Circular Letter of the Financial Services Authority Number 4/SEOJK.05/2018 Regarding the Implementation Report of Good Corporate Governance for Venture Capital Companies

To:

The Board of Directors of Venture Capital Companies; and
The Board of Directors of Sharia Venture Capital Companies,
At your offices.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 4 /SEOJK.05/2018

REGARDING

THE IMPLEMENTATION REPORT OF GOOD CORPORATE GOVERNANCE FOR VENTURE CAPITAL COMPANIES

In relation to the mandate of Article 42 paragraph (3) of the Financial Services Authority Regulation Number 36/POJK.05/2015 concerning Good Corporate Governance for Venture Capital Companies (State Gazette of the Republic of Indonesia Year 2015 Number 318, Supplement to the State Gazette of the Republic of Indonesia Number 5788), it is necessary to regulate the format and structure of the implementation report of good corporate governance for venture capital companies and Sharia venture capital companies in this Circular Letter of the Financial Services Authority as follows:

I. GENERAL PROVISIONS

Venture Capital Business is a financing business through capital participation and/or financing for a certain period in the context of developing the business of partner businesses or debtors.
Venture Capital Companies, hereinafter abbreviated as PMV, are business entities that carry out Venture Capital Business activities, venture fund management, fee-based service activities, and other business activities with the approval of the Financial Services Authority.
Sharia Venture Capital Business is a financing business through investment activities and/or service provision activities carried out for a certain period in the context of developing businesses implemented based on Sharia principles.
Sharia Venture Capital Companies, hereinafter abbreviated as PMVS, are business entities that carry out Sharia Venture Capital Business activities, venture fund management, and other business activities with the approval of the Financial Services Authority, all of which are implemented based on Sharia principles.
Sharia Business Unit, hereinafter abbreviated as UUS, is a work unit of the PMV headquarters that functions as the parent office of offices carrying out Sharia Venture Capital Business activities.
Good Corporate Governance for PMV or PMVS, hereinafter referred to as Good Corporate Governance, is the structure and process used and applied by the PMV or PMVS organs to improve the achievement of business results and optimize the value of PMV or PMVS for all stakeholders in an accountable manner and based on legislation and ethical values.
General Meeting of Shareholders, hereinafter abbreviated as GMS, is the general meeting of shareholders as referred to in Law Number 40 of 2007 concerning Limited Liability Companies for PMV or PMVS that are legal entities in the form of a limited liability company or equivalent to GMS for PMV or PMVS that are legal entities in the form of a cooperative and that are business entities in the form of a limited partnership.
Board of Directors is the board of directors as referred to in Law Number 40 of 2007 concerning Limited Liability Companies for PMV or PMVS that are legal entities in the form of a limited liability company or equivalent to the Board of Directors for PMV or PMVS that are legal entities in the form of a cooperative or that are business entities in the form of a limited partnership.
Board of Commissioners is the board of commissioners as referred to in Law Number 40 of 2007 concerning Limited Liability Companies for PMV or PMVS that are legal entities in the form of a limited liability company or equivalent to the Board of Commissioners for PMV or PMVS that are legal entities in the form of a cooperative or that are business entities in the form of a limited partnership.
Sharia Supervisory Board, hereinafter abbreviated as SSB, is part of the PMV or PMVS organ that has the task and function of supervising the implementation of business activities to ensure compliance with Sharia principles.
Conflict of Interest is a state where there is a conflict between the economic interests of PMV or PMVS and the personal economic interests of shareholders, members of the Board of Directors, members of the Board of Commissioners, and/or SSB as well as employees of PMV or PMVS.

II. IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

The Principles of Good Corporate Governance include:

transparency, namely openness in the decision-making process and openness in disclosure and provision of relevant information regarding PMV or PMVS, which is easily accessible by stakeholders in accordance with regulations in the field of venture capital as well as standards, principles, and practices of healthy business conduct;
accountability, namely clarity of function and implementation of accountability of the PMV or PMVS organs so that the performance of PMV or PMVS can run transparently, fairly, effectively, and efficiently;
responsibility, namely the suitability of the management of PMV or PMVS with regulations in the field of venture capital and ethical values as well as standards, principles, and practices of healthy business conduct;
independence, namely the state of PMV or PMVS that is managed independently and professionally and free from Conflicts of Interest and influence or pressure from any party that is not in accordance with regulations in the field of venture capital and ethical values as well as standards, principles, and practices of healthy business conduct; and
fairness and justice, namely equality, balance, and justice in fulfilling the rights of stakeholders arising from agreements, regulations in the field of venture capital, and ethical values as well as standards, principles, and practices of healthy business conduct.

III. IMPLEMENTATION REPORT OF GOOD CORPORATE GOVERNANCE

PMV or PMVS is required to prepare an implementation report of Good Corporate Governance at the end of each fiscal year.
The implementation report of Good Corporate Governance as referred to in item 1 must at least contain:
a. transparency of the implementation of Good Corporate Governance which at least includes the disclosure of all aspects of the implementation of the principles of Good Corporate Governance as referred to in Section II; b. self-assessment of the implementation of Good Corporate Governance; and
c. action plan which includes corrective actions required and the completion time and obstacles/difficulties in resolution, if there are still deficiencies in the implementation of Good Corporate Governance.

IV. TRANSPARENCY OF THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

Transparency of the implementation of Good Corporate Governance as referred to in Section III item 2 letter a, which at least includes:
a. the implementation of duties and responsibilities of the Board of Directors, Board of Commissioners, and SSB (if any); b. the completeness and implementation of functions that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system;
c. the implementation of internal and external audits;
d. the implementation of risk management, including the internal control system; e. the implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, SSB (if any), and employees; f. the implementation of transparency of the financial and non-financial conditions of PMV or PMVS; and g. disclosure of other important matters, including:
1. resignation or dismissal of independent commissioners, external auditors, and/or SSB (if any);
2. certification;
3. foreign workers;
4. material transactions with related parties;
5. Conflicts of Interest that are ongoing and/or may occur;
6. fraud control reports and the implementation of anti-fraud strategies;
7. legal issues;
8. business ethics; and
9. other material information regarding PMV or PMVS related to Good Corporate Governance.
Transparency of the implementation of Good Corporate Governance as referred to in item 1 is prepared by PMV or PMVS based on the format as contained in Appendix I which is an integral part of this Circular Letter of the Financial Services Authority.

