OJK Circular No. 28/SEOJK.06/2025 on the Good Corporate Governance Implementation Report for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions

To:

The Board of Directors of Financing Institutions;
The Board of Directors of Infrastructure Financing Institutions;
The Board of Directors of Venture Capital Companies;
The Board of Directors of Microfinance Institutions;
The Board of Directors of Pawnshop Companies; and
The Board of Directors of Technology-Based Joint Financing Service Providers,

At your respective locations.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY NUMBER 28/SEOJK.06/2025

CONCERNING
THE GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT FOR FINANCING INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICROFINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS

In relation to the mandate of Article 108 paragraph (7) of Financial Services Authority Regulation Number 48 of 2024 concerning Good Corporate Governance for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions (State Gazette of the Republic of Indonesia Year 2024 Number 61/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 129/OJK), it is necessary to regulate provisions regarding the form and structure of the good corporate governance implementation report for financing institutions, venture capital companies, microfinance institutions, and other financial service institutions in this Financial Services Authority Circular Letter as follows:

I. GENERAL PROVISIONS

Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions, hereinafter referred to as PVML, are financial service institutions that include financing companies, infrastructure financing companies, venture capital companies, microfinance institutions, pawnshop companies, and technology-based joint financing service providers.
Financing Institution is a legal entity that conducts financing activities for goods and/or services to the public, including those conducting business activities based on Sharia principles.
Infrastructure Financing Institution is a legal entity specifically established to conduct financing activities in the form of providing funds for infrastructure projects and/or carrying out other activities or facilities in support of infrastructure financing, including those conducting business activities based on Sharia principles.
Venture Capital Company is a legal entity that conducts venture capital business activities, including those conducting business activities based on Sharia principles.
Microfinance Institution is a financial institution specifically established to provide business development services and community empowerment, either through loans or financing in micro-scale businesses to members and the public, managing deposits, or providing business development consulting services that are not solely profit-oriented, including those conducting business activities based on Sharia principles.
Pawnshop Company is a legal entity that conducts business activities providing loans secured by movable assets, including those conducting business activities based on Sharia principles.
Technology-Based Joint Financing Service Provider is an Indonesian legal entity that provides, manages, and operates the provision of financial service facilities to match fund providers with fund recipients in conducting financing, either conventionally or based on Sharia principles, directly through an electronic system using the internet.
Sharia Principle is an Islamic legal principle based on fatwas and/or Sharia conformity statements issued by institutions having authority in setting fatwas in the Sharia field.
Sharia Business Unit, hereinafter abbreviated as UUS, is a work unit of the PVML headquarters that conducts business activities based on Sharia Principles and/or functions as the head office of offices conducting business activities based on Sharia Principles.
Good Corporate Governance for PVML, hereinafter referred to as Good Corporate Governance, is the structure and process used and applied by PVML organs to improve the achievement of business results and optimize the value of PVML for all stakeholders in an accountable manner and based on legislation and ethical values.
PVML Organ is the General Meeting of Shareholders, Board of Directors, and Board of Commissioners for PVML in the form of a limited liability company or equivalent to the General Meeting of Shareholders, Board of Directors, and Board of Commissioners for PVML in the form of a cooperative legal entity.
Stakeholder is a party having an interest in PVML, either directly or indirectly regarding PVML's business activities, such as debtors, fund recipients, consumers, business partners, depositors, members/shareholders, employees, creditors, fund providers, venture capital investors, goods and service providers, and/or the government.
Debtor is a business entity or individual who receives financing and/or loans from PVML or a consumer, whether a business entity or individual, who enters into a financing and/or loan agreement based on Sharia Principles.
Controlling Shareholder, hereinafter abbreviated as PSP, is a legal entity, individual, and/or business group that directly or indirectly owns shares or shares equivalent to shares in PVML and/or has the ability to control the aforementioned PVML.
General Meeting of Shareholders, hereinafter abbreviated as GMS, is the company organ that has authority not delegated to the Board of Directors or Board of Commissioners within the limits determined by laws regulating limited liability companies and/or the articles of association for PVML in the form of a limited liability company or equivalent for cooperative legal entities.
Board of Directors is the PVML organ authorized and fully responsible for managing PVML for the benefit of PVML, in accordance with the purpose and objectives of PVML, and representing PVML, both in and out of court, in accordance with the provisions of the articles of association for PVML in the form of a limited liability company or equivalent to the Board of Directors for PVML in the form of a cooperative legal entity.
Board of Commissioners is the PVML organ tasked with conducting general and/or specific supervision in accordance with the articles of association and providing advice to the Board of Directors for PVML in the form of a limited liability company or equivalent to the Board of Commissioners for PVML in the form of a cooperative legal entity.
Sharia Supervisory Board, hereinafter abbreviated as SSAB, is a party having the task and function of supervising the implementation of PVML activities to ensure compliance with Sharia Principles.
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 SSAB, meaning they do 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 SSAB, or other relationships that could influence their ability to act independently.
Independent Party is a party outside PVML that does not have financial, managerial, shareholding, and/or family relationships with members of the Board of Directors, members of the Board of Commissioners, and/or PSP, or relationships with PVML that could influence the relevant party's ability to act independently.
Executive Official is a PVML official who reports directly to members of the Board of Directors or has significant influence over PVML's policies and/or operations.
Manager is a cooperative member and/or third party appointed by the management and given authority to manage the cooperative business.
Conflict of Interest is a state where there is a conflict between the economic interests of PVML and the personal, family, and shareholder group economic interests of members of the Board of Directors, members of the Board of Commissioners, members of PVML committees, Executive Officials, and/or SSAB, as well as PVML employees.

II. IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE

The implementation of Good Corporate Governance for PVML is based on the principles of Good Corporate Governance, which include:

Openness includes openness in the decision-making process and openness in the disclosure and provision of relevant information that is easily accessible to stakeholders.

In implementing the principle of openness in the decision-making process as well as openness in the disclosure and provision of relevant information for stakeholders, it must be supported by adequate guidelines and information systems.

Accountability includes clarity of function and the implementation of responsibility.

In implementing the principle of accountability, members of the Board of Directors, Managers, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, PVML employees, and work units must have guidelines and codes of conduct so that task implementation is carried out optimally and can be fully accounted for.

Responsibility includes the conformity of management with legislative provisions and ethical values as well as standards, principles, and practices.

In implementing the principle of responsibility, members of the Board of Directors, Managers, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, PVML employees, and work units carry out their duties in accordance with legislative provisions and ethical values as well as applicable standards, principles, and practices.

Independence includes a state of being managed independently and professionally and free from conflicts of interest and influence or pressure from any party that is not in accordance with legislative provisions and ethical values as well as standards, principles, and practices.

In implementing the principle of independence, members of the Board of Directors, Managers, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, and PVML employees carry out their respective roles and responsibilities in accordance with their tasks, functions, and authority without mutual domination and without being intervened.

Members of the Board of Directors, Managers, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, and PVML employees must also avoid Conflicts of Interest and influence or pressure from any party. In the event of a Conflict of Interest, members of the Board of Directors, Managers, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, and PVML employees must disclose such Conflict of Interest in accordance with the conflict of interest policy owned by PVML.

Furthermore, the existence of Independent Commissioners and Independent Parties is required, which is expected to create a condition of mutual control (check and balance), avoid Conflicts of Interest in the implementation of their duties, and protect stakeholders, particularly minority shareholders, fund owners, fund providers, and other stakeholders.

Fairness includes equality, balance, and justice in fulfilling the rights of stakeholders arising from agreements, legislative provisions, and ethical values as well as standards, principles, and practices.

In implementing the principle of fairness, PVML needs to pay attention to, among others:
a. the interests of shareholders, including protection for minority shareholders, fund owners, fund providers, and other stakeholders; and b. the fulfillment of rights for all human resources of PVML, in accordance with legislative provisions.

III. GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT

PVML is required to prepare a Good Corporate Governance Implementation Report at the end of each fiscal year.
The Good Corporate Governance Implementation Report as referred to in item 1 must contain at least:
a. transparency of Good Corporate Governance implementation disclosing all aspects of the implementation of the principles of Good Corporate Governance as referred to in Roman numeral II; b. self-assessment of Good Corporate Governance implementation; and
c. an action plan including necessary corrective actions and completion timeframes and obstacles to completion, if there are still deficiencies in the implementation of Good Corporate Governance.
Transparency of Good Corporate Governance implementation as referred to in item 2 letter a and self-assessment of Good Corporate Governance implementation as referred to in item 2 letter b must be manifested at least in:
a. the implementation of duties and authority of shareholders and GMS; b. the implementation of duties, responsibilities, and authority of the Board of Directors;
c. the implementation of duties, responsibilities, and authority of the Board of Commissioners;
d. the implementation of duties, responsibilities, and authority of the SSAB; e. the completeness and implementation of committee duties; f. the implementation of risk management; g. the implementation of antifraud strategy; h. the implementation of the compliance function;
i. the implementation of internal and external audit functions;
j. the handling of Conflicts of Interest; k. the implementation of remuneration policy;
l. information openness;
m. business ethics; n. financing policy; o. the implementation of sustainable finance, including the implementation of social and environmental responsibility; and p. business plan.
The Good Corporate Governance Implementation Report as referred to in items 1 and 2 is prepared using the format as contained in Appendix I, Appendix II, and Appendix III, which are an integral part of this Financial Services Authority Circular Letter.

IV. TRANSPARENCY OF GOOD CORPORATE GOVERNANCE IMPLEMENTATION

Transparency of Good Corporate Governance implementation as referred to in Roman numeral III item 2 letter a is prepared by PVML based on the format as contained in Appendix I, which is an integral part of this Financial Services Authority Circular Letter.
Transparency of Good Corporate Governance implementation regarding the implementation of risk management as referred to in Roman numeral III item 3 letter f also includes the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction (AML, CFT, and CPF) programs in carrying out PVML's business activities.
Transparency of Good Corporate Governance implementation regarding the implementation of antifraud strategy as referred to in Roman numeral III item 3 letter g also includes internal fraud deviations of PVML.
Transparency of Good Corporate Governance implementation regarding the handling of Conflicts of Interest as referred to in Roman numeral III item 3 letter j includes the handling of Conflicts of Interest that are currently ongoing and/or may occur for members of the Board of Directors, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, and PVML employees.
Transparency of Good Corporate Governance implementation regarding the disclosure of information openness as referred to in Roman numeral III item 3 letter l includes the obligation of PVML to disclose:
a. share ownership of members of the Board of Directors and members of the Board of Commissioners reaching 5% (five percent) or more in the PVML where members of the Board of Directors and members of the Board of Commissioners serve and/or in other companies located domestically and abroad; b. financial relationships of members of the Board of Directors and members of the Board of Commissioners with other members of the Board of Directors, other members of the Board of Commissioners, SSAB, PVML shareholders, and/or PVML employees where members of the Board of Directors and members of the Board of Commissioners serve; What is meant by having a financial relationship is when members of the Board of Directors and members of the Board of Commissioners receive income, financial assistance, and/or loans from other members of the Board of Directors, other members of the Board of Commissioners, SSAB, PVML shareholders, and/or PVML employees;
c. family relationships of members of the Board of Directors and members of the Board of Commissioners with other members of the Board of Directors, other members of the Board of Commissioners, SSAB, PVML shareholders, and/or PVML employees where members of the Board of Directors and members of the Board of Commissioners serve up to the second degree, both horizontally and vertically; and
d. remuneration and facilities received by members of the Board of Directors and members of the Board of Commissioners.
In addition to the disclosure of information openness as referred to in item 5, PVML has the obligation to disclose to the Financial Services Authority regarding important matters, including:
a. the resignation or dismissal of external auditors; b. material transactions with parties having affiliate relationships; PVML needs to establish limits regarding material transactions adjusted to the size, characteristics, and complexity of PVML.
c. Conflicts of Interest that are currently ongoing and/or may occur; and
d. other material information regarding PVML, including:

appointment, dismissal, replacement, and/or resignation of members of the Board of Directors, Managers, members of the Board of Commissioners, and SSAB, including those who are permanently unable due to death, mental disability, or other conditions that prevent the relevant party from carrying out duties well;
resignation or dismissal of Independent Commissioners;
training for members of the Board of Directors, members of the Board of Commissioners, and SSAB;
concurrent positions held by members of the Board of Directors, members of the Board of Commissioners, and SSAB;
frequency of meetings held within 1 (one) year;
foreign workers, including:
a) Board of Directors; b) Board of Commissioners; c) experts; or d) consultants;
legal issues, both civil and criminal law, faced by PVML during the reporting year period and which have been submitted through legal processes and settlement efforts;
transparency of PVML's financial and non-financial conditions not yet disclosed in other reports;
long-term plans and work plans; and
annual budget plans.

PVML must also follow industry dynamics developments to encourage the implementation of Good Corporate Governance in PVML so that it can perform its function in supporting the financial sector industry to conduct healthy business practices.

One form of PVML following industry dynamics developments is implementing PVML management in line with the development of current legislative provisions and policies, as well as in accordance with PVML industry needs.

PVML must have, evaluate, and update internal procedures regarding the implementation of Good Corporate Governance in the conduct of business activities for each evaluation factor of governance implementation in accordance with legislative provisions, including business processes and approval mechanisms in PVML.

V. SELF-ASSESSMENT OF GOOD CORPORATE GOVERNANCE IMPLEMENTATION

Self-assessment of Good Corporate Governance implementation as referred to in Roman numeral III item 2 letter b is conducted by PVML based on Good Corporate Governance guidelines.
In order to ensure the implementation of the 5 (five) basic principles of Good Corporate Governance as referred to in Roman numeral II, PVML must conduct periodic self-assessments that cover at least 16 (sixteen) governance implementation evaluation factors, namely:
a. the implementation of duties and authority of shareholders and GMS; b. the implementation of duties, responsibilities, and authority of the Board of Directors;
c. the implementation of duties, responsibilities, and authority of the Board of Commissioners;
d. the implementation of duties, responsibilities, and authority of the SSAB; e. the completeness and implementation of committee duties; f. the implementation of risk management; g. the implementation of antifraud strategy; h. the implementation of the compliance function;
i. the implementation of internal and external audit functions;
j. the handling of Conflicts of Interest; k. the implementation of remuneration policy;
l. information openness;
m. business ethics; n. financing policy; o. the implementation of sustainable finance, including the implementation of social and environmental responsibility; and p. business plan.
The 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 Financial Services Authority Circular Letter.
The assessment of Good Corporate Governance implementation in PVML is conducted on the factors as referred to in item 2 and is evaluated based on measurement:
a. governance structure, aimed at assessing the adequacy of PVML's governance structure and infrastructure so that the implementation process of Good Corporate Governance principles produces outcomes in accordance with the expectations of PVML stakeholders. Included in PVML's governance structure are shareholders, members of the Board of Directors, Managers, members of the Board of Commissioners, members of PVML committees, SSAB, Executive Officials, PVML employees, and work units. As for PVML's governance infrastructure, including among others PVML policies and procedures, information technology systems, risk management, internal controls, and the main tasks and functions of each organizational structure. b. governance process, aimed at assessing the effectiveness of the implementation process of governance principles supported by the adequacy of PVML's governance structure and infrastructure so as to produce outcomes in accordance with the expectations of PVML stakeholders.
c. governance outcome, aimed at assessing the quality of outcomes meeting the expectations of PVML stakeholders, which are the result of the implementation process of Good Corporate Governance principles and supported by the adequacy of PVML's governance structure and infrastructure.
Included in governance outcome cover qualitative aspects and quantitative aspects, including among others:

adequacy of report transparency;
compliance with legislative provisions;
improvement of human resource quality;
consumer protection;
objectivity in conducting assessments or audits;
PVML performance such as liquidity, solvency, and capitalization; and/or
improvement or decline in compliance with regulations and resolution of issues faced by PVML such as fraud, violations of maximum financing provision limits (BMPP), and violations of regulations regarding PVML reports to the Financial Services Authority.

PVML may add other parameters or indicators in accordance with the characteristics and complexity of PVML's business without reducing the substance and scope of assessment in the self-assessment worksheet as referred to in item 2.
Assessment of parameters or indicators that are quantitative in nature is conducted based on position and trends over the last 12 (twelve) months.
In assessing the implementation of Good Corporate Governance on a consolidated basis, PVML may use parameters or indicators for the assessment of Good Corporate Governance implementation on an individual basis, adjusted to the scale, characteristics, and complexity of the company's business.
Determination of Good Corporate Governance ratings and the value of each indicator is conducted based on analysis of:
a. application of Good Corporate Governance principles; b. measurement of governance over structure, process, and results of governance application as referred to in point 3; and
c. other information related to Good Corporate Governance based on relevant data and information.
Completion of the self-assessment worksheet is conducted through the following stages:
a. For PVML consisting of Financing Companies, Infrastructure Financing Companies, and Venture Capital Companies, the stages are as follows:

PVML assesses Good Corporate Governance factors using the self-assessment worksheet as contained in Appendix II Part A, which is an integral part of this Financial Services Authority Circular;
PVML determines Good Corporate Governance factor ratings categorized into 5 (five) ratings, namely:
Rating
1 Very Good
2 Good
3 Fairly Good
4 Less Good
5 Not Good with the order of Good Corporate Governance factor ratings being smaller reflecting better governance application. b. For PVML consisting of Microfinance Institutions and Other Financial Service Institutions, the stages are as follows:
PVML prepares a self-assessment analysis by comparing the fulfillment of each indicator with the PVML's condition based on relevant data and information for each statement/question in each factor as referred to in Appendix III point 3.
Based on the analysis results, the value of each indicator is determined.
For each statement/question in the self-assessment, the indicator value is given as in the following table:

Indicator Value	Definition
Meets the condition of structure and/or infrastructure fulfillment according to regulations, governance implementation process is conducted very adequately and demonstrated by very good governance implementation results.	Very Good
Meets the condition of structure and/or infrastructure fulfillment according to regulations, governance implementation process is conducted adequately and demonstrated by good governance implementation results.	Good
Meets the condition of structure and/or infrastructure fulfillment according to regulations, governance implementation process is conducted fairly adequately and demonstrated by fairly good governance implementation results.	Fairly Good
Meets the condition where structure and/or infrastructure fulfillment according to regulations is not fully met, governance implementation process is conducted less adequately and demonstrated by less good governance implementation results.	Less Good
Meets the condition where structure and/or infrastructure fulfillment according to regulations is not met, governance implementation process is conducted inadequately and demonstrated by not good governance implementation results.	Not Good

To obtain the value of each factor, PVML uses the following formula:
$$\text{Factor Value} = \frac{\sum \text{indicator values}}{5 \times \text{number of statements/questions}} \times \text{factor weight}$$ The weight of each factor is determined as in the following table:
a) for conventional PVML

No.	Factor	Weight
1.	Implementation of duties and authority of shareholders and GMS	5.00
2.	Implementation of duties, responsibilities, and authority of the Board of Directors	15.00
3.	Implementation of duties, responsibilities, and authority of the Board of Commissioners	10.00
4.	Completeness and implementation of committee duties	5.00
5.	Risk management application	10.00
6.	Anti-fraud strategy application	5.00
7.	Compliance function application	10.00
8.	Internal and external audit function application	5.00
9.	Conflict of interest handling	8.00
10.	Remuneration policy application	3.00
11.	Information transparency	10.00
12.	Business ethics	3.00
13.	Financing policy	5.00
14.	Sustainable finance application, including social and environmental responsibility application	3.00
15.	Business plan	3.00
Total		100.00

b) for PVML based on Sharia Principles and PVML that have Sharia Business Units (UUS)

No.	Factor	Weight
1.	Implementation of duties and authority of shareholders and GMS	5.00
2.	Implementation of duties, responsibilities, and authority of the Board of Directors	15.00
3.	Implementation of duties, responsibilities, and authority of the Board of Commissioners	10.00
4.	Implementation of duties, responsibilities, and authority of the Sharia Supervisory Board (DPS)	12.00
5.	Completeness and implementation of committee duties	4.00
6.	Risk management application	8.00
7.	Anti-fraud strategy application	4.00
8.	Compliance function application	9.00
9.	Internal and external audit function application	4.00
10.	Conflict of interest handling	6.00
11.	Remuneration policy application	2.50
12.	Information transparency	8.00
13.	Business ethics	2.50
14.	Financing policy	5.00
15.	Sustainable finance application, including social and environmental responsibility application	2.50
16.	Business plan	2.50
Total		100.00

To obtain the governance value, PVML sums the values of all factors. Based on this value, PVML determines the rating for the application of Good Corporate Governance for the said PVML as in the following table:

Governance Value	Governance Rating
84-100	1
68-83	2
52-67	3
36-51	4
20-35	5

PVML determines the governance rating, accompanied by the preparation of a general conclusion from the self-assessment results, referring to the definition of governance ratings as follows:

Governance Rating	Definition
1	Reflects that PVML management has applied Good Corporate Governance which is generally very good. This is reflected in the very adequate fulfillment of Good Corporate Governance principles. In case there are weaknesses in the application of Good Corporate Governance principles, generally these weaknesses are not significant and can be immediately corrected by PVML management.
2	Reflects that PVML management has applied Good Corporate Governance which is generally good. This is reflected in the adequate fulfillment of Good Corporate Governance principles. In case there are weaknesses in the application of Good Corporate Governance principles, generally these weaknesses are less significant and can be resolved with normal actions by PVML management.
3	Reflects that PVML management has applied Good Corporate Governance which is generally fairly good. This is reflected in the fairly adequate fulfillment of Good Corporate Governance principles. In case there are weaknesses in the application of Good Corporate Governance principles, generally these weaknesses are quite significant and require considerable attention from PVML management.
4	Reflects that PVML management has applied Good Corporate Governance which is generally less good. This is reflected in the less adequate fulfillment of Good Corporate Governance principles. There are weaknesses in the application of Good Corporate Governance principles, generally these weaknesses are significant and require comprehensive correction by PVML management.
5	Reflects that PVML management has applied Good Corporate Governance which is generally not good. This is reflected in the inadequate fulfillment of Good Corporate Governance principles. There are weaknesses in the application of Good Corporate Governance principles, generally these weaknesses are very significant and difficult to correct by PVML management.

