board of Directors is submitted in computer printout form (hardcopy); b. the content of the report on the implementation of Good Corporate Governance is submitted in electronic form (softcopy); and
   c. the self-assessment checklist with the format prepared by the committee formed by the government tasked with formulating good corporate governance policies is submitted in electronic form (softcopy) with a spreadsheet format.

2. Submission address for Insurance Companies and Reinsurance Companies:
   Executive Head of Non-Bank Financial Industry Supervision Financial Services Authority attn: Director of Insurance Supervision and BPJS Kesehatan Sumitro Djojohadikusumo Building, 14th Floor Jl. Lapangan Banteng Timur Number 2-4 Jakarta 10710

3. Submission address for Insurance Companies or Reinsurance Companies that have Sharia units:
   a. Executive Head of Non-Bank Financial Industry Supervision Financial Services Authority attn: Director of Insurance Supervision and BPJS Kesehatan Sumitro Djojohadikusumo Building, 14th Floor Jl. Lapangan Banteng Timur Number 2-4 Jakarta 10710; and b. Executive Head of Non-Bank Financial Industry Supervision Financial Services Authority attn: Director of Sharia IKNB Sumitro Djojohadikusumo Building, 13th Floor Jl. Lapangan Banteng Timur Number 2-4 Jakarta 10710

4. Submission address for Sharia Insurance Companies and Sharia Reinsurance Companies:
   Executive Head of Non-Bank Financial Industry Supervision Financial Services Authority attn: Director of Sharia IKNB Sumitro Djojohadikusumo Building, 13th Floor Jl. Lapangan Banteng Timur Number 2-4 Jakarta 10710

5. In the event of a change in the address of the Financial Services Authority Office for submission of reports as referred to in items 2, 3, and 4, the Financial Services Authority will convey notification regarding the address change via letter or announcement.

IX. CLOSING

The provisions in this Circular Letter of the Financial Services Authority shall take effect on the date of establishment.

To ensure that everyone knows, order the announcement of this Circular Letter of the Financial Services Authority by placing it in the State Gazette of the Republic of Indonesia.

Established in Jakarta on December 9, 2014

EXECUTIVE HEAD OF INSURANCE, PENSION FUND,
FINANCING INSTITUTIONS, AND
OTHER FINANCIAL SERVICE INSTITUTIONS SUPERVISION FINANCIAL SERVICES AUTHORITY, Signed, FIRDAUS DJAELANI

STATE GAZETTE OF THE REPUBLIC OF INDONESIA YEAR 2015 NUMBER 2 DATE 6 JANUARY 2015

Copy matches the original
Director of Law 1
Department of Law,
Signed. Signed.
Sudarmaji

APPENDIX
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 17/SEOJK.05/2014 CONCERNING THE REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE FOR INSURANCE COMPANIES, SHARIA INSURANCE COMPANIES, REINSURANCE COMPANIES, AND SHARIA REINSURANCE COMPANIES

TABLE OF CONTENTS
I. INTRODUCTION
II. TRANSPARENCY OF THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE
A. Disclosure of the implementation of Good Corporate Governance.

1. Implementation of duties and responsibilities of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board.
   a) number, job titles, criteria, date of appointment by the GMS, term of office, nationality, and domicile of members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board. (1) Board of Directors No Name Job Title Criteria Date of Appointment by GMS Term of Office Nationality Last Formal Education and Professional Degree Domicile Work Experience in the Insurance Field Competency and Fit Test 1. 2. Etc Describe the table above

In the event that there are changes in the composition of Board of Directors members during the reporting year, the previous composition of Board of Directors members must be stated with a table as follows:
No Name Job Title Date of Appointment by GMS Date of Dismissal by GMS (2) Board of Commissioners No Name Job Title Criteria Date of Appointment by GMS Term of Office Nationality Last Formal Education and Professional Degree Domicile Work Experience in the Insurance Field Competency and Fit Test 1. 2. Etc Describe the table above

---

In the event that there are changes in the composition of the Board of Commissioners during the reporting year, the previous composition of the Board of Commissioners must be included in a table as follows:

No	Name	Position	Date of Appointment by GMS	Date of Dismissal by GMS
(3) Sharia Supervisory Board
No	Name	Position	Date of Appointment by GMS	Term of Office	Citizenship	Last Formal Education and Professional Title	Experience in Insurance Field	Fit and Proper Test
1.
2.
Etc.

