OJK Regulation No. 17/POJK.04/2022 on Investment Manager Code of Conduct

COPY
FINANCIAL SERVICES AUTHORITY REGULATION
OF THE REPUBLIC OF INDONESIA
NUMBER 17/POJK.04/2022
CONCERNING
INVESTMENT MANAGER CODE OF CONDUCT
BY THE GRACE OF GOD THE ALMIGHTY
THE COMMISSIONERS OF THE FINANCIAL SERVICES AUTHORITY,

Considering:
a. that public trust and capital market investor protection, particularly regarding investment management, need to be enhanced through the ethical, credible, and well-governed conduct of investment managers; b. that to enhance the conduct of investment managers as referred to in letter a, it is necessary to replace the Financial Services Authority Regulation Number 43/POJK.04/2015 concerning the Investment Manager Code of Conduct to align with the conduct of investment managers prevailing in the capital market community and international principles;
c. that based on the considerations referred to in letters a and b, it is necessary to establish a Financial Services Authority Regulation concerning the Investment Manager Code of Conduct;

Recalling:

1. Law Number 8 of 1995 concerning the Capital Market (State Gazette of the Republic of Indonesia Year 1995 Number 64, Supplement to the State Gazette of the Republic of Indonesia Number 3608);
2. Law Number 21 of 2011 concerning the Financial Services Authority (State Gazette of the Republic of Indonesia Year 2011 Number 111, Supplement to the State Gazette of the Republic of Indonesia Number 5253);

DECIDING:

To Establish: FINANCIAL SERVICES AUTHORITY REGULATION CONCERNING THE INVESTMENT MANAGER CODE OF CONDUCT.

CHAPTER I
GENERAL PROVISIONS

Article 1
In this Financial Services Authority Regulation, the following terms are defined:

1. Party means an individual, company, joint venture, association, or organized group.
2. Investment Manager means a Party whose business activity is to manage securities portfolios for clients or manage collective investment portfolios for a group of clients, excluding insurance companies, pension funds, and banks that conduct their own business activities based on statutory regulations.
3. Securities means negotiable instruments, namely debt acknowledgment instruments, commercial paper, shares, bonds, debt certificates, units of participation in collective investment contracts, futures contracts over securities, and every derivative of securities.
4. Securities Portfolio means a collection of Securities owned by a Party.
5. Custodian Bank means a general bank that has obtained approval from the Financial Services Authority to conduct business activities as a custodian.
6. Custodian means a Party that provides services for the safekeeping of Securities and other assets related to Securities, as well as other services, including receiving dividends, interest, and other rights, settling Securities transactions, and representing account holders who are its clients.
7. Affiliation means:
   a. family relationships due to marriage and descent up to the second degree, both horizontally and vertically; b. relationships between a Party and its employees, directors, or commissioners;
   c. relationships between 2 (two) companies where there is one or more members of the board of directors or board of commissioners in common;
   d. relationships between a company and a Party, directly or indirectly, controlling or being controlled by such company; e. relationships between 2 (two) companies controlled, directly or indirectly, by the same Party; or f. relationships between a company and major shareholders.
8. Investment Committee means a committee tasked with directing and supervising the investment management team in implementing investment policies and strategies.
9. Investment Management Team means a team tasked with managing Securities Portfolios for clients or collective investment portfolios for the benefit of a group of clients.
10. Compliance Function Coordinator means the directors or employees of the Investment Manager tasked with coordinating matters related to the Investment Manager's compliance.
11. Rebate means the return in cash form from a third party related to transactions conducted by the Investment Manager for the benefit of clients.
12. Non-Cash Commission means the provision to the Investment Manager in the form of goods and/or facilities from a third party related to transactions conducted by the Investment Manager for the benefit of clients.
13. Investment Product means mutual funds, asset-backed securities in the form of collective investment contracts, infrastructure investment funds, real estate investment funds, individual management of clients' Securities Portfolios, multi-asset investment funds, collective investment contracts for the fundraising of people's housing savings, and other investment products established by the Financial Services Authority based on statutory regulations.
14. Risk Management means a series of procedures and methodologies used to identify, measure, monitor, and control risks arising from the business activities of the Investment Manager.
15. Liquidity Risk Management means a series of procedures and methodologies used to identify, measure, monitor, and control liquidity risks of investment portfolios managed by the Investment Manager for the benefit of clients.
16. Public Offering means the activity of offering Securities conducted by the issuer to sell Securities to the public based on procedures regulated according to statutory regulations in the capital market sector.
17. Securities Broker means a Party that conducts business activities of buying and selling Securities for its own interest or for the interest of other Parties.

Article 2
In conducting its business activities, the Investment Manager is required to apply the following principles:
a. independence; b. integrity;
c. professionalism;
d. prioritizing the interests of the Investment Product; e. supervision and control; f. adequacy of resources; g. protection of Investment Product assets; h. information openness;
i. conflict of interest;
j. protection against money laundering and terrorism financing risks; and k. compliance.

Article 3
(1) The Investment Manager is required to become a member of an association that accommodates Investment Managers that have received recognition from the Financial Services Authority. (2) Regulations concerning the association that accommodates Investment Managers are established by the Financial Services Authority.

CHAPTER II
CONFLICT OF INTEREST, BENEFITS, AS WELL AS REBATES AND NON-CASH COMMISSIONS

Section One
Disclosure of Conflict of Interest by Investment Manager and Its Affiliated Parties

Article 4
An Investment Manager that manages Securities Portfolios for the benefit of clients individually and has a conflict of interest is required to disclose in writing to the client the existence of a conflict of interest regarding the Securities transacted, with the following provisions:
a. disclosure is conducted when entering into a written investment management agreement for the Securities Portfolio with the client, if the Securities constituting the Securities Portfolio have been determined by the client in the agreement; b. disclosure is conducted before conducting Securities transactions for the benefit of the client, if the determination of Securities constituting the Securities Portfolio:

1. is recommended by the Investment Manager but the decision lies with the client; or
2. is fully entrusted to the Investment Manager;
   c. the disclosure conducted includes or mentions the risks of conflict of interest that may arise; and
   d. there is a statement from the Investment Manager and the client regarding the understanding of the risks of conflict of interest that may arise.

Article 5
(1) Shareholders, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager are required to disclose to the Investment Manager:
a. the existence or non-existence of interests and/or ownership of a Security, whether directly or indirectly, including through nominees or Affiliated Parties, since becoming shareholders, holding office, or working at the Investment Manager; and b. every change in interest and/or ownership of a Security, whether directly or indirectly, including through nominees or Affiliated Parties, as referred to in letter a, including interests or ownership of a Security held by the Party concerned while being a shareholder, holding office, or working at the Investment Manager. (2) In the event that the Investment Manager has conducted a Public Offering of shares, the provisions as referred to in paragraph (1) only apply to controlling shareholders and/or major shareholders. (3) Members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager are required to notify in writing to the Investment Manager concerned no later than 2 (two) working days before and after executing buy or sell Securities transactions conducted by:
a. themselves for personal interest, nominees, and/or Affiliated Parties which are Parties where the person concerned has ownership of a Security, whether directly or indirectly, as referred to in paragraph (1); and b. nominees or Affiliated Parties which are Parties where the person concerned has ownership of a Security, whether directly or indirectly, as referred to in paragraph (1). (4) Members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager who execute buy or sell Securities transactions for personal interest, nominees, and/or Affiliated Parties which are Parties where the members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager have ownership of a Security, whether directly or indirectly, are prohibited from:
a. executing transactions first on a specific Security based on information that the Investment Product will execute a large volume transaction on such Security, which is estimated to affect market prices, with the aim of gaining profit, reducing losses, and/or avoiding losses; b. executing cross transactions with the Investment Manager's Investment Product; and/or
c. selling Securities owned for less than 30 (thirty) days.

Article 6
The Compliance Function of the Investment Manager coordinates:
a. the disclosure of interests or ownership by shareholders, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager regarding a Security as referred to in Article 5 paragraph (1); and b. written notification to the Investment Manager before and after executing buy or sell Securities transactions for personal interest, nominees, and/or Affiliated Parties which are Parties where shareholders, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager have ownership of a Security, whether directly or indirectly, as referred to in Article 5 paragraph (4).

Article 7
(1) Members of the Investment Committee who have a conflict of interest regarding decisions to be made in the Investment Committee meeting are required to abstain from such Investment Committee meeting. (2) In the event that all members of the Investment Committee have a conflict of interest regarding decisions to be made in the Investment Committee meeting, the Investment Manager is required to formulate and apply written policies and procedures regarding the implementation of the Investment Committee meeting.

Article 8
The Investment Manager is required to prioritize the interests of the Investment Product over the interests of:
a. the Investment Manager; b. Parties having an Affiliation relationship with the Investment Manager; and/or
c. Parties having an Affiliation relationship with members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager.

Article 9
(1) The Investment Manager is required to create, document, and maintain documents and/or records of interests or ownership of Securities that have been disclosed by:
a. the Investment Manager to clients as referred to in Article 4; and b. shareholders, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager to the Investment Manager as referred to in Article 5 paragraph (1). (2) The Investment Manager is required to create, document, and maintain documents and/or records of written notifications before and after executing buy or sell Securities transactions conducted by members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager to the Investment Manager as referred to in Article 5 paragraph (3).

Article 10
The Compliance Function of the Investment Manager coordinates the creation, documentation, and maintenance of documents and/or records as referred to in Article 9.

Article 11
The Investment Manager is required to formulate and apply written policies and procedures regarding:
a. disclosure of interests or ownership of a Security as referred to in Article 4; b. disclosure of interests or ownership of a Security by Parties as referred to in Article 5 paragraph (1); and
c. prohibitions as referred to in Article 5 paragraph (4).