The self-assessment worksheet and supporting documents (if any) of the self-assessment must be well documented in accordance with regulations regarding archive retention so as to facilitate tracing by interested parties.
The Financial Services Authority conducts an assessment of the application of Good Corporate Governance, including conducting assessments or evaluations of the self-assessment results by PVML regarding governance implementation.
In the event that based on the Financial Services Authority's assessment or evaluation results as referred to in point 11, there are factors assessed to significantly influence PVML's governance and potentially impact PVML's condition and/or business continuity, the Financial Services Authority may adjust the composite governance rating of PVML.
For PVML with total assets less than Rp10,000,000,000.00 (ten billion rupiah) but whose financial statements have been audited by a public accountant, the assessment for the external audit function application factor must still be conducted.
For PVML with total assets less than Rp250,000,000,000.00 (two hundred fifty billion rupiah) but which form audit committees, risk monitoring committees, and/or remuneration and nomination committees, the assessment for the completeness and implementation of committee duties factor must still be conducted.

VI. ACTION PLAN

The action plan is prepared to improve or perfect the application of Good Corporate Governance as a follow-up to the self-assessment results. The aforementioned action plan includes necessary corrective actions, completion time, and obstacles/difficulties in completion, if there are still deficiencies in the application of Good Corporate Governance.
In the event that based on the self-assessment results of governance application, the governance factor rating obtained is rating 4 or rating 5, PVML prepares and submits an action plan containing comprehensive and systematic improvement steps and target times for action plan implementation to the Financial Services Authority.
If necessary, the Financial Services Authority may request PVML to submit an action plan containing comprehensive and systematic improvement steps and target times for action plan implementation, within a time limit as requested by the Financial Services Authority.
In the event that PVML has submitted the action plan as referred to in points 2 and 3 but based on the Financial Services Authority's consideration, adjustments to the action plan are necessary, the Financial Services Authority may request PVML to adjust the submitted action plan and resubmit the adjusted action plan within a time limit as requested by the Financial Services Authority.
The action plan as referred to in Appendix III point 2 letter c is prepared by PVML in the format as contained in Appendix III, which is an integral part of this Financial Services Authority Circular.

VII. SUBMISSION TIME OF GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT

PVML has the obligation to submit the Good Corporate Governance implementation report at the end of each fiscal year to the Financial Services Authority no later than April 30 of the following year.
In the event that April 30 as referred to in point 1 is a holiday, the submission deadline is on the first working day after April 30.
In the event that the report submission date for Good Corporate Governance application as referred to in point 1 or point 2 falls on a national holiday or joint holiday, the Financial Services Authority has the authority to determine the final submission date for the Good Corporate Governance implementation report.
For PVML that apply health level assessment with the Good Corporate Governance factor, the Good Corporate Governance implementation report as referred to in point 1 is part of the health level assessment report submitted to the Financial Services Authority no later than February 15 of the following year.
What is meant by being part of the health level assessment report submitted to the Financial Services Authority as referred to in point 4 is:
a. the Good Corporate Governance implementation transparency worksheet format as referred to in Appendix IV point 1; b. the self-assessment worksheet format as referred to in Appendix V point 2; and
c. the action plan worksheet format (if any) as referred to in Appendix VI point 5,
submitted as an attachment which is an integral part of the health level assessment.
For PVML that apply health level assessment with the Good Corporate Governance factor as referred to in point 4, PVML does not need to resubmit the Good Corporate Governance implementation report on April 30 as referred to in point 1.

VIII. PROCEDURE FOR SUBMISSION OF GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT

The submission of the cover letter and Good Corporate Governance implementation report must be submitted by PVML to the Financial Services Authority online through the Financial Services Authority's data communication network system.
In the event that:
a. the Financial Services Authority's data communication network system as referred to in point 1 is not yet available; and/or b. the Financial Services Authority's data communication network system and/or PVML experience technical disturbances or force majeure, PVML submits the Good Corporate Governance implementation report online in the form of an electronic document through the email address determined by the Financial Services Authority.
In the event that the Financial Services Authority's data communication network system is not yet available, technical disturbances, or force majeure as referred to in point 2, the Financial Services Authority provides notification or announcement on the Financial Services Authority website and/or via email to PVML.
In the event that technical disturbances or force majeure as referred to in point 2 letter b occurs at PVML, PVML submits written notification to the Financial Services Authority on the same day after the occurrence of the technical disturbance or force majeure.
Force majeure as referred to in point 2 letter b includes fire, mass riots, war, armed conflict, sabotage, pandemic, cyber attacks, as well as natural disasters, non-natural disasters, and/or social disasters that disrupt PVML's operational activities, which can be proven by a statement from the competent official of the relevant agency.
In the event that the Financial Services Authority's data communication network system is not yet available as referred to in point 2 letter a, the submission of the Good Corporate Governance implementation report in the form of an electronic document via email is submitted through the address mailingroomwismul@ojk.go.id or another address determined by the Financial Services Authority and addressed to:
a. for Financing Companies, Infrastructure Financing Companies, and Venture Capital Companies headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Supervision of Financing Institutions and Venture Capital Companies. b. for Microfinance Institutions and Pawnshop Companies headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Supervision of Microfinance Institutions, Pawnshops, and Coordination of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Regional.
c. for Technology-Based Collective Financing Service Providers headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Supervision of Technology-Based Financing Business. d. for PVML conducting business activities based on Sharia Principles and PVML that have Sharia Business Units headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Special Supervision and Supervision of Sharia Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions. e. for Financing Companies, Venture Capital Companies, Microfinance Institutions, Pawnshop Companies, and Technology-Based Collective Financing Service Providers headquartered outside the Jakarta city area, addressed to the Head of the local Financial Services Authority Office.
In the event that the email address determined by the Financial Services Authority as referred to in point 6 experiences technical disturbances, PVML submits the Good Corporate Governance implementation report offline in the form of an electronic document using electronic data storage media sent offline to the Financial Services Authority through a letter signed by the Board of Directors and addressed to:
a. for Financing Companies, Infrastructure Financing Companies, and Venture Capital Companies headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Supervision of Financing Institutions and Venture Capital Companies Wisma Mulia 2 Building, 11th Floor Jalan Jenderal Gatot Subroto Kav. 40, Jakarta 12710. b. for Microfinance Institutions and Pawnshop Companies headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Supervision of Microfinance Institutions, Pawnshops, and Coordination of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Regional Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Kav. 40, Jakarta 12710.
c. for Technology-Based Collective Financing Service Providers headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Supervision of Technology-Based Financing Business Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Kav. 40, Jakarta 12710. d. for PVML conducting business activities based on Sharia Principles and PVML that have Sharia Business Units headquartered in the Jakarta, Bogor, Depok, Tangerang, Bekasi area:
Executive Head of Supervision of Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Financial Services Authority u.p. Director of Special Supervision and Supervision of Sharia Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions Wisma Mulia 2 Building, 11th Floor Jalan Jenderal Gatot Subroto Kav. 40, Jakarta 12710. e. for Financing Companies, Venture Capital Companies, Microfinance Institutions, Pawnshop Companies, and Technology-Based Collective Financing Service Providers headquartered outside the Jakarta city area, addressed to the Head of the local Financial Services Authority Office.
In the event that the Financial Services Authority's data communication network system and/or PVML experience technical disturbances or force majeure as referred to in point 2 letter b, the submission of the Good Corporate Governance implementation report in the form of an electronic document via email is submitted through the address mailingroommrp@ojk.go.id or another address determined by the Financial Services Authority and addressed to:
Financial Services Authority u.p. Head of Data and Statistics Management Department with a copy to the relevant Supervision Department of PVML.
In the event that the email address determined by the Financial Services Authority as referred to in point 8 experiences technical disturbances, PVML submits the Good Corporate Governance implementation report offline in the form of an electronic document using electronic data storage media sent offline to the Financial Services Authority through a letter signed by the Board of Directors and addressed to:
Financial Services Authority u.p. Head of Data and Statistics Management Department Radius Prawiro Tower Building, 14th Floor Bank Indonesia Office Complex Jalan MH. Thamrin Number 2, Jakarta, 10110 with a copy to the relevant Supervision Department of PVML.
The offline submission of the Good Corporate Governance implementation report as referred to in point 7 can be done in the following ways:
a. submitted directly; or b. sent via a courier service company, to the Financial Services Authority office, according to the address as referred to in point 7.
The offline submission of the Good Corporate Governance implementation report as referred to in point 8 is submitted to the Financial Services Authority on working days and working hours of the Financial Services Authority.
In the event of technical disturbances or force majeure, the Financial Services Authority may determine a postponement of the submission deadline for the Good Corporate Governance implementation report during the system application recovery period.
In determining the postponement of the submission deadline for the Good Corporate Governance implementation report as referred to in point 10, the Financial Services Authority considers the time and resolution of the technical disturbances and force majeure.
In the event that technical disturbances and force majeure as referred to in point 2 have been successfully resolved and the Financial Services Authority's data communication network system has returned to normal, the Good Corporate Governance implementation report is submitted online again.
For PVML that apply health level assessment with the Good Corporate Governance factor, the procedure for submitting the Good Corporate Governance implementation report is conducted in accordance with the Financial Services Authority Circular regarding the health level assessment of PVML.
In the event of a change in the Financial Services Authority office address for report submission as referred to in point 7, the Financial Services Authority provides notification or announcement regarding the address change on the Financial Services Authority website and/or via email to PVML.
PVML is deemed to have submitted the Good Corporate Governance implementation report with the following conditions:
a. for online submission via:

the Financial Services Authority's data communication network system is proven by a receipt from the Financial Services Authority's data communication network system; or
email to the Financial Services Authority is proven by email delivery proof and/or receipt from the Financial Services Authority's email, in the case of submission through the data communication network system

This copy is consistent with the original
Director of Legal Development Head
Legal Department signed.
Aat Windradi
The Financial Services Authority is not available, experiencing technical disturbances, or a force majeure event occurs; or b. for offline submission in the form of electronic documents using electronic data storage media, evidenced by a receipt from the Financial Services Authority.
18. Questions related to the submission of the Good Corporate Governance Implementation Report can be submitted to the Financial Services Authority helpdesk via telephone number 021-29600000 ext. 7000 or email address helpdesk@ojk.go.id.
IX. CLOSING

At the time this Financial Services Authority Circular takes effect:
a. Financial Services Authority Circular Number 15/SEOJK.05/2016 concerning the Implementation Report of Financing Company Corporate Governance; and b. the provisions of Section IV and Appendix I of Financial Services Authority Circular Number 11/SEOJK.05/2020 concerning the Assessment of the Health Level of Financing Companies and Sharia Financing Companies;
c. the provisions of Section IV and Appendix I of Financial Services Authority Circular Number 27/SEOJK.05/2021 concerning the Assessment of the Health Level of Infrastructure Financing Companies; and
d. the provisions of Section IV and Appendix I of Financial Services Authority Circular Number 19/SEOJK.06/2024 Concerning the Assessment of the Health Level of Venture Capital Companies and Sharia Venture Capital Companies, are repealed and declared invalid.
With the implementation of this Financial Services Authority Circular, PVML submits the report on the implementation of Good Corporate Governance based on this Financial Services Authority Circular for the first time for the December 2025 reporting position.
The provisions in this Financial Services Authority Circular take effect on the date of establishment.
Established in Jakarta on 19 November 2025
EXECUTIVE HEAD OF SUPERVISOR
PAYMENT INSTITUTIONS,
VENTURE CAPITAL COMPANIES,
MICROFINANCE INSTITUTIONS,
AND OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

AGUSMAN signed.

APPENDIX I
FINANCIAL SERVICES AUTHORITY CIRCULAR
REPUBLIC OF INDONESIA
NUMBER 28/SEOJK.06/2025
CONCERNING
THE GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT FOR FINANCING INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICROFINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS

CHAPTER I
GENERAL EXPLANATION
The preparation of transparency reports on the implementation of Good Corporate Governance as referred to in Article 108 paragraph (2) letter a of POJK Corporate Governance for PVML is carried out in the context of implementing the principle of openness. PVML discloses all aspects of Good Corporate Governance transparency in the format as mentioned in this Appendix. PVML may submit general explanations of the implementation of Good Corporate Governance or other matters deemed significant in accordance with the conditions and policies of each PVML.

CHAPTER II
FORMAT OF TRANSPARENCY REPORT ON THE IMPLEMENTATION OF GOOD CORPORATE GOVERNANCE FOR PVML A. Summary of Self-Assessment Results on the Implementation of Good Corporate Governance Address :
Telephone Number :
General Explanation :
Composite Score of Self-Assessment Results of Good Corporate Governance :
Explanation of Composite Score of Self-Assessment Results :
B. Disclosure of Good Corporate Governance Implementation

Implementation of Duties and Authorities of Shareholders and GMS
a. PSP
No. Implementation of Duties and Authorities of PSP
NIK*) :
Name :
Date of Approval of Competence and Fit and Proper Test Results :
Number of Competence and Fit and Proper Test Results :
Country of Origin :
Citizenship*) :
Domicile :
Duties and Authorities :
NIK*) :
Name :
Date of Approval of Competence and Fit and Proper Test Results :
Number of Competence and Fit and Proper Test Results :
Country of Origin :
Citizenship*) :
Domicile :
Duties and Authorities :
etc.
*) NIK and Citizenship are only submitted in reporting to the Financial Services Authority and are filled in only for individual PSPs. b. Shareholders No. Implementation of Duties and Authorities of Shareholders
NIK*) :
Name :
Country of Origin :
Citizenship*) :
Domicile :
Duties and Authorities :
NIK*) :
Name :
Country of Origin :
Citizenship*) :
Domicile :

No. Implementation of Duties and Authorities of Shareholders Duties and Authorities :
etc.
*) NIK and Citizenship are only submitted in reporting to the Financial Services Authority and are filled in only for individual shareholders.
c. Implementation of GMS
No. Implementation of GMS

Date :
Number of Participants :
Topics/Materials Discussed :
Date :
Number of Participants :
Topics/Materials Discussed :
etc.
Implementation of Duties, Responsibilities, and Authorities of the Board of Directors
No. Implementation of Duties, Responsibilities, and Authorities of the Board of Directors
NIK*) :
Name :
Position :
Date of Approval of Competence and Fit and Proper Test Results :
Number of Competence and Fit and Proper Test Results :
Date of Appointment by GMS :
Term of Office :
Citizenship :
Domicile :
Work History in the Last Five Years :
Education :
Professional Degree :
KITAS Work Permit :
KITAS Validity Period :
IMTA Permit Number :
IMTA Validity Period :
Duties, Responsibilities, and Authorities) :
NIK*) :
Name :
Position :
Date of Approval of Competence and Fit and Proper Test Results :
Number of Competence and Fit and Proper Test Results :
Date of Appointment by GMS :
Term of Office :
Citizenship :
Domicile :
Work History in the Last Five Years :
Education :

No. Implementation of Duties, Responsibilities, and Authorities of the Board of Directors Professional Degree :
KITAS Work Permit :
KITAS Validity Period :
IMTA Permit Number :
IMTA Validity Period :
Duties, Responsibilities, and Authorities) :
etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) Filled with a description of the duties, responsibilities, and authorities of the PVML Board of Directors.
*) Follow-up on Board of Commissioners recommendations not reported in the previous year's Good Corporate Governance Implementation Report.
3. Implementation of Duties, Responsibilities, and Authorities of the Board of Commissioners
No. Implementation of Duties, Responsibilities, and Authorities of the Board of Commissioners, including Independent Commissioners (if any)

NIK*) :
Name :
Position :
Date of Approval of Competence and Fit and Proper Test Results :
Number of Competence and Fit and Proper Test Results :
Date of Appointment by GMS :
Term of Office :
Citizenship :
Domicile :
Work History in the Last Five Years :
Education :
Professional Degree :
KITAS Work Permit :
KITAS Validity Period :
IMTA Permit Number :
IMTA Validity Period :
Duties, Responsibilities, and Authorities) :
etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) Filled with a description of the duties, responsibilities, and authorities of the PVML Board of Commissioners, including Independent Commissioners (if any)

Board of Commissioners Recommendations Follow-up*) -

Implementation of Duties, Responsibilities, and Authorities of the DPS
No. Implementation of Duties, Responsibilities, and Authorities of the DPS
NIK*) :
Name :
Position :
Date of Approval of Competence and Fit and Proper Test Results :
Number of Competence and Fit and Proper Test Results :
Date of Appointment by GMS :
Term of Office :
Citizenship :
Domicile :
Duties, Responsibilities, and Authorities) :
etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) Filled with a description of the duties, responsibilities, and authorities of the PVML DPS.
Completeness and Implementation of Committee Duties
a. Duties, Responsibilities, Work Programs, and Realization of Committee Work Programs No. Work Programs and Realization of Committee Work Programs*)
Audit Committee
Duties and Responsibilities :
Work Program :
Realization :
Number of Meetings :
Risk Monitoring Committee
Duties and Responsibilities :
Work Program :
Realization :
Number of Meetings :
Remuneration and Nomination Committee
Duties and Responsibilities :
Work Program :
Realization :

Recommendations to the Board of Directors -
Recommendations to the Board of Directors -

No. Work Programs and Realization of Committee Work Programs*) Number of Meetings :
4. Risk Management Committee
Duties and Responsibilities :
Work Program :
Realization :
Number of Meetings :
5. Other Committees)
Duties and Responsibilities :
Work Program :
Realization :
Number of Meetings :
*) The number of work programs reported is the same as the realization of work programs.
) Filled if PVML has committees other than the audit committee, risk monitoring committee, remuneration and nomination committee, and risk management committee. b. Structure, Membership, Expertise, and Independence of Committee Members No. Structure, Membership, Expertise, and Independence of Committee Members Audit Committee

NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No
NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No etc.
Risk Monitoring Committee
NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No
NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No etc.
Remuneration and Nomination Committee
NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No
NIK*) :
Name :

No. Structure, Membership, Expertise, and Independence of Committee Members Expertise) :
Structure*) :
Independent Party : Yes/No etc.
Risk Management Committee

NIK*) :
Name :
Expertise) :
Independent Party : Yes/No
NIK*) :
Name :
Expertise) :
Independent Party : Yes/No etc.
Other Committees)
NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No
NIK*) :
Name :
Expertise) :
Structure*) :
Independent Party : Yes/No etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) Filled with the competence and/or experience of each committee member in accordance with the duties and responsibilities of the committee.
*) Filled with: chairman, member, or not holding office.
Implementation of Risk Management
a. Implementation of Risk Management

Ownership of Risk Management Work Unit
No. Person in Charge of Work Unit Head
Active Supervision by the Board of Commissioners, Board of Directors, and DPS
-Brief description example ensuring that PVML implements Good Corporate Governance-
Adequacy of Policies, Procedures, and Risk Limit Determination
Adequacy of risk identification, measurement, monitoring, and control processes
Risk management information system
Comprehensive internal control system
b. Implementation of Anti-Money Laundering, Counter-Terrorism Financing, and Counter-Proliferation Financing of Weapons of Mass Destruction Programs No. Person in Charge of Work Unit Head/Executor of Function
c. Ownership of Work Units or Functions in Handling and Resolving Complaints Submitted by Consumers
No. Person in Charge of Work Unit Head/Executor of Function -Brief description- -Brief description- -Brief description- -Brief description-

Implementation of Antifraud Strategy
Number of Internal Violations (Internal Fraud) Number Internal Violations*) (Within 1 Year) Number of Cases (Units) Committed By Board of Directors Members Board of Commissioners Members DPS Permanent Employees Non-Permanent Employees Previous Year Report Year Previous Year Report Year Previous Year Report Year Previous Year Report Year Previous Year Report Year Previous Year Report Year Previous Year Report Year Total Fraud Resolved In Process of Resolution) Not Yet Attempted Resolution*) Followed Up Through Legal Process *) PVML must explain further regarding efforts to resolve internal violations by PVML. In the event of internal violations not yet attempted for resolution, the research efforts conducted can be explained. ) Includes internal violations not resolved previously up to the report year. *) Refers to internal violations still under investigation.
Implementation of Compliance Function
a. Board of Directors Members Who Supervise the Compliance Function b. Work Unit or Function Responsible for Compliance Implementation
c. Compliance Implementation with Legislation
Implementation of Internal Audit and External Audit Functions
a. Internal Auditor Function
Effectiveness and scope of internal auditor task implementation in assessing all aspects and elements of activities

Audit Work Scope
Structure or Position of Internal Audit Work Unit or Function
Independence of Internal Auditors
-Brief description-
-Brief description-
-Brief description of the duties of the work unit or function responsible for compliance implementation in ensuring policies, regulations, systems, procedures, and business activities conducted by PVML are in accordance with legislation- -Uraian singkat- -Uraian singkat- -Uraian singkat-
Description of Duties of Internal Audit Work Unit or Function
Profile of Head of Internal Audit Work Unit or Function
Number of Employees in Internal Audit Work Unit or Function
Internal Audit Task Implementation Results Report.
b. External Auditor Function
Effectiveness of external auditor task implementation and company compliance with regulations, including providing all accounting records and supporting data required by external auditors, enabling external auditors to provide their opinion on the fairness, compliance, and consistency of the company's financial reports with applicable audit standards. -Uraian singkat- -Uraian singkat- -Uraian singkat- -Uraian singkat regarding the plan and realization of annual audit programs, for example: branch office audits, headquarters audits, and information system technology audits - -Uraian singkat-

Public Accounting Firm Conducting Company Financial Audits for the Last 5 (Five) Years Year Public Accounting Firm Accountant Name (Individual) and Registration Number at the Financial Services Authority Auditor Fees External Auditor

Handling Conflicts of Interest
Examples of ongoing and/or potential conflicts of interest include the purchase of company assets and/or financing distribution by Board of Directors members, Board of Commissioners members, DPS members, and/or PVML employees. No. Party with Conflict of Interest Decision Maker Type Transaction Transaction Value (Millions of Rupiah) Notes) NIK*) Name Position NIK*) Name Position 1. 2. etc. *) NIK is only submitted in reporting to the Financial Services Authority. ) Notes are filled with:

consistency and/or inconsistency of transactions with internal regulations;
explaining the relationship between the party with the conflict of interest and the decision maker; and
the form of follow-up handling of Conflicts of Interest found.