Elaborate on the table above.

In the event that there are changes in the composition of the members of the Sharia Supervisory Board during the reporting year, the previous composition of the Sharia Supervisory Board must be included in a table as follows:

No	Name	Position	Date of Appointment by GMS	Date of Dismissal by GMS

b) duties and responsibilities of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board. c) concurrent positions held by the Board of Directors, Board of Commissioners, and Sharia Supervisory Board.

(1) Board of Directors

No	Name	Position in Company	Position in Other Company	Name of Other Company	Business Field
1.	1.
2.
Etc.

2 1.
2.
Etc.
Etc.

(2) Board of Commissioners

No	Name	Position in Company	Position in Other Company	Name of Other Company	Business Field
1.	1.
2.
Etc.

2 1.
2.
Etc.
Etc.

(3) Sharia Supervisory Board

No	Name	Position in Company	Position in Other Company	Name of Other Company	Business Field
1.	1.
2.
Etc.

2 1.
2.
Etc.
Etc.

d) training for the Board of Directors, Board of Commissioners, and Sharia Supervisory Board.
Training related to enhancing the company's human resource capabilities to achieve the company's vision and mission.

(1) Board of Directors

No	Name	Position	Workshop/training/seminar	Organizer	Date	Place
1.
2.
Etc.

(2) Board of Commissioners

No	Name	Position	Workshop/training/seminar	Organizer	Date	Place
1.
2.
Etc.

(3) Sharia Supervisory Board

No	Name	Position	Workshop/training/seminar	Organizer	Date	Place
1.
2.
Etc.

e) implementation of activities and recommendations of the Board of Commissioners and Sharia Supervisory Board.

f) frequency of meetings of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board held within 1 (one) year.

(1) Board of Directors Meetings

No	Name	Position	Number of Board of Directors Meetings (... meetings)	Number of Attendances	% Attendance
Physical	Teleconference / Video Conference / Other Electronic Media
1.
2.
Etc.

(2) Board of Commissioners Meetings

No	Name	Position	Number of Board of Commissioners Meetings (... meetings)	Number of Attendances	% Attendance
Physical	Teleconference / Video Conference / Other Electronic Media
1.
2.
Etc.

(3) Board of Commissioners Meetings with the Board of Directors

No	Name	Position	Number of Board of Commissioners Meetings with the Board of Directors (... meetings)	Number of Attendances	% Attendance
Physical	Teleconference / Video Conference / Other Electronic Media
1.
2.
Etc.

(4) Sharia Supervisory Board Meetings

No	Name	Position	Number of Sharia Supervisory Board Meetings (... meetings)	Number of Attendances	% Attendance
Physical	Teleconference / Video Conference / Other Electronic Media
1.
2.
Etc.

(5) Board of Commissioners Meetings with External Auditors

No	Name	Position	Number of Board of Commissioners Meetings with External Auditors (... meetings)	Number of Attendances	% Attendance
Physical	Teleconference / Video Conference / Other Electronic Media
1.
2.
Etc.

2. Implementation of duties of work units and committees exercising the company's internal control functions, consisting of:
   a) implementation of duties of work units exercising the company's internal control functions. b) implementation of duties of committees exercising the company's internal control functions.

(1) Completeness and implementation of duties of committees formed by the Board of Directors, consisting of:
(i) structure, membership, and expertise of the committee.
(ii) duties and responsibilities of the committee.
(iii) frequency of committee meetings.
(a) Investment Committee Meetings

No	Name of Committee Members	Investment Committee Meetings	Number of Attendances	%
1.
2.
Etc.

(b) Product Development Committee Meetings

No	Name of Committee Members	Product Development Committee Meetings	Number of Attendances	%
1.
2.
Etc.

(iv) committee work programs and their realization.