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

Self-assessment of the implementation of Good Corporate Governance as referred to in Section III item 2 letter b is conducted by PMV or PMVS based on the guidelines for the implementation of Good Corporate Governance.
Self-assessment as referred to in item 1 is documented in the self-assessment worksheet as contained in Appendix II which is an integral part of this Circular Letter of the Financial Services Authority.
Filling out the self-assessment worksheet is done in the following stages:
a. preparing a self-assessment analysis, by comparing the fulfillment of each indicator with the conditions of PMV or PMVS based on relevant data and information for each statement/question; b. based on the results of the analysis, the ranking of each indicator is determined. The ranking criteria are as follows:
1. ranking 1:
  The result of the self-assessment analysis by PMV or PMVS shows that the implementation of Good Corporate Governance is very consistent with the indicator;
2. ranking 2:
  The result of the self-assessment analysis by PMV or PMVS shows that the implementation of Good Corporate Governance is consistent with the indicator;
3. ranking 3:
  The result of the self-assessment analysis by PMV or PMVS shows that the implementation of Good Corporate Governance is fairly consistent with the indicator;
4. ranking 4:
  The result of the self-assessment analysis by PMV or PMVS shows that the implementation of Good Corporate Governance is less consistent with the indicator; or
5. ranking 5:
  The result of the self-assessment analysis by PMV or PMVS shows that the implementation of Good Corporate Governance is not consistent with the indicator; and
  c. preparing a general conclusion on the results of the self-assessment, which contains an explanation regarding:
6. strengths in the implementation of Good Corporate Governance; and
7. weaknesses in the implementation of Good Corporate Governance and the root causes of the weaknesses.
For each statement/question in the self-assessment, a value is given as in the following table:

Indicator Assessment Value
Yes 5
N/A 5
1 5
2 4
3 3
4 2
5 1
No 1

To obtain the value of each factor, PMV or PMVS uses the following formula:

The weight of each factor is set as in the following table:
a. for PMV

No. Factor Weight
Factor

Implementation of duties and responsibilities of the Board of Directors and Board of Commissioners. 35%
Completeness and implementation of functions that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system. 10%
Implementation of internal and external audits. 10%
Implementation of risk management, including the internal control system. 15%
Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and employees. 5%
Implementation of transparency of financial and non-financial conditions of PMV. 15%
Disclosure of other important matters. 10%
TOTAL 100%

b. for PMV that has a UUS and PMVS

No. Factor Weight
Factor

Implementation of duties and responsibilities of the Board of Directors, Board of Commissioners, and SSB. 40%
Completeness and implementation of functions that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system. 10%
Implementation of internal and external audits. 10%
Implementation of risk management, including the internal control system. 12,5%
Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, SSB, and employees. 5%
Implementation of transparency of financial and non-financial conditions of PMV or PMVS. 12,5%

No. Factor Weight
Factor
7. Disclosure of other important matters. 10%
TOTAL 100%

To obtain the total factor value, PMV or PMVS sums all factor values. Based on the total factor value, PMV or PMVS determines the ranking and predicate as in the following table:

Total Factor Value Ranking Predicate
84%-100% 1 Very Good
68%-83% 2 Good
52%-67% 3 Fairly Good
36%-51% 4 Less Good
20%-35% 5 Not Good

The self-assessment worksheet and supporting documents for the self-assessment must be documented properly.
The Financial Services Authority may conduct verification and/or validation of the truthfulness and fairness of the data that serves as the basis for the calculation of the self-assessment conducted by PMV or PMVS.
In the event of a difference between the self-assessment conducted by PMV or PMVS and the assessment determined by the Financial Services Authority using data from the Financial Services Authority's verification and/or validation, the assessment of the implementation of Good Corporate Governance that applies is the assessment of the implementation of Good Corporate Governance determined by the Financial Services Authority.

VI. ACTION PLAN

The action plan as referred to in Section III item 2 letter c is prepared in order to improve or perfect the implementation of Good Corporate Governance as a follow-up to the results of the self-assessment. The action plan includes corrective actions required and the completion time and obstacles/difficulties in resolution, if there are still deficiencies in the implementation of Good Corporate Governance.
The action plan as referred to in item 1 is prepared by PMV or PMVS according to the format as contained in Appendix III which is an integral part of this Circular Letter of the Financial Services Authority.

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

PMV or PMVS is required to submit the Good Corporate Governance report for the first time in the 2017 period, submitted no later than April 30, 2018.
The implementation report of Good Corporate Governance must be submitted no later than April 30 of the following year.
If April 30 as referred to in items 1 and 2 falls on a holiday, the deadline for submission of the report is the next working day.

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

PMV or PMVS must submit a cover letter and the implementation report of Good Corporate Governance online via the Financial Services Authority's data communication network system.
In the event that the Financial Services Authority's data communication network system as referred to in item 1 is not yet available or there is a technical disruption during the submission of the cover letter and implementation report of Good Corporate Governance, the cover letter and implementation report of Good Corporate Governance are submitted to the Financial Services Authority offline by one of the following methods:
a. handed over directly; or b. sent through a courier service company.
In the event of a technical disruption as referred to in item 2, the Financial Services Authority announces the occurrence of the technical disruption through the Financial Services Authority's website.
Submission of the cover letter and implementation report of Good Corporate Governance offline as referred to in item 2 must be submitted in electronic data format (softcopy) using media in the form of a compact disc (CD) or other electronic data storage media.
In the event that the technical disruption as referred to in item 2 has been resolved and the Financial Services Authority's data communication network system has returned to normal, the implementation report of Good Corporate Governance is submitted again online.
Submission of the implementation report of Good Corporate Governance as referred to in item 1 must be accompanied by a printed (hardcopy) cover letter signed by the Board of Directors.
PMV or PMVS must archive the printed (hardcopy) documents of the cover letter and implementation report of Good Corporate Governance signed by the Board of Directors as referred to in item 6 in accordance with regulations regarding archival retention.
Submission of the cover letter and implementation report of Good Corporate Governance offline as referred to in item 2 is addressed to:
a. for PMV:
Executive Head of Insurance, Pension Fund, Financing Institution, and Other Financial Service Institution Supervision Financial Services Authority u.p. Director of Financing Institution Supervision Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Number 42 Jakarta 12710;

b. for PMV that has a UUS, submitted to:
Executive Head of Insurance, Pension Fund, Financing Institution, and Other Financial Service Institution Supervision Financial Services Authority u.p. Director of Financing Institution Supervision Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Number 42 Jakarta 12710; and copied to:
Director of Sharia Financial Institution Supervision Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Number 42 Jakarta 12710; and
c. for PMVS:
Executive Head of Insurance, Pension Fund, Financing Institution, and Other Financial Service Institution Supervision Financial Services Authority u.p. Director of Sharia Financial Institution Supervision Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Number 42 Jakarta 12710.
In the event of a change in the address of the Financial Services Authority office for submission of the report as referred to in item 8, the Financial Services Authority will convey notification regarding the address change via letter or announcement.
A company is declared to have submitted the implementation report of Good Corporate Governance with the following provisions:
a. for online submission via the Financial Services Authority's data communication network system, proven by a receipt from the Financial Services Authority's data communication network system; or b. for offline submission, proven by:
1. a receipt letter from the Financial Services Authority, if the report is handed over directly as referred to in item 2 letter a; or
2. a shipping receipt from the courier service company, if the report is sent via courier service as referred to in item 2 letter b.