Section Two
Receipt and Provision of Benefits

Article 12
(1) In managing investment portfolios for the benefit of Investment Products, the Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and/or employees of the Investment Manager are prohibited from:
a. receiving benefits originating from clients outside of fund management fees, service providers, target prospective investments, or other business partners; and/or b. providing benefits to clients and/or other Parties that:

1. originate from the wealth of the Securities Portfolio or collective investment portfolio of the Investment Product managed by them;
2. harm the Investment Product;
3. contain conflicts of interest with their obligations to the Investment Product;
4. encourage clients to conduct excessive transactions;
5. encourage clients to ignore their investment profiles and objectives;
6. obscure information and/or material facts regarding risks and information openness of the Investment Product offered to clients; and/or
7. aim to promise specific income yield returns and/or equivalent benefits to be obtained by clients.
   (2) The Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and/or employees of the Investment Manager are required to refuse to engage in any business relationship with clients that can affect independence, objectivity, or loyalty to clients.

Article 13
The provision of benefits to clients and/or other Parties by the Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager that does not contradict the provisions as referred to in Article 12 paragraph (1) letter b must be based on rational considerations.

Article 14
The Investment Manager is required to create, document, and maintain documents and/or records related to benefits provided by the Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager.

Article 15
The Compliance Function of the Investment Manager coordinates the creation, documentation, and maintenance of documents and/or records as referred to in Article 14.

Article 16
(1) The Investment Manager is required to formulate and apply written policies and procedures regarding the provision of benefits by the Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager to clients and/or other Parties. (2) The written policies and procedures as referred to in paragraph (1) must contain at least:
a. monetary value limits that can be provided by the Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager; b. prohibitions on receiving benefits and providing benefits as referred to in Article 12 paragraph (1);
c. reporting provisions for the provision of benefits by members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager to the Investment Manager; and
d. provisions for the creation, documentation, and maintenance of documents and/or records related to benefits provided by the Investment Manager, members of the board of commissioners, members of the board of directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager.

Section Three
Rebates and Non-Cash Commissions

Article 17
(1) The Investment Manager is prohibited from receiving Rebates except for the benefit of the Investment Product.
(2) Rebates for the benefit of the Investment Product as referred to in paragraph (1) must be conveyed directly to the respective Investment Product's account proportionally.

Article 18
(1) The Investment Manager is prohibited from receiving Non-Cash Commissions except for the benefit of the Investment Product.
(2) Non-Cash Commissions for the benefit of the Investment Product as referred to in paragraph (1) must directly benefit the Investment Manager in the investment decision-making process for the benefit of the Investment Product and must not cause conflicts of interest with the Investment Product and/or harm the interests of the Investment Product.

Article 19
The Investment Manager is required to create, document, and maintain documents and/or records of every receipt of Rebates and/or Non-Cash Commissions.

Article 20
The Compliance Function of the Investment Manager coordinates:
a. the creation, documentation, and maintenance of documents and/or records as referred to in Article 19; and b. verification of every Rebate and/or Non-Cash Commission received in accordance with the provisions as referred to in Article 17 and Article 18.

Article 21
The Investment Manager is required to formulate and apply written policies and procedures regarding the receipt of Rebates and/or Non-Cash Commissions originating from transactions or orders for the benefit of the Investment Product.

Section Four
Implementation of Anti-Bribery Management Systems

Article 22
The Investment Manager is required to consider principles in the anti-bribery management system that are generally applicable in the formulation and implementation of written policies and procedures regarding:
a. prohibition of receiving benefits; b. provision of benefits; and
c. receipt of Rebates and/or Non-Cash Commissions.

CHAPTER III
INVESTMENT PRODUCT MANAGEMENT

Section One
Rational Reasons and Mandate-Compliant Investment in Investment Product Management

Article 23
(1) The Investment Manager is required to create and implement every investment policy, provide investment recommendations, and make investment decisions based on rational reasons, supported by adequate working papers, and meeting the interests of the Investment Product. (2) Investment Manager decisions are considered based on rational reasons as referred to in paragraph (1) with criteria using:
a. investment methods or combinations of various investment methods contained in books or various articles published regarding Securities analysis and portfolio management; b. methods created by the Investment Manager that are documented; or
c. investment methods or combinations of various investment methods commonly used by the Investment Manager profession or taught in official courses regarding Securities analysis and portfolio management,
with reasonable calculation assumptions.
(3) Adequate working papers as referred to in paragraph (1) must contain at least:
a. analysis and consideration of fundamental aspects of Securities and the issuer of Securities; b. analysis and consideration of technical aspects of Securities, if there is analysis and consideration of technical aspects of Securities;
c. analysis and consideration of risk exposure aspects of Securities transactions against the performance of the Securities Portfolio; and
d. analysis and consideration of cost-to-efficiency ratios in the management of the Securities Portfolio.
(4) Investment Manager decisions or implementation of investments are considered to meet the interests of the Investment Product if they meet at least the following criteria:
a. the Investment Manager has managed the Investment Product's investments by applying the Investment Manager Code of Conduct principles as referred to in this Financial Services Authority Regulation; b. the Investment Manager has inquired of the client regarding their general financial situation and made records of such matters that must be signed by the client concerned, except for Investment Products in the form of collective investment contracts; and
c. investment decisions or their implementation are in accordance with written investment policies that have been understood and approved by the client, and such policies have fully disclosed the nature, methods, and risks of investment.

Article 24
The implementation of investment policies, investment recommendations, and investment decision-making as referred to in Article 23 paragraph (1) must be conducted independently without interference from the interests of other Parties.

Article 25
The Investment Manager is required to ensure:
a. investment policies, investment recommendations, and/or transactions for the benefit of the Investment Product are conducted in accordance with the objectives, limits, and investment guidelines contained in the investment management contract and statutory regulations in the capital market sector related to investment management; and b. the implementation of investment policies, provision of investment recommendations, and/or transactions for investment for the benefit of the Investment Product are documented in writing for every investment portfolio managed by it.

Article 26
An Investment Manager that manages Securities Portfolios for the benefit of clients individually is prohibited from:
a. providing recommendations to clients in the form of:

1. investment management services; and/or
2. consultation services for the purchase, sale, or exchange of Securities,

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without considering the investment objectives, financial conditions, and needs of customers, as well as other customer information known to the Investment Manager; b. executing sell and/or buy orders for securities for customer accounts based on instructions from third parties who have not been previously granted written authority by the customer; and
c. purchasing and/or selling securities for the benefit of customers that do not align with:

1. investment policies as regulated in relevant capital market legislation regarding investment management; and/or
2. investment policies contained in the investment management agreement, unless prior written consent has been obtained from the customer.

Article 27
(1) In implementing investment policies, Investment Managers are required to create, document, and maintain records and/or worksheets related to the reasons for every investment decision to purchase or sell securities for the benefit of Investment Products. (2) Investment Managers are required to have an internal control system so that every investment decision to purchase or sell securities for the benefit of Investment Products as referred to in paragraph (1) complies with applicable legislation.

Second Section
Investment Research

Article 28
(1) Investment Managers are required to formulate and implement written policies and procedures regarding research so that the results of research conducted by the Investment Manager's analysts are independent to support the company's investment decision-making, provide every information, advice, and recommendation to customers and/or disseminate it to the public. (2) The written policies and procedures as referred to in paragraph (1) must at least cover:
a. the reporting flow of the Investment Manager's analysts; and b. the basis for calculating compensation for such analysts, which can eliminate or significantly limit the occurrence of conflicts of interest.

Third Section
Order Allocation and Securities Transactions

Article 29
(1) Investment Managers are required to create, document, and maintain records and/or worksheets related to the plan for the allocation of purchases and/or sales of securities for the benefit of each Investment Product based on the principle of fair and equitable allocation. (2) In the event that an Investment Manager executes securities transactions for the benefit of more than one (1) Investment Product simultaneously, the allocation plan as referred to in paragraph (1) is prohibited from harming specific Investment Products. (3) The plan for the allocation of purchases and/or sales of securities for the benefit of each Investment Product as referred to in paragraph (1) must be submitted through an integrated investment management system before the securities transaction is executed by uploading data and information regarding the plan for the allocation of purchases and/or sales of securities for the benefit of each Investment Product, which can prove the time of submission. (4) Investment Managers are required to ensure that executed securities transactions are allocated promptly in accordance with the plan for the allocation of purchases and/or sales of securities as referred to in paragraph (1), unless there are adjustments and/or revisions to the allocation plan. (5) Adjustments and/or revisions to the allocation plan as referred to in paragraph (4) must:
a. not harm specific Investment Products and/or benefit other Investment Products; b. be carried out in the best interest of Investment Products based on the principle of fair and equitable allocation; and
c. document the reasons for the adjustments and/or revisions.
(6) Investment Managers are required to create, document, and maintain documents and/or records of securities allocation resulting from securities transactions for each Investment Product, along with the reasons, so that the allocation complies with the principle of fair and equitable allocation and does not harm specific Investment Products.

Article 30
(1) In executing securities transactions for the benefit of Investment Products, Investment Managers are required to use securities account names in the name of the Investment Product. (2) The obligation to use securities account names in the name of the Investment Product as referred to in paragraph (1) is exempted for securities transactions for the benefit of mutual funds in the form of collective investment contracts whose participation units are traded on the stock exchange. (3) In the event that an Investment Manager executes securities transactions for the benefit of more than one (1) Investment Product simultaneously, the Investment Manager is required to allocate successfully transacted securities pro-rata using the average price. (4) In the event that the allocation of securities as referred to in paragraph (3) cannot be done pro-rata and using the average price, the Investment Manager is required to make decisions regarding the allocation of such securities based on rational reasons. (5) Investment Managers are required to create, document, and maintain records and/or worksheets related to the reasons as referred to in paragraph (4).