(2) Completeness and implementation of duties of committees formed by the Board of Commissioners, consisting of:
(i) structure, membership, expertise, and independence of the committee.
(ii) duties and responsibilities of the committee; (iii) frequency of committee meetings (a) Audit Committee Meetings

No	Name of Committee Members	Number of Audit Committee Meetings (... meetings)	Number of Attendances	%
1.
2.
Etc.

(b) Risk Monitoring Committee Meetings

No	Name of Committee Members	Number of Risk Monitoring Committee Meetings (... meetings)	Number of Attendances	%
1.
2.
Etc.

(c) Nomination and Remuneration Committee Meetings (if any)

No	Name of Committee Members	Number of Nomination and Remuneration Committee Meetings (... meetings)	Number of Attendances	%
1.
2.
Etc.

(d) Corporate Governance Policy Committee Meetings (if any)

No	Name of Committee Members	Number of Other Corporate Governance Policy Committee Meetings (... meetings)	Number of Attendances	%
1.
2.
Etc.

(iv) committee work programs and their realization.

3. Implementation of compliance, internal audit, and external audit functions.
   Information to be disclosed is the performance of the compliance function, internal audit, and external audit. a) Compliance function. (1) existence of a Board of Directors member who oversees the compliance function and work units or employees responsible to the respective Board of Directors member.

(2) obligation to meet minimum own capital requirements.
(3) financial health level, including solvency ratio, liquidity ratio, and investment adequacy ratio.
(i) Solvency Ratio for Companies.

Solvency Ratio	Per December 31
T-4	T-3	T-2	T-1	T
Company Solvency Ratio
Tabarru' Funds
Company Funds

(ii) Liquidity Ratio for Companies.

Liquidity Ratio	Per December 31
T-4	T-3	T-2	T-1	T
Company Liquidity Ratio
Tabarru' Funds
Year T-4 T-3 T-2 T-1 T
Total Per December 31

(iii) Investment Adequacy Ratio for Companies.

Investment Adequacy Ratio	Per December 31
T-4	T-3	T-2	T-1	T
Company Investment Adequacy Ratio
Tabarru' Funds

(4) implementation of customer due diligence principles and reporting of cash financial transactions and suspicious financial transactions to the Center for Reporting and Analysis of Financial Transactions (PPATK).

No	Activity	Number of Reports
1.	Submit Cash Financial Transaction Reports (CTR) to PPATK
2.	Submit Suspicious Financial Transaction Reports (STR) to PPATK
3.	Follow up on requests for account data and information related to CTR and STR from: PPATK (Center for Reporting and Analysis of Financial Transactions)
4.	AML/CFT due diligence requests from Other Financial Service Institutions

(5) Ownership of work units or functions to handle and resolve complaints submitted by consumers.

No.	Person in Charge	Head of Work Unit Leader	Executor of Function

b) Internal audit function.
Effectiveness and scope of internal audit task implementation in assessing all aspects and elements of activities.
(1) scope of audit work.
(2) structure or position of the internal audit work unit.
(3) independence of internal auditors.
(4) description of work unit duties.

(5) number of employees in the internal audit work unit.
(6) reports on the results of internal audit task implementation. examples: branch office audits, headquarters audits, and information system technology audits. c) External audit function. Effectiveness of external audit task implementation and company compliance with regulations, including providing all accounting records and supporting data required by external auditors, thereby enabling external auditors to provide their opinion on the fairness, compliance, and conformity of the company's financial reports with applicable audit standards.

Public Accounting Firms that audited the Company's Financial Reports during the last 6 years:

Year	Public Accounting Firm	Accountant Name (Individual)

4. Implementation of risk management, including internal control systems.
   a) active supervision by the Board of Commissioners and Board of Directors. examples: reviewing the adequacy and appropriateness of underwriting policies and human resources. b) adequacy of policies, procedures, and risk limit determinations.

c) adequacy of risk identification, measurement, monitoring, and control processes. d) risk management information systems. e) comprehensive internal control systems.

5. Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board.
   a) Disclosure regarding remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board. (1) remuneration in non-natura form, including salaries and other fixed income, including allowances (benefits), stock-based compensation, bonuses, and other forms of remuneration.