This copy is in accordance with the original
Legal Director 1
Legal Department signed
Yuliana

IX. CLOSING

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

Determined in Jakarta on January 25, 2018

EXECUTIVE HEAD OF INSURANCE, PENSION FUND,
FINANCING INSTITUTION, AND
OTHER FINANCIAL SERVICE INSTITUTION SUPERVISION FINANCIAL SERVICES AUTHORITY, signed RISWINANDI

APPENDIX I
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 4 /SEOJK.05/2018 REGARDING THE IMPLEMENTATION REPORT OF GOOD CORPORATE GOVERNANCE FOR VENTURE CAPITAL COMPANIES

Transparency of the Implementation of Good Corporate Governance

Introduction:

In accordance with Circular Letter of the Financial Services Authority Number /SEOJK.05/2018, this form is one of the provisions regarding transparency of the implementation of Good Corporate Governance.
This form is filled out by PMV and PMVS.
Please fill out and submit this form in accordance with the provisions and deadlines established.

Instructions for Filling Out:

Before filling out the form, read the instructions carefully.
This form is filled out by providing answers to the columns available.
Fill out the form correctly, carefully, and in accordance with the actual conditions of the PMV or PMVS.

TRANSPARENCY OF THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

A. Implementation of duties and responsibilities of the Board of Directors, Board of Commissioners, and SSB (if any)

Number, name, position, date of approval and number of competency and suitability assessment, date of appointment by GMS and term of office, citizenship, and domicile of members of the Board of Directors, Board of Commissioners, and SSB (if any).

No. Name Position
Date of Approval and Number of Competency and Suitability Assessment Date of Appointment by GMS and Term of Office (years) Citizenship Domicile 1. 2. Etc.

Licensing Data for Foreign Citizen Directors and Commissioners

No. Name Position
KITAS IMTA
Work Permit Validity Period
License No. Validity Period
1.
2.
Etc.

-Brief biodata of Directors, work history in the last five years, education, and professional degrees- -Brief biodata of Commissioners, work history in the last five years, education, and professional degrees-

-Brief biodata of SSB, work history in the last five years, education, and professional degrees-

In the event that there are changes in the composition of members of the Board of Directors, Board of Commissioners, and/or SSB (if any) during the reporting year, the previous composition of members of the Board of Directors, Board of Commissioners, and SSB (if any) must be stated with a table as follows:

No. Name Position
Date of Appointment by GMS
Date of Dismissal by GMS
1.
2.
Etc.

Implementation of duties and responsibilities of each Director, Commissioner, and SSB (if any)
-Brief description-
Concurrent positions of the Board of Directors, Board of Commissioners, and SSB (if any)
a. Board of Directors

No. Name
Position at PMV or PMVS
Position at Other Company
Name of Other Company
Intended Business Field
Etc
Etc
Etc

b. Board of Commissioners

No. Name
Position at PMV or PMVS
Position at Other Company
Name of Other Company
Intended Business Field
Etc
Etc
Etc

c. SSB (if any)

No. Name
Position at PMV or PMVS
Position at Other Company
Name of Other Company
Intended Business Field
Etc
Etc
Etc

Training for Directors, Commissioners, and SSB (if any)

Training related to improving the capabilities of Directors, Commissioners, and SSB (if any) in achieving the vision and mission of PMV or PMVS

a. Board of Directors

No. Name Workshop/Training/Seminar Date Place of Organization 1.
2.
Etc

b. Board of Commissioners

No. Name Workshop/Training/Seminar Date Place of Organization 1.
2.
Etc

c. SSB (if any)

No. Name Workshop/Training/Seminar Date Place of Organization 1.
2.
Etc

Implementation of activities and recommendations of the Board of Commissioners and SSB (if any)
-Brief description-
Implementation of duties of independent commissioners (if any)
-Brief description-
Frequency of Board of Directors meetings, Board of Commissioners meetings, and SSB meetings (if any) held in 1 (one) year

a. Board of Directors Meetings
-Brief description regarding the implementation of meetings including the number of meetings-

No. Name Number of Meetings Number of Attendances % Attendance Reason Physical Absence Electronic Media Facilities*) Etc

b. Board of Commissioners Meetings
-Brief description regarding the implementation of meetings including the number of meetings-

No. Name Number of Meetings Number of Attendances % Attendance Reason Physical Absence Electronic Media Facilities*) Etc

c. SSB Meetings (if any)
-Brief description regarding the implementation of meetings including the number of meetings-

No. Name Number of Meetings Number of Attendances % Attendance Reason Physical Absence Electronic Media Facilities*) Etc

Note:
*) Electronic media facilities are limited to teleconference or videoconference media only.

B. Completeness and implementation of functions that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system, consisting of:

Structure of duties of committees and work units that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system

-Uraian singkat2. Brief description of the duties and responsibilities of committees and work units assisting the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system -Uraian singkat3. Work program of the duties and responsibilities of committees and work units assisting the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system and its realization -Uraian singkat4. Structure of other committees (if any) No. Committee Structure

Chairman:
Members:
Chairman:
Members:
Etc.
Work programs related to the duties and responsibilities of other committees (if any)
No. Committee Duties and Responsibilities

Etc.

C. Implementation of internal and external audit

Internal audit function
The effectiveness and scope of the implementation of internal audit duties in assessing all aspects and elements of activities. a. Scope of audit work -Uraian singkatb. Structure or position of the internal audit work unit -Uraian singkatc. Internal audit independence -Uraian singkatd. Description of the duties of the internal audit work unit -Uraian singkate. Profile of the head of the internal audit work unit -Uraian singkat-

f. Number of employees in the internal audit work unit -Uraian singkatg. Report on the results of the implementation of internal audit duties -Uraian singkat for example: branch office audit, headquarters audit, and information system technology audit
2. External audit function
The effectiveness of the implementation of external audit duties and the compliance of the VC or Sharia VC with regulations, including regarding the provision of all accounting records and supporting data required for external audit, thereby enabling the external auditor to provide an opinion on the fairness, compliance, and conformity of the VC or Sharia VC financial reports with applicable audit standards. -Uraian singkatPublic accounting firm that audited the financial reports of the VC or Sharia VC for the last 5 (five) years Year Public Accounting Firm Public Accountant Name (Individual) and Registration Number at OJK External Audit Cost