Article 31
Investment Managers executing securities transactions for the benefit of Investment Products are prohibited from:
a. directing such securities transactions for the benefit of:

1. the Investment Manager;
2. Parties affiliated with the Investment Manager; or
3. other Investment Products;
   b. engaging in securities transactions with the facility of securities company financing that results in debt between collective investment contract Investment Products, the Investment Manager, and the securities company;
   c. conducting transactions and/or engaging in trading of illegal securities; and
   d. engaging in securities transactions that result in violations of applicable legislation.

Article 32
Investment Managers are prohibited from using investment management fees or fees for specific transactions received from Investment Products as considerations in determining the allocation of purchases and/or sales of securities for each Investment Product.

Article 33
(1) Investment Managers are required to consider investment policies, investment strategies, investment objectives of Investment Products, and calculate the cost-to-efficiency ratio of Portfolio management when executing securities transactions for the benefit of Investment Products. (2) Investment Managers are prohibited from causing excessive trading that results in losses to Investment Products.

Article 34
(1) Investment Managers managing mutual funds are prohibited from conducting negotiation transactions for the benefit of mutual funds on stocks traded on the securities exchange.
(2) The provisions as referred to in paragraph (1) do not apply if:
a. it is conducted at most 10% (ten percent) of the net asset value of the mutual fund on every stock exchange day; b. every transaction conducted is supported by rational reasons and adequate worksheets;
c. the conducted transactions refer to best execution standards based on volume-weighted average price analysis, are not excessive, and do not result in losses to the mutual fund; and
d. the transactions in question are cross-transactions, executed in accordance with applicable legislation.

Article 35
Investment Managers are required to formulate and implement written policies and procedures regarding:
a. the allocation of purchases and/or sales of securities for the benefit of each Investment Product to ensure that such allocation is carried out fairly and equitably; and b. the prevention of violations of applicable legislation, including but not limited to insider trading, market manipulation, insider information, and ensuring that every member of the Board of Commissioners, members of the Board of Directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager implement them.

Fourth Section
Execution of Securities Transactions

Article 36
Investment Managers are required to execute securities transactions for the benefit of Investment Products under the best available conditions at the time the transaction is conducted.

Article 37
(1) Investment Managers are required to conduct due diligence before appointing Securities Brokers used in executing securities transactions for the benefit of Investment Products.
(2) Investment Managers are required to conduct periodic reviews at least once a year against Securities Brokers appointed to execute securities transactions for the benefit of Investment Products. (3) Investment Managers are prohibited from executing securities transactions through one (1) Securities Broker exceeding 30% (thirty percent) of the total transaction value during one (1) year. (4) The prohibition as referred to in paragraph (3) does not apply if the Investment Manager conducts:
a. securities purchase transactions in Public Offerings; b. transactions on securities that are the underlying assets for the formation of mutual funds whose participation units are traded on the stock exchange and index funds, for Investment Managers managing mutual funds whose participation units are traded on the stock exchange and index funds;
c. transactions on securities offered not through Public Offerings;
d. transactions on foreign securities; e. transactions on pre-emptive rights; and/or f. other transactions on securities that must be conducted through specific Securities Brokers as determined in applicable capital market legislation or determined by the Parties conducting the purchase and/or sale of such securities.

Fifth Section
Purchase of Securities in Public Offerings and Shareholder Voting Policies

Article 38
Investment Managers purchasing securities in Public Offerings for the benefit of Investment Products are required to:
a. allocate the distribution of purchased securities to Investment Products proportionally and fairly in accordance with investment policies; and b. create, document, and maintain documents and/or records of the basis for the allocation of securities purchases.

Article 39
(1) In general meetings of shareholders and/or general meetings of bondholders, Investment Managers for the benefit of Investment Products are required to exercise voting rights on shares and/or bonds owned by the Investment Product. (2) The exercise of voting rights as referred to in paragraph (1) must be based on accurate and responsible information and intended for the best interest of the Investment Product. (3) Investment Managers may delegate the voting rights on shares and/or bonds owned by the Investment Product to Custodian Banks, provided that it is only to cast abstention votes in general meetings of shareholders and/or general meetings of bondholders. (4) The exercise of voting rights as referred to in paragraph (1) is prohibited from:
a. being conducted for the benefit of the Investment Manager and/or other Parties other than for the best interest of the Investment Product; and/or b. being conducted with the purpose of controlling open companies through mutual funds, except for control through limited participation collective investment contracts. (5) Investment Managers are required to create, have, and implement policies and procedures for the exercise of voting rights on shares and/or bonds for the benefit of Investment Products. (6) The policies and procedures as referred to in paragraph (5) must contain at least:
a. guidelines for institutionalizing regular reviews, new issues, or controversial issues related to the exercise of voting rights on shares and/or bonds for the benefit of Investment Products in general meetings of shareholders and/or general meetings of bondholders; and b. review mechanisms and decisions taken for the benefit of Investment Products. (7) The exercise of voting rights as referred to in paragraph (1) must take into account provisions related to control as referred to in Financial Services Authority regulations regarding the conduct of activities in the capital market sector.

Sixth Section
Securities Transactions Through Parties Affiliated with the Investment Manager

Article 40
Investment Managers are prohibited from conducting securities transactions for the benefit of Investment Products through their Affiliated Parties, except:
a. such securities transactions are conducted based on the principle of fair and independent transactions; b. commissions or transaction fees charged by their Affiliated Parties are not higher than commissions or transaction fees charged by non-Affiliated Parties;
c. securities transactions are not conducted excessively; and
d. consistent with best execution standards.

Article 41
Investment Managers may place funds for the benefit of Investment Products with their Affiliated Parties, provided that the interest rate received is not lower than the interest rate received from non-Affiliated Parties for the same or equivalent value and duration.

Seventh Section
Cross Transactions

Article 42
Investment Managers are prohibited from conducting cross-transactions between Investment Product accounts, except with the following provisions:
a. buy or sell decisions for securities are based on the interest of both Investment Products; b. transactions are executed through Securities Brokers based on the principle of fair and independent transactions at prevailing market prices; and
c. the reasons for conducting cross-transactions are documented before the execution of the transaction.

Article 43
(1) Investment Managers are prohibited from conducting cross-transactions of securities between:
a. the Investment Manager's account and the Investment Product's account, except if such cross-transactions are conducted for the formation of portfolios of protected mutual funds; and b. the accounts of members of the Board of Commissioners, members of the Board of Directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager, and the Investment Product's account. (2) In the event that an Investment Manager conducts cross-transactions of securities between the Investment Manager's account and the Investment Product's account as referred to in paragraph (1) letter a, such securities transactions must be executed through Securities Brokers based on the principle of fair and independent transactions at prevailing market prices.

Eighth Section
Securities Transactions for the Benefit of the Investment Manager

Article 44
Investment Managers conducting securities transactions that are the same and at the same time, for their own benefit and for the benefit of Investment Products, are required to:
a. separate the securities transaction orders; and b. prioritize securities transactions for the benefit of Investment Products.

Article 45
In conducting securities transactions for their own benefit, Investment Managers are required to:
a. use securities account names in the name of the Investment Manager separate from securities accounts for the benefit of Investment Products; b. appoint a Custodian Bank to conduct administration and storage of securities for the benefit of the Investment Manager's own transactions; and
c. use asset transaction facilities available in the integrated investment management system.

Article 46
(1) Investment Managers are required to create, document, and maintain documents and/or records related to securities transactions that are the same and at the same time for their own benefit and for the benefit of Investment Products. (2) Investment Managers are required to formulate and implement written policies and procedures related to securities transactions for their own benefit.

Ninth Section
Risk Management

Article 47
(1) Investment Managers are required to apply Risk Management effectively.
(2) Investment Managers are required to establish, apply, and maintain effective Risk Management policies and strategies adjusted to the size and complexity of the business and the capabilities of the Investment Manager. (3) The application of effective Risk Management as referred to in paragraph (1) covers at least:
a. active supervision by the Board of Directors and Board of Commissioners of the Investment Manager; b. adequacy of Risk Management policies, standards, and procedures;
c. adequacy of processes for risk identification, measurement, monitoring, and control; and
d. Risk Management internal control systems.
(4) The application of effective Risk Management as referred to in paragraph (3) must at least cover:
a. risks related to investment products, including:

1. market risk;
2. credit risk;
3. liquidity risk;
4. Portfolio concentration risk; and
5. other risks in investment management for the benefit of Investment Products;
   b. risks related to the Investment Manager, including:
6. operational risk, including:
   a) information technology risk; b) employee supervision risk; c) partnership risk; d) risk of outsourcing of Investment Manager functions, if there is a risk of outsourcing of Investment Manager functions; and e) other risks in the operation of the Investment Manager;
7. compliance risk;
8. reputation risk;
9. legal risk;
10. strategic risk; and
11. investment risk, if the Investment Manager conducts investments for its own benefit.
    (5) Risk Management strategies as referred to in paragraph (2) must contain at least:
    a. identification, measurement, monitoring, and control of all risks that may arise in the business activities of the Investment Manager; b. explanation of the causes of the emergence of risks;
    c. identification of the possibility of risk occurrence;
    d. explanation of the implications of risk occurrence; e. establishment of risk limits; f. steps that must be taken if risks occur; and g. risk monitoring and management.
    (6) Investment Managers are required to conduct periodic reviews and periodic assessments of Risk Management policies and strategies to ensure continuous compliance with applicable legislation. (7) Investment Managers are required to create, document, and maintain documents and/or records related to Risk Management strategies, including periodic assessments and changes made.