Implementation of Remuneration Policy
a. Remuneration in Non-Natura Form, Including Salaries and Other Fixed Income, Such as Allowances (Benefits), Stock-Based Compensation, Bonuses, and Other Forms of Remuneration -Brief description-

b. Other Facilities in Natura/Non-Natura Form, i.e., Other Variable Income, including Allowances for Housing, Transportation, Health Insurance, and Other Facilities
c. Remuneration Packages or Other Facilities for Board of Directors, Board of Commissioners, and DPS Members Determined by GMS in 1 (One) Year
d. Remuneration and Other Facilities for All Board of Directors, Board of Commissioners, and DPS Members at Least Covering the Number of Board of Directors Members, Number of Board of Commissioners Members, Number of DPS Members, and Number of All Remuneration Policies and Other Facilities in 1 (One) Year Amount Received in One Year (Millions of Rupiah) Number of Members Nominal Remuneration*) Nominal Other Facilities in Natura Form) Board of Directors Board of Commissioners DPS Note:
*) Includes salaries and other fixed income, such as allowances (benefits), stock-based compensation, bonuses, and other forms of remuneration in non-natura form ) Housing, transportation, health insurance, etc. -Uraian singkat- -Uraian singkat- -Uraian singkat-

e. Number of Board of Directors, Board of Commissioners, and DPS Members Receiving Remuneration Packages in 1 (One) Year Grouped by Income Level Remuneration Amount per Person in 1 (One) Year in Cash Number Board of Directors Number Board of Commissioners Number DPS >Rp2,000,000,000.00 (Two Billion Rupiah) >Rp1,000,000,000.00 (One Billion Rupiah) to Rp2,000,000,000.00 (Two Billion Rupiah) >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 f. Highest and Lowest Salary Ratio Salaries compared in the salary ratio are the compensation received by Board of Directors, Board of Commissioners, and PVML employees in the last month of the reporting year. Note*) Comparison) (a/b) Ratio of highest paid employee (a) and lowest paid employee (b) Ratio of highest paid Board of Directors member (a) and lowest paid Board of Directors member (b) Ratio of highest paid Board of Commissioners member (a) and lowest paid Board of Commissioners member (b) Ratio of highest paid Board of Directors member (a) and highest paid Board of Commissioners member (b) Ratio of highest paid Board of Directors member (a) and highest paid Employee (b) *) The salary referred to is the total salary received, including basic salary and allowances in 1 (one) year. ) Example of salary ratio comparison calculation Highest paid employee salary = Rp200,000,000.00 Lowest paid employee salary = Rp50,000,000.00 Ratio of highest to lowest paid employee = Highest Paid Employee Salary Lowest Paid Employee Salary = Rp200,000,000.00 Rp50,000,000.00 = 4 : 1 The ratio of highest to lowest paid employees is reported in the smallest fraction. -Uraian singkat-

Information Openness
a. Share Ownership of Board of Directors and Board of Commissioners Members in PVML

Share Ownership of Board of Directors Members in PVML
No. NIK*) Name of Board of Directors Member Nominal (Rp) Ownership Percentage (%) Nominal (Rp) Previous Year Ownership Percentage (%) Previous Year 1.

etc
*) NIK is only submitted in reporting to the Financial Services Authority.

Share Ownership of Board of Commissioners Members in PVML
No. NIK*) Name of Board of Commissioners Member Nominal (Rp) Ownership Percentage (%) Nominal (Rp) Previous Year Ownership Percentage (%) Previous Year 1.

etc
*) NIK is only submitted in reporting to the Financial Services Authority. b. Share Ownership of Board of Directors and Board of Commissioners Members in Other Companies

Share Ownership of Board of Directors Members in Other Companies
No. NIK*) Name of Board of Directors Member Name of Other Company) Nominal (Rp) Ownership Percentage (%) Nominal (Rp) Previous Year Ownership Percentage (%) Previous Year 1.

etc
*) NIK is only submitted in reporting to the Financial Services Authority.
) In the event that the other company is another PVML, the code reported is in accordance with the Financial Services Authority Circular regarding monthly reports of each PVML.

Share Ownership of Board of Commissioners Members in Other Companies
No. NIK*) Name of Board of Commissioners Member Name of Other Company) Nominal (Rp) Ownership Percentage (%) Nominal (Rp) Previous Year Ownership Percentage (%) Previous Year 1.

etc
*) NIK is only submitted in reporting to the Financial Services Authority.
) In the event that the other company is another PVML, the code reported is in accordance with the Financial Services Authority Circular regarding monthly reports of each PVML.
c. Financial Relationships of Board of Directors and Board of Commissioners Members in PVML

Financial Relationships of Board of Directors Members in PVML
No. NIK*) Name of Board of Directors Member Financial Relationship) Board of Directors Members Board of Commissioners Members DPS Shareholders Employees 1.

etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) - In the event of a financial relationship, filled with "Name – Financial Relationship". Financial relationships can include, among others, receiving and/or providing income, financial assistance, loans, and/or acting as a guarantor or receiving guarantees, example "Mr. A – Loan".

In the event that a Board of Directors member has a financial relationship with more than one party in each column, it can be added separated by a comma (,).
In the event of no financial relationship, filled with "None".

Financial Relationships of Board of Commissioners Members in PVML
No. NIK*) Name of Board of Commissioners Member Financial Relationship) Board of Directors Members Board of Commissioners Members DPS Shareholders Employees 1.

etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) - In the event of a financial relationship, filled with "Name – Financial Relationship". Financial relationships can include, among others, receiving and/or providing income, financial assistance, loans, and/or acting as a guarantor or receiving guarantees, example "Mr. A – Loan".

In the event that a Board of Commissioners member has a financial relationship with more than one party in each column, it can be added separated by a comma (,).
In the event of no financial relationship, filled with "None".
d. Family Relationships of Board of Directors and Board of Commissioners Members in PVML

Family Relationships of Board of Directors Members in PVML
No. NIK*) Name of Board of Directors Member Family Relationship) Board of Directors Members Board of Commissioners Members DPS Shareholders Employees 1.

etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) - In the event of a family relationship, filled with "Name – Family Relationship", example "Mr. A – Cousin".

In the event that a Board of Directors member has a family relationship with more than one party in each column, it can be added separated by a comma (,).
In the event of no family relationship, filled with "None".

Family Relationships of Board of Commissioners Members in PVML
No. NIK*) Name of Board of Commissioners Member Family Relationship) Board of Directors Members Board of Commissioners Members DPS Shareholders Employees 1.

etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) - In the event of a family relationship, filled with "Name – Family Relationship", example "Mr. A – Cousin".

In the event that a Board of Commissioners member has a family relationship with more than one party in each column, it can be added separated by a comma (,).
In the event of no family relationship, filled with "None".
e. Remuneration and Other Facilities Received by Board of Directors and Board of Commissioners Members No. Type of Remuneration (Within 1 Year) Board of Directors Board of Commissioners Number of People Total Amount (Rp) Number of People Total Amount (Rp)

Salary*)
Allowances
Bonuses
Stock-based compensation
Other Remuneration)
Total Remuneration
Type of Other Facilities
Housing
Transportation
Health Insurance
Other Facilities*)
Total Other Facilities

No. Type of Remuneration
(Within 1 Year)
Board of Directors Board of Commissioners
Number of People Total Amount (Rp) Number of People Total Amount (Rp) Total Remuneration and Other Facilities *) Salary refers to basic salary, not including allowances received by Board of Directors and Board of Commissioners members and their families. ) Other remuneration for PVML officials and determined based on GMS considering the duties, authorities, responsibilities, and risks of each Board of Directors and Board of Commissioners member. Disclosure of Other Important Matters a. Resignation or Dismissal of External Auditors No. Resignation or Dismissal of External Auditors

Name :
Position :
Date of Appointment :
Date of Resignation or Dismissal :
Reason for Resignation and/or Dismissal :
etc. b. Material Transactions with Parties Having Affiliation Relationships No.
Party with Affiliation Relationship Decision Maker Type Transaction Transaction Value (Millions of Rupiah) Notes) NIK*) Name Position NIK*) Name Position 1.
etc.
*) NIK is only submitted in reporting to the Financial Services Authority.
) Notes are filled with:

Consistency and/or inconsistency of transactions with internal regulations; and
Explaining the relationship between the party with the affiliation relationship and the decision maker.

c. Other Material Information regarding PVML Related to Good Corporate Governance

Changes in the Composition of the Board of Directors, Managers, Board of Commissioners Members, and/or DPS

Changes in the Composition of the Board of Directors, Managers, Board of Commissioners Members, and/or DPS include the appointment, dismissal, replacement, and/or resignation of members of the Board of Directors, managers, members of the Board of Commissioners, and DPS.

In the event that there are changes in the composition of the Board of Directors, managers, Board of Commissioners members, and/or DPS during the reporting year, the previous membership composition of the Board of Directors, Board of Commissioners, and/or DPS must be stated in a table as follows:

a) Board of Directors Members
No. Changes in the Composition of the Board of Directors Members

Name :
Position :
Date of Appointment by GMS :
Date of Dismissal, Replacement, and/or Resignation by GMS :
Reason for Dismissal, Replacement, and/or Resignation :
etc.

b) Managers
No. Changes in the Composition of Managers

Name :
Position :
Date of Appointment by GMS :
Date of Dismissal, Replacement, and/or Resignation by GMS :
Reason for Dismissal, Replacement, and/or Resignation :
etc.

c) Board of Commissioners Members
No. Changes in the Composition of Board of Commissioners Members

Name :
Position :
Date of Appointment by GMS :
Date of Dismissal, Replacement, and/or Resignation by GMS :
Reason for Dismissal, Replacement, and/or Resignation :
etc.

d) DPS
No. Changes in the Composition of DPS

Name :
Position :
Date of Appointment by GMS :
Date of Dismissal, Replacement, and/or Resignation by GMS :
Reason for Dismissal, Replacement, and/or Resignation :
etc.

Resignation or Dismissal of Independent Commissioners
No. Resignation or Dismissal of Independent Commissioners

Name :
Position :
Date of Appointment by GMS :
Date of Resignation or Dismissal by GMS :
Reason for Resignation and/or Dismissal by GMS :
etc.

Training for Board of Directors Members, Board of Commissioners Members, and DPS

Training related to enhancing the capabilities of Board of Directors members, Board of Commissioners members, and DPS in achieving the vision and mission of PVML.

a) Board of Directors Members
No. Training for Board of Directors Members

Name :
Workshop/Training/Seminar :
Date :
Organizer - Location :
Name :
Workshop/Training/Seminar :
Date :
Organizer - Location :
etc.

b) Board of Commissioners Members
No. Training for Board of Directors Members

Name :
Workshop/Training/Seminar :
Date :
Organizer - Location :
Name :
Workshop/Training/Seminar :
Date :
Organizer - Location :
etc.

c) DPS
No. Training for Board of Directors Members

Name :
Workshop/Training/Seminar :
Date :
Organizer - Location :
Name :
Workshop/Training/Seminar :
Date :
Organizer - Location :
etc.

Dual Positions of Board of Directors Members, Board of Commissioners Members, and DPS

a) Board of Directors Members
No. Dual Positions of Board of Directors Members

Name :
Position at PVML :
Position at Other Company :
Name of Other Company :
Business Field :
Name :
Position at PVML :
Position at Other Company :
Name of Other Company :
Business Field :
etc.

b) Board of Commissioners Members
No. Dual Positions of Board of Commissioners Members

Name :
Position at PVML :
Position at Other Company :
Name of Other Company :
Business Field :
Name :
Position at PVML :
Position at Other Company :
Name of Other Company :
Business Field :
etc.

c) DPS
No. Dual Positions of DPS

Name :
Position at PVML :
Position at Other Company :
Name of Other Company :
Business Field :
Name :
Position at PVML :
Position at Other Company :
Name of Other Company :
Business Field :
etc.

Frequency of Meetings Held in 1 (One) Year

a) Board of Directors Meetings
No. Execution of Board of Directors Meetings

Date :
Number of Participants :
Topic/Discussion Material :
Date :
Number of Participants :
Topic/Discussion Material :
etc.

Attendance at Board of Directors Meetings
No. Attendance at Board of Directors Meetings

Name :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
Name :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
etc.

*) Attendance Rate =
(Number of Physical Attendances + Number of Electronic Media Facility Attendances) / Number of Meetings × 100%

b) Joint Board of Directors and Board of Commissioners Meetings No. Execution of Joint Board of Directors and Board of Commissioners Meetings

Date :
Number of Participants :
Topic/Discussion Material :
Date :
Number of Participants :
Topic/Discussion Material :
etc.

Attendance at Joint Board of Directors and Board of Commissioners Meetings No. Attendance at Joint Board of Directors and Board of Commissioners Meetings

Name :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
Name :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
etc.

*) Attendance Rate =
(Number of Physical Attendances + Number of Electronic Media Facility Attendances) / Number of Meetings × 100%

c) Board of Commissioners Meetings
No. Execution of Board of Commissioners Meetings

Date :
Number of Participants :
Topic/Discussion Material :
Date :
Number of Participants :
Topic/Discussion Material :
etc.

Attendance at Board of Commissioners Meetings
No. Attendance at Board of Commissioners Meetings

Name :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
Name :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
etc.

d) DPS Meetings Jointly with the Board of Directors, Executive Officers, and/or UUS Leaders No. Execution of DPS Meetings Jointly with the Board of Directors, Executive Officers, and/or UUS Leaders

Date :
Number of Participants :
Topic/Discussion Material :
Date :
Number of Participants :
Topic/Discussion Material :
etc.

Attendance at DPS Meetings Jointly with the Board of Directors, Executive Officers, and/or UUS Leaders No. Attendance at DPS Meetings Jointly with the Board of Directors, Executive Officers, and/or UUS Leaders

Name :
Number of Meetings :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
Name :
Number of Meetings :
Number of Physical Attendances :
Number of Electronic Media Facility Attendances :
Attendance Rate (%)*) :
Reason for Absence :
etc.

*) Attendance Rate =
(Number of Physical Attendances + Number of Electronic Media Facility Attendances) / Number of Meetings × 100%

Foreign Workers
No. Name Position KITAS IMTA Permit Work Permit Validity Period Permit Number Validity Period 1.

etc.

Legal Issues
Legal Issues Quantity (Unit)
Civil Criminal
Completed (has permanent legal force)
In Settlement Process
Total

PVML must explain further regarding the efforts to resolve legal issues by PVML.

Transparency of PVML's Financial and Non-Financial Conditions Not Disclosed in Other Reports
Long-Term Plans and Work Plans
Annual Budget Plan

Implementation of Business Ethics according to Guidelines

Brief description, for example: disclosure of company rating results conducted by rating agencies, transparency regarding financing services presented in the form of brochures, leaflets, and other promotional media as well as on the company website, transparency regarding complaint procedures and dispute resolution for Debtors, and share buyback -
Brief description -
Brief description -
Brief description -
Brief description regarding PVML's business ethics values that serve as guidelines for PVML organs and all employees -

This copy is consistent with the original
Head of Legal Development Directorate
Legal Department signed.
Aat Windradi

Financing Policy

Brief description -
Brief description -
Brief description -

Implementation of Sustainable Finance, including Social and Environmental Responsibility
Business Plan

Approving,
THE BOARD OF DIRECTORS
Established in Jakarta on November 19, 2025
EXECUTIVE HEAD OF SUPERVISOR
LEMBAGA PEMBIAYAAN,
PERUSAHAAN MODAL VENTURA,
LEMBAGA KEUANGAN MIKRO, DAN
LEMBAGA JASA KEUANGAN LAINNYA
OTORITAS JASA KEUANGAN
REPUBLIK INDONESIA,
AGUSMAN

Brief description -
Brief description signed.

APPENDIX II
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 28/SEOJK.06/2025 REGARDING THE GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT FOR FINANCING INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICROFINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS

SELF-ASSESSMENT OF GOOD CORPORATE GOVERNANCE IMPLEMENTATION

The filling out of the Good Corporate Governance implementation worksheet is conducted by the respective PVML. The filling out of this worksheet is done by answering questions/statements in the said worksheet. The analysis/comment column is filled with explanations and reasons for the indicator values given for each statement/question according to the PVML's conditions, accompanied by relevant supporting documents (if any). In the event that there are parameters that do not match the PVML's conditions, as an example:

PVMLs not required to form committees according to Financial Services Authority Regulation Number 48 of 2024 on Good Corporate Governance for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions, then PVMLs;
or
PVMLs conducting activities conventionally,
the said PVMLs do not need to fill out assessments regarding committee factors or Sharia Supervisory Board factors.

PART A
SELF-ASSESSMENT OF GOOD CORPORATE GOVERNANCE IMPLEMENTATION FOR FINANCING COMPANIES, INFRASTRUCTURE FINANCING COMPANIES, AND VENTURE CAPITAL COMPANIES

The PVML referred to in this self-assessment worksheet on Good Corporate Governance implementation is:

Financing Companies;
Infrastructure Financing Companies; and
Venture Capital Companies

A. Implementation of Shareholders' and GMS's Duties and Authorities A. Governance Structure and Infrastructure (S)

Composition and requirements of shareholders in accordance with statutory regulations.
Policies and procedures for decision-making through GMS are stated in the articles of association and in accordance with statutory regulations.
Each party who is a shareholder of PVML has obtained approval from the Financial Services Authority through the implementation of fitness and propriety assessments.

B. Governance Implementation Process (P)
4. Implementation of communication regarding the vision and mission of PVML development to the Board of Directors and/or Board of Commissioners.
5. Monitoring of PVML's development through the results of the Board of Commissioners' supervision.
6. Shareholders' support in PVML's development through capital planning or other development support.
7. Shareholders ensure the implementation of healthy governance, including avoiding conflicts of interest, intervention, taking personal benefits or the interests of certain groups, and decisions on the appointment, replacement, or dismissal of Board of Directors and/or Board of Commissioners members.
8. Shareholders comply with Financial Services Authority Regulations and statutory regulations in the financial services sector, and support the implementation of healthy, competitive business activities and management of PVML in accordance with the principle of prudence and risk management.
9. PVML shareholders also support the implementation of healthy, competitive PVML business activities in accordance with the principle of prudence and risk management.
10. PVML shareholders also maintain the continuity of PVML's business.
11. PVML shareholders do not interfere in PVML's operational activities which are the responsibility of the Board of Directors in accordance with PVML's articles of association and statutory regulations, except in exercising rights and obligations as GMS.
12. Decision-making through GMS takes into account inputs and recommendations from the Board of Commissioners, as well as inputs or opinions from all shareholders.
13. Decision-making through GMS protects the interests of all parties, particularly the interests of Debtors, fund recipients, consumers, business partners, depositors, creditors, fund providers, venture capital investors, and/or minority shareholders' interests.