D. Implementation of risk management, including internal control system

Active supervision by the Board of Commissioners, Board of Directors, and DPS (if any)
-Uraian singkat example: ensuring that the VC and Sharia VC implement Good Corporate Governance
Adequacy of policies, procedures, and risk limit determinations
-Uraian singkat3. Adequacy of the process for risk identification, measurement, monitoring, and control -Uraian singkat4. Risk management information system -Uraian singkat5. Comprehensive internal control system -Uraian singkatE. Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, DPS (if any), and employees
Disclosure regarding remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and DPS (if any)

a. Remuneration in non-natura form, including salaries and other fixed income, such as allowances (benefits), stock-based compensation, tantiems, and other forms of remuneration -Uraian singkatb. Other facilities in natura/non-natura form, i.e., other variable income, including allowances for housing, transportation, health insurance, and other facilities -Uraian singkat2. Disclosure of remuneration packages or policies in 1 (one) year a. Remuneration packages or policies and other facilities for members of the Board of Directors, Board of Commissioners, and DPS (if any) determined by the GMS -Uraian singkatb. Remuneration and other facilities for all members of the Board of Directors, Board of Commissioners, and DPS (if any) must at least cover the number of Board of Directors members, number of Board of Commissioners members, number of DPS members (if any), and the number of all remuneration policies and other facilities -Uraian singkat-

Amount received in one year Remuneration*)
Other facilities in natura)
Board of Directors
Total Board of Directors
Nominal (Millions of Rupiah)
Board of Commissioners
Total Board of Commissioners
Nominal (Millions of Rupiah)
DPS
(if any)
Total DPS
Nominal (Millions of Rupiah)
Note:
*) Including salaries and other fixed income, such as allowances (benefits), stock-based compensation, tantiems, and other forms of remuneration in non-natura form. ) Housing, transportation, health insurance, and others.
c. Number of Board of Directors, Board of Commissioners, and DPS (if any) members receiving remuneration packages in 1 (one) year grouped according to income level as follows:
Total Remuneration per Person in 1
(one) year in cash
Number
Board of Directors
Number
Board of Commissioners
Number
DPS
(if any)
Above Rp2,000,000,000.00 (two billion rupiah)
Above Rp1,000,000,000.00 (one billion rupiah) to Rp2,000,000,000.00 (two billion rupiah) Above Rp500,000,000.00 (five hundred million rupiah) to Rp1,000,000,000.00 (one billion rupiah) Rp500,000,000.00 (five hundred million rupiah) and below -Uraian singkat3. Ratio of highest and lowest salaries The salaries compared in the salary ratio are the compensation received by members of the Board of Directors, Board of Commissioners, DPS (if any), and employees in the last month of the reporting year.

Ratio of highest and lowest salaries, 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;
d. ratio of highest and lowest DPS member (if any) salaries; and e. ratio of highest Board of Directors member salary to highest employee salary. -Uraian singkatF. Implementation of transparency of financial and non-financial conditions of the VC or Sharia VC -Uraian singkat for example: disclosure of VC or Sharia VC rating results conducted by rating agencies, transparency regarding Venture Capital Business or Sharia Venture Capital Business presented in the form of brochures, leaflets, and other promotional media and on the VC or Sharia VC website, transparency of complaint procedures and dispute resolution to debtors, and share buy-backs.- G. Disclosure of other important matters

Resignation or dismissal of independent commissioners, external auditors, and/or DPS (if any)
-Uraian singkat2. Certification
No. Certification Material Place/Date Organizer 1.

Etc.

Foreign workers
No.
Name Position
Number
Assessment of
Competence and
Fit and Proper
KITAS IMTA
Work Permit
Validity Period Permit No. Validity Period

Etc.
4. Material transactions with related parties
-Uraian singkat5. Conflicts of Interest that are ongoing and/or may occur Example of Conflicts of Interest that are ongoing and/or may occur is the purchase of VC or Sharia VC assets by members of the Board of Directors, members of the Board of Commissioners, members of DPS (if any), and employees of the VC or Sharia VC. No. Name and Position of Party Having Conflict of Interest Name and Position of Decision Maker Type Transaction Transaction Value (millions of rupiah) Note*) 1. 2. Etc. Note:
*) Not in accordance with applicable systems and procedures -Uraian singkat related to Conflicts of Interest-

Fraud control report and implementation of anti-fraud strategy
a. Inventory of fraud incidents and follow-up
Type
Fraud 1)
Date
Fraud
Occurred
Division/Department
Fraud
Occurred
Parties
Involved 2)
Position
Loss in
Rupiah 3)
Company
Action 4)
Weakness/
Cause of Fraud 5)
Follow-up/
Improvement 6)
Chronology of Fraud
Incident b. Progress in the implementation of anti-fraud strategy 7)

Prevention:
...............................................................................................................................................................................................
...............................................................................................................................................................................................
Detection:
...............................................................................................................................................................................................
...............................................................................................................................................................................................
Investigation, Reporting, and Sanctions:
...............................................................................................................................................................................................
...............................................................................................................................................................................................
Monitoring, Evaluation, and Follow-up:
...............................................................................................................................................................................................
...............................................................................................................................................................................................

Explanation:

Types of fraud include, among others, fraud, deception, asset misappropriation,
information leakage, corporate criminal acts, and others.
Parties involved include all parties indicated to be involved/participate in fraud. If more than
1 (one) party is involved, the role of each party is explained.
Loss is filled with losses that have occurred or estimated losses.
VC or Sharia VC action is the response of the VC or Sharia VC to fraud incidents, whether in the form of actions against perpetrators, parties harmed, or other actions. Actions against
fraud perpetrators include, among others, administrative sanctions and/or obligation to compensate. Actions against parties harmed include, among others, compensation and/or efforts to restore reputation. Other actions include reports to competent authorities and/or legal efforts.
Weakness/cause of fraud is the identification of weaknesses in the VC or Sharia VC that cause fraud, which can be weaknesses in policies, systems and procedures, or human resources, or other causes not originating from the VC or Sharia VC.
Follow-up/improvement is the effort that has been or will be undertaken by the VC or Sharia VC regarding weaknesses causing fraud.
Briefly explains the process of prevention, detection,
investigation, reporting, sanctions, and monitoring, evaluation, and follow-up steps in the implementation of anti-fraud strategy during the reporting period. Internal deviation in 1 (one) year Number of cases committed by Board of Directors Members, Board of Commissioners Members, and DPS Members (if any) Permanent Employees Non-Permanent Employees Total Deviations Resolved In Process of Resolution Internally

Internal deviation in 1 (one) year
Number of cases committed by
Board of Directors Members,
Board of Commissioners Members, and DPS Members (if any) Permanent Employees Non-Permanent Employees Resolution Not Yet Attempted Followed up through Legal Process
7. Legal issues
Legal Issues
Number of Cases
Civil Criminal
Has received a decision with permanent legal force a. b.
In the process of resolution in Court and in Alternative Dispute Resolution Institutions for civil cases a. b. Total
8. Business Ethics
-Uraian singkat regarding the business ethics values of the VC or Sharia VC that serve as guidelines for the organs of the VC or Sharia VC and all employees
9. Other material information regarding the VC or Sharia VC related to the exercise of GMS authority and the implementation of Good Corporate Governance, including owner intervention, internal disputes, and issues arising as a result of remuneration policies at the VC or Sharia VC.