Tenth Section
Information Technology Risk Management

Article 48
(1) Investment Managers are required to establish, apply, and maintain effective Risk Management policies in the use of information technology used for the implementation of electronic transaction systems for Investment Products and/or supporting the business operations of the Investment Manager. (2) The application of effective Risk Management in the use of information technology as referred to in paragraph (1) covers at least:
a. active supervision by the Board of Directors and Board of Commissioners of the Investment Manager; b. adequacy of policies, standards, and procedures for the use of information technology;
c. adequacy of processes for the identification, measurement, monitoring, and control of risks in the use of information technology; and
d. internal control systems for the use of information technology.

Article 49
(1) Investment Managers that have electronic systems for Investment Product transactions and/or electronic systems supporting business operations are required to implement policies, standards, and procedures for the use of information technology. (2) The policies, standards, and procedures for the use of information technology as referred to in paragraph (1) must at least cover aspects:
a. management; b. development and procurement;
c. information technology operations;
d. communication networks that meet the principles of confidentiality, integrity, and availability; e. information security; f. disaster recovery plans; and g. use of third-party information technology service providers.

Article 50
(1) Investment Managers are required to ensure that the control and security of information, Investment Product data, and operational data of the Investment Manager's business activities are conducted effectively and take into account at least:
a. information security aimed at ensuring that managed information and data maintain confidentiality, integrity, and availability effectively and efficiently, taking into account compliance with applicable legislation; b. information security conducted on aspects of technology, human resources, and processes in the use of information technology;
c. information security applied based on the results of assessments of risks to information owned by the Investment Manager; and
d. the availability of cyber risk management and/or information security risk management.
(2) The principles of data and information security control as referred to in paragraph (1) cover at least:
a. confidentiality; b. integrity;
c. availability;
d. authenticity; e. non-repudiation; f. authorization control in systems, databases, and applications; g. separation of duties and responsibilities; and h. audit trail maintenance.
(3) In the event that an Investment Manager operates an electronic transaction system for Investment Products, then:
a. the implementation of the authenticity principle must at least establish two authentication factors; and b. the implementation of the non-repudiation principle must at least apply data transmission security and end-to-end encryption.

Article 51
Investment Managers that have electronic systems for Investment Product transactions and/or electronic systems supporting business operations are required to:
a. ensure the continuity and stability of information technology operations used for the implementation of electronic transaction systems for Investment Products and/or supporting the business operations of the Investment Manager; and b. mitigate risks that have the potential to disrupt the implementation of electronic transaction systems for Investment Products and/or support the business operations of the Investment Manager.

Article 52
(1) Investment Managers are required to place electronic systems in data centers and disaster recovery centers within the territory of Indonesia.
(2) Investment Managers are prohibited from placing electronic systems in data centers and disaster recovery centers outside the territory of Indonesia unless they have obtained approval from the Financial Services Authority. (3) Electronic systems that can be placed in data centers and disaster recovery centers outside the territory of Indonesia with approval from the Financial Services Authority as referred to in paragraph (2) are:
a. electronic systems used to support integrated analysis for compliance with applicable legislation that includes principles that are global, adopted in cross-border regulations, provided that they are not directly related to individual customer data and transaction data of each customer;

b. electronic systems used for Risk Management integrated with regional offices or head offices outside the Indonesian territory, provided that aggregated Investment Product data is used; and

c. electronic systems used with regional offices or head offices outside the Indonesian territory for communication management and/or internal management not related to Investment Product transaction electronic systems and/or systems supporting the operational activities of the Investment Manager's business.

(4) The approval of the Financial Services Authority as referred to in paragraph (2) is granted if the Investment Manager:

a. has a written agreement with the electronic system provider as referred to in paragraph (3), which contains at least:

1. obligations and rights of the Parties;
2. choice of law clauses in the event of a dispute; and
3. data and information confidentiality;

b. ensures that the use of electronic systems as referred to in paragraph (3) does not reduce the effectiveness of the Financial Services Authority's supervision, evidenced by a statement letter;

c. ensures that the Risk Management of the implementation of electronic systems as referred to in paragraph (3) meets at least the provisions of this Financial Services Authority Regulation; and

d. ensures that the benefits obtained by the Investment Manager from the use of electronic systems as referred to in paragraph (3) are greater than the costs to be incurred.

(5) The procedures for the approval of the Financial Services Authority as referred to in paragraph (2) are established by the Financial Services Authority.

Article 53

(1) Investment Managers that have electronic systems for Investment Product transactions must conduct regular audits of the aforementioned electronic systems at least once every 3 (three) years.

(2) Regular audits as referred to in paragraph (1) must use the services of independent external parties.

(3) Investment Managers must follow up on the results of regular audits as referred to in paragraph (2).

Eleventh Part
Liquidity Risk Management in the Management of Open-Ended Investment Products

Article 54

(1) Investment Managers managing open-ended Investment Products must establish, implement, and maintain appropriate and effective Liquidity Risk Management policies and procedures for:

a. monitoring the liquidity risk of Investment Products; b. mitigating the risk of asset liquidity mismatch in the Investment Product portfolio with the needs for fulfilling Investment Product repurchases; and
c. ensuring fair and equitable treatment for all customers.

(2) The Liquidity Risk Management policies and procedures as referred to in paragraph (1) must consider at least:

a. the type of Investment Product; b. investment policies and strategies;
c. the liquidity profile of assets in the Investment Product portfolio;
d. the distribution channel profile; e. the target market and/or customer profile; and f. the Investment Product's repurchase policies.

(3) The implementation of appropriate and effective Liquidity Risk Management as referred to in paragraph (1) is carried out at least by:

a. having board members and functions that are independent and separate from investment function activities to conduct continuous supervision and monitoring of the implementation of Liquidity Risk Management; b. implementing Liquidity Risk Management policies and procedures from the initial formation of the Investment Product until throughout the Investment Product's life cycle;
c. establishing risk mitigation steps to anticipate or identify asset limitations in meeting the Investment Product's liquidity needs;
d. conducting monthly assessments of the liquidity profile of assets in the managed Investment Product portfolio for the benefit of the Investment Product; e. conducting monthly assessments of the liquidity profile of the Investment Product's liabilities; f. conducting monthly assessments of the liquidity profile of assets or the level of the Investment Product's liabilities in responding to various market situation scenarios, including stress testing; and

g. disclosing liquidity risks in the Investment Product portfolio, the applied Liquidity Risk Management policies and procedures, and their explanations in the Investment Product's information disclosure documents.

(4) Investment Managers must report the results of monthly assessments as referred to in paragraph (3) letters d, e, and f to the Financial Services Authority through the electronic reporting system provided by the Financial Services Authority no later than on the 10th (tenth) day after the end of the relevant month.

Article 55

(1) Monthly assessments as referred to in Article 54 paragraph (3) letters d, e, and f must:

a. be conducted for each open-ended Investment Product; and b. be based on reliable and up-to-date information.

(2) Liquidity stress testing as referred to in Article 54 paragraph (3) letter f must be adjusted by considering:

a. the size of the Investment Product; b. the Investment Product's investment strategies and policies;
c. the characteristics of underlying assets;
d. the investor profile; and e. other relevant factors.

(3) Liquidity stress testing scenarios as referred to in Article 54 paragraph (3) letter f are conducted with considerations of at least:

a. historical conditions of assets and markets; b. future hypothesis scenarios and projections;
c. scenarios of worsening asset liquidity conditions;
d. a number of different scenarios that can cover pressure levels from the Investment Product; and e. a combination of factors that can increase liquidity pressure.

Article 56

Investment Managers must consider Liquidity Risk Management in every investment decision-making process for the benefit of the Investment Product.

Article 57

(1) The implementation of Liquidity Risk Management must be adjusted to the characteristics of each Investment Product, consisting of:

a. nature; b. liquidity profile; and
c. asset and liability management.

(2) The implementation of Liquidity Risk Management by Investment Managers must:

a. be based on rational and justifiable considerations; b. consider the principle of prudence; and
c. consider good governance.

(3) In the implementation of Liquidity Risk Management, Investment Managers must prepare, implement, and periodically test contingency plans with the purpose:

a. to ensure that every mechanism in maintaining liquidity management can be used when needed; and b. to be implemented quickly, orderly, and in accordance with statutory regulations.

(4) The implementation of contingency plans as referred to in paragraph (3) must consider:

a. operational capacity to implement and activate the Liquidity Risk Management mechanisms transparently, fairly, and orderly for the best interests of investors; b. operational capacity to implement and activate the Liquidity Risk Management mechanisms in a short time temporarily based on orders from the Financial Services Authority;
c. the legal basis and implementation of every Liquidity Risk Management mechanism have been disclosed in the Investment Product's information disclosure documents;
d. the existence of internal procedures regarding when policies will be taken, condition escalation, decision-making mechanisms, responsibilities, and execution regarding the implementation and activation of Liquidity Risk Management mechanisms, accompanied by conditions and considerations before decision-making is made; e. the existence of working papers, documentation of every decision made in the implementation and activation of Liquidity Risk Management mechanisms; f. the periodic updating of Liquidity Risk Management mechanisms by considering the investment product characteristics as referred to in paragraph (1); and g. mechanisms for conveying information to Investment Product investors and/or the Financial Services Authority in a short timeframe regarding the implementation and activation of Liquidity Risk Management mechanisms, accompanied by conditions and considerations before decision-making is made.

(5) Testing as referred to in paragraph (3) includes testing of operational capacity with reasonable grounds to ensure that available liquidity management mechanisms can be used, including in pressured market conditions, thereby enabling orderly and continuous management of Investment Products and maintaining investor confidence.

(6) Further provisions regarding the implementation of Liquidity Risk Management, Liquidity Risk Management mechanisms, and the reporting of Liquidity Risk Management implementation conducted by Investment Managers are established by the Financial Services Authority.