C. Results of Governance Implementation (H)
14. Shareholders receive fair rights and treatment, including in the implementation of corporate actions.
15. PVML's performance development aligns with strategic plans, including through the realization of capital plans or other support plans.
16. Shareholders do not engage in conflicts of interest, intervention, taking personal benefits or the interests of certain groups, and decisions on the appointment, replacement, or dismissal of Board of Directors and/or Board of Commissioners members.
17. The use of profits and dividend distribution considers profit usage and dividend distribution policies that align with the articles of association and statutory regulations, as well as considering external and internal conditions.
18. The implementation of share disposal by PVML owned by Board of Directors members, Board of Commissioners members, PVML committee members, DPS, Executive Officers, and/or PVML employees originating from management stock ownership programs and/or employee stock ownership programs considers Good Corporate Governance at PVML and considers PVML's conditions.

Positive Factors
Contains a summary of positive factors from the implementation of shareholders' and GMS's duties and authorities that have a significant impact on governance implementation. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the implementation of shareholders' and GMS's duties and authorities that have a significant impact on governance implementation. a. Structure b. Process
c. Results

B. Implementation of Board of Directors' Duties, Responsibilities, and Authorities A. Governance Structure and Infrastructure (S)

The number of Board of Directors members in accordance with Financial Services Authority regulations and one of the Board of Directors members acts as the Director overseeing the compliance function.
PVML appoints one Board of Directors member as the President Director or equivalent.
PVML appoints other Board of Directors members as Vice President Directors or equivalents.
The President Director or equivalent is not an individual shareholder in the same PVML and/or has family relations up to the second degree, both horizontally and vertically, with individual shareholders in the same PVML.
Board of Directors' nationality in accordance with Financial Services Authority regulations.
All Board of Directors members reside within the territory of the Republic of Indonesia.
All Board of Directors members of Pawning Companies and Microfinance Institutions reside within the operational area of the respective PVML and areas directly bordering the PVML's operational area.
Foreign nationality Board of Directors members have residence permits.
Foreign nationality Board of Directors members have work permits from competent authorities.
Board of Directors members do not hold dual positions in the same company, other companies, and/or other institutions in accordance with Financial Services Authority regulations.
Board of Directors members are responsible for supervision over PVML's participation in subsidiary companies, which perform functional duties as Board of Commissioners members in subsidiary companies controlled by PVML, and do not cause the concerned person to neglect the implementation of duties and authorities as Board of Directors members, and have obtained approval from the Board of Commissioners.
Board of Directors members are association managers who perform functional duties as Board of Commissioners members in subsidiary companies controlled by the association, and do not cause the concerned person to neglect the implementation of duties and authorities as Board of Directors members.
Board of Directors members are association managers who perform functional duties as Board of Commissioners members in institutions based on Financial Services Authority appointments, and do not cause the concerned person to neglect the implementation of duties and authorities as Board of Directors members.
Board of Directors members hold positions in non-profit organizations or institutions, and do not cause the concerned person to neglect the implementation of duties and authorities as Board of Directors members.
Board of Directors members do not originate from active employees or officials of the Financial Services Authority.
Board of Directors members do not originate from former employees or officials of the Financial Services Authority if the concerned person stopped working at the Financial Services Authority for less than 6 (six) months.
Conflicts of Interest or potential Conflicts of Interest from former employees or officials of the Financial Services Authority, candidate Board of Directors members, have been disclosed in the fitness and propriety assessment process.
All Board of Directors members meet requirements related to

share ownership, financial relationships, and family relationships as regulated in Financial Services Authority regulations.

The Board of Directors ensures the fulfillment of human resources and organizational structure, including having formed work units or appointed Executive Officers with adequate quantity and quality to support the implementation of duties and functions of the Board of Directors.
The Board of Directors has guidelines and working procedures for Board of Directors members as regulated in Financial Services Authority regulations.
The Board of Directors formulates and establishes remuneration policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees, considering recommendations from remuneration and nomination committees or the Board of Commissioners.
The Board of Directors does not use individual advisors and/or professional services as experts or consultants unless they meet requirements in accordance with Financial Services Authority regulations.
Each Board of Directors member has obtained fitness and propriety assessment approval.
Each manager has obtained fitness and propriety assessment approval.
The Board of Directors has competence in accordance with Financial Services Authority regulations, and has the willingness and ability to conduct continuous learning to enhance capabilities, experience, and expertise to carry out duties and responsibilities for managing PVML in accordance with regulations.

B. Governance Implementation Process (P)
26. The Board of Directors executes duties with good faith, full responsibility, prudence, independent responsibility, and does not grant general power of attorney that could result in the transfer of duties and authorities of the Board of Directors.
27. The Board of Directors implements the application of governance principles, risk management, and compliance in an integrated manner.
28. The Board of Directors complies with statutory regulations, articles of association, and other internal regulations of PVML in executing duties.
29. The Board of Directors manages PVML in accordance with its authorities and responsibilities.
30. The Board of Directors is accountable for the execution of duties to shareholders through GMS.
31. The Board of Directors ensures that PVML considers the interests of all parties, particularly the interests of Debtors, fund recipients, consumers, business partners, depositors, creditors, fund providers, venture capital investors, and/or other Stakeholders with good faith and the principle of prudence in accordance with statutory regulations, articles of association, and/or GMS decisions.
32. PVML's Board of Directors holds Board of Directors meetings regularly at least 1 (one) time in 1 (one) month.
33. The Board of Directors attends Board of Directors meetings at least 50% (fifty percent) of the total Board of Directors meetings in a 1 (one) year period.
34. The Board of Directors holds joint meetings with the Board of Commissioners at least 1 (one) time in 3 (three) months.
35. The number of Board of Directors meetings held and the attendance of each Board of Directors member are included in the Good Corporate Governance implementation report.
36. The Board of Directors follows up on findings from audits or examinations and recommendations from PVML's internal audit work units, external auditors, results of Financial Services Authority supervision, and/or results of supervision by authorities and other institutions.
37. The Board of Directors provides accurate, relevant, and timely data and information to parties entitled to receive data and information in accordance with statutory regulations, including to the Board of Commissioners and DPS.
38. The Board of Directors assists and provides facilities and/or resources for the smooth implementation of duties and authorities of PVML organs and DPS.
39. The Board of Directors prioritizes the interests of PVML and/or other stakeholders over personal interests.
40. Decision-making by the Board of Directors is taken in accordance with guidelines and working procedures.
41. Strategic policies and decisions decided through Board of Directors meetings are in accordance with mechanisms stated in PVML's articles of association and statutory regulations, and are first conducted based on deliberation to reach consensus.
42. The Board of Directors does not utilize their position at PVML where the Board of Directors serves for personal, family, and/or other parties' interests that can harm or reduce the profits of PVML where Board of Directors members serve.
43. The Board of Directors does not take and/or receive personal benefits from PVML where Board of Directors members serve, other than remuneration and facilities established based on GMS decisions.
44. The Board of Directors is able to avoid requests from shareholders related to PVML's operational activities where the concerned Board of Directors member serves, other than those established in GMS.
45. Board of Directors members cultivate continuous learning to enhance knowledge about PVML and recent developments in the financial sector and other fields supporting the implementation of duties and responsibilities, including continuous compliance competence enhancement for Directors overseeing the compliance function.
46. The Board of Directors has communicated to all employees regarding PVML's strategic policies that can affect employees' rights and obligations in achieving PVML's vision and mission using media (electronic and non-electronic) that are easily accessible by all employees.
47. The Board of Directors discloses:
a. share ownership in the respective PVML and/or in other companies located domestically and abroad; b. financial relationships of Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where Board of Directors members and Board of Commissioners members serve; and
c. family relationships of Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where Board of Directors members and Board of Commissioners members serve up to the second degree, both horizontally and vertically.
48. Board of Directors members are able to maintain financial integrity and reputation and implement their competencies in the execution of duties and responsibilities

The Board of Directors implements and evaluates the guidelines and working procedures of Board of Directors members consistently.
The Board of Directors evaluates remuneration policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees with principles of fairness and reasonableness, while considering recommendations from the remuneration and nomination committee or the Board of Commissioners.

C. Results of Governance Implementation (H)
51. The Board of Directors performs its duties well and has accounted for the implementation of its duties to shareholders through the General Meeting of Shareholders (GMS).
52. Board of Directors members holding positions in organizations or non-profit institutions report the implementation of their duties to the Board of Commissioners.
53. All employees are aware of and involved in the implementation of strategic policies to achieve the PVML's vision and mission.
54. Board of Directors decisions are binding and become the responsibility of all Board of Directors members.
55. The Board of Directors makes effective, precise, and quick decisions and can act independently, having no interests that could interfere with its ability to perform its duties independently and objectively.
56. Board of Directors meeting results are recorded in meeting minutes and documented well, distributed to all Directors, and followed up according to agreed commitments.
57. Dissenting opinions occurring in Board of Directors meeting decisions must be clearly stated in the Board of Directors meeting minutes, accompanied by the reasons for such dissenting opinions.

There is an increase in the ability, experience, and expertise of Board of Directors members in managing the PVML and an increase in knowledge across all levels or tiers of the organization, demonstrated among others by increased individual performance, increased PVML performance, resolution of problems faced by the PVML, and achievement of results according to stakeholder expectations.
The Board of Directors submits reports related to governance implementation to parties as regulated in Financial Services Authority (OJK) regulations, completely, accurately, currently, wholly, and on time.

Positive Factors
Contains a summary of positive factors from the factors of duty implementation, responsibility, and authority of the Board of Directors that have a significant impact on governance implementation. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the factors of duty implementation, responsibility, and authority of the Board of Directors that have a significant impact on governance implementation. a. Structure b. Process
c. Results

C. Implementation of Duties, Responsibilities, and Authority of the Board of Commissioners
A. Structure and Governance Infrastructure (S)

The number of Board of Commissioners members and Independent Commissioners complies with Financial Services Authority (OJK) regulations.
PVML appoints one of the Board of Commissioners members as the Chief Commissioner or equivalent.
PVML appoints other Board of Commissioners members as Deputy Chief Commissioner or equivalent.
The nationality of the Board of Commissioners complies with Financial Services Authority (OJK) regulations.
Board of Commissioners members reside in the territory as regulated by Financial Services Authority (OJK) regulations.
Board of Commissioners members with foreign nationality possess a residence permit.
Board of Commissioners members with foreign nationality possess a work permit from the competent authority.
Board of Commissioners members do not hold concurrent positions in the same company, company, and/or other institutions as regulated by Financial Services Authority (OJK) regulations.
Non-independent Board of Commissioners members performing functional duties from PVML shareholders that are legal entities become members of the board of commissioners in subsidiary companies within their business group, without causing the relevant person to neglect the implementation of duties and authority as a Board of Commissioners member.
Board of Commissioners members who are officials of an association performing functional duties become members of the board of commissioners in subsidiary companies controlled by the association, without causing the relevant person to neglect the implementation of duties and authority as a Board of Directors member.
Board of Commissioners members who are officials of an association performing functional duties become members of the board of commissioners in institutions based on Financial Services Authority (OJK) appointment, without causing the relevant person to neglect the implementation of duties and authority as a Board of Commissioners member.
Board of Commissioners members hold positions in organizations or non-profit institutions without causing the relevant person to neglect the implementation of duties and authority as a Board of Commissioners member.
Board of Commissioners members do not come from active employees or officials of the Financial Services Authority (OJK).
Board of Commissioners members do not come from former employees or officials of the Financial Services Authority (OJK) if the relevant person ceased working from the Financial Services Authority (OJK) for less than 6 (six) months.
Conflicts of Interest or potential Conflicts of Interest from former employees or officials of the Financial Services Authority (OJK) who are candidates for Board of Commissioners members have been disclosed in the competency and propriety assessment process.
All Board of Commissioners members meet requirements related to share ownership, financial relationships, and family relationships as regulated in Financial Services Authority (OJK) regulations.
PVML has at least 1 (one) Independent Commissioner.
No Independent Commissioner has any affiliation relationship with shareholders, Board of Directors members, other Board of Commissioners members, and/or DPS in the same PVML that could influence their ability to act independently.
No Independent Commissioner has ever been a Board of Directors member, Board of Commissioners member, DPS, and/or Executive Officer in the same PVML or another company having an affiliation relationship with the PVML within the last 6 (six) months that could influence their ability to act independently.
The Board of Commissioners has guidelines and working procedures that are binding for each Board of Commissioners member as regulated in Financial Services Authority (OJK) regulations.
Board of Commissioners members meet requirements of not having been a Board of Directors member and/or Executive Officer in the same PVML within the last 6 (six) months.
Each Board of Commissioners member has passed the competency and propriety assessment.
The Board of Commissioners has competence as regulated in Financial Services Authority (OJK) regulations, and has the willingness and ability to conduct continuous learning to increase ability, experience, and expertise to implement the competence possessed in the implementation of PVML supervision duties and responsibilities.
The Board of Commissioners forms other committees to support the implementation of the Board of Commissioners' duties.

B. Process of Governance Implementation (P)
25. The Board of Commissioners performs supervision and advisory duties to the Board of Directors.
26. The Board of Commissioners performs duties, authority, and responsibilities for the benefit of the PVML in good faith and with the principle of prudence, and does not grant general power of attorney that results in the transfer of duties and authority of the Board of Commissioners in accordance with legislation, the Articles of Association, and/or GMS decisions.
27. The Board of Commissioners supervises the policy of management and the course of management generally conducted by the Board of Directors for the benefit of the PVML and in accordance with the purpose and objectives of the PVML.
28. The Board of Commissioners directs, monitors, and evaluates the implementation of governance, risk management, compliance, and internal audit.
29. Independent Commissioners perform supervision functions to voice the interests of Debtors, fund recipients, consumers, business partners, depositors, creditors, fund providers, venture capital investors, and/or other Stakeholders.
30. The Board of Commissioners is not involved in operational decision-making activities of the PVML, except in the case of providing funds to related parties as regulated in regulations regarding the maximum limit of PVML credit provision and other matters established in legislation regulations to perform supervision functions.
31. For PVMLs having more than 1 (one) Board of Commissioners member, the Board of Commissioners holds Board of Commissioners meetings at least 1 (one) time in every 3 (three) months.
32. The Board of Commissioners attends Board of Directors meetings at least 75% (seventy-five percent) of the number of Board of Commissioners meetings in a 1 (one) year period.
33. The number of Board of Commissioners meetings held and the attendance of each Board of Commissioners member are included in the Good Governance Implementation Report.
34. The Board of Commissioners holds joint meetings with the Board of Directors at least 1 (one) time in every 3 (three) months.
35. The Board of Commissioners gives approval when DPS requires assistance from committee members whose organizational structure is below the Board of Commissioners.
36. The Board of Commissioners ensures that the Board of Directors has followed up on audit findings or examinations and recommendations from the PVML internal audit unit, external auditors, Financial Services Authority (OJK) supervision results, and/or supervision results from other authorities and institutions, among others by requesting the Board of Directors to submit documents of follow-up results of findings.
37. The Board of Commissioners requests the Board of Directors to provide explanations regarding problems, performance, and operational policies of the PVML.
38. The Board of Commissioners implements and evaluates the guidelines and working procedures of Board of Commissioners members consistently.
39. The Board of Commissioners has provided sufficient time to perform duties and responsibilities optimally according to guidelines and working procedures.
40. Board of Commissioners decisions are taken in accordance with guidelines and working procedures.
41. Strategic policies and decisions decided in Board of Commissioners meetings with the Board of Directors consider Board of Commissioners supervision and are first conducted through deliberation to reach consensus.
42. The Board of Commissioners complies with legislation, the Articles of Association, and other internal regulations of the PVML in performing its duties.
43. The Board of Commissioners does not utilize its position at the PVML where the Board of Commissioners serves for personal, family, and/or other parties' interests that could harm or reduce the profits of the PVML where the Board of Commissioners members serve.
44. The Board of Commissioners does not take and/or receive personal benefits from the PVML where the Board of Commissioners serves, other than remuneration and facilities established based on GMS decisions.
45. The Board of Commissioners supervises the Board of Directors' duties and ensures the Board of Directors follows up on the results of the Board of Commissioners' supervision.
46. The Board of Commissioners submits to the GMS, which may be preceded by proposals from the remuneration and nomination committee regarding remuneration and nomination policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees.
47. The Board of Commissioners ensures the implementation of duties and conducts evaluations on the implementation of duties of committees formed by the Board of Commissioners.
48. The Board of Commissioners periodically evaluates remuneration and nomination policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees.
49. The Board of Commissioners cultivates continuous learning to increase knowledge about the PVML and recent developments related to supervision fields and other fields supporting the implementation of duties and responsibilities.

The Board of Commissioners discloses:
a. share ownership in the relevant PVML and/or in other companies located domestically and abroad; and b. financial relationships of Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where Board of Directors and Board of Commissioners members serve; and
c. family relationships of Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where Board of Directors and Board of Commissioners members serve, up to the second degree both horizontally and vertically.
Board of Commissioners members are able to maintain financial integrity and reputation and implement the competence they possess in the implementation of duties and responsibilities.
The Board of Commissioners implements and evaluates the guidelines and working procedures of Board of Commissioners members consistently.

C. Results of Governance Implementation (H)
53. The Board of Commissioners performs duties well and has accounted for the implementation of duties to shareholders through the GMS.
54. Board of Commissioners meeting results are recorded in meeting minutes and documented well, distributed to all Board of Commissioners members, and followed up according to agreed commitments.
55. Dissenting opinions occurring in Board of Commissioners meeting decisions must be clearly stated in the Board of Commissioners meeting minutes, accompanied by the reasons for such dissenting opinions.
56. There is an increase in the ability, experience, and expertise of Board of Commissioners members in performing duties and responsibilities for PVML supervision, demonstrated among others by increased individual performance, increased PVML performance, resolution of problems faced by the PVML, and achievement of results according to stakeholder expectations.
57. The Board of Commissioners submits reports related to the Board of Commissioners' functions to the Financial Services Authority (OJK) as regulated in Financial Services Authority (OJK) regulations, completely, accurately, currently, wholly, and on time.

Positive Factors
Contains a summary of positive factors from the factors of duty implementation, responsibility, and authority of the Board of Commissioners that have a significant impact on governance implementation. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the factors of duty implementation, responsibility, and authority of the Board of Commissioners that have a significant impact on governance implementation. a. Structure b. Process
c. Results

D. Implementation of Duties, Responsibilities, and Authority of the DPS A. Structure and Governance Infrastructure (S)

The number of DPS complies with Financial Services Authority (OJK) regulations.
DPS members reside in the territory as regulated by Financial Services Authority (OJK) regulations.
DPS members do not hold concurrent positions in the same company, financial service institution, company, and/or other institutions as regulated by Financial Services Authority (OJK) regulations.
DPS members perform functional duties from PVML shareholders that are legal entities to become members of the board of commissioners and/or Sharia Supervisory Board in subsidiary companies within their business group, without causing the relevant person to neglect the implementation of duties and authority as DPS.
DPS members hold positions in organizations or non-profit institutions without causing the relevant person to neglect the implementation of duties and authority as DPS.
DPS members do not come from active employees or officials of the Financial Services Authority (OJK).
DPS members do not come from former employees or officials of the Financial Services Authority (OJK) if the relevant person ceased working from the Financial Services Authority (OJK) for less than 6 (six) months.
Conflicts of Interest or potential Conflicts of Interest from former employees or officials of the Financial Services Authority (OJK) who are candidates for DPS have been disclosed in the competency and propriety assessment process.
DPS members meet requirements related to share ownership, financial relationships, and family relationships as regulated in Financial Services Authority (OJK) regulations.
Each DPS member has passed the competency and propriety assessment.
DPS members are appointed in the GMS.
DPS members have competence as regulated in Financial Services Authority (OJK) regulations, and have the willingness and ability to conduct continuous learning to increase ability, experience, and expertise to implement the competence possessed in the implementation of PVML supervision duties and responsibilities.

B. Process of Governance Implementation (P)
13. DPS members perform duties, authority, and responsibilities in good faith and with the principle of prudence.
14. DPS members direct, monitor, and evaluate the effectiveness of Good Governance implementation, risk management, compliance, and internal audit.
15. DPS members supervise and provide advice and suggestions to the Board of Directors regarding business activities based on Sharia Principles.
16. DPS members supervise and provide advice and suggestions to the Board of Directors regarding business contracts based on Sharia Principles marketed by the PVML and UUS.
17. DPS members supervise and provide advice and suggestions to the Board of Directors regarding business marketing practices based on Sharia Principles conducted by the PVML and UUS.
18. DPS members obtain information from the Board of Directors regarding the PVML accurately, relevantly, and on time.
19. The number of DPS meetings with the Board of Directors, Executive Officers, and/or UUS leaders held and the number of meeting participants' attendance are included in the Good Governance Implementation Report.
20. DPS members hold joint meetings with the Board of Directors, Executive Officers, and/or UUS leaders at least 1 (one) time in every 2 (two) months.
21. DPS members ensure that the Board of Directors has followed up on audit findings or examinations and recommendations from the PVML internal audit unit, external auditors, Financial Services Authority (OJK) supervision results, and/or supervision results from other authorities and institutions, related to Sharia Principles implementation, among others by requesting the Board of Directors to submit documents of follow-up results of findings.
22. DPS decisions are made effectively, precisely, and quickly, and can act independently, having no interests that could interfere with their ability to perform duties independently and objectively.
23. Strategic policies and decisions decided in DPS meetings with the Board of Directors, Executive Officers, and/or UUS leaders consider DPS supervision and are first conducted through deliberation to reach consensus.
24. DPS members comply with legislation, the Articles of Association, and other internal regulations of the PVML in performing their duties.
25. DPS members do not utilize their position at the PVML and UUS where DPS serves for personal, family, and/or other parties' interests that could harm or reduce the profits of the PVML and UUS where DPS members serve.
26. DPS members do not take and/or receive personal benefits from the PVML and UUS where DPS serves, other than remuneration and other facilities established based on GMS decisions.
27. DPS members evaluate policies or actions of Board of Directors members related to the implementation of duties based on Sharia Principles and ensure the Board of Directors follows up on the results of the DPS evaluation.
28. DPS members request the Board of Directors to provide explanations regarding problems, performance, and operational policies of the PVML that do not comply with Sharia Principles.
29. DPS duty implementation is assisted by committee members and/or employees whose organizational structure is below the Board of Commissioners and/or Board of Directors.
30. The Board of Commissioners gives approval when DPS requires assistance from committee members whose organizational structure is below the Board of Commissioners.
31. DPS members cultivate continuous learning to increase knowledge about the PVML and recent developments related to supervision fields and other fields supporting the implementation of duties and responsibilities.
32. DPS members are able to maintain financial integrity and reputation and implement the competence they possess in the implementation of duties and responsibilities.