This copy is in accordance with the original
Legal Director 1
Legal Department signed
Yuliana
-Uraian singkatApproved,
(Board of Directors Name)
Determined in Jakarta on January 25, 2018
EXECUTIVE HEAD OF SUPERVISOR
OF INSURANCE, PENSION FUNDS,
LENDING INSTITUTIONS, AND
OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES AUTHORITY, signed
RISWINANDI

APPENDIX II
LETTER OF THE FINANCIAL SERVICES AUTHORITY
NUMBER 4 /SEOJK.05/2018
REGARDING
REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE FOR VENTURE CAPITAL COMPANIES

Self Assessment on the Implementation of Good Corporate Governance Introduction:

In accordance with the Financial Services Authority Letter
Number /SEOJK.05/2018, this form is one of the regulations regarding transparency in the implementation of Good Corporate Governance.
This questionnaire is conducted by the VC or Sharia VC.
Please fill out and submit this questionnaire in accordance with the regulations and deadlines established.
Filling Instructions:
Before filling out the questionnaire, read the filling instructions carefully.
Place a cross (X) in column 1 "Very Appropriate", 2 "Appropriate", 3
"Fairly Appropriate", 4 "Less Appropriate", and 5 "Not Appropriate", or in column "Yes", "No", and "N/A" according to the actual situation.
The VC or Sharia VC fills in the cross (X) in the "N/A" column in case
the statement/question cannot be applied to the respective VC or Sharia VC.
For example, for a VC or Sharia VC that does not have a foreign national Board of Directors, in the statement/question "Foreign national Board of Directors has a residence permit", the VC or Sharia VC fills in the cross (X) in the "N/A" column.
Filling out this questionnaire is done by providing answers to the statements/questions in each of the factors present.
This questionnaire consists of 7 (seven) factors, each having statements/questions related to the assessment of that factor.
"Sheet A" to "Sheet K" are the fillings for each of the 7 (seven) factors according to the regulations, and "Sheet L"
is the general conclusion of the self-assessment results.
Fill out the questionnaire correctly, carefully, and according to the actual conditions of the VC or Sharia VC.

Indicator Weight Value Details for VC
No. Factor Weight
Factor Description

Implementation of duties and responsibilities of the Board of Directors
and Board of Commissioners. 35%
See
"Sheet A"

Completeness and implementation of functions that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system. 10% See "Sheet B"
3. Implementation of internal and external audit. 10%
See
"Sheet C"
4. Implementation of risk management, including internal
control system. 15%
See
"Sheet D"
5.
Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, and employees. 5% See "Sheet E"
6. Implementation of transparency of financial and
non-financial conditions of the VC. 15%
See
"Sheet F"
7. Disclosure of other important matters. 10%
See
"Sheet G"
TOTAL 100%
Indicator Weight Value Details for VC with UUS and Sharia VC No. Factor Weight Factor Description

Implementation of duties and responsibilities of the Board of Directors
Board of Commissioners, and/or DPS. 40%
See
"Sheet A"

Completeness and implementation of functions that assist the Board of Commissioners in monitoring and ensuring the effectiveness of the internal control system. 10% See "Sheet B"
3. Implementation of internal and external audit. 10%
See
"Sheet C"
4. Implementation of risk management, including internal
control system. 12.5%
See
"Sheet D"
5.
Implementation of remuneration policies and other facilities for members of the Board of Directors, Board of Commissioners, DPS, and employees. 5% See "Sheet E"
6. Implementation of transparency of financial and
non-financial conditions of the VC or Sharia VC. 12.5% See "Sheet F"
7. Disclosure of other important matters. 10%
See
"Sheet G"
TOTAL 100%

Self Assessment Scoring Dashboard
Assessment Rules Assessment Result
Total Score
Factor Ranking Factor Predicament Sheet Factor Score 84%-100% 1 Very Good 1 A 68%-83% 2 Good 2 B 52%-67% 3 Fairly Good 3 C 36%-51% 4 Less Good 4 D 20%-35% 5 Not Good 5 E 6 F 7 G Total Score Factor Predicament

SELF ASSESSMENT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE Filling out the questionnaire on the implementation of Good Corporate Governance is done by the respective VC or Sharia VC. Filling out this questionnaire is done by providing answers to the statements/questions in the questionnaire. A. Implementation of Duties and Responsibilities of the Board of Directors, Board of Commissioners, and DPS (if any).

Board of Directors
No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
The Board of Directors has relevant knowledge for the position as Board of Directors.
The Board of Directors is able to act with good faith, honesty, and professionalism.
The Board of Directors acts for the interests of the VC or Sharia VC and other stakeholders.
The Board of Directors prioritizes the interests of the VC or Sharia VC and/or other stakeholders over personal interests. The Board of Directors is able to make decisions based on independent and objective assessment for the interests of the VC or Sharia VC and other stakeholders.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
The Board of Directors is able to be objective for the interests of the VC or Sharia VC and debtors, creditors, and/or other stakeholders. The Board of Directors complies with laws and regulations, articles of association, and other internal regulations of the VC or Sharia VC in performing its duties. The Board of Directors manages the VC or Sharia VC according to its authority and responsibilities. The Board of Directors is able to be accountable for the performance of its duties to the GMS. The Board of Directors has ensured that the VC or Sharia VC considers the interests of all parties, especially the interests of business partners, debtors, creditors, funders, and/or venture capital investors. The Board of Directors has ensured that information regarding the VC or Sharia VC is provided to the Board of Commissioners and DPS members timely and completely.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
The Board of Directors has helped and provided facilities and/or resources for the smooth performance of duties and authority of VC or Sharia VC organs. The Board of Directors is able to avoid transactions that have Conflict of Interest with the activities of the VC or Sharia VC where the Board of Directors member holds office. The Board of Directors is able to not utilize its position at the VC or Sharia VC where the Board of Directors member holds office for personal, family, and/or other parties' interests that harm or reduce the profits of the VC or Sharia VC where the Board of Directors member holds office. The Board of Directors is able to avoid acts of taking and/or receiving personal profit from the VC or Sharia VC where the Board of Directors member holds office other than remuneration and facilities determined based on GMS decision.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
The Board of Directors is able to avoid requests from shareholders related to operational activities of the VC or Sharia VC where the Board of Directors member holds office other than those established in the GMS. Board of Directors meeting results are recorded in the Board of Directors meeting minutes. Meeting minutes that are joint decisions of all Board of Directors members have been documented well. Dissenting opinions that occur in Board of Directors meeting decisions must be clearly stated in the Board of Directors meeting minutes accompanied by the reasons for the dissenting opinions (dissenting opinions). The Board of Directors is able to guarantee the effective, precise, and quick decision-making, and can act independently, without interests that can interfere with its ability to perform duties independently and objectively.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
Board of Directors members of the VC or Sharia VC reside in Indonesia.
The Board of Directors foreign nationals have a residence permit.
The Board of Directors foreign nationals have a work permit from the competent authority.
Each Board of Directors member has been approved for competence and fit and proper assessment. The Board of Directors follows training related to improving the human resource capabilities of the VC or Sharia VC in achieving the vision and mission of the VC or Sharia VC. The Board of Directors of the VC or Sharia VC holds Board of Directors meetings periodically at least 1 (one) time in 1 (one) month. The Board of Directors attends Board of Directors meetings at least 50% (fifty percent) of the total number of Board of Directors meetings in a 1 (one) year period. The number of Board of Directors meetings held and the number of attendance of each Board of Directors member is included