CHAPTER IV
INTERACTION WITH CUSTOMERS

First Part
Provision of Company Information

Article 58

(1) Investment Managers must:

a. provide sufficient information regarding the identity of the Investment Manager, business license, scope of the Investment Manager's business activities, as well as the identity and position of Parties acting on behalf of the Investment Manager when the Investment Manager offers services or Investment Products; and b. convey material facts regarding the Investment Manager, services, and/or Investment Products offered, to customers or prospective customers.

(2) Investment Managers are prohibited from providing untrue impressions to customers or prospective customers regarding the qualifications of the Investment Manager, services, and/or Investment Products offered.

Second Part
Single Investor Identity Number

Article 59

(1) Investment Managers must create a single investor identity number for each of their customers at the depository and settlement institution.

(2) In the event that an Investment Manager delegates the authority to create a single investor identity number to a mutual fund sales agent, the Investment Manager must ensure that every customer has a single investor identity number.

Third Part
Confidentiality

Article 60

(1) Investment Managers are prohibited from disclosing customer data, information, and activities to unauthorized Parties, except with written consent from the customer or as required by statutory regulations.

(2) Investment Managers must prepare and implement written policies and procedures to maintain the confidentiality of customer data and information.

Fourth Part
Investment Portfolio Valuation of Investment Products

Article 61

Investment Managers must calculate the fair market value of Investment Product Securities in accordance with statutory regulations in the capital market sector.

Fifth Part
Commissions and Fees

Article 62

Investment Managers must establish fair and rational commissions and fees for services provided to Investment Products.

Sixth Part
Customer Complaints

Article 63

(1) Investment Managers are responsible and must take active steps in resolving customer complaints.

(2) Investment Managers must create, document, and maintain documents and/or records of all:

a. customer complaints received; b. steps taken; and
c. resolution status for each customer complaint.

Article 64

(1) Investment Managers must prepare and implement written policies and procedures to ensure that every customer complaint is handled properly and promptly.

(2) In handling customer complaints, Investment Managers must consider the implementation of provisions regarding guidelines for the implementation of Investment Manager functions and consumer complaint service provisions in the financial services sector.

Seventh Part
Business Activities

Article 65

Investment Managers and their Affiliated companies are prohibited from:

a. raising funds with products and/or mechanisms that do not comply with statutory regulations; and b. engaging in sales activities of fund-raising products that do not comply with statutory regulations.

Article 66

(1) Investment Managers intending to conduct other business activities must obtain approval from the Financial Services Authority.

(2) Other business activities as referred to in paragraph (1) must be related to the main business activities of the Investment Manager in conducting investment management.

(3) In the event that an Investment Manager conducts other business activities as referred to in paragraph (2), the Investment Manager must ensure that the aforementioned other activities and their implementation:

a. do not conflict with statutory regulations; and b. are based on adequate Risk Management to mitigate arising risks.

(4) Further provisions regarding the approval of other business activities conducted by Investment Managers are established by the Financial Services Authority.

CHAPTER V
MARKETING ACTIVITIES, ADVERTISING, AND PROMOTIONAL MATERIALS

Article 67

Investment Managers are prohibited from:

a. promising specific results that customers will obtain from Investment Products managed by the Investment Manager; or b. promising specific results that customers will obtain from advice given.

Article 68

(1) Investment Managers must provide true, non-misleading, and non-contradictory information to customers in accordance with statutory regulations, including when the Investment Manager provides marketing materials, advertisements, and/or promotions in verbal form, electronic form, or non-electronic form.

(2) Information to customers, including marketing materials, advertisements, and/or promotions as referred to in paragraph (1), is prohibited from containing:

a. untrue information; b. words or sentences that give the impression that customers will not suffer losses or will definitely profit;
c. words or sentences that give the impression that customers are promised a certain level of profit, certain returns, or will not suffer losses;
d. impressions that customers can obtain profits without any risk; and/or e. information that defames:

1. services or products offered by other Investment Managers;
2. other Investment Managers; and/or
3. the investment management industry in the capital market sector as a whole.

(3) Marketing materials, advertisements, and/or promotions as referred to in paragraph (1) must contain information regarding investment risks.

(4) Marketing materials, advertisements, and/or promotions for mutual funds must be implemented in accordance with statutory regulations in the capital market sector governing mutual fund advertising guidelines.

(5) In the event that Investment Product marketing is conducted through cooperation with other Parties, the Investment Manager must ensure compliance with the provisions as referred to in paragraphs (1) through (4).

Article 69

(1) In the event that information, including marketing materials, advertisements, and/or promotions, contains statements about the Investment Manager's investment management performance, the Investment Manager must make statements regarding the Investment Manager's investment management performance that are factual, accurate, clear, and non-misleading.

(2) Investment Managers are responsible for statements regarding the Investment Manager's investment management performance as referred to in paragraph (1).

Article 70

(1) Investment Managers must create summary information of Investment Products every month based on information at the end of the previous business day of the month, with the following conditions:

a. it is made based on factual information and reflects the actual conditions of the Investment Product; b. it contains at least:

1. name of the Investment Product;
2. date of data collection for the Investment Product;
3. type of Investment Product;
4. statement of effectiveness or recording letter of the Investment Product;
5. name and profile of the Investment Manager;
6. name and profile of the Custodian Bank;
7. investment objectives and policies;
8. currency;
9. unit price;
10. total net asset value;
11. fees;
12. main risks;
13. risk classification;
14. 10 (ten) Securities with the largest value in the Investment Product portfolio, along with their percentages compared to the total net asset value of the aforementioned Investment Product;
15. Investment Product performance;
16. disclaimer statement; and
17. information related to the Investment Product.
    c. it is made in the format of the Investment Product summary information guidelines as contained in the Appendix which is an inseparable part of this Financial Services Authority Regulation.

(2) Summary information as referred to in paragraph (1) must be available to all customers.

Article 71

In Investment Product marketing activities, Investment Managers must:

a. be responsible for all actions related to the sale of Investment Products conducted by employees and/or other Parties working for the Investment Manager; b. conduct continuous supervision over all employees and/or other Parties working for the Investment Manager;
c. ensure that marketing personnel conducting Investment Product marketing activities do not hold concurrent positions at other companies;
d. ensure that marketing personnel conducting Investment Product marketing activities for the Investment Manager do not conduct marketing reference activities for Investment Products for other Investment Managers and/or other Securities companies other than their place of work; e. have a supervision system over the activities of Securities company representatives, mutual fund sales agent representatives, and all their employees to guarantee compliance with all capital market statutory regulations; f. provide and convey to prospective customers summary information about the marketed Investment Products based on information originating from the prospectus or disclosure documents and having obtained approval from the Investment Manager;

g. ensure that customers are given the opportunity to read the prospectus or disclosure documents of the Investment Product, summary information of the Investment Product, or other important information before or at the time of purchasing the Investment Product; and

h. create a statement document in electronic or non-electronic form that must be approved by prospective customers of the Investment Product before purchasing the Investment Product, containing the clause:

"That my Investment Product transaction is conducted based on information in the prospectus or disclosure documents and summary information of the Investment Product provided by the Investment Manager (PT...) and/or the Mutual Fund Sales Agent (PT...). There are no other Investment Product offering documents in other forms that do not comply with statutory regulations offered and/or promised by the Investment Manager (PT...) and/or the Mutual Fund Sales Agent (PT...) to me. I understand that the prospectus or disclosure documents and summary information of the Investment Product are the official offering documents of the Investment Product (Investment Product name...) managed by the Investment Manager (PT...)".

Article 72

Investment Managers must ensure the fulfillment of customers' rights to obtain information regarding the annual financial reports of Investment Products, which are available through the issuance of prospectus updates or disclosure documents at the end of the third month after the end of the Investment Product's annual financial report period.

CHAPTER VI
PROTECTION OF CUSTOMER ASSETS

Article 73

(1) Investment Managers must store funds and/or Investment Product Securities in the name of each Investment Product at the Custodian.

(2) Investment Managers must ensure that the Custodian administers and stores funds and/or Investment Product Securities in the name of each Investment Product.

Article 74

Investment Managers appointing a Custodian for the administration and storage of funds and/or Investment Product Securities must conduct due diligence on the Custodian's ability to perform its duties.

Article 75

Investment Managers must create, document, and maintain documents and/or records related to the investment management activities they conduct for at least 5 (five) years since the closing of the account, covering:

a. records related to customer accounts, including information regarding the single investor identity number; b. records of investment management conducted by the Investment Manager and disclosures by the Investment Manager as referred to in this Financial Services Authority Regulation; and
c. records of all Securities transactions, both for the benefit of the Investment Product and Securities transactions for the benefit of the Investment Manager, including audit trails of all Securities transactions conducted by the Investment Manager.

CHAPTER VII
OFFERING OF INVESTMENT PRODUCTS THROUGH PUBLIC OFFERINGS AND NOT THROUGH PUBLIC OFFERINGS

Article 76

(1) Investment Managers managing Investment Products offered through Public Offerings or not through Public Offerings must ensure that the implementation of offerings through Public Offerings or not through Public Offerings of Investment Products is carried out in accordance with statutory regulations.

(2) The implementation of offerings through Public Offerings as referred to in paragraph (1) must be evidenced by:

a. the existence of Public Offering documents to prospective unit holders; b. the offering of Investment Products through mass media, websites, and/or other electronic facilities;
c. the offering is accessible to the public and/or the purchase of Investment Product unit shares is conducted in accordance with the collective investment contract and prospectus; or
d. the availability of:

1. presentation documents; and
2. the conveyance of the prospectus or disclosure documents of the Investment Product,
   to prospective unit holders in the event they are conveyed to prospective unit holders.

(3) The implementation of offerings not through Public Offerings as referred to in paragraph (1) must be evidenced by the existence of offering documents to prospective unit holders on a limited basis.

(4) Implementation Documents for Offerings

Implementation documents for offerings through Public Offerings or offerings not through Public Offerings as referred to in paragraph (1), paragraph (2), and paragraph (3) must be stored and administered by the Investment Manager.