C. Results of Governance Implementation (H)
33. DPS members perform duties well and have accounted for the implementation of duties to shareholders through the GMS.
34. DPS meeting results with the Board of Directors, Executive Officers, and/or UUS leaders are recorded in meeting minutes and documented well, distributed to all meeting participants, and followed up according to agreed commitments.
35. Dissenting opinions occurring in DPS meeting decisions with the Board of Directors, Executive Officers, and/or UUS leaders must be clearly stated in the meeting minutes, accompanied by the reasons for such dissenting opinions.
36. There is an increase in the ability, experience, and expertise of DPS members in performing duties and responsibilities for PVML supervision, demonstrated among others by increased individual performance, increased PVML performance, resolution of problems faced by the PVML, and achievement of results according to stakeholder expectations.
37. DPS members submit reports related to the Board of Directors' rejection of DPS evaluations of Board of Directors members' policies or actions that do not comply with Sharia Principles to the Financial Services Authority (OJK) as regulated in Financial Services Authority (OJK) regulations, completely, accurately, currently, wholly, and on time.

Positive Factors
Contains a summary of positive factors from the factors of duty implementation, responsibility, and authority of the DPS that have a significant impact on governance implementation. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the factors of duty implementation, responsibility, and authority of the DPS that have a significant impact on governance implementation. a. Structure b. Process
c. Results

E. Completeness and Implementation of Committee Duties A. Structure and Governance Infrastructure (S)

PVMLs having total assets exceeding Rp250,000,000,000.00 (two hundred fifty billion rupiah) form:
a. audit committee; b. risk monitoring committee; and
c. remuneration and nomination committee,
to assist in the implementation of duties and responsibilities of the Board of Commissioners.
The Board of Commissioners forms other committees to support the implementation of the Board of Commissioners' duties.
PVMLs have guidelines and working procedures for each committee formed by the Board of Commissioners as regulated in Financial Services Authority (OJK) regulations.
The Board of Directors conducts the appointment and dismissal of committee members formed by the Board of Commissioners based on Board of Commissioners meeting decisions.
Committees formed by the Board of Commissioners have members as regulated in Financial Services Authority (OJK) regulations.
The committee chair is one of the Independent Commissioners.
Committee members do not come from Board of Directors members.
Independent parties who are committee members have competence to support the implementation of committee functions and responsibilities as regulated in Financial Services Authority (OJK) regulations, and have the willingness and ability to conduct continuous learning to increase ability, experience, and expertise to implement the competence possessed in the implementation of committee member duties and responsibilities.

B. Implementation Process (P)
9. The audit committee has performed its functions well in assessing the adequacy of internal controls, including the adequacy of the financial reporting process, by monitoring and evaluating the planning and implementation of audits and monitoring the follow-up on audit results.
10. The audit committee provides recommendations to the Board of Commissioners.
11. The audit committee plays a role and performs its duties and responsibilities in accordance with the Financial Services Authority Regulations regarding the use of public accountants and public accounting firms in financial service activities.
12. The risk monitoring committee has performed its functions well, including by evaluating the alignment between risk management policies and the implementation of PVML policies, and monitoring and evaluating the implementation of the risk management committee and risk management unit tasks.
13. The remuneration and nomination committee has performed its functions well, including by evaluating and recommending remuneration policies and preparing and providing recommendations regarding nomination policies.
14. The number of committee meetings held and the attendance of each committee member are included in the Good Corporate Governance Implementation Report.
15. Committee meetings are held in accordance with the established guidelines and rules of procedure.
16. Committees assist in the implementation of DPS tasks.
17. Committee members cultivate continuous learning to enhance knowledge about PVML and recent developments that support the implementation of their duties and responsibilities.
18. Committees are able to maintain financial integrity and reputation and implement their competencies in the execution of duties and responsibilities.
19. Each committee consistently evaluates its guidelines and rules of procedure.

C. Implementation Results (H)
20. Committees perform their duties well and have accounted for the implementation of their duties to the Board of Commissioners.
21. Committee meeting results are recorded in meeting minutes and documented well, distributed to all committee members, and followed up in accordance with agreed commitments.
22. Dissenting opinions occurring in committee meeting decisions must be clearly stated in the meeting minutes, accompanied by the reasons for such dissenting opinions.
23. There is an increase in the ability, experience, and expertise of committee members in the implementation of PVML oversight duties and responsibilities, demonstrated by, among others, improved individual performance, improved PVML performance, resolution of PVML problems, and achievement of results in accordance with stakeholder expectations.
24. Committees report the realization of committee work programs.

Positive Factors
Contains a summary of positive factors from the completeness and implementation of committee duties that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the completeness and implementation of committee duties that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

F. Risk Management Implementation
A. Structure and Governance Infrastructure (S)

PVML has committees, units, and/or risk management functions based on total assets, including anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs, in accordance with Financial Services Authority regulations.
PVML has and establishes risk management policies, risk management procedures, and risk limit determinations.
PVML has and establishes written policies and procedures regarding the management of risks inherent in new products and activities in accordance with applicable regulations.
B. Implementation Process (P)
Risk management is carried out effectively in accordance with objectives, business policies, size, and business complexity as well as PVML's capabilities in accordance with policies and procedures based on Financial Services Authority regulations, including the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs.
PVML implements integrated governance, risk management, and compliance supported by necessary policies or procedures.
PVML implements risk management over all risks required in accordance with Financial Services Authority regulations.
PVML has adequate information systems, namely management information systems capable of providing complete, accurate, current, and whole data and information.
PVML pays attention to the adequacy of policies in risk management.
PVML pays attention to procedures in risk management.
PVML pays attention to the determination of risk limits in risk management.
PVML pays attention to the adequacy of the identification process in risk management.
PVML pays attention to measurement in risk management.
PVML pays attention to risk control.
PVML pays attention to risk monitoring.
Comprehensive internal control systems are implemented optimally.
Comprehensive internal control systems pay attention to reporting mechanisms in the event of deviations.
The Board of Directors has developed a risk management culture at all levels of the organization and improved human resource competencies, including through training and/or socialization regarding risk management.
C. Implementation Results (H)
PVML prepares risk profile reports and other risk profiles (if any) reported to the Financial Services Authority in accordance with Financial Services Authority regulations, and is able to maintain and improve risk profiles to support better risk management implementation.
The risk management information system presents reports or information regarding risk exposures, including quantitative and qualitative exposures, both composite and detailed by risk type and functional activity type.
The risk management information system presents reports or information regarding compliance with risk management policies and procedures and risk limit determinations.
The risk management information system presents reports or information regarding the realization of risk management implementation compared to established targets.

Positive Factors
Contains a summary of positive factors from the implementation of risk management that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the implementation of risk management that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

G. Anti-Fraud Strategy Implementation
A. Structure and Governance Infrastructure (S)

PVML has and establishes anti-fraud strategy policies in accordance with Financial Services Authority regulations.
B. Implementation Process (P)
PVML prepares and implements anti-fraud strategies effectively in conducting business activities in accordance with Financial Services Authority regulations.
The Board of Directors ensures implementation and conducts periodic evaluations of anti-fraud strategy policies.
The Board of Commissioners ensures implementation and conducts periodic evaluations of anti-fraud strategy policies.
Resolution of internal deviations involves legal processes.
There are no deviations committed by members of the Board of Directors, Board of Commissioners, DPS, permanent employees, and non-permanent employees.
PVML provides mediation for the resolution of internal deviations.
C. Implementation Results (H)
PVML prepares and submits regular reports on the implementation of anti-fraud strategies and reports on fraud incidents with significant impact.

Positive Factors
Contains a summary of positive factors from the implementation of anti-fraud strategies that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the implementation of anti-fraud strategies that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

H. Compliance Function Implementation
A. Structure and Governance Infrastructure (S)

PVML has a member of the Board of Directors who oversees the compliance function.
The member of the Board of Directors overseeing the compliance function is not concurrently held by a member of the Board of Directors overseeing the financing function, marketing function, and finance and accounting function.
PVML has a compliance unit or function responsible for the implementation of compliance based on total assets in accordance with Financial Services Authority regulations.
The compliance unit and risk management unit are merged into 1 (one) unit handling compliance and risk management.
The compliance unit or function responsible for the implementation of compliance has prepared and/or established work guidelines, systems, and compliance procedures.
PVML has provided human resources with adequate quantity and quality in the compliance unit or function responsible for the implementation of compliance to complete tasks effectively.
B. Implementation Process (P)
The member of the Board of Directors overseeing the compliance function formulates strategies to encourage the creation of a PVML compliance culture, including through the preparation of compliance policies oriented towards PVML's vision, mission, and values, as well as socialization and training on current regulations.
The member of the Board of Directors overseeing the compliance function formulates strategies to encourage the creation of a compliance culture.
The member of the Board of Directors overseeing the compliance function ensures that PVML's business activities have met all regulations in the field of PVML and other applicable regulations.
The member of the Board of Directors overseeing the compliance function is able to ensure PVML's compliance with commitments made by PVML to the Financial Services Authority and/or other competent supervisory authorities.
The member of the Board of Directors overseeing the compliance function performs other tasks related to the implementation of the compliance function.
The unit or function responsible for the implementation of compliance assists the Board of Directors in ensuring compliance with regulations in the field of PVML and other applicable regulations.
The compliance unit or function responsible for the implementation of compliance performs duties and responsibilities in accordance with work guidelines, systems, and compliance procedures.
The unit or function responsible for the implementation of compliance is responsible to the member of the Board of Directors overseeing the compliance function.
For PVML conducting business activities based on Sharia Principles, the member of the Board of Directors overseeing the compliance function, the compliance unit or function responsible for the implementation of compliance, coordinates with the DPS regarding the implementation of the compliance function for Sharia Principles.
C. Implementation Results (H)
PVML has succeeded in reducing the level of violations of regulations.
The member of the Board of Directors overseeing the compliance function submits reports regarding the implementation of the compliance function to the Financial Services Authority as regulated in Financial Services Authority regulations, completely, accurately, currently, wholly, and on time.

Positive Factors
Contains a summary of positive factors from the implementation of the compliance function that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the implementation of the compliance function that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

I. Internal and External Audit Function Implementation

Internal Audit Function Implementation
A. Structure and Governance Infrastructure (S)
PVML has an internal audit unit or internal audit function based on total assets in accordance with Financial Services Authority regulations.
The internal audit unit or internal audit function has established and issued guidelines and rules of procedure in accordance with Financial Services Authority regulations and has been approved by the President Director and the Board of Commissioners.
The internal audit unit or internal audit function is directly responsible to the President Director.
PVML has provided human resources with adequate quantity and quality in the internal audit unit or internal audit function to complete tasks effectively.
B. Implementation Process (P)
PVML implements the internal audit function in accordance with the internal audit guidelines prepared by PVML and Financial Services Authority regulations on all aspects and elements of activities that are directly estimated to affect the interests of PVML and the public.
PVML assigns external parties to conduct a review containing opinions on the results of the internal audit unit's work and its compliance with the standards for implementing the internal audit function.
The implementation of the internal audit function (audit activities) is carried out independently and adequately, covering audit preparation, audit program preparation, audit implementation, audit result reporting, and follow-up on audit results.
PVML carries out periodic and continuous improvement of human resource skills related to the implementation of the internal audit function.
The internal audit unit prepares and realizes the annual audit program plan.
The internal audit unit assists the President Director and the Board of Commissioners in conducting PVML operational oversight, especially in monitoring audit results.
The internal audit unit conducts analysis and assessment in the fields of finance, accounting, operations, and other activities.
The internal audit unit provides improvement suggestions and objective information about audited activities at all levels of management.
C. Implementation Results (H)
PVML presents the annual audit program plan and realization as requested by the Financial Services Authority.
PVML submits reports regarding the implementation of the internal audit function to the Financial Services Authority as regulated in Financial Services Authority regulations, completely, accurately, currently, wholly, and on time.
External Audit Implementation
A. Structure and Governance Infrastructure (S)
The assignment of audits to public accountants and public accounting firms (KAP) has met aspects of legal work agreement aspects, audit scope, public accountant professional standards, audit completion time targets, communication between the Financial Services Authority and KAP, and considers the adequate competence of the KAP (including public accountants).
The appointed public accountants and KAP have competencies in accordance with the complexity of PVML's business.
B. Implementation Process (P)
In the implementation of PVML financial statement audits, PVML appoints public accountants and KAP registered with the Financial Services Authority and obtains approval from the General Meeting of Shareholders based on the proposal of the Board of Commissioners and considers the audit committee's recommendation (for PVML that has an audit committee).
PVML provides all accounting records and data required for external audits.
PVML has reported the results of the public accountant or KAP audit and the management letter to the Financial Services Authority on time.
External auditors are independent.
C. Implementation Results (H)
Audit results and management letters have described PVML's problems and presented transparent and high-quality financial information.
The scope of audit results is at least in accordance with the audit scope in accordance with Financial Services Authority regulations.

Positive Factors
Contains a summary of positive factors from the implementation of the internal audit function and the implementation of the external audit function that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the implementation of the internal audit function and the implementation of the external audit function that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

J. Conflict of Interest Handling
A. Structure and Governance Infrastructure (S)

PVML has a conflict of interest policy aimed at identifying, reducing, and managing potential conflicts of interest that may arise in PVML due to the implementation of PVML's business activities, which are embodied in regulations.
B. Implementation Process (P)
Members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and PVML employees avoid all forms of conflict of interest in the implementation of PVML management and oversight duties.
Members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and PVML employees do not take actions that have the potential to harm PVML or reduce PVML's profits.
C. Implementation Results (H)
Members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and PVML employees disclose conflicts of interest in every decision that meets the conditions of a conflict of interest to the Financial Services Authority.
PVML discloses to the Financial Services Authority regarding PVML transactions that have potential Conflicts of Interest with other PVMLs.

Positive Factors
Contains a summary of positive factors from the handling of Conflicts of Interest that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the handling of Conflicts of Interest that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

K. Remuneration Policy Implementation
A. Structure and Governance Infrastructure (S)

PVML establishes in its articles of association regarding policies and procedures for the determination of remuneration and nominations for members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees in accordance with applicable regulations.
PVML prepares and establishes remuneration policies for members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees.
For PVMLs that have a remuneration and nomination committee, the preparation of remuneration policies considers the recommendations of the remuneration and nomination committee.
B. Implementation Process (P)
PVML implements governance in the provision of remuneration for members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees.
The provision of remuneration considers financial performance and the fulfillment of PVML's obligations as regulated in applicable regulations.
The provision of remuneration considers individual work performance.
The provision of remuneration considers fairness with PVML and/or equivalent job levels (peer group).
The provision of remuneration considers considerations of PVML's long-term goals and strategies.
PVML submits the ratio of highest to lowest salaries to the Financial Services Authority.
C. Implementation Results (H)
In implementing remuneration policies, PVML has implemented good governance.

Positive Factors
Contains a summary of positive factors from the implementation of remuneration policies that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the implementation of remuneration policies that have a significant impact on the implementation of corporate governance. a. Structure b. Process
c. Results

L. Information Disclosure
A. Structure and Governance Infrastructure (S)

PVML has procedures and guidelines regarding information disclosure and other important matters.
PVML has a reliable and adequate management information system in order to implement information disclosure for all stakeholders.
PVML has procedures for the use of PVML consumer data in the context of information transparency.
B. Implementation Process (P)
PVML discloses information disclosure and other important matters.
PVML implements information transparency regarding the use of consumer data in accordance with Financial Services Authority regulations regarding consumer and public protection in the financial services sector.
PVML optimizes reliable and adequate management information systems to improve the quality of decision-making processes by the Board of Directors and all levels of the organization.
PVML optimizes reliable and adequate management information systems to improve the quality of oversight processes by the Board of Commissioners.
PVML optimizes reliable and adequate management information systems for the purposes of oversight by the Financial Services Authority and other stakeholders.
For PVMLs that form a remuneration and nomination committee, recommendations from the remuneration and nomination committee are considered in every proposal for the appointment and/or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS to the General Meeting of Shareholders.
For PVMLs that do not form a remuneration and nomination committee, proposals for the appointment and/or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS consider recommendations from members of the Board of Commissioners.
The appointment and/or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS prioritize professional composition, independence, competency suitability, and consider diversity, which are needed appropriately in the implementation of the duties and responsibilities of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS prioritizes the primary interests of PVML.
The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS is because the members are assessed as unable to perform their duties and responsibilities in the management and implementation of healthy PVML strategies.
The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS is not based on subjective assessments from shareholders, but is based on objective assessments regarding PVML management.
For PVMLs that form a remuneration and nomination committee, the dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS that

conducted before the term of office of the Board of Directors, Board of Commissioners, and/or Supervisory Board (DPS) ends has gone through the applicable planning and mechanism, which at least considers the assessment from the Remuneration and Nomination Committee and has been scheduled in the General Meeting of Shareholders (GMS).

For PVMLs that do not form a Remuneration and Nomination Committee, the dismissal or replacement of members of the Board of Directors, Board of Commissioners, and/or DPS conducted before the term of office of the Board of Directors, Board of Commissioners, and/or DPS ends has gone through the applicable planning and mechanism, which at least considers the assessment from the members of the Board of Commissioners and has been scheduled in the GMS.
Dismissal or replacement of members of the Board of Directors, Board of Commissioners, and/or DPS conducted before the term of office of the Board of Directors, Board of Commissioners, and/or DPS ends is due to information that the members of the Board of Directors, Board of Commissioners, and/or DPS are included in the parties prohibited as principal parties established by the competent authority.
PVML appoints a replacement for members of the Board of Directors, Board of Commissioners, and/or DPS in the event of dismissal of members of the Board of Directors, Board of Commissioners, and/or DPS that results in the number of members of the Board of Directors, Board of Commissioners, and/or DPS becoming less than the minimum number of members of the Board of Directors, Board of Commissioners, and/or DPS.
PVML appoints a replacement for members of the Board of Directors, Board of Commissioners, and/or DPS in the event that members of the Board of Directors, Board of Commissioners, and/or DPS are permanently unable to perform duties, resulting in the number of members of the Board of Directors, Board of Commissioners, and/or DPS becoming less than the minimum number of members of the Board of Directors, Board of Commissioners, and/or DPS.
PVML appoints a replacement for members of the Board of Directors, Board of Commissioners, and/or DPS in the event that members of the Board of Directors, Board of Commissioners, and/or DPS resign, resulting in the number of members of the Board of Directors, Board of Commissioners, and/or DPS becoming less than the minimum number of members of the Board of Directors, Board of Commissioners, and/or DPS.
There is no intervention from the PVML owner.
There is no internal dispute within the PVML.
PVML does not have legal issues that are civil cases.
PVML does not have legal issues that are criminal cases.
PVML implements transparency of financial and non-financial conditions to stakeholders.