(2) other facilities in natura/non-natura form, i.e., other variable income, including allowances for housing, transportation, health insurance, and other facilities. b) Disclosure of remuneration packages or policies in 1 (one) year. (1) remuneration packages or other facilities for members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board determined by the GMS. (2) types of remuneration and other facilities for all members of the Board of Directors, Board of Commissioners, and Sharia Supervisory Board must at least cover the number of Board of Directors members, number of Board of Commissioners members, and number of all remuneration policies and other facilities as referred to in letter a.

Type of Remuneration and Other Facilities	Number Received in 1 Year
Board of Directors	Board of Commissioners	Sharia Supervisory Board
Millions of Persons (Rp)	Millions of Persons (Rp)	Millions of Persons (Rp)
1. Remuneration (including salaries and other fixed income, including allowances (benefits), stock-based compensation, bonuses, and other forms of remuneration in non-natura form)
2. Other facilities in natura form (housing, transportation, health insurance, etc.)
Total

(3) number of Board of Directors, Board of Commissioners, and Sharia Supervisory Board members receiving remuneration packages in 1 (one) year, grouped according to income level as follows:

Total Remuneration per Person in 1 Year *)	Number of Directors	Number of Commissioners	Number of Sharia Supervisory Board Members
Above Rp2 billion
Above Rp1 billion to Rp2 billion
Above Rp500 million to Rp1 billion
Rp500 million and below

Note:
*) requested in cash

6. Company Strategic Plan.
   a) corporate plan covering the formulation of objectives and targets to be achieved by the company within a 5 (five) year period. b) business plan describing the company's business activities plan within a 1 (one) year and 3 (three) year period.

7. Transparency of the Company's financial and non-financial conditions not disclosed in other reports.
   examples: disclosure of company rating results conducted by rating agencies, transparency regarding products presented in brochures, leaflets, and other promotional media, as well as on the company website, transparency regarding complaint procedures and dispute resolution for policyholders, and share buybacks.

8. Company functions outsourced to third parties.

No	Function Outsourced to Third Parties	Third Party Partner	Third Party Business License	Contract Duration	Reason for Selecting Third Party
1.
2.
Etc.

9. Implementation of GMS authority, consisting of:
   a) implementation of annual GMS and extraordinary GMS, as well as decisions resulting from each GMS. b) GMS announcement and summons process. c) other matters awaiting GMS approval. examples: transactions, appointment of directors, and subordinated loans.

10. Implementation of Independent Commissioner duties regarding the protection of policyholders, insured parties, participants, and/or parties entitled to benefits, both regarding services and claim resolution, including reports on disputes currently being resolved by mediation bodies, arbitration bodies, or judicial bodies.
    This regulation only applies to Insurance Companies and Sharia Insurance Companies.

11. Cooperation relationships between Insurance Companies and Sharia Insurance Companies with insurance agency companies marketing insurance products, including agency names, number of agencies, agency certificate ownership, and agency cooperation agreements.

No	Agency Name	Number of Agencies	Agency Certificate Ownership	Agency Cooperation Agreement
1.
2.
Etc.

This regulation only applies to Insurance Companies and Sharia Insurance Companies.

B. Disclosure of share ownership by Board of Directors and Board of Commissioners members reaching 5% (five percent) or more of paid-up capital, including the type and number of share certificates.

Name	Position	Share Ownership by Board of Directors and Board of Commissioners Members Reaching 5% (five percent) or More of Paid-up Capital
A	B	C	D
Indonesia/Foreign	Total	Nominal Shares	Ownership Percentage	Nominal Shares	Ownership Percentage	Nominal Shares	Ownership Percentage	Nominal Shares	Ownership Percentage
Note:
A. The company itself;
B. other insurance companies;
C. financial service companies other than insurance companies; and
D. other companies located domestically or internationally, including shares obtained through the stock exchange.

C. Financial relationships and family relationships of Board of Directors members with other Board of Directors members, Board of Commissioners members, Sharia Supervisory Board members, and/or shareholders of the company where the respective Board of Directors member serves.
Note:
*) Form of financial relationship: debt-credit, business cooperation, etc.
) Form of family relationship: husband/wife/children/parents/siblings/in-laws, etc.