Article 77

(1) Investment Products offered through Public Offerings must be owned by at least 10 (ten) Parties during the period of the Public Offering of the said Investment Product.
(2) Investment Products offered through Public Offerings must be dissolved if the number of owners is less than 10 (ten) Parties for 120 (one hundred twenty) consecutive trading days. (3) The Investment Manager must ensure that the ownership of Investment Products by Parties as referred to in paragraph (1) occurs not due to specific commitments but occurs due to the Public Offering mechanism implemented in accordance with applicable legislation. (4) In the event that Investment Products offered through Public Offerings have unit holders with significant unit ownership compared to other unit holders, the Investment Manager must:
a. act with the principle of fairness and not discriminate in treatment among unit holders; b. uphold the integrity, professionalism, and independence of the Investment Manager in making investment decisions and not have specific commitments with unit holders who have significant unit ownership compared to other unit holders that result in market manipulation and violations of applicable legislation in the capital market sector;
c. implement written policies and procedures supporting every investment decision;
d. formulate and implement every investment policy, provide investment recommendations, and conduct transactions for the benefit of the Investment Product based on rational reasons; and e. act professionally and independently and not be directed by other Parties, including unit holders, that result in market manipulation and violations of applicable legislation in the capital market sector.

Article 78

(1) Investment Products not offered through Public Offerings may be owned by one or more Parties as unit holders.
(2) The Investment Manager must ensure that the ownership of Investment Products by Parties as referred to in paragraph (1) occurs not due to specific commitments but occurs due to the mechanism carried out in accordance with applicable legislation. (3) In the event that Investment Products not offered through Public Offerings are owned by one or have unit holders with significant unit ownership compared to other unit holders, the Investment Manager must:
a. act with the principle of fairness and not discriminate in treatment among unit holders; b. uphold the integrity, professionalism, and independence of the Investment Manager in making investment decisions and not have specific commitments with unit holders who have significant unit ownership compared to other unit holders that result in market manipulation and violations of applicable legislation in the capital market sector;
c. implement written policies and procedures supporting every investment decision;
d. formulate and implement every investment policy, provide investment recommendations, and conduct transactions for the benefit of the Investment Product based on rational reasons; and e. act professionally and independently and not be directed by other Parties, including unit holders, that result in market manipulation and violations of applicable legislation in the capital market sector.

CHAPTER VIII

ADMINISTRATIVE SANCTIONS

Article 79

(1) Any Party that violates the provisions as referred to in Article 2, Article 3 paragraph (1), Article 4, Article 5 paragraph (1), paragraph (3), paragraph (4), Article 7, Article 8, Article 9, Article 11, Article 12, Article 13, Article 14, Article 16, Article 17, Article 18, Article 19, Article 21, Article 22, Article 23 paragraph (1), Article 24, Article 25, Article 26, Article 27, Article 28 paragraph (1), Article 29, Article 30 paragraph (1), paragraph (3), paragraph (4), paragraph (5), Article 31, Article 32, Article 33, Article 34 paragraph (1), Article 35, Article 36, Article 37 paragraph (1), paragraph (2), paragraph (3), Article 38, Article 39 paragraph (1), paragraph (2), paragraph (4), paragraph (5), Article 40, Article 42, Article 43, Article 44, Article 45, Article 46, Article 47 paragraph (1), paragraph (2), paragraph (4), paragraph (6), paragraph (7), Article 48 paragraph (1), Article 49 paragraph (1), Article 50 paragraph (1), Article 51, Article 52 paragraph (1), paragraph (2), Article 53, Article 54 paragraph (1), paragraph (4), Article 55 paragraph (1), Article 56, Article 57 paragraph (2), paragraph (3), Article 58, Article 59, Article 60, Article 61, Article 62, Article 63, Article 64, Article 65, Article 66 paragraph (1), paragraph (2), paragraph (3), Article 67, Article 68, Article 69, Article 70, Article 71, Article 72, Article 73, Article 74, Article 75, Article 76, Article 77, Article 78 paragraph (2), paragraph (3) shall be subject to administrative sanctions. (2) Sanctions as referred to in paragraph (1) shall also be imposed on Parties who cause the violation as referred to in paragraph (1). (3) Sanctions as referred to in paragraph (1) and paragraph (2) shall be imposed by the Financial Services Authority. (4) Administrative sanctions as referred to in paragraph (1) consist of:
a. written warning; b. fines, namely the obligation to pay a certain amount of money;
c. restriction of business activities;
d. suspension of business activities; e. revocation of business license; f. cancellation of approval; and/or g. cancellation of registration.
(5) Administrative sanctions as referred to in paragraph (4) letter b, letter c, letter d, letter e, letter f, or letter g may be imposed with or without prior imposition of administrative sanctions in the form of written warnings as referred to in paragraph (4) letter a. (6) Administrative sanctions in the form of fines as referred to in paragraph (4) letter b may be imposed separately or together with the imposition of administrative sanctions as referred to in paragraph (4) letter c, letter d, letter e, letter f, or letter g. (7) The procedure for imposing sanctions as referred to in paragraph (3) shall be carried out in accordance with applicable legislation.

Article 80

In addition to administrative sanctions as referred to in Article 79 paragraph (4), the Financial Services Authority may take specific actions against any Party that commits and/or causes violations of the provisions of this Financial Services Authority Regulation.

Article 81

The Financial Services Authority may announce the imposition of administrative sanctions as referred to in Article 79 paragraph (4) and specific actions as referred to in Article 80 to the public.

CHAPTER IX

TRANSITIONAL PROVISIONS

Article 82

(1) The obligation to report valuation results as referred to in Article 54 paragraph (4) to the Financial Services Authority through the electronic reporting system provided by the Financial Services Authority shall take effect after 2 (two) years calculated from the date this Financial Services Authority Regulation is promulgated. (2) Provisions regarding the obligation to submit plans for the purchase and/or sale of Securities for the benefit of each Investment Product through the integrated investment management system as referred to in this Financial Services Authority Regulation shall fully take effect after 1 (one) year calculated from the date this Financial Services Authority Regulation is promulgated. (3) Since this Financial Services Authority Regulation takes effect until the full implementation date as referred to in paragraph (2):
a. the plan for the purchase and/or sale of Securities for the benefit of each Investment Product, along with adjustments and the timing of its creation, shall be administered by the Investment Manager; and b. the Investment Manager must provide a connected system and conduct trials for the submission of plans for the purchase and/or sale of Securities for the benefit of each Investment Product through the integrated investment management system within the timeframe determined by the provider of the integrated investment management system.

Article 83

(1) Investment Products offered through Public Offerings and which have obtained an effectiveness statement from the Financial Services Authority before the date of promulgation of this Financial Services Authority Regulation, which do not yet meet the provisions as referred to in Article 77 paragraph (1), are required to meet the said provisions at the latest 1 (one) year calculated from the date this Financial Services Authority Regulation is promulgated. (2) The provisions as referred to in paragraph (1) do not apply to Investment Products offered through Public Offerings in the form of protected mutual funds, protected sharia mutual funds, real estate investment funds, infrastructure investment funds, asset-backed securities collective investment contracts, asset-backed securities in the form of participation certificates, and limited participation mutual funds.

CHAPTER X

CLOSING PROVISIONS

Article 84

Upon the entry into force of this Financial Services Authority Regulation, Financial Services Authority Regulation Number 43/POJK.04/2015 concerning Guidelines for Investment Manager Conduct (State Gazette of the Republic of Indonesia Year 2015 Number 370, Supplement to the State Gazette of the Republic of Indonesia Number 5810) is revoked and declared invalid.

Article 85

This Financial Services Authority Regulation shall take effect on the date of promulgation.

This copy is in accordance with the original.
Director of Law 1
Legal Department signed
Mufli Asmawidjaja

To ensure everyone knows it, it is ordered to promulgate this Financial Services Authority Regulation by placing it in the State Gazette of the Republic of Indonesia.

Determined in Jakarta on September 1, 2022
CHAIRMAN OF THE COMMISSIONERS BOARD
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA, signed
MAHENDRA SIREGAR

Promulgated in Jakarta on September 5, 2022
MINISTER OF LAW AND HUMAN RIGHTS
REPUBLIC OF INDONESIA, signed
YASONNA H. LAOLY

STATE GAZETTE OF THE REPUBLIC OF INDONESIA YEAR 2022 NUMBER 20/OJK

EXPLANATION

OF
FINANCIAL SERVICES AUTHORITY REGULATION
OF THE REPUBLIC OF INDONESIA
NUMBER 17 /POJK.04/2022
CONCERNING
GUIDELINES FOR INVESTMENT MANAGER CONDUCT

I. GENERAL

Investment Managers are Parties whose business activities manage Securities Portfolios for clients or manage collective investment portfolios for a group of clients, except insurance companies, pension funds, and banks that conduct their own business activities in accordance with applicable legislation. In fulfilling their role, aspects of good behavior and ethics in managing Securities Portfolios for clients and managing Securities Portfolios for a group of clients must be upheld by Investment Managers. The application of good behavior and ethics by Investment Managers must continue to be improved and accommodate international best practices. Through the refinement of regulations regarding Investment Manager behavior, it is expected that the interests of clients and groups of clients are protected and able to create a fair and orderly capital market industry. A number of refinements in the regulation of Investment Manager behavior include, among others, Investment Manager principles, the role of associations that accommodate Investment Managers, disclosure of conflicts of interest, order allocation, best execution, Rebates, Non-Cash Commissions, provision of benefits, marketing activities, advertisements, and promotional materials, as well as the addition of provisions related to Risk Management for Investment Managers in conducting Securities Portfolio management for clients and collective Securities Portfolio management for groups of clients.