C. Results of Governance Implementation (H)

PVML reports share ownership by members of the Board of Directors and Board of Commissioners reaching 5% (five percent) or more in the PVML where the members of the Board of Directors and Board of Commissioners serve and/or in other companies located domestically and abroad.
PVML reports the financial relationships of members of the Board of Directors and Board of Commissioners with other members of the Board of Directors, other members of the Board of Commissioners, DPS, PVML shareholders, and/or employees of the PVML where the members of the Board of Directors and Board of Commissioners serve.
PVML reports the family relationships of members of the Board of Directors and Board of Commissioners with other members of the Board of Directors, other members of the Board of Commissioners, DPS, PVML shareholders, and/or employees of the PVML where the members of the Board of Directors and Board of Commissioners serve up to the second degree, both horizontally and vertically.
PVML reports remuneration and other facilities received by members of the Board of Directors and Board of Commissioners.
Members of the Board of Directors, Board of Commissioners, and/or DPS, including Independent Commissioners who resign from their positions before the term of office ends, submit written notification to PVML.
External auditors who resign submit written notification to PVML.
PVML discloses to the Financial Services Authority (OJK) regarding the resignation of members of the Board of Directors, Board of Commissioners, and/or DPS, including Independent Commissioners.
PVML discloses to the Financial Services Authority (OJK) regarding the dismissal of members of the Board of Directors, Board of Commissioners, and/or DPS, including Independent Commissioners, including those permanently unable to perform duties due to death, mental disability, or other conditions that do not allow the relevant person to perform their duties well.
PVML discloses to the Financial Services Authority (OJK) regarding the resignation of external auditors.
PVML discloses to the Financial Services Authority (OJK) regarding the dismissal of external auditors.
PVML implements orders from the Financial Services Authority (OJK) to conduct evaluations and corrective actions regarding decisions to dismiss, replace, and/or resign members of the Board of Directors, Board of Commissioners, and/or DPS conducted before the term of office of the Board of Directors, Board of Commissioners, and/or DPS ends.
PVML conducts the appointment of replacements for members of the Board of Directors, Board of Commissioners, and/or DPS no later than 6 (six) months from the date of dismissal of members of the Board of Directors, Board of Commissioners, and/or DPS.
PVML conducts the appointment of replacements for members of the Board of Directors, Board of Commissioners, and/or DPS no later than 6 (six) months from the date members of the Board of Directors, Board of Commissioners, and/or DPS become permanently unable to perform duties.
PVML conducts the appointment of replacements for members of the Board of Directors, Board of Commissioners, and/or DPS no later than 6 (six) months from the date members of the Board of Directors, Board of Commissioners, and/or DPS resign.
The Board of Commissioners reports to the Financial Services Authority (OJK) no later than 10 (ten) working days from the discovery of violations of financial and PVML-related legislation.
The Board of Commissioners reports to the Financial Services Authority (OJK) no later than 10 (ten) working days from the discovery of conditions or estimated conditions that can endanger the continuity of the PVML business.
PVML discloses to the Financial Services Authority (OJK) regarding material transactions with other parties.
PVML discloses to the Financial Services Authority (OJK) regarding legal issues that are civil cases.
PVML discloses to the Financial Services Authority (OJK) regarding legal issues that are criminal cases.
PVML provides data and information to the Financial Services Authority (OJK) completely and on time.

Positive Factors
Contains a summary of positive factors from the information openness factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the information openness factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

M. Business Ethics
A. Structure and Governance Infrastructure (S)

PVML formulates guidelines on ethical behavior, containing business ethics values, as a guide for PVML Organs and all PVML employees.

B. Process of Governance Implementation (P)
2. PVML does not take actions intended to exploit loopholes in regulations or business ethics that are not in accordance with the principles of healthy PVML management, which can increase risks to PVML, and/or bring unjustified profits.
3. Members of the Board of Directors, Board of Commissioners, DPS, and PVML employees do not offer or give anything, directly or indirectly, to other parties, to influence decision-making related to PVML business activities, in violation of legislation regulations.
4. Members of the Board of Directors, Board of Commissioners, DPS, and PVML employees do not receive anything for their own interests, family, and/or other parties in violation of legislation regulations, directly or indirectly, from anyone, which can influence decision-making related to PVML business activities.

C. Results of Governance Implementation (H)
5. PVML does not violate guidelines on ethical behavior, including business ethics values, in conducting business activities.

Positive Factors
Contains a summary of positive factors from the business ethics factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the business ethics factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

N. Financing Policy
A. Structure and Governance Infrastructure (S)

PVML has written policies and procedures for financing disbursement in accordance with Financial Services Authority (OJK) regulations.
PVML has a reliable financial reporting system for supervision purposes and other stakeholders.

B. Process of Governance Implementation (P)
3. Financing disbursement policies and procedures are established by the Board of Directors.
4. Financing disbursement policies and procedures are approved by the Board of Commissioners.
5. Financing disbursement policies and procedures are socialized to management and employees in relevant work units.
6. PVML ensures that the Board of Directors and all levels or tiers of the organization make financing decisions professionally while still considering protection for consumers and other Stakeholders.
7. PVML optimizes the added value of PVML wealth while still considering protection for consumers and other Stakeholders.
8. PVML periodically evaluates and updates financing disbursement policies and procedures to be adjusted to legislation regulations.
9. The financing disbursement process by PVML to related parties and/or large financing disbursements in accordance with Financial Services Authority (OJK) regulations and considering prudent principles as well as legislation regulations.
10. PVML explains financing agreements as well as the rights and obligations of debtors in each financing transaction.
11. PVML conducts promotions regarding financing services.

C. Results of Governance Implementation (H)
12. Reports on financing disbursement by PVML to related parties and/or PVMLs that violate and/or exceed Financial Services Authority (OJK) regulations have been submitted periodically to the Financial Services Authority (OJK) correctly and on time in accordance with Financial Services Authority (OJK) regulations.
13. PVML does not violate and/or exceed Financial Services Authority (OJK) regulations in financing disbursement.
14. PVML transparently communicates the complaint procedures and dispute resolution to debtors.
15. Financing disbursement is carried out by considering prudent principles and the principles of risk management implementation.

Positive Factors
Contains a summary of positive factors from the financing policy factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the financing policy factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

O. Implementation of Sustainable Finance, including Implementation of Social and Environmental Responsibility A. Structure and Governance Infrastructure (S)

PVML formulates a sustainable finance action plan in accordance with Financial Services Authority (OJK) regulations as well as having been formulated by the Board of Directors and approved by the Board of Commissioners in accordance with the vision and mission of PVML.

B. Process of Governance Implementation (P)
2. PVML implements sustainable finance in business activities.
3. PVML implements the sustainable finance action plan effectively.
4. PVML communicates the sustainable finance action plan to shareholders and all organizational tiers existing in PVML.

C. Results of Governance Implementation (H)
5. PVML submits the sustainable finance action plan to the Financial Services Authority (OJK) in accordance with Financial Services Authority (OJK) regulations.
6. PVML submits sustainability reports to the Financial Services Authority (OJK) in accordance with Financial Services Authority (OJK) regulations.

Positive Factors
Contains a summary of positive factors from the sustainable finance implementation factors, including the implementation of social and environmental responsibility, that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the sustainable finance implementation factors, including the implementation of social and environmental responsibility, that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

P. Business Plan
A. Structure and Governance Infrastructure (S)

The PVML business plan has been formulated by the Board of Directors and approved by the Board of Commissioners in accordance with the vision and mission of PVML.
The PVML business plan describes long-term strategic plans and annual business plans, including capital strengthening plans, plans to handle PVML financial problems affecting the continuity of the PVML business, with coverage in accordance with Financial Services Authority (OJK) regulations.
The PVML business plan is fully supported by shareholders in order to strengthen capital and adequate infrastructure, including human resources, information technology, office networks, policies, and procedures.
The PVML business plan is formulated based on comprehensive studies considering business opportunities and strengths possessed by PVML and identifying weaknesses and threats (strength, weakness, opportunity, threat/SWOT Analysis);
The PVML business plan must be supported by adequate infrastructure preparation, including human resources, information technology, office networks, as well as policies and procedures.

B. Process of Governance Implementation (P)
6. The PVML business plan is formulated realistically, comprehensively, and measurably (achievable) by considering at least:
a. external and internal factors that can affect the continuity of the PVML business; b. prudent principles; and
c. risk management implementation.
7. The Board of Commissioners implements supervision over the implementation of the PVML business plan.
8. The PVML business plan describes the continuous growth of PVML.

C. Results of Governance Implementation (H)
9. The business plan, including changes to the business plan, is submitted to the Financial Services Authority (OJK) in accordance with Financial Services Authority (OJK) regulations.
10. Financial and non-financial performance indicators in the business plan are achieved in accordance with established targets, including the realization of shareholder commitments.

Positive Factors
Contains a summary of positive factors from the business plan factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the business plan factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

RANKING AND FINAL CONCLUSION OF GOVERNANCE FACTORS Ranking of Good Governance Factors for PVML Individual Consolidation Final Conclusion Contains the final conclusion of the governance implementation assessment linked to the definition of composite rankings.

Positive Factors
Contains a summary of positive factors from the main factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the main factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Approved,
BOARD OF DIRECTORS

PART B
SELF-ASSESSMENT OF THE IMPLEMENTATION OF GOOD GOVERNANCE FOR MICROFINANCE INSTITUTIONS, PLEDGE COMPANIES, AND JOINT FINANCING SERVICE PROVIDERS BASED ON INFORMATION TECHNOLOGY

The PVML referred to in this self-assessment worksheet on the implementation of Good Governance is:

Microfinance Institution;
Pledge Company; and
Joint Financing Service Provider Based on Information Technology.

A. Implementation of Shareholder and GMS Duties and Authorities Indicator Description A. Structure and Governance Infrastructure (S)

Composition and requirements of shareholders in accordance with legislation regulations.
Policies and procedures for decision-making through GMS are stated in the Articles of Association and in accordance with legislation regulations.
Every party that is a PSP of PVML has obtained approval from the Financial Services Authority (OJK) through the implementation of fitness and propriety assessments.

B. Process of Governance Implementation (P)
4. Implementation of communication of the vision and mission of PVML development to the Board of Directors and/or Board of Commissioners.
5. Monitoring of PVML development through the results of Board of Commissioners supervision.
6. Shareholder support in PVML development through capital planning or other development support.
7. Shareholders ensure the implementation of healthy governance, including avoiding conflicts of interest, intervention, taking personal or group interests, and decisions on the appointment, replacement, or dismissal of members of the Board of Directors and/or Board of Commissioners.

Indicator Description
8. PSP meets Financial Services Authority (OJK) Regulations and legislation regulations in the financial services sector, and supports the implementation of healthy, competitive PVML business activities and management, as well as in accordance with prudent principles and risk management.
9. PVML shareholders participate in supporting the implementation of healthy, competitive PVML business activities in accordance with prudent principles and risk management.
10. PVML shareholders participate in maintaining the continuity of the PVML business.
11. PVML shareholders do not interfere in PVML operational activities that are the responsibility of the Board of Directors in accordance with the PVML Articles of Association and legislation regulations, except in exercising rights and duties as GMS.
12. Decision-making through GMS considers input and recommendations from the Board of Commissioners, as well as input or opinions from all shareholders.
13. Decision-making through GMS protects the interests of all parties, especially the interests of Debtors, fund recipients, consumers, business partners, depositing customers, creditors, fund providers, venture capital investors, and/or minority shareholder interests.

C. Results of Governance Implementation (H)
14. Shareholders receive fair rights and treatment, including in the implementation of corporate actions.
15. PVML performance development is in line with strategic plans, including through the realization of capital plans or other support plans.

Indicator Description
16. Shareholders do not engage in conflicts of interest, intervention, taking personal or group interests, and decisions on the appointment, replacement, or dismissal of members of the Board of Directors and/or Board of Commissioners.
17. The use of profits and dividend distribution considers profit use and dividend distribution policies that are in accordance with the Articles of Association and legislation regulations, and consider external and internal conditions.
18. The implementation of the release of PVML shares owned by members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and/or PVML employees originating from management stock ownership programs and/or employee stock ownership programs considers Good Governance at PVML and considers PVML conditions.

Total Indicator Value

Positive Factors
Contains a summary of positive factors from the shareholder and GMS duties and authorities implementation factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the shareholder and GMS duties and authorities implementation factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

B. Implementation of Board of Directors Duties, Responsibilities, and Authorities Indicator Description A. Structure and Governance Infrastructure (S)

Number of Board of Directors members in accordance with Financial Services Authority (OJK) regulations and one member of the Board of Directors acts as the Director overseeing the compliance function.
PVML appoints one of the Board of Directors members as the Chief Executive Officer or equivalent.
PVML appoints other Board of Directors members as Deputy Chief Executive Officer or equivalent.
The Chief Executive Officer or equivalent is not an individual shareholder in the same PVML and/or has family relationships up to the second degree, both horizontally and vertically, with individual shareholders in the same PVML.
Board of Directors citizenship in accordance with Financial Services Authority (OJK) regulations.
All Board of Directors members reside within the territory of the Republic of Indonesia.
All Board of Directors members of Pledge Companies and Microfinance Institutions reside within the scope of the operational area of the respective PVML and bordering directly with the operational area of the PVML.
Foreign citizen Board of Directors members have a residence permit.
Foreign citizen Board of Directors members have a work permit from the competent authority.
Board of Directors members do not hold concurrent positions in the same company, company, and/or other institutions in accordance with Financial Services Authority (OJK) regulations.
Board of Directors members are responsible for supervision over PVML participation in subsidiary companies, which perform functional duties as members of the Board of Commissioners in subsidiary companies controlled by PVML and do not cause the relevant person to neglect the implementation of duties and authorities as a Board of Directors member and have obtained approval from the Board of Commissioners.

Indicator Description
12. Board of Directors members are association executives who perform functional duties as members of the Board of Commissioners in subsidiary companies controlled by the association and do not cause the relevant person to neglect the implementation of duties and authorities as a Board of Directors member.
13. Board of Directors members are association executives who perform functional duties as the Board of Commissioners in institutions based on Financial Services Authority (OJK) appointment and do not cause the relevant person to neglect the implementation of duties and authorities as a Board of Directors member.
14. Board of Directors members hold positions in organizations or non-profit institutions and do not cause the relevant person to neglect the implementation of duties and authorities as a Board of Directors member.
15. Board of Directors members do not come from active employees or officials of the Financial Services Authority (OJK).
16. Board of Directors members do not come from former employees or officials of the Financial Services Authority (OJK) if the relevant person stopped working from the Financial Services Authority (OJK) for less than 6 (six) months.
17. Conflicts of Interest or potential Conflicts of Interest from former employees or officials of the Financial Services Authority (OJK) as candidate Board of Directors members have been disclosed in the fitness and propriety assessment process.

Indicator Description
18. All members of the Board of Directors meet the requirements regarding share ownership, financial relationships, and family relationships as regulated in Financial Services Authority regulations.
19. The Board of Directors ensures the fulfillment of human resources and organizational structure, including having formed a working unit or appointed Executive Officials with adequate quantity and quality to support the execution of the Board of Directors' duties and functions.
20. The Board of Directors has guidelines and rules of procedure for Board of Directors members as regulated in Financial Services Authority regulations.
21. The Board of Directors formulates and establishes remuneration policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees, taking into account recommendations from the remuneration and nomination committee or the Board of Commissioners.
22. The Board of Directors does not use individual advisors and/or professional services as experts or consultants unless they meet the requirements in accordance with Financial Services Authority regulations.
23. Each member of the Board of Directors has had their fitness and propriety assessment approved.
24. Each manager has had their fitness and propriety assessment approved.
25. The Board of Directors has competence in accordance with Financial Services Authority regulations, and has the willingness and ability to conduct continuous learning to enhance capabilities, experience, and expertise to carry out the management duties and responsibilities of PVML in accordance with regulations.

Indicator Description
B. Implementation Process of Governance (P)
26. The Board of Directors executes its duties with good faith, full responsibility, prudence, independent responsibility, and does not grant general powers that could result in the transfer of the Board of Directors' duties and authorities.
27. The Board of Directors implements the application of governance principles, risk management, and compliance in an integrated manner.
28. The Board of Directors complies with legislation, the Articles of Association, and other internal regulations of PVML in executing its duties.
29. The Board of Directors manages PVML in accordance with its authorities and responsibilities.
30. The Board of Directors is accountable for the execution of its duties to shareholders through the General Meeting of Shareholders (GMS).
31. The Board of Directors ensures that PVML considers the interests of all parties, particularly the interests of Debtors, fund recipients, consumers, business partners, depositors, creditors, fund providers, venture capital investors, and/or other Stakeholders, with good faith and the principle of prudence in accordance with legislation, the Articles of Association, and/or GMS decisions.
32. The PVML Board of Directors holds Board of Directors meetings regularly at least 1 (one) time in 1 (one) month.
33. The Board of Directors attends Board of Directors meetings at least 50% (fifty percent) of the total Board of Directors meetings in a 1 (one) year period.
34. The Board of Directors holds joint meetings with the Board of Commissioners at least 1 (one) time in 3 (three) months.
35. The number of Board of Directors meetings held and the attendance of each Board of Directors member are included in the Good Corporate Governance Implementation Report.

Indicator Description
36. The Board of Directors follows up on audit or examination findings and recommendations from PVML's internal audit working unit, external auditors, Financial Services Authority supervision results, and/or supervision results from other authorities and institutions.
37. The Board of Directors provides accurate, relevant, and timely data and information to parties entitled to receive data and information in accordance with legislation, including to the Board of Commissioners and DPS.
38. The Board of Directors assists and provides facilities and/or resources for the smooth execution of duties and authorities of PVML organs and DPS.
39. The Board of Directors prioritizes the interests of PVML and/or other stakeholders over personal interests.
40. Board of Directors decisions are taken in accordance with guidelines and rules of procedure.
41. Strategic policies and decisions decided through Board of Directors meetings follow the mechanisms contained in the PVML Articles of Association and legislation, and are first conducted through deliberation to achieve consensus.
42. The Board of Directors does not utilize its position at the PVML where the Board of Directors serves for personal, family, and/or third-party interests that can harm or reduce the profits of the PVML where the Board of Directors members serve.
43. The Board of Directors does not take and/or receive personal benefits from the PVML where Board of Directors members serve, other than remuneration and facilities established based on GMS decisions.

Indicator Description
44. The Board of Directors is able to reject shareholder requests related to the operational activities of the PVML where the respective Board of Directors member serves, other than those established in the GMS.
45. Board of Directors members cultivate continuous learning to enhance knowledge about PVML and recent developments in the financial sector and other fields supporting the execution of their duties and responsibilities, including continuous compliance competence enhancement for Directors overseeing the compliance function.
46. The Board of Directors has communicated to all employees the strategic policies of PVML that can affect employee rights and obligations in achieving the vision and mission of PVML, using media (electronic and non-electronic) easily accessible to all employees.
47. The Board of Directors discloses:
a. share ownership in the PVML concerned and/or in other companies located domestically and internationally; b. financial relationships between Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where the Board of Directors and Board of Commissioners members serve; and
c. family relationships between Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where the Board of Directors and Board of Commissioners members serve, up to the second degree both horizontally and vertically.

Indicator Description
48. Board of Directors members are able to maintain integrity and financial reputation and implement their competencies in the execution of duties and responsibilities.
49. The Board of Directors consistently implements and evaluates the guidelines and rules of procedure for Board of Directors members.
50. The Board of Directors evaluates remuneration policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees with principles of fairness and reasonableness, taking into account recommendations from the remuneration and nomination committee or the Board of Commissioners.
C. Implementation Results of Governance (H)
51. The Board of Directors executes its duties well and has accounted for the execution of its duties to shareholders through the GMS.
52. Board of Directors members holding positions in organizations or non-profit institutions report the execution of their duties to the Board of Commissioners.
53. All employees know and are involved in the implementation of strategic policies to achieve the vision and mission of PVML.
54. Board of Directors decisions are binding and become the responsibility of all Board of Directors members.
55. The Board of Directors makes effective, precise, and quick decisions and can act independently, without interests that can interfere with its ability to execute duties independently and objectively.
56. Board of Directors meeting results are recorded in meeting minutes and documented well, distributed to all Directors, and followed up in accordance with agreed commitments.
57. Dissenting opinions occurring in Board of Directors meeting decisions must be clearly stated in the Board of Directors meeting minutes accompanied by the reasons for such dissenting opinions.

Indicator Description
58. There is an increase in the capabilities, experience, and expertise of Board of Directors members in managing PVML and an increase in knowledge of all levels or tiers of the organization, demonstrated among others by increased individual performance, increased PVML performance, resolution of problems faced by PVML, and achievement of results according to stakeholder expectations.
59. The Board of Directors submits reports related to governance implementation to parties as regulated in Financial Services Authority regulations completely, accurately, currently, wholly, and on time.
Total Indicator Value
Positive Factors
Contains a summary of positive factors from the factors of duty execution, responsibility, and Board of Directors authority that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from the factors of duty execution, responsibility, and Board of Directors authority that have a significant impact on governance implementation. a. Structure b. Process
c. Results

C. Execution of Duties, Responsibilities, and Authorities of the Board of Commissioners
Indicator Description
A. Structure and Governance Infrastructure (S)

The number of Board of Commissioners members and Independent Commissioners is in accordance with Financial Services Authority regulations.
PVML appoints one of the Board of Commissioners members as the Chief Commissioner or equivalent.
PVML appoints other Board of Commissioners members as Deputy Chief Commissioner or equivalent.
The citizenship of the Board of Commissioners is in accordance with Financial Services Authority regulations.
Board of Commissioners members reside in the territory in accordance with Financial Services Authority regulations.
Foreign citizen Board of Commissioners members have a residence permit.
Foreign citizen Board of Commissioners members have a work permit from the competent authority.
Board of Commissioners members do not hold concurrent positions in the same company, company, and/or other institution in accordance with Financial Services Authority regulations.
Non-independent Board of Commissioners members execute functional duties from PVML shareholders that are legal entities to become Board of Commissioners members in subsidiary companies within their business group, without causing the individual to neglect the execution of duties and authorities as a Board of Commissioners member.
Board of Commissioners members are association officials who execute functional duties to become Board of Commissioners members in subsidiary companies controlled by the association, without causing the individual to neglect the execution of duties and authorities as a Board of Directors member.