Name	Financial Relationship with Other Directors	Board of Commissioners	Sharia Supervisory Board	Shareholders
Yes	No	Note	Yes	No	Note	Yes	No	Note	Yes	No	Note
1.
2.
Etc.

Name	Family Relationship with Other Directors	Board of Commissioners	Sharia Supervisory Board	Shareholders
Yes	No	Note	Yes	No	Note	Yes	No	Note	Yes	No	Note
1.
2.
Etc.

D. Financial relationships and family relationships of Board of Commissioners members with other Board of Commissioners members, Board of Directors members, Sharia Supervisory Board members, and/or shareholders of the company where the respective Board of Commissioners member serves. Note:
*) Form of financial relationship: debt-credit, business cooperation, etc.
) Form of family relationship: husband/wife/children/parents/siblings/in-laws, etc.

Name	Financial Relationship with Other Board of Commissioners	Board of Directors	Sharia Supervisory Board	Shareholders
Yes	No	Note	Yes	No	Note	Yes	No	Note	Yes	No	Note
1.
2.
Etc.

Name	Family Relationship with Other Board of Commissioners	Board of Directors	Sharia Supervisory Board	Shareholders
Yes	No	Note	Yes	No	Note	Yes	No	Note	Yes	No	Note
1.
2.
Etc.

E. Ratio of highest and lowest salaries.
Salaries compared in the salary ratio are the compensation received by Board of Directors, Board of Commissioners, and employees in the last month of the reporting year. The ratio of highest and lowest salaries, on the following comparison scale:

1. ratio of highest and lowest employee salaries;
2. ratio of highest and lowest Board of Directors member salaries;
3. ratio of highest and lowest Board of Commissioners member salaries; and
4. ratio of highest Board of Directors member salary and highest employee salary.

F. Implementation of investment governance, consisting of:

1. investment policies and strategies.

2. investment management, i.e., application of analysis of investment risks.

3. outsourcing of investments to third parties, if any.

G. Number of internal deviations (internal fraud).

1. disclosure regarding internal deviations must at least include:

Internal Deviations in 1 Year	Number of Cases Committed by Board of Commissioners and Board of Directors Members	Employees
T-1	T	T-1	T	T-1	T
Permanent	Non-permanent
Total deviations
Already resolved
In the process of resolution internally
Resolution not yet pursued
Already followed up through legal processes.

H. Disclosure of other important matters:

1. resignation or dismissal of external auditors
2. material transactions with related parties;
3. insurance claims submitted by and/or against the Company with a value of 10% or more of the Company's own capital.

No	Business Line	Object of Coverage	Claim Value	Own Retention	Notes
1.
2.
Etc.

4. conflicts of interest currently ongoing and/or likely to occur.
   Examples of conflicts of interest currently ongoing and/or likely to occur include the purchase of company assets by Board of Directors members, Board of Commissioners members, and/or company employees.

No	Name and Position of Party with Conflict of Interest	Name and Position of Decision Maker	Type of Transaction	Transaction Value (Millions of Rupiah)	Notes *)
1.
2.
Etc.

Note:
*) Does not comply with applicable systems and procedures

5. other material information regarding the Company related to Good Corporate Governance, including owner intervention, internal disputes, or issues arising as a result of remuneration policies on the Company.

I. Legal Issues.

Legal Issues	Number of Cases
Civil	Criminal
Already obtained a decision with permanent legal force:
a. Civil
b. Criminal
In the process of resolution in court and in Alternative Dispute Resolution Institutions for civil cases:
a. Civil
b. Criminal
Total

III. ACTION PLAN

No	Corrective Action	Resolution Target	Resolution Obstacles	Notes
1.
2.
Etc.

Approved,
Board of Directors Board of Commissioners Sharia Supervisory Board Established in Jakarta on December 9, 2014 EXECUTIVE HEAD OF SUPERVISION OF INSURANCE, PENSION FUNDS, FINANCING INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS FINANCIAL SERVICES AUTHORITY, Signed, FIRDAUS DJAELANI Copy matches the original Legal Director 1 Legal Department, Signed. Signed. Sudarmaji