II. ARTICLE BY ARTICLE

Article 1

Sufficiently clear.

Article 2

Letter a
What is meant by "applying the principle of independence" is conducting business activities based on rational and objective considerations in making investment decisions in accordance with the investment management competence possessed, among others, evidenced by not being directed by other Parties but basing decisions on rational considerations, not being influenced by promises, and remuneration from other Parties in making investment decisions.

Letter b
What is meant by "applying the principle of 'integrity'" is conducting business activities with good faith and full responsibility, upholding honesty, and committing to comply with written agreements and applicable legislation.

Letter c
What is meant by "applying the principle of professionalism" is conducting business activities professionally. An example of an Investment Manager applying the principle of professionalism is when they meet the provisions of Article 27 of Law Number 8 of 1995 concerning the Capital Market, which states that Investment Managers must, in good faith and with full responsibility, perform their duties as best as possible solely for the benefit of mutual funds.

Letter d
What is meant by "applying the principle of prioritizing the interests of Investment Products" is always prioritizing the interests of their Investment Products and not endangering or ignoring the interests of Investment Products as long as the interests of Investment Products do not conflict with applicable legislation, among others by implementing applicable legislation in the capital market sector related to Investment Manager behavior. Examples of applicable legislation in the capital market sector related to Investment Manager behavior include:

1. the obligation of Investment Managers to perform their duties with good faith and full responsibility;
2. the prohibition for Securities Companies acting as Investment Managers and also Securities Brokers or Affiliated Parties of the Securities Company from acting as Securities Brokers charging commissions or fees higher than those charged by Securities Brokers that are not their Affiliates; and
3. the prohibition for Securities Companies acting as Investment Managers or their Affiliated Parties from receiving remuneration in any form, directly or indirectly, that can influence the respective Investment Manager to buy or sell Securities for the Investment Product.

Letter e
What is meant by "applying the principle of supervision and control" is organizing, supervising, and controlling activities effectively and responsibly through adequate supervision and control systems of activities at least as regulated in this Financial Services Authority Regulation and applicable legislation in the capital market sector related to supervision and control required for Investment Managers. Examples of applicable legislation in the capital market sector related to supervision and control required for Investment Managers include Financial Services Authority Regulation Number 24/POJK.04/2014 concerning Guidelines for the Implementation of Investment Manager Functions.

Letter f
What is meant by "applying the principle of sufficiency of resources" is having and maintaining adequate financial resources, human resources, and other resources in accordance with business activity activities at least as regulated in this Financial Services Authority Regulation and applicable legislation in the capital market sector. As an example, an Investment Manager has and maintains adequate financial resources if they have net working capital adjusted at least as required in regulations regarding the maintenance and reporting of adjusted net working capital.

Letter g
What is meant by "applying the principle of protection of Investment Product assets" is:

1. making and keeping good records of orders, transactions, and Investment Product investment activities;
2. storing Investment Product assets in separate accounts and places from the Investment Manager's own asset storage accounts and places and other Investment Products;
3. prohibited from using Investment Product assets for the benefit of any Party other than the benefit of the Investment Product; and
4. ensuring that the custodian of Investment Product assets, for example, Custodian Banks, stores mutual fund assets in the form of collective investment contracts managed by them securely and provides regular information on Investment Product investments, at least as regulated in applicable legislation in the capital market sector related thereto.

Letter h
What is meant by "applying the principle of information openness" is providing and/or conveying correct, non-misleading, and non-conflicting information to clients in accordance with applicable legislation.

Letter i
What is meant by "applying the principle of conflict of interest" is establishing and implementing written policies and procedures related to:

1. actions to avoid conflicts of interest between the interests of Investment Products and the interests of Investment Managers and Affiliated Parties of the Investment Manager's company as regulated in this Financial Services Authority Regulation and applicable legislation in the capital market sector; and
2. information openness if there is a conflict of interest between the Investment Manager and the interests of individual clients regarding a Security.
   Examples of conflicts of interest can occur in conditions:
3. Investment Managers, board members, employees, and Affiliated Parties of the Investment Manager own Securities and/or have interests in Security transactions, where at the same time the Investment Product:
   a. owns the same Securities as those owned by the Investment Manager, board members, employees, and Affiliated Parties of the Investment Manager; and/or b. conducts the same Security transactions as those owned by the Investment Manager, board members, employees, and Affiliated Parties of the Investment Manager.
4. Securities to be transacted or transacted by the Investment Product are Securities issued by the Investment Manager and Affiliated Parties of the Investment Manager.

Letter j
What is meant by "applying the principle of protection against money laundering and terrorism financing risks" is carrying out identification, verification, and applying adequate measures including in the form of written policies and procedures to control money laundering and terrorism financing risks at least in accordance with applicable legislation.

Letter k
What is meant by "applying the principle of compliance" is having and implementing written policies and procedures related to supervision of Investment Manager behavior and activities to support the creation of Investment Manager compliance with applicable legislation in the capital market sector as regulated in this Financial Services Authority Regulation and applicable legislation in the capital market sector as well as internal company regulations and/or standard operating procedures. Examples of applicable legislation related to the application of the "compliance" principle by Investment Managers include the provisions of Article 16 of Financial Services Authority Regulation Number 24/POJK.04/2014 concerning Guidelines for the Implementation of Investment Manager Functions.

Article 3

Sufficiently clear.

Article 4

Investment Manager interests in Securities arise in conditions including:
a. Investment Managers, directly or indirectly, alone or together with other Parties, own Securities or are entitled to dividends, interest, or proceeds from the sale and/or use of Securities; and b. Investment Managers have been bound by agreements or contracts to buy Securities, have the right to transfer or assign Securities, or have pre-emptive rights to order Securities.

Letter a
What is meant by "disclosure is done when entering into a written investment management agreement" is when signing written agreements for fund management for individual clients, either as an attachment to a separate disclosure statement or as one of the additional disclosure clauses in the agreement.

Letter b
Disclosure done before conducting Security transactions for client benefit is done in written form with digital or non-digital formats.

Letter c
Sufficiently clear.

Letter d
Sufficiently clear.

Article 5

Paragraph (1)
Sufficiently clear.

Paragraph (2)
Sufficiently clear.

Paragraph (3)
Sufficiently clear.

Paragraph (4)
Letter a
Profiting is also known as front running.

Letter b
Prohibited cross-transactions with the Investment Manager's Investment Product are Security transactions conducted on Securities Exchanges other than the regular market.

Letter c
Sufficiently clear.

Article 6

Sufficiently clear.

Article 7

Paragraph (1)
What is meant by "abstain" is not using voting rights and not taking a stance.

Paragraph (2)
Sufficiently clear.

Article 8

What is meant by "prioritizing the interests of Investment Products" is Investment Managers always prioritizing the interests of their Investment Products and not endangering or ignoring the interests of Investment Products as long as the interests of the said Investment Products do not conflict with applicable legislation. An example of behavior prioritizing the interests of Investment Products above the interests of Investment Managers is if investors from an Investment Product direct the Investment Manager to invest in an investment portfolio that violates applicable legislation, then the Investment Manager is required to reject the order and uphold compliance with applicable legislation even though this has the potential for the investor's investment in the said Investment Product to be withdrawn.

Article 9

Sufficiently clear.

Article 10

Sufficiently clear.

Article 11

Sufficiently clear.

Article 12

Paragraph (1)
Letter a
What is meant by "benefits" includes, among others, provision in the form of goods, cash, or in any form as a return for the use of Investment Manager services by clients or the business relationship of Investment Managers with other Parties. Management fees include investment management fees (management fee), subscription fees, and redemption fees.

Letter b
Provision of benefits by Investment Managers to clients or other Parties in this Financial Services Authority Regulation is that done by anyone for the benefit of the Investment Manager.

Number 1
What is meant by “derived from the assets of the Securities Portfolio or Collective Investment Portfolio of an Investment Product” is taking a portion of the assets of the Securities Portfolio or Collective Investment Portfolio of an Investment Product to provide any benefit to a Third Party.

Number 2
Clearly sufficient.

Number 3
What is meant by “containing a conflict of interest with its obligations to the Investment Product” includes benefits that can influence the independence and/or objectivity of the Investment Manager in managing investments for the benefit of the Investment Product.

Number 4
What is meant by “excessive transactions” is when a customer buys and sells Investment Products without considering their risk profile and financial condition.

Number 5
What is meant by “encouraging customers to ignore the customer’s risk profile and investment objectives” is when customers are influenced by benefits provided to the extent that they ignore their financial conditions and investment objectives.

Number 6
What is meant by “obscuring information and/or material facts regarding the risk and information disclosure of the Investment Product offered to customers” is conducting marketing that prioritizes benefits while downplaying information and/or material facts regarding the risk and information disclosure of the offered Investment Product, so that customers are influenced by the benefits provided and do not understand the Investment Product they are purchasing.

Number 7
Examples of “intending to promise a certain yield and/or income level to be obtained by customers” include:
a) purchasing mutual funds with a certain value every 3 (three) months will receive a gift of 1 gram of gold; and b) not selling mutual funds back within a certain period will receive a gift of a trip to Europe and a stay at a five-star hotel.

Paragraph (2)
Examples of business relationships with customers that can influence independence, objectivity, or loyalty to customers are when an investor invests in an Investment Product because the investor provides benefits so that the Investment Manager is willing to execute the investor’s orders which clearly violate applicable laws and regulations.

Article 13
Rational considerations in providing benefits to customers and/or Third Parties include considering the company’s financial health and being conducted within monetary limits set by the Investment Manager while maintaining principles of independence, objectivity, or loyalty to customers.

Article 14
Clearly sufficient.

Article 15
Clearly sufficient.