Indicator Description
11. Board of Commissioners members are association officials who execute functional duties to become Board of Commissioners members in institutions based on Financial Services Authority appointment, without causing the individual to neglect the execution of duties and authorities as a Board of Commissioners member.
12. Board of Commissioners members hold positions in organizations or non-profit institutions without causing the individual to neglect the execution of duties and authorities as a Board of Commissioners member.
13. Board of Commissioners members do not come from active employees or officials of the Financial Services Authority.
14. Board of Commissioners members do not come from former employees or officials of the Financial Services Authority if the individual ceased working from the Financial Services Authority for less than 6 (six) months.
15. Conflicts of Interest or potential Conflicts of Interest from former employees or officials of the Financial Services Authority who are candidates for Board of Commissioners members have been disclosed in the fitness and propriety assessment process.
16. All Board of Commissioners members meet the requirements regarding share ownership, financial relationships, and family relationships as regulated in Financial Services Authority regulations.
17. PVML has at least 1 (one) Independent Commissioner.
18. Independent Commissioners do not have any affiliation relationships with shareholders, Board of Directors members, other Board of Commissioners members, and/or DPS at the same PVML that can influence their ability to act independently.
19. Independent Commissioners have not previously been Board of Directors members, Board of Commissioners members, DPS, and/or Executive Officials at the same PVML or other companies having an affiliation relationship with said PVML within the last 6 (six) months that can influence their ability to act independently.
20. The Board of Commissioners has guidelines and rules of procedure that are binding for each Board of Commissioners member as regulated in Financial Services Authority regulations.
21. Board of Commissioners members meet the requirement of never having been a Board of Directors member and/or Executive Official at the same PVML within the last 6 (six) months.
22. Each Board of Commissioners member has had their fitness and propriety assessment approved.
23. The Board of Commissioners has competence in accordance with Financial Services Authority regulations, and has the willingness and ability to conduct continuous learning to enhance capabilities, experience, and expertise to implement the competencies possessed in the execution of PVML supervision duties and responsibilities.
24. The Board of Commissioners forms other committees to support the execution of the Board of Commissioners' duties.
B. Implementation Process of Governance (P)
25. The Board of Commissioners executes supervision duties and provides advice to the Board of Directors.
26. The Board of Commissioners executes duties, authorities, and responsibilities for the benefit of PVML with good faith and the principle of prudence, and does not grant general powers that result in the transfer of the Board of Commissioners' duties and authorities in accordance with legislation, the Articles of Association, and/or GMS decisions.
27. The Board of Commissioners supervises the policy of management and the course of management generally carried out by the Board of Directors for the benefit of PVML and in accordance with the purpose and objectives of PVML.
28. The Board of Commissioners directs, monitors, and evaluates the implementation of governance, risk management, compliance, and internal audit.
29. Independent Commissioners perform supervision functions to voice the interests of Debtors, fund recipients, consumers, business partners, depositors, creditors, fund providers, venture capital investors, and/or other Stakeholders.
30. The Board of Commissioners is not involved in operational decision-making of PVML, except in the case of providing funds to related parties as regulated in regulations regarding the maximum limit of PVML credit provision and other matters established in legislation regulations to execute supervision functions.
31. For PVMLs having more than 1 (one) Board of Commissioners member, the Board of Commissioners holds Board of Commissioners meetings at least 1 (one) time in 3 (three) months.
32. The Board of Commissioners attends Board of Directors meetings at least 75% (seventy-five percent) of the total Board of Commissioners meetings in a 1 (one) year period.
33. The number of Board of Commissioners meetings held and the attendance of each Board of Commissioners member are included in the Good Corporate Governance Implementation Report.
34. The Board of Commissioners holds joint meetings with the Board of Directors at least 1 (one) time in 3 (three) months.
35. The Board of Commissioners provides approval when DPS requires assistance from committee members whose organizational structure is under the Board of Commissioners.
36. The Board of Commissioners ensures that the Board of Directors has followed up on audit or examination findings and recommendations from PVML's internal audit working unit, external auditors, Financial Services Authority supervision results, and/or supervision results from other authorities and institutions, among others by requesting the Board of Directors to submit documents on the follow-up of findings.
37. The Board of Commissioners requests the Board of Directors to provide explanations regarding problems, performance, and operational policies of PVML.
38. The Board of Commissioners consistently implements and evaluates the guidelines and rules of procedure for Board of Commissioners members.
39. The Board of Commissioners has provided sufficient time to execute duties and responsibilities optimally in accordance with guidelines and rules of procedure.
40. Board of Commissioners decisions are taken in accordance with guidelines and rules of procedure.
41. Strategic policies and decisions decided in Board of Commissioners meetings with the Board of Directors consider Board of Commissioners supervision and are first conducted through deliberation to achieve consensus.
42. The Board of Commissioners complies with legislation, the Articles of Association, and other internal regulations of PVML in executing its duties.
43. The Board of Commissioners does not utilize its position at the PVML where the Board of Commissioners serves for personal, family, and/or third-party interests that can harm or reduce the profits of the PVML where Board of Commissioners members serve.
44. The Board of Commissioners does not take and/or receive personal benefits from the PVML where the Board of Commissioners serves, other than remuneration and facilities established based on GMS decisions.
45. The Board of Commissioners supervises the duties of the Board of Directors and ensures the Board of Directors follows up on the results of the Board of Commissioners' supervision.
46. The Board of Commissioners submits to the GMS, which may be preceded by proposals from the remuneration and nomination committee, regarding remuneration and nomination policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees.
47. The Board of Commissioners ensures the execution of duties and conducts evaluations on the execution of duties of committees formed by the Board of Commissioners.
48. The Board of Commissioners periodically evaluates remuneration and nomination policies for Board of Directors members, Board of Commissioners members, DPS, and PVML employees.
49. The Board of Commissioners cultivates continuous learning to enhance knowledge about PVML and recent developments in the supervision sector and other fields supporting the execution of their duties and responsibilities.

Indicator Description
50. The Board of Commissioners discloses:
a. share ownership in the PVML concerned and/or in other companies located domestically and internationally; and b. financial relationships between Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where the Board of Directors and Board of Commissioners members serve; and
c. family relationships between Board of Directors members and Board of Commissioners members with other Board of Directors members, other Board of Commissioners members, DPS, PVML shareholders, and/or PVML employees where the Board of Directors and Board of Commissioners members serve, up to the second degree both horizontally and vertically.
51. Board of Commissioners members are able to maintain integrity and financial reputation and implement their competencies in the execution of duties and responsibilities.
52. The Board of Commissioners consistently implements and evaluates the guidelines and rules of procedure for Board of Commissioners members.
C. Implementation Results of Governance (H)
53. The Board of Commissioners executes its duties well and has accounted for the execution of its duties to shareholders through the GMS.
54. Board of Commissioners meeting results are recorded in meeting minutes and documented well, distributed to all Board of Commissioners members, and followed up in accordance with agreed commitments.
55. Dissenting opinions occurring in Board of Commissioners meeting decisions must be clearly stated in the Board of Commissioners meeting minutes accompanied by the reasons for such dissenting opinions.
56. There is an increase in the capabilities, experience, and expertise of Board of Commissioners members in executing duties and PVML supervision responsibilities, demonstrated among others by increased individual performance, increased PVML performance, resolution of problems faced by PVML, and achievement of results according to stakeholder expectations.
57. The Board of Commissioners submits reports related to the Board of Commissioners' functions to the Financial Services Authority as regulated in Financial Services Authority regulations completely, accurately, currently, wholly, and on time.
Total Indicator Value
Positive Factors
Contains a summary of positive factors from the factors of duty execution, responsibility, and Board of Commissioners authority that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from the factors of duty execution, responsibility, and Board of Commissioners authority that have a significant impact on governance implementation. a. Structure b. Process
c. Results

D. Execution of Duties, Responsibilities, and Authorities of DPS Indicator Description A. Structure and Governance Infrastructure (S)

The number of DPS is in accordance with Financial Services Authority regulations.
DPS resides in the territory in accordance with Financial Services Authority regulations.
DPS does not hold concurrent positions in the same company, financial service institution, company, and/or other institution in accordance with Financial Services Authority regulations.
DPS executes functional duties from PVML shareholders that are legal entities to become Board of Commissioners members and/or Sharia Supervisory Board members in subsidiary companies within their business group, without causing the individual to neglect the execution of duties and authorities as DPS.
DPS holds positions in organizations or non-profit institutions without causing the individual to neglect the execution of duties and authorities as DPS.
DPS does not come from active employees or officials of the Financial Services Authority.
DPS does not come from former employees or officials of the Financial Services Authority if the individual ceased working from the Financial Services Authority for less than 6 (six) months.
Conflicts of Interest or potential Conflicts of Interest from former employees or officials of the Financial Services Authority who are candidates for DPS have been disclosed in the fitness and propriety assessment process.
DPS meets the requirements regarding share ownership, financial relationships, and family relationships as regulated in Financial Services Authority regulations.
Each DPS has had their fitness and propriety assessment approved.

Indicators Description compliance.
11. DPS is appointed in the General Meeting of Shareholders (RUPS).
12. DPS possesses competence in accordance with Financial Services Authority regulations, as well as the willingness and ability to engage in continuous learning to enhance capabilities, experience, and expertise to implement their competencies in carrying out PVML supervision tasks and responsibilities.

B. Process of Governance Implementation (P)
13. DPS carries out tasks, authorities, and responsibilities with good faith and the principle of prudence.
14. DPS directs, monitors, and evaluates the effectiveness of the implementation of Good Corporate Governance, risk management, compliance, and internal audit.
15. DPS conducts supervision and provides advice and suggestions to the Board of Directors regarding business activities based on Sharia Principles.
16. DPS conducts supervision and provides advice and suggestions to the Board of Directors regarding business contracts based on Sharia Principles marketed by PVML and UUS.
17. DPS conducts supervision and provides advice and suggestions to the Board of Directors regarding business marketing practices based on Sharia Principles conducted by PVML and UUS.
18. DPS obtains information from the Board of Directors regarding PVML that is accurate, relevant, and timely.
19. The number of DPS meetings with the Board of Directors, Executive Officials, and/or UUS leadership that have been held, and the number of meeting attendees, are included in the Good Corporate Governance Implementation Report.
20. DPS holds joint meetings with the Board of Directors, Executive Officials, and/or UUS leadership at least 1 (one) time in every 2 (two) months.
21. DPS ensures that the Board of Directors has followed up on audit findings or examinations and recommendations from PVML internal audit work units, external auditors, Financial Services Authority supervision results, and/or supervision results from other authorities and institutions, related to the implementation of Sharia Principles, including by requesting the Board of Directors to submit follow-up documents on findings.
22. DPS decision-making is conducted effectively, accurately, and quickly, and can act independently, without interests that could interfere with its ability to carry out tasks independently and objectively.
23. Strategic policies and decisions decided in DPS meetings with the Board of Directors, Executive Officials, and/or UUS leadership consider DPS supervision and are first conducted through deliberation to reach consensus.
24. DPS complies with laws and regulations, the Articles of Association, and other internal regulations of PVML in carrying out its tasks.
25. DPS does not utilize its position at PVML and UUS where DPS serves for personal, family, and/or third-party interests that could harm or reduce the profits of PVML and UUS where DPS members serve.
26. DPS does not take and/or receive personal benefits from PVML and UUS where DPS serves, other than remuneration and other facilities established based on RUPS decisions.
27. DPS evaluates policies or actions of Board of Directors members related to the implementation of tasks based on Sharia Principles and ensures the Board of Directors follows up on DPS evaluation results.
28. DPS requests the Board of Directors to provide explanations regarding issues, performance, and operational policies of PVML that are not in accordance with Sharia Principles.
29. DPS task implementation is assisted by committee members and/or employees whose organizational structure is under the Board of Commissioners and/or Board of Directors.
30. The Board of Commissioners provides approval when DPS requires assistance from committee members whose organizational structure is under the Board of Commissioners.
31. DPS cultivates continuous learning to enhance knowledge about PVML and recent developments in supervision and other fields supporting task and responsibility implementation.
32. DPS is able to maintain integrity and financial reputation and implement its competencies in carrying out tasks and responsibilities.

C. Results of Governance Implementation (H)
33. DPS carries out tasks well and has accounted for task implementation to shareholders through the General Meeting of Shareholders (RUPS).
34. Results of DPS meetings with the Board of Directors, Executive Officials, and/or UUS leadership are recorded in meeting minutes and documented well, distributed to all meeting participants, and followed up according to agreed commitments.
35. Dissenting opinions occurring in DPS meeting decisions with the Board of Directors, Executive Officials, and/or UUS leadership must be clearly stated in meeting minutes accompanied by reasons for the dissenting opinions.
36. There is an increase in DPS capabilities, experience, and expertise in carrying out PVML supervision tasks and responsibilities, demonstrated by individual performance improvements, PVML performance improvements, resolution of PVML issues, and achievement of results according to stakeholder expectations.
37. DPS submits reports regarding the Board of Directors' rejection of DPS evaluations of Board of Directors policies or actions not in accordance with Sharia Principles to the Financial Services Authority as regulated in Financial Services Authority provisions, completely, accurately, currently, wholly, and timely.

Indicator Value
Positive Factors
Contains a summary of positive factors from the task execution, responsibility, and authority factors of DPS that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from the task execution, responsibility, and authority factors of DPS that have a significant impact on governance implementation. a. Structure b. Process
c. Results

E. Completeness and Committee Task Implementation Indicators Description A. Governance Structure and Infrastructure (S)

PVML with total assets exceeding IDR 250,000,000,000.00 (two hundred fifty billion rupiah) forms:
a. audit committee; b. risk monitoring committee; and
c. remuneration and nomination committee,
to assist in carrying out the tasks and responsibilities of the Board of Commissioners.
The Board of Commissioners forms other committees to support the Board of Commissioners' task implementation.
PVML has guidelines and working rules for each committee formed by the Board of Commissioners in accordance with Financial Services Authority regulations.
The Board of Directors carries out the appointment and dismissal of committee members formed by the Board of Commissioners based on Board of Commissioners meeting decisions.
Committees formed by the Board of Commissioners have members in accordance with Financial Services Authority regulations.
The committee chair is one of the Independent Commissioners.
Committee members do not come from Board of Directors members.
Independent Parties who are committee members have competence to support the execution of committee functions and responsibilities in accordance with Financial Services Authority regulations, as well as the willingness and ability to engage in continuous learning to enhance capabilities, experience, and expertise to implement competencies in carrying out committee member tasks and responsibilities.

B. Process of Governance Implementation (P)
9. The audit committee has carried out its functions well in assessing the adequacy of internal controls, including the adequacy of financial reporting processes, by monitoring and evaluating audit planning and implementation and monitoring follow-up on audit results.
10. The audit committee provides recommendations to the Board of Commissioners.
11. The audit committee plays a role and carries out tasks and responsibilities in accordance with Financial Services Authority Regulations regarding the use of public accountants and public accounting firms in financial service activities.
12. The risk monitoring committee has carried out its functions well, including by evaluating the suitability between risk management policies and PVML policy implementation, and monitoring and evaluating the task execution of the risk management committee and risk management work units.
13. The remuneration and nomination committee has carried out its functions well, including by evaluating and recommending remuneration policies and drafting and providing recommendations on nomination policies.
14. The number of committee meetings held and the attendance of each committee member are included in the Good Corporate Governance Implementation Report.
15. Committee meetings are held in accordance with established guidelines and working rules.
16. Committees assist in DPS task implementation.
17. Committee members cultivate continuous learning to enhance knowledge about PVML and recent developments supporting task and responsibility implementation.
18. Committees are able to maintain integrity and financial reputation and implement their competencies in carrying out tasks and responsibilities.
19. Each committee consistently evaluates committee guidelines and working rules.

C. Results of Governance Implementation (H)
20. Committees carry out tasks well and have accounted for task implementation to the Board of Commissioners.
21. Committee meeting results are recorded in meeting minutes and documented well, distributed to all committee members, and followed up according to agreed commitments.
22. Dissenting opinions occurring in committee meeting decisions must be clearly stated in meeting minutes accompanied by reasons for the dissenting opinions.
23. There is an increase in committee members' capabilities, experience, and expertise in carrying out PVML supervision tasks and responsibilities, demonstrated by individual performance improvements, PVML performance improvements, resolution of PVML issues, and achievement of results according to stakeholder expectations.
24. Committees report on the realization of committee work programs.

Indicator Value
Positive Factors
Contains a summary of positive factors from committee completeness and task execution factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from committee completeness and task execution factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results

F. Risk Management Implementation
Indicators Description
A. Governance Structure and Infrastructure (S)

PVML has a committee, work unit, and/or risk management function based on total assets, including anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs, in accordance with Financial Services Authority regulations.
PVML has and establishes risk management policies, risk management procedures, and risk limit determinations.
PVML has and establishes written policies and procedures regarding the management of risks inherent in new products and activities in accordance with applicable regulations.

B. Process of Governance Implementation (P)
4. Risk management is conducted effectively in accordance with objectives, business policies, business size and complexity, and PVML capabilities in accordance with Financial Services Authority regulations and procedures, including the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs.
5. PVML implements integrated governance, risk management, and compliance supported by necessary policies or procedures.
6. PVML implements risk management over all risks required by Financial Services Authority regulations.
7. PVML has adequate information systems, namely management information systems capable of providing complete, accurate, current, and whole data and information.
8. PVML considers the adequacy of policies in risk management.
9. PVML considers procedures in risk management.
10. PVML considers risk limit determinations in risk management.
11. PVML considers the adequacy of identification processes in risk management.
12. PVML considers measurement in risk management.
13. PVML considers risk control.
14. PVML considers risk monitoring.
15. Comprehensive internal control systems are implemented optimally.
16. Comprehensive internal control systems consider reporting mechanisms in case of deviations.
17. The Board of Directors has developed a risk management culture at all organizational levels and improved human resource competence, including through training and/or socialization regarding risk management.

C. Results of Governance Implementation (H)
18. PVML prepares risk profile reports and other risk profiles (if any) reported to the Financial Services Authority in accordance with Financial Services Authority regulations, and is able to maintain and improve risk profiles to support better risk management implementation.
19. Risk management information systems present reports or information regarding risk exposures covering quantitative and qualitative exposures, both composite and detailed by risk type and functional activity type.
20. Risk management information systems present reports or information regarding compliance with risk management policies and procedures and risk limit determinations.
21. Risk management information systems present reports or information regarding the realization of risk management implementation compared to established targets.

Indicator Value
Positive Factors
Contains a summary of positive factors from risk management implementation factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from risk management implementation factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results

G. Antifraud Strategy Implementation
Indicators Description
A. Governance Structure and Infrastructure (S)

PVML has and establishes antifraud strategy policies in accordance with Financial Services Authority regulations.

B. Process of Governance Implementation (P)
2. PVML drafts and implements antifraud strategies effectively in conducting business activities in accordance with Financial Services Authority regulations.
3. The Board of Directors ensures implementation and conducts periodic evaluations of antifraud strategy policies.
4. The Board of Commissioners ensures implementation and conducts periodic evaluations of antifraud strategy policies.
5. Resolution of internal deviations involves legal processes.
6. There are no deviations committed by Board of Directors members, Board of Commissioners members, DPS, permanent employees, and non-permanent employees.
7. PVML provides mediation for resolving internal deviations.

C. Results of Governance Implementation (H)
8. PVML drafts and submits regular antifraud strategy implementation reports and significant fraud incident reports.

Indicator Value
Positive Factors
Contains a summary of positive factors from antifraud strategy implementation factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from antifraud strategy implementation factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results

H. Compliance Function Implementation
Indicators Description
A. Governance Structure and Infrastructure (S)

PVML has a Board of Directors member who oversees the compliance function.
The Board of Directors member overseeing the compliance function is not concurrently held by a Board of Directors member overseeing the financing function, marketing function, and financial and accounting function.
PVML has a compliance work unit or function responsible for compliance implementation based on total assets in accordance with Financial Services Authority regulations.
The compliance work unit and risk management work unit are merged into 1 (one) work unit handling compliance and risk management.
The compliance work unit or function responsible for compliance implementation has drafted and/or established work guidelines, systems, and compliance procedures.
PVML has provided human resources with adequate quantity and quality in the compliance work unit or function responsible for compliance implementation to complete tasks effectively.

B. Process of Governance Implementation (P)
7. The Board of Directors member overseeing the compliance function formulates strategies to encourage the creation of a PVML compliance culture, including through the drafting of compliance policies oriented towards PVML vision, mission, and values, as well as socialization and training on current regulations.
8. The Board of Directors member overseeing the compliance function formulates strategies to encourage the creation of a compliance culture.
9. The Board of Directors member overseeing the compliance function ensures PVML business activities have met all laws and regulations in the PVML field and other laws and regulations.
10. The Board of Directors member overseeing the compliance function is able to ensure PVML compliance with commitments made by PVML to the Financial Services Authority and/or other competent supervisory authorities.
11. The Board of Directors member overseeing the compliance function carries out other tasks related to compliance function implementation.
12. The work unit or function responsible for compliance implementation assists the Board of Directors in ensuring compliance with laws and regulations in the PVML field and other laws and regulations.
13. The compliance work unit or function responsible for compliance implementation carries out tasks and responsibilities in accordance with work guidelines, systems, and compliance procedures.
14. The work unit or function responsible for compliance implementation reports to the Board of Directors member overseeing the compliance function.
15. For PVML conducting business activities based on Sharia Principles, the Board of Directors member overseeing the compliance function, the compliance work unit or function responsible for compliance implementation, coordinate with DPS regarding compliance function implementation against Sharia Principles.