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator in the report on the implementation of Good Corporate Governance.
2. Board of Commissioners
No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
The Board of Commissioners is able to perform supervisory duties and provide advice to the Board of Directors. The Board of Commissioners is able to supervise the Board of Directors in maintaining balance of interests of all parties. The Board of Commissioners is able to monitor the effectiveness of the implementation of Good Corporate Governance. The Board of Commissioners is able to ensure that the Board of Directors has followed up on audit findings and recommendations from the internal audit work unit of the VC or Sharia VC, external audit, results of supervision by the Financial Services Authority and/or results of supervision by other authorities.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
Board of Commissioners members are able to not conduct transactions that have Conflict of Interest with the activities of the VC or Sharia VC where the Board of Commissioners member holds office. Board of Commissioners members are able to not utilize their position at the VC or Sharia VC where the Board of Commissioners member holds office for personal, family, and/or other parties' interests that can harm or reduce the profits of the VC or Sharia VC where the Board of Commissioners member holds office. Board of Commissioners members are able to avoid acts of taking and/or receiving personal profit from the VC or Sharia VC where the Board of Commissioners member holds office other than remuneration and facilities determined based on GMS decision.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
Board of Commissioners members are able to not interfere with operational activities of the VC or Sharia VC that are the responsibility of the Board of Directors. Board of Commissioners meeting results are recorded in the Board of Commissioners meeting minutes. Meeting minutes that are joint decisions of all Board of Commissioners members have been documented well. Dissenting opinions that occur in Board of Commissioners meeting decisions must be clearly stated in the Board of Commissioners meeting minutes accompanied by the reasons for the dissenting opinions (dissenting opinions). The Board of Commissioners is able to guarantee the effective, precise, and quick decision-making and can act independently in performing its duties. The VC or Sharia VC has at least 1 (one) Board of Commissioners member residing in Indonesia.

No.
Statement/
Question
Assessment Indicator
Score
1 2 3 4 5 Yes No N/A Indicator
Board of Commissioners members who are foreign nationals have a work permit from the competent authority. Board of Commissioners members who are foreign nationals have a residence permit from the competent authority. Each Board of Commissioners member has been approved for competence and fit and proper assessment. Board of Commissioners members follow training related to improving the human resource capabilities of the VC or Sharia VC in achieving the vision and mission of the VC or Sharia VC. The Board of Commissioners compiles a report on Board of Commissioners activities that is part of the report on the implementation of Good Corporate Governance. Board of Commissioners members of the VC or Sharia VC receive information from the Board of Directors regarding the VC completely and timely.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
Members of the Board of Commissioners of the PMV or PMVS hold Board of Commissioners meetings periodically at least 1 (one) time in 3 (three) months. Members of the Board of Commissioners attend Board of Commissioners meetings for at least 75% (seventy-five percent) of the total Board of Commissioners meetings in a 1 (one) year period. The number of Board of Commissioners meetings held and the attendance of each member of the Board of Commissioners are included in the report on the implementation of Good Corporate Governance.

DPS
(To be filled only by PMVS or PMV that has a UUS) No Statement/Question Assessment Indicator Value 1 2 3 4 5 Yes No Indicator The DPS is able to act in good faith, honestly, and professionally. The DPS is able to act in the interest of the PMVS, UUS, and/or other stakeholders.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The DPS is able to prioritize the interests of the PMVS, UUS, and/or other stakeholders over personal interests. The DPS is able to make decisions based on independent and objective assessments for the interest of the PMVS, UUS, and/or other stakeholders. The DPS is able to prevent the abuse of authority to obtain improper personal gain or cause losses to the PMVS or UUS. The DPS of the PMVS and UUS is able to ensure effective, precise, and swift decision-making and act independently, without interests that could hinder its ability to perform its duties independently and objectively.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The DPS is able to perform its responsibility of providing advice and suggestions to the Board of Directors so that the activities of the PMVS or UUS are in accordance with Sharia principles. The DPS carries out supervision and provides advice and suggestions regarding Sharia Venture Capital Business activities. The DPS carries out supervision and provides advice and suggestions regarding Sharia Venture Capital Business contracts marketed by the PMVS or UUS. The DPS carries out supervision and provides advice and suggestions regarding the marketing practices of Sharia Venture Capital Business conducted by the PMVS or UUS. DPS members receive complete and timely information from the Board of Directors regarding the PMVS or UUS. The results of DPS member meetings are recorded in the DPS meeting minutes.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
Meeting minutes that are joint decisions of all DPS members have been well documented.
DPS decisions have been recorded in meeting minutes, including any differences of opinion (dissenting opinion) that occurred clearly. DPS members are able to avoid transactions that have Conflicts of Interest with the activities of the PMVS or UUS where the DPS member in question holds office. DPS members are able to not exploit their position for personal, family, and/or other interests that reduce the assets or profits of the PMVS or UUS where the DPS member in question holds office.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
DPS members do not take and/or receive personal profit from the PMVS or UUS where the DPS member in question holds office, other than remuneration and other facilities established based on the General Meeting of Shareholders (GMS). The DPS requests explanations from Board of Directors members regarding policies or actions of Board of Directors members that are not in accordance with Sharia principles concerning Sharia Venture Capital Business activities, Sharia Venture Capital Business contracts marketed by the PMVS or UUS, and marketing practices of Sharia Venture Capital Business conducted by the PMVS or UUS. The DPS reports completely and comprehensively to the Financial Services Authority (OJK) and copies it to the Board of Directors since the explanation from Board of Directors members was received by the DPS regarding the Board of Directors' rejection of the DPS's assessment results on the implementation of Sharia principles by the Board of Directors.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The DPS immediately reports completely and comprehensively to the Financial Services Authority (OJK) and copies it to the Board of Directors since it is known that Board of Directors members do not make improvement efforts as requested by the DPS to comply with Sharia principles. The Board of Commissioners is able to give approval in the event that the DPS requires assistance from committee members whose organizational structure is under the Board of Commissioners. The DPS is appointed by the GMS based on the recommendation of the National Sharia Council – Indonesian Ulema Council (DSN-MUI). The appointment of the DPS by the GMS is recorded in a notarial deed. DPS members provide recommendations regarding the implementation of the Board of Directors' duties concerning Sharia aspects of the operational activities of the PMV or PMVS.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
DPS members have had their competence and propriety assessments approved.
DPS members do not hold concurrent positions as members of the Board of Directors or Board of Commissioners in the same PMV or PMVS. DPS members participate in training related to improving the human resource capabilities of the PMV or PMVS in achieving the vision and mission of the PMV or PMVS. In carrying out their duties, the DPS is assisted by employees whose organizational structure is under the Board of Commissioners and/or the Board of Directors. DPS members hold meetings periodically at least 6 (six) times in 1 (one) year. The number of DPS meetings held and the attendance of each DPS member are included in the report on the implementation of Good Corporate Governance.