Article 16
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Letter a
The monetary value limit is a maximum value limit on benefits that can be equated to a monetary amount that can be received or given by the Investment Manager, members of the Board of Commissioners, members of the Board of Directors, members of the Investment Committee, members of the Investment Management Team, and employees of the Investment Manager.

Letter b
Clearly sufficient.

Letter c
Clearly sufficient.

Letter d
Clearly sufficient.

Article 17
Paragraph (1)
Examples of Rebates include interest rate spreads on deposits, vouchers given for deposit placements, and transaction fee refunds.

Paragraph (2)
As an example of “proportional” in these regulations, in conditions such as when an Investment Manager receives a Rebate from a Securities Trading Broker for Securities transactions intended by the Investment Manager for several Investment Products, then the Rebate is allocated to each Investment Product account proportionally according to the transaction value of the Investment Product accounts conducted through that Securities Trading Broker.

Article 18
Paragraph (1)
Non-Cash Commissions, also known as soft dollar commissions, include seminar funding, travel funding for research, paid research facilities, and information technology facilities.

Paragraph (2)
Clearly sufficient.

Article 19
Clearly sufficient.

Article 20
Clearly sufficient.

Article 21
Clearly sufficient.

Article 22
Clearly sufficient.

Article 23
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Clearly sufficient.

Paragraph (3)
Letter a
Analysis and consideration of fundamental aspects of Securities and Securities issuers are conducted using financial analysis methods or a combination of various financial analysis methods commonly used by the Investment Manager profession or taught in official courses regarding Securities analysis and Securities Portfolio management.

Letter b
Analysis and consideration of technical aspects of Securities in these regulations, when there is consideration by the Investment Manager to choose this method, is conducted using technical analysis methods commonly used by the Investment Manager profession or taught in official courses regarding Securities analysis and Securities Portfolio management.

Letter c
Clearly sufficient.

Letter d
Clearly sufficient.

Paragraph (4)
Clearly sufficient.

Article 24
Clearly sufficient.

Article 25
Letter a
Investment management contracts include collective investment contracts for the benefit of a group of customers and Securities Portfolio management agreements for the benefit of individual customers.

Letter b
Investment portfolios include Securities Portfolios for individual customers and collective investment portfolios for a group of customers.

Article 26
Clearly sufficient.

Article 27
Paragraph (1)
Examples of records and/or worksheets related to the reasons for investment decisions include:
a. research result records; b. records in electronic form;
c. records in transaction instructions; and/or
d. Investment Committee meeting results.

Paragraph (2)
The implementation of the internal control system is adjusted according to the size, complexity, and capabilities of the Investment Manager.

Article 28
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Work of Investment Manager analysts based on Financial Services Authority regulations regarding guidelines for the implementation of Investment Manager functions and Financial Services Authority regulations regarding internal control of Securities Companies conducting business activities as Securities Trading Brokers is conducted under the research function.

Letter a
Examples of policies regarding the reporting flow of Investment Manager analysts from Securities Companies conducting business activities as Investment Managers, Securities Underwriters, and/or Securities Trading Brokers, whether the research function of the Securities Company is conducted by one work unit under one of the business activities of the Securities Company or not under the Securities Company but for the needs of all business activities of the Securities Company above, then the analysis results in the research function produced are not reported to or require approval from other work units existing in the Securities Company that requests, needs, or bases its work on the analysis results in the research function or uses the analysis results in the research function to conduct its work on behalf of the Securities Company.

Furthermore, the compensation received by the analyst of the Securities Company must not be linked to the performance of other work units that request, need, or base their work on the analysis results or use the analysis results to conduct their work on behalf of the Securities Company, or the amount of remuneration received by the Securities Company based on the analysis results.

Letter b
Compensation includes but is not limited to the salary received by the analyst from the Securities Company.

Article 29
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Clearly sufficient.

Paragraph (3)
What is meant by “integrated investment management system” is the Integrated Investment Management System as referred to in Financial Services Authority regulations regarding integrated investment management systems.

Paragraph (4)
Clearly sufficient.

Paragraph (5)
Clearly sufficient.

Paragraph (6)
Clearly sufficient.

Article 30
Paragraph (1)
Examples of using Securities account names in the name of the Investment Product include:
Investment Manager ABC has made a transaction allocation plan to purchase 100,000 (one hundred thousand) WXYZ shares for mutual fund 1 and purchase 100,000 (one hundred thousand) ABCD shares for mutual fund 2. For the WXYZ share transactions and ABCD share transactions planned for each mutual fund, the Securities account used is in the name of the respective mutual fund.

Paragraph (2)
Clearly sufficient.

Paragraph (3)
Example calculation:
Investment Manager ABC conducts a large volume transaction of 1,000,000 (one million) WXYZ shares for 4 (four) mutual funds it manages, with initial allocation as follows: 500,000 (five hundred thousand) WXYZ shares for MF 1, 200,000 (two hundred thousand) WXYZ shares for MF 2, 200,000 (two hundred thousand) WXYZ shares for MF 3, and 100,000 (one hundred thousand) WXYZ shares for MF 4.

The acquisition result of WXYZ share purchases by the appointed Securities Trading Broker is 800,000 (eight hundred thousand) WXYZ shares. The market price at the time of purchase for these 800,000 (eight hundred thousand) WXYZ shares consists of 1470 (one thousand four hundred seventy), 1495 (one thousand four hundred ninety-five), and 1490 (one thousand four hundred ninety).

The WXYZ shares are allocated proportionally among the 4 (four) mutual funds according to the initial allocation needs, as follows:
MF1 = 5/10 x 800,000 = 400,000
MF2 = 2/10 x 800,000 = 160,000
MF3 = 2/10 x 800,000 = 160,000
MF4 = 1/10 x 800,000 = 80,000

The price for WXYZ shares for the 4 (four) mutual funds uses the average price, resulting in an average price of 1485 (one thousand four hundred eighty-five).

Paragraph (4)
Securities allocation cannot be done on a pro-rata basis and using an average price may be caused by:
a. execution results of the transaction do not allow for pro-rata allocation; or b. pro-rata allocation results would result in odd fractions.

Paragraph (5)
Clearly sufficient.

Article 31
Letter a
Clearly sufficient.

Letter b
Securities Company funding facilities are facilities for providing funds by the Securities Company to customers or Third Parties in the form of financing for Securities transactions or other funding facilities, including funding provided by the Securities Company as a result of the customer’s failure to fulfill obligations arising from non-financing transactions. Securities Company funding facilities also include those conducted for regular transactions, namely the provision of funds by the Securities Company to settle customer transactions as a result of the customer’s failure to fulfill obligations in regular transactions. Examples of Securities Company funding facilities: early settlement, t-plus.

Letter c
Examples of illegal Securities include Securities that, based on applicable laws and regulations, are required to have a registration statement but do not have one.

Letter d
Clearly sufficient.

Article 32
Clearly sufficient.

Article 33
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Excessive trading of Securities Portfolios resulting in losses to the Investment Product occurs when the turnover of Securities in the Investment Product’s portfolio is very high and increases the cost burden borne by the Investment Product, thereby potentially reducing the overall performance of the Investment Product. Examples of conditions causing this include the intention to:
a. enrich Affiliates and/or Third Parties through continuous Securities transactions, so that the Investment Product is burdened with transaction costs that are potentially higher than the potential profits obtained; or b. raise, lower, or fix the price of a certain Security.

Article 34
Clearly sufficient.

Article 35
Clearly sufficient.

Article 36
Transactions for the benefit of the Investment Product under best conditions are determined based on considerations of price, cost, volume, and/or other relevant factors regarding transaction execution. Best available conditions are also known as best available terms.

Article 37
Paragraph (1)
Due diligence is known as due diligence.

Paragraph (2)
Examples of periodic review implementation of appointed Securities Trading Brokers conducting Securities transactions for the benefit of the Investment Product include aspects of the Securities Trading Broker’s performance, application of corporate governance, and Risk Management of the Securities Trading Broker.

Paragraph (3)
The method for calculating the percentage of Securities transaction execution through 1 (one) Securities Trading Broker as referred to in these regulations is based on the total overall transaction volume of Securities from January to December of the current year.

Paragraph (4)
Letter a
Clearly sufficient.

Letter b
Clearly sufficient.

Letter c
Examples of Securities transactions offered not through Public Offer include transactions for medium-term notes for mutual funds in the form of limited participation investment contracts or transactions for shares offered not through Public Offer for the benefit of individual customers.

Letter d
Clearly sufficient.

Letter e
Clearly sufficient.

Letter f
Examples of other transactions that must be conducted through specific Securities Trading Brokers or determined by the party conducting the purchase and/or sale of Securities include tender offer transactions.

Article 38
Letter a
What is meant by “proportional and fair” is that Securities purchased from an Initial Public Offer are allocated equally to all Investment Products ordering the Securities, considering the proportion of the initial allocation plan established from the beginning.

Letter b
Clearly sufficient.

Article 39
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Clearly sufficient.

Paragraph (3)
Delegation of voting rights over shares and/or bonds from the Investment Manager to the Custodian Bank is known as proxy voting.

Paragraph (4)
Clearly sufficient.

Paragraph (5)
Clearly sufficient.

Paragraph (6)
Clearly sufficient.

Paragraph (7)
Clearly sufficient.

Article 40
Letter a
The principle of fair and independent transactions is known as arm’s length conditions.
In this case, even if there is an Affiliate relationship between the Investment Manager and the Securities Trading Broker, the transaction must be conducted like a transaction with a non-Affiliate party.

Letter b
Clearly sufficient.

Letter c
What is meant by “Securities transactions are not conducted excessively” is Securities transactions in quantity or frequency that consider, among others, the financial condition, the profile of the Investment Product, and the investment objectives of the Investment Product.

Letter d
What is meant by “consistent with best execution standards” is Securities transactions conducted for the benefit of the Investment Product through its