C. Results of Governance Implementation (H)
16. PVML successfully reduces the level of violations against regulations.
17. The Board of Directors member overseeing the compliance function submits reports regarding compliance function implementation to the Financial Services Authority as regulated in Financial Services Authority provisions, completely, accurately, currently, wholly, and timely.

Indicator Value
Positive Factors
Contains a summary of positive factors from compliance function implementation factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factors
Contains a summary of negative factors from compliance function implementation factors that have a significant impact on governance implementation. a. Structure b. Process
c. Results

I. Internal and External Audit Function Implementation

Internal Audit Function Implementation
Indicators Description
A. Governance Structure and Infrastructure (S)
PVML has an internal audit work unit or internal audit function based on total assets in accordance with Financial Services Authority regulations.
The internal audit work unit or internal audit function has established and established guidelines and working rules in accordance with Financial Services Authority regulations and has been approved by the Chief Director and Board of Commissioners.
The internal audit work unit or internal audit function reports directly to the Chief Director.
PVML has provided human resources with adequate quantity and quality in the internal audit work unit or internal audit function to complete tasks effectively.

B. Process of Governance Implementation (P)
5. PVML implements the internal audit function in accordance with internal audit guidelines drafted by PVML and Financial Services Authority regulations on all aspects and elements of activities that are directly estimated to affect PVML and public interests.
6. PVML assigns external parties to conduct reviews containing opinions on internal audit work unit results and their compliance with internal audit function implementation standards.
7. Internal audit function implementation (audit activities) is conducted independently and adequately, covering audit preparation, audit program drafting, audit implementation, audit result reporting, and audit result follow-up.
8. PVML conducts periodic and continuous quality improvement of human resource skills related to internal audit function implementation.
9. The internal audit work unit drafts and realizes annual audit program plans.
10. The internal audit work unit assists the Chief Director and Board of Commissioners in conducting PVML operational supervision, especially in monitoring audit results.
11. The internal audit work unit creates analyses and assessments in the fields of finance, accounting, operations, and other activities.
12. The internal audit work unit provides improvement suggestions and objective information about audited activities at all management levels.

C. Results of Governance Implementation (H)
13. PVML presents annual audit program plans and realizations as requested by the Financial Services Authority.
14. PVML submits reports regarding internal audit function implementation to the Financial Services Authority as regulated in Financial Services Authority provisions, completely, accurately, currently, wholly, and timely.

Indicator Value
2. External Audit Implementation
Indicators Description
A. Governance Structure and Infrastructure (S)

Audit assignments to public accountants and public accounting firms (KAP) have met aspects of work agreement legality, audit scope, public accountant professional standards, audit completion time targets, communication between the Financial Services Authority and KAP, and consider the adequate competence of KAP (including public accountants).
Appointed public accountants and KAP have competence in accordance with business complexity

Indicator Description
PVML.
B. Implementation Process of Governance (P)
3. In the implementation of the PVML financial report audit, PVML appoints a public accountant and an Accounting Firm registered with the Financial Services Authority and obtains approval from the General Meeting of Shareholders based on the proposal of the Board of Commissioners and pays attention to the audit committee's recommendation (for PVML that has an audit committee).
4. PVML provides all accounting records and data required for external audit.
5. PVML has reported the results of the public accountant or Accounting Firm audit and the management letter to the Financial Services Authority on time.
6. External auditors are independent.
C. Governance Implementation Results (H)
7. Audit results and management letters have described PVML's issues and presented transparent and quality financial information.
8. The scope of audit results is at least in accordance with the audit scope in accordance with Financial Services Authority regulations.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the implementation of internal audit functions and external audit functions that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the implementation of internal audit functions and external audit functions that have a significant impact on governance implementation. a. Structure b. Process
c. Results

J. Handling Conflicts of Interest
Indicator Description
A. Governance Structure and Infrastructure (S)

PVML has a conflict of interest policy aimed at identifying, reducing, and managing potential conflicts of interest that may arise in PVML resulting from the implementation of PVML's business activities, which are codified in regulations.
B. Implementation Process of Governance (P)
Members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and PVML employees avoid all forms of conflict of interest in the implementation of PVML management and supervision tasks.
Members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and PVML employees do not take actions that have the potential to harm PVML or reduce PVML's profits.
C. Governance Implementation Results (H)
Members of the Board of Directors, members of the Board of Commissioners, PVML committee members, DPS, Executive Officials, and PVML employees disclose conflicts of interest in every decision that meets the conditions of a conflict of interest to the Financial Services Authority.
PVML discloses to the Financial Services Authority regarding PVML transactions that have a potential Conflict of Interest with other PVMLs.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the handling of Conflicts of Interest that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the handling of Conflicts of Interest that have a significant impact on governance implementation. a. Structure b. Process
c. Results

K. Implementation of Remuneration Policy
Indicator Description
A. Governance Structure and Infrastructure (S)

PVML establishes in its articles of association regarding the policy and procedures for setting remuneration and nomination for members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees in accordance with applicable legislation.
PVML formulates and establishes remuneration policies for members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees.
For PVML that has a remuneration and nomination committee, the formulation of remuneration policies pays attention to the recommendation of the remuneration and nomination committee.
B. Implementation Process of Governance (P)
PVML implements governance in the provision of remuneration for members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees.
The provision of remuneration pays attention to financial performance and the fulfillment of PVML's obligations as regulated in applicable legislation.
The provision of remuneration pays attention to individual work performance.
The provision of remuneration pays attention to fairness with PVML and/or equivalent job levels (peer group).
The provision of remuneration pays attention to considerations of PVML's medium and long-term goals and strategies.
PVML submits the ratio of highest to lowest salaries to the Financial Services Authority.
C. Governance Implementation Results (H)
In implementing remuneration policies, PVML has implemented good governance.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the implementation of remuneration policies that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the implementation of remuneration policies that have a significant impact on governance implementation. a. Structure b. Process
c. Results

L. Information Openness
Indicator Description
A. Governance Structure and Infrastructure (S)

PVML has procedures and methods regarding the disclosure of information openness and other important matters.
PVML has a reliable and adequate information management system in order to implement information openness for all stakeholders.
PVML has procedures for the use of PVML consumer data in the context of information transparency.
B. Implementation Process of Governance (P)
PVML discloses information openness and other important matters.
PVML implements information transparency regarding the use of consumer data with reference to Financial Services Authority regulations regarding consumer and public protection in the financial services sector.
PVML optimizes reliable and adequate information management systems to improve the quality of decision-making processes by the Board of Directors and all levels or tiers of the organization.
PVML optimizes reliable and adequate information management systems to improve the quality of supervision processes by the Board of Commissioners.
PVML optimizes reliable and adequate information management systems for the needs of supervision by the Financial Services Authority and other Stakeholders.
For PVML that forms a remuneration and nomination committee, recommendations from the remuneration and nomination committee are considered in every proposal for the appointment and/or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS to the General Meeting of Shareholders.

Indicator Description
10. For PVML that does not form a remuneration and nomination committee, proposals for the appointment and/or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS pay attention to recommendations from members of the Board of Commissioners.
11. The appointment and/or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS prioritize professional composition, independence, competency suitability, and pay attention to diversity, which are needed appropriately in the implementation of the tasks and responsibilities of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
12. The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS prioritizes the primary interests of PVML.
13. The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS is because the members of the Board of Directors, members of the Board of Commissioners, and/or DPS are assessed as unable to carry out tasks and responsibilities in the management and implementation of healthy PVML strategies.
14. The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS is not based on subjective assessments from shareholders, but is based on objective assessments regarding PVML management.
15. For PVML that forms a remuneration and nomination committee, the dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS has gone through established planning and mechanisms, which at least pay attention to assessments from the remuneration and nomination committee and has been scheduled in the General Meeting of Shareholders.
16. For PVML that does not form a remuneration and nomination committee, the dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS has gone through established planning and mechanisms, which at least pay attention to assessments from members of the Board of Commissioners and has been scheduled in the General Meeting of Shareholders.
17. The dismissal or replacement of members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS is because there is information that members of the Board of Directors, members of the Board of Commissioners, and/or DPS are included in parties prohibited as principal parties established by competent authorities.
18. PVML appoints replacements for members of the Board of Directors, members of the Board of Commissioners, and/or DPS in the event of the dismissal of members of the Board of Directors, members of the Board of Commissioners, and/or DPS that results in the number of members of the Board of Directors, members of the Board of Commissioners, and/or DPS becoming less than the minimum number of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
19. PVML appoints replacements for members of the Board of Directors, members of the Board of Commissioners, and/or DPS in the event that members of the Board of Directors, members of the Board of Commissioners, and/or DPS are permanently unable to attend, resulting in the number of members of the Board of Directors, members of the Board of Commissioners, and/or DPS becoming less than the minimum number of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
20. PVML appoints replacements for members of the Board of Directors, members of the Board of Commissioners, and/or DPS in the event that members of the Board of Directors, members of the Board of Commissioners, and/or DPS resign, resulting in the number of members of the Board of Directors, members of the Board of Commissioners, and/or DPS becoming less than the minimum number of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
21. There is no intervention from PVML owners.
22. There are no internal disputes within PVML.
23. PVML does not have legal issues that are civil cases.
24. PVML does not have legal issues that are criminal cases.
25. PVML implements transparency of financial and non-financial conditions to stakeholders.
C. Governance Implementation Results (H)
26. PVML reports the share ownership of members of the Board of Directors and members of the Board of Commissioners that reaches 5% (five percent) or more on the PVML where members of the Board of Directors and members of the Board of Commissioners serve and/or on other companies located domestically and internationally.
27. PVML reports the financial relationships of members of the Board of Directors and members of the Board of Commissioners with other members of the Board of Directors, other members of the Board of Commissioners, DPS, PVML shareholders, and/or PVML employees where members of the Board of Directors and members of the Board of Commissioners serve.

Indicator Description
28. PVML reports the family relationships of members of the Board of Directors and members of the Board of Commissioners with other members of the Board of Directors, other members of the Board of Commissioners, DPS, PVML shareholders, and/or PVML employees where members of the Board of Directors and members of the Board of Commissioners serve up to the second degree both horizontally and vertically.
29. PVML reports remuneration and other facilities received by members of the Board of Directors and members of the Board of Commissioners.
30. Members of the Board of Directors, members of the Board of Commissioners, and/or DPS, including Independent Commissioners who resign from their positions before the end of their term of office, submit written notifications to PVML.
31. Resigning external auditors submit written notifications to PVML.
32. PVML discloses to the Financial Services Authority regarding the resignation of members of the Board of Directors, members of the Board of Commissioners, and/or DPS, including Independent Commissioners.
33. PVML discloses to the Financial Services Authority regarding the dismissal of members of the Board of Directors, members of the Board of Commissioners, and/or DPS, including Independent Commissioners, including those who are permanently unable to attend due to death, mental disability, or other conditions that do not allow the relevant person to carry out tasks well.
34. PVML discloses to the Financial Services Authority regarding the resignation of external auditors.
35. PVML discloses to the Financial Services Authority regarding the dismissal of external auditors.
36. PVML implements orders from the Financial Services Authority to conduct evaluations and corrective actions regarding decisions to dismiss, replace, and/or resign members of the Board of Directors, members of the Board of Commissioners, and/or DPS carried out before the end of the term of office of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
37. PVML appoints replacements for members of the Board of Directors, members of the Board of Commissioners, and/or DPS no later than 6 (six) months from the date of dismissal of members of the Board of Directors, members of the Board of Commissioners, and/or DPS.
38. PVML appoints replacements for members of the Board of Directors, members of the Board of Commissioners, and/or DPS no later than 6 (six) months from the date members of the Board of Directors, members of the Board of Commissioners, and/or DPS are permanently unable to attend.
39. PVML appoints replacements for members of the Board of Directors, members of the Board of Commissioners, and/or DPS no later than 6 (six) months from the date members of the Board of Directors, members of the Board of Commissioners, and/or DPS resign.
40. The Board of Commissioners reports to the Financial Services Authority no later than 10 (ten) working days from the discovery of violations of financial legislation regulations and related PVML.
41. The Board of Commissioners reports to the Financial Services Authority no later than 10 (ten) working days from the discovery of conditions or estimated conditions that can endanger the continuity of PVML's business.
42. PVML discloses to the Financial Services Authority regarding material transactions with other parties.
43. PVML discloses to the Financial Services Authority regarding legal issues that are civil cases.
44. PVML discloses to the Financial Services Authority regarding legal issues that are criminal cases.
45. PVML provides data and information to the Financial Services Authority completely and on time.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the information openness factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the information openness factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results

M. Business Ethics
Indicator Description
A. Governance Structure and Infrastructure (S)

PVML formulates guidelines on ethical behavior, which contain business ethical values, as a guide for PVML Organs and all PVML employees.
B. Implementation Process of Governance (P)
PVML does not take actions aimed at exploiting regulatory or business ethics loopholes that are not in accordance with the principles of healthy PVML management, which can increase risks for PVML, and/or bring unfair profits.
Members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees do not offer or give anything, directly or indirectly, to other parties, to influence decision-making related to PVML's business activities, in violation of applicable legislation.
Members of the Board of Directors, members of the Board of Commissioners, DPS, and PVML employees do not receive anything for their personal, family, and/or other parties' interests in violation of applicable legislation, directly or indirectly, from anyone, which can influence decision-making related to PVML's business activities.
C. Governance Implementation Results (H)
PVML does not violate guidelines on ethical behavior, including business ethical values, in conducting business activities.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the business ethics factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the business ethics factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results

N. Financing Policy
Indicator Description
A. Governance Structure and Infrastructure (S)

PVML has written policies and procedures for the disbursement of financing in accordance with Financial Services Authority regulations.
PVML has a reliable financial reporting system for supervision and other stakeholders.
B. Implementation Process of Governance (P)
Policies and procedures for the disbursement of financing are established by the Board of Directors.
Policies and procedures for the disbursement of financing are approved by the Board of Commissioners.
Policies and procedures for the disbursement of financing are socialized to management and employees in relevant work units.
PVML ensures that the Board of Directors and all levels or tiers of the organization make financing decisions professionally while still paying attention to protection for consumers and other Stakeholders.
PVML optimizes the added value of PVML's wealth while still paying attention to protection for consumers and other Stakeholders.
PVML periodically evaluates and updates policies and procedures for the disbursement of financing to be adjusted to applicable legislation.
The process of financing disbursement by PVML to related parties and/or large financing disbursements in accordance with Financial Services Authority regulations and pays attention to prudential principles and applicable legislation.
PVML explains financing agreements and the rights and obligations of debtors in every financing transaction.

Indicator Description
11. PVML conducts promotions regarding financing services.
C. Governance Implementation Results (H)
12. Reports on financing disbursement by PVML to related parties and/or PVML that violates and/or exceeds Financial Services Authority regulations have been submitted periodically to the Financial Services Authority correctly and on time in accordance with Financial Services Authority regulations.
13. PVML does not violate and/or exceed Financial Services Authority regulations in financing disbursement.
14. PVML transparently communicates complaint procedures and dispute resolution to debtors.
15. Financing disbursement is carried out by paying attention to prudential principles and risk management application principles.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the financing policy factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the financing policy factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results

O. Implementation of Sustainable Finance, including Implementation of Social and Environmental Responsibility Indicator Description A. Governance Structure and Infrastructure (S)

PVML formulates a sustainable finance action plan in accordance with Financial Services Authority regulations and has been formulated by the Board of Directors and approved by the Board of Commissioners in accordance with PVML's vision and mission.
B. Implementation Process of Governance (P)
PVML implements sustainable finance in business activities.
PVML effectively implements the sustainable finance action plan.
PVML communicates the sustainable finance action plan to shareholders and all organizational tiers within PVML.
C. Governance Implementation Results (H)
PVML submits the sustainable finance action plan to the Financial Services Authority in accordance with Financial Services Authority regulations.
PVML submits sustainability reports to the Financial Services Authority in accordance with Financial Services Authority regulations.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the implementation of sustainable finance, including the implementation of social and environmental responsibility, that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the implementation of sustainable finance, including the implementation of social and environmental responsibility, that have a significant impact on governance implementation. a. Structure b. Process
c. Results

P. Business Plan
Indicator Description
A. Governance Structure and Infrastructure (S)

PVML's business plan has been formulated by the Board of Directors and approved by the Board of Commissioners in accordance with PVML's vision and mission.
PVML's business plan describes long-term strategic plans and annual business plans, including capital strengthening plans, plans to handle PVML's financial issues that affect the continuity of PVML's business, with a scope in accordance with Financial Services Authority regulations.
PVML's business plan is fully supported by shareholders in order to strengthen capital and adequate infrastructure, including human resources, information technology, office networks, policies, and procedures.
PVML's business plan is formulated based on comprehensive studies paying attention to business opportunities and strengths possessed by PVML and identifying weaknesses and threats (strength, weakness, opportunity, threat/SWOT Analysis);
PVML's business plan must be supported by adequate infrastructure preparation, including human resources, information technology, office networks, as well as policies and procedures.
B. Implementation Process of Governance (P)
PVML's business plan is formulated realistically, comprehensively, and measurably (achievable) by considering at least:
a. external and internal factors that can affect the continuity of PVML's business; b. prudential principles; and
c. risk management application.
The Board of Commissioners supervises the implementation of PVML's business plan.

Indicator Description
8. PVML's business plan describes PVML's continuous growth.
C. Governance Implementation Results (H)
9. Business plans, including changes to business plans, are submitted to the Financial Services Authority in accordance with Financial Services Authority regulations.
10. Financial and non-financial performance indicators in the business plan are achieved according to established targets, including the realization of shareholder commitments.
Indicator Value Total
Positive Factor
Contains a summary of positive factors from the business plan factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results
Negative Factor
Contains a summary of negative factors from the business plan factor that have a significant impact on governance implementation. a. Structure b. Process
c. Results

RECAPITULATION OF VALUES AND FINAL CONCLUSION OF GOVERNANCE ASSESSMENT

Value Recapitulation for Conventional PVML
Factor Number of Indicators Total
Statement/Question Weight Value
Factor
1 18 5.00
2 59 15.00
3 57 10.00
4 24 5.00
5 21 10.00
6 8 5.00
7 17 10.00
8 22 5.00
9 5 8.00
10 10 3.00
11 45 10.00
12 5 3.00
13 15 5.00
14 6 3.00
15 10 3.00
Governance Value
Governance Ranking
Value Recapitulation for PVML based on Sharia Principles or PVML with Sharia Business Units
Factor Number of Indicators Total
Statement/Question Weight Value
Factor
1 18 5.00
2 59 15.00
3 57 10.00
4 37 12.00
5 24 4.00
6 21 8.00
7 8 4.00
8 17 9.00
9 22 4.00
10 5 6.00
11 10 2.50
12 45 8.00
13 5 2.50
14 15 5.00
15 6 2.50
16 10 2.50
Governance Value
Governance Ranking

This copy is consistent with the original
Head of the Legal Development Directorate
Legal Department signed.
Aat Windradi

Final Conclusions
Contains the final conclusions of the governance implementation assessment linked to the definition of composite ratings.

Positive Factors
Contains a summary of positive factors from the main factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Negative Factors
Contains a summary of negative factors from the main factors that have a significant impact on the implementation of governance. a. Structure b. Process
c. Results

Approved,
THE BOARD OF DIRECTORS

Established in Jakarta on 19 November 2025
EXECUTIVE HEAD OF SUPERVISOR
FOR FINANCING INSTITUTIONS,
VENTURE CAPITAL COMPANIES,
MICROFINANCE INSTITUTIONS, AND
OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,

AGUSMAN signed.

APPENDIX III
CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 28/SEOJK.06/2025 CONCERNING THE GOOD CORPORATE GOVERNANCE IMPLEMENTATION REPORT FOR FINANCING INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICROFINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS

This copy is consistent with the original
Head of the Legal Development Directorate
Legal Department signed.
Aat Windradi

ACTION PLAN
No. Weakness Corrective Action Target Completion Time Completion Obstacles Remarks 1.
2.
3.
Etc.

Approved,
THE BOARD OF DIRECTORS

Established in Jakarta on 19 November 2025
EXECUTIVE HEAD OF SUPERVISOR FOR FINANCING INSTITUTIONS, VENTURE CAPITAL COMPANIES, MICROFINANCE INSTITUTIONS, AND OTHER FINANCIAL SERVICE INSTITUTIONS FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA, AGUSMAN signed.

OJK Circular No. 28/SEOJK.06/2025 on the Good Corporate Governance Implementation Report for Financing Institutions, Venture Capital Companies, Microfinance Institutions, and Other Financial Service Institutions

Lineage: In force

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