Total
Statements/Questions
Factor Weight
Factor Value
Assessment Indicator
Indicator 1 2 3 4 5
Predicates Very Appropriate Appropriate Fairly Appropriate Less Appropriate Not Appropriate Indicator Yes N/A 1 2 3 4 5 No Value Indicator 5 4 3 2 1 1

B. Completeness and Implementation of Functions Assisting the Board of Commissioners in Monitoring and Ensuring the Effectiveness of the Internal Control System No Statement/Question Assessment Indicator Value 1 2 3 4 5 Yes No Indicator The unit or employees monitoring audit implementation are independent. The unit or employees monitoring audit implementation monitor and ensure the effectiveness of the internal control system and external audit by conducting monitoring and evaluation of audit planning and implementation to assess the adequacy of internal controls including the financial reporting process. The unit or employees monitoring audit implementation hold meetings regularly. The PMV or PMVS has a unit or employees monitoring audit implementation. The PMV or PMVS forms other units to support the implementation of the Board of Commissioners' duties.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The unit or employees monitoring audit implementation have a structure.
The unit or employees monitoring audit implementation have expertise in performing their duties. The unit or employees monitoring audit implementation have a work program. The unit or employees monitoring audit implementation report realization related to the work program to the Board of Commissioners. Total Statements/Questions Factor Weight Factor Value Assessment Indicator Indicator 1 2 3 4 5 Predicates Very Appropriate Appropriate Fairly Appropriate Less Appropriate Not Appropriate Indicator Yes 1 2 3 4 5 No Value Indicator 5 5 4 3 2 1 1

C. Implementation of Internal Audit and External Audit

Internal Audit Function
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The PMV or PMVS has internal audit.
Internal audit has a scope of audit work.
Internal audit has an organizational structure.
Internal audit is independent.
Internal audit reports the results of internal audit task implementation.
External Audit Function
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The PMV or PMVS uses external audit services.
External audit is requested by the Board of Commissioners.
External audit is appointed by the GMS.
The PMV or PMVS provides all accounting records and data required for external audit.
External audit is independent.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The PMV or PMVS uses the same Public Accounting Firm in the last 6 (six) years.
Total
Statements/Questions
Factor Weight
Factor Value
Assessment Indicator
Indicator 1 2 3 4 5
Predicates Very Appropriate Appropriate Fairly Appropriate Less Appropriate Not Appropriate Indicator Yes 1 2 3 4 5 No Value Indicator 5 5 4 3 2 1 1

D. Implementation of Risk Management, including Internal Control System

Implementation of Duties of Independent Commissioners
(for PMV or PMVS that has assets > Rp500,000,000,000.00 (five hundred billion rupiah)) No Statement/Question Assessment Indicator Value 1 2 3 4 5 Yes No N/A Indicator Independent commissioners report to the Financial Services Authority (OJK) at the latest 10 (ten) calendar days since the discovery of violations of regulations in the venture capital field. Independent commissioners report to the Financial Services Authority (OJK) at the latest 10 (ten) calendar days since the discovery of conditions or estimated conditions that can endanger the continuity of the business of the PMV or PMVS.
Active Supervision by the Board of Commissioners
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The PMV or PMVS implements risk management by identifying, assessing, monitoring, and managing risks effectively. Risk management is in accordance with the objectives, business policies, size, and complexity of the business as well as the capabilities of the PMV or PMVS.
Adequacy of Policies, Procedures, and Risk Limit Setting
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The implementation of risk management by the PMV or PMVS pays attention to the adequacy of policies in risk management. The implementation of risk management by the PMV or PMVS pays attention to procedures in risk management. The implementation of risk management by the PMV or PMVS pays attention to the setting of risk limits in risk management.
Adequacy of Risk Identification, Measurement, Monitoring, and Control Processes
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The implementation of risk management by the PMV or PMVS pays attention to the adequacy of the identification process in risk management. The implementation of risk management by the PMV or PMVS pays attention to measurement in risk management. The implementation of risk management by the PMV or PMVS pays attention to monitoring and control of risks.
Risk Management Information System
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The risk management information system presents reports regarding operational activities in the venture capital field. The risk management information system presents reports regarding financial activities in the venture capital field. The risk management information system presents reports regarding compliance with regulations in the venture capital field.
Comprehensive Internal Control System
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The comprehensive internal control system is implemented optimally.
The comprehensive internal control system pays attention to the reporting mechanism in the event of deviations.

E. Implementation of Remuneration and Other Facilities Policies for Board of Directors Members, Board of Commissioners Members, DPS Members (if any), and Employees

Disclosure regarding Remuneration and Other Facilities Policies for Board of Directors Members, Board of Commissioners Members, DPS Members (if any), and Employees
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The PMV or PMVS implements a remuneration policy for Board of Directors members, Board of Commissioners members, DPS members (if any), and employees that encourages prudent behavior in line with the long-term interests of the PMV or PMVS and fair treatment of debtors, creditors, and/or other stakeholders. The remuneration policy pays attention to financial performance and the fulfillment of obligations of the PMV or PMVS as regulated in regulations. The remuneration policy pays attention to individual work performance. The remuneration policy pays attention to fairness with the PMV or PMVS

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator and/or equivalent job level (peer group).
The remuneration policy pays attention to the consideration of long-term objectives and strategies of the PMV or PMVS. Board of Directors, Board of Commissioners, and DPS members (if any) receive remuneration in non-natura form. Board of Directors, Board of Commissioners, and DPS members (if any) receive remuneration in natura form.
2. Disclosure of Remuneration Package or Policy in 1 (One) Year
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The remuneration package or other facilities policy for Board of Directors, Board of Commissioners, and DPS members (if any) established by the GMS. Remuneration and other facilities for all Board of Directors, Board of Commissioners, and DPS members (if any) must at least include the number of Board of Directors members, the number of Board of Commissioners members, the number of DPS members (if any), and

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator the total number of all remuneration policies and other facilities. The number of Board of Directors, Board of Commissioners, and DPS members (if any) receiving remuneration packages in 1 (one) year grouped by income level.
3. Ratio of Highest and Lowest Salaries
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No Indicator
The PMV or PMVS submits the ratio of the highest and lowest salary comparison.
Total
Statements/Questions
Factor Weight
Factor Value
Assessment Indicator
Indicator 1 2 3 4 5
Predicates Very Appropriate Appropriate Fairly Appropriate Less Appropriate Not Appropriate Indicator Yes 1 2 3 4 5 No Value Indicator 5 5 4 3 2 1 1

F. Implementation of Transparency of Financial and Non-Financial Conditions of the PMV or PMVS No Statement/Question Assessment Indicator Value 1 2 3 4 5 Yes No Indicator The PMV or PMVS implements transparency of financial and non-financial conditions to stakeholders. The PMV or PMVS provides complete and timely data and information to the Financial Services Authority (OJK). The PMV or PMVS explains business activity agreements as well as the rights and obligations of debtors in each business activity transaction. The PMV or PMVS has a reliable financial reporting system for supervision and other stakeholders. The PMV or PMVS conducts promotion regarding Venture Capital Business. The PMV or PMVS transparently communicates the complaint and dispute resolution procedures to debtors.

G. Disclosure of Other Material Matters

Resignation or Dismissal of Independent Commissioners, External Auditors, and/or DPS (if any)
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The PMV or PMVS discloses to the Financial Services Authority (OJK) regarding the resignation of independent commissioners, external auditors, and/or DPS (if any). The PMV or PMVS discloses to the Financial Services Authority (OJK) regarding the reasons for the resignation of independent commissioners, external auditors, and/or DPS (if any). The PMV or PMVS discloses to the Financial Services Authority (OJK) regarding the dismissal of independent commissioners, external auditors, and/or DPS (if any). The PMV or PMVS submits the reasons for the dismissal of independent commissioners, external auditors, and/or DPS (if any) to the Financial Services Authority (OJK).
Certification
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The PMV or PMVS has reported to the Financial Services

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
Authority regarding the implementation of certification for the human resources of the PMV or PMVS.
3. Foreign Workers
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The PMV or PMVS has reported to the Financial Services Authority (OJK) regarding the use of foreign workers by the PMV or PMVS. The PMV or PMVS has conducted knowledge transfer activities from foreign workers to employees of the PMV or PMVS.
4. Material Transactions with Related Parties
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The PMV or PMVS has disclosed to the Financial Services Authority (OJK) regarding material transactions with other parties.

Ongoing and/or Potential Conflicts of Interest
No
Statement/Question
Assessment Indicator
Value
Indicator 1 2 3 4 5 Yes No N/A
The PMV or PMVS has disclosed to the Financial Services Authority (OJK) regarding Conflicts of Interest that are ongoing with other parties. The PMV or PMVS has disclosed to the Financial Services Authority (OJK) regarding transactions of the PMV or PMVS that have potential Conflicts of Interest with other PMVs or PMVSs.
Fraud Control Report and Anti-Fraud Strategy Implementation
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
Resolution of internal deviations involves legal processes.
There are no deviations committed by Board of Directors, Board of Commissioners, and DPS members (if any). There are no deviations committed by permanent employees. There are no deviations committed by non-permanent employees. The PMV or PMVS provides mediation for resolution related to

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator internal deviations.
7. Legal Issues
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The PMV or PMVS does not have legal issues that are civil cases.
The PMV or PMVS does not have legal issues that are criminal cases.
8. Business Ethics
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The Board of Directors, Board of Commissioners, DPS (if any), and employees of the PMV or PMVS are able to not offer or give anything, directly or indirectly, to other parties, to influence decision-making related to venture capital transactions, in violation of regulations.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
The Board of Directors, Board of Commissioners, DPS (if any), and employees of the PMV or PMVS are able to not receive anything for personal interests in violation of regulations, directly or indirectly, from anyone, which can influence decision-making related to venture capital transactions. The PMV or PMVS has guidelines on ethical behavior, containing business ethics values as a guide for the PMV or PMVS organization and all employees of the PMV or PMVS.
9. Other Material Information regarding the PMV or PMVS related to Good Corporate Governance
No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
There is no intervention from the owner of the PMV or PMVS.
There are no internal disputes in the PMV or PMVS.

No
Statement/Question
Assessment Indicator
Value
1 2 3 4 5 Yes No N/A Indicator
There are no issues that are impacts of the remuneration policy of the PMV or PMVS.
Total
Statements/Questions
Factor Weight
Factor Value
Assessment Indicator
Indicator 1 2 3 4 5
Predicates Very Appropriate Appropriate Fairly Appropriate Less Appropriate Not Appropriate Indicator Yes N/A 1 2 3 4 5 No Value Indicator 5 4 3 2 1 1

This copy is in accordance with the original
Director of Law 1
Legal Department signed
Yuliana
H. General Conclusion of Self-Assessment Results -Description of General Conclusion (Strengths and Weaknesses of Good Corporate Governance Implementation)- Approve, (Board of Directors Name) Established in Jakarta on January 25, 2018 EXECUTIVE HEAD OF INSURANCE, PENSION FUNDS, LENDING INSTITUTIONS, AND OTHER FINANCIAL SERVICES INSTITUTIONS FINANCIAL SERVICES AUTHORITY, signed RISWINANDI

APPENDIX III
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 4 /SEOJK.05/2018 REGARDING REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE FOR VENTURE CAPITAL COMPANIES

Action Plan
Introduction:

In accordance with the Financial Services Authority Circular Letter Number /SEOJK.05/2018, this form is one of the regulations regarding the follow-up action plan;
This form is to be filled out by the PMV or PMVS;
Please fill out and submit this form in accordance with the established regulations and deadlines.
Filling Instructions:
Before filling out the form, read the filling instructions carefully;
This form is filled out by providing answers to the existing columns;
Fill out the form correctly, carefully, and in accordance with the actual conditions of the PMV or PMVS.

This copy is in accordance with the original
Director of Law 1
Legal Department signed
Yuliana
ACTION PLAN (ACTION PLAN)
No.
Cause of Weakness
(Root Cause)
Corrective Action
Completion Target
Completion Obstacles
Remarks
Etc...
Approve,
(Board of Directors Name)
Established in Jakarta on January 25, 2018
EXECUTIVE HEAD OF INSURANCE, PENSION FUNDS,
LENDING INSTITUTIONS, AND OTHER FINANCIAL SERVICES INSTITUTIONS FINANCIAL SERVICES AUTHORITY, signed RISWINANDI

Circular Letter of the Financial Services Authority Number 4/SEOJK.05/2018 Regarding the Implementation Report of Good Corporate Governance for Venture Capital Companies

Lineage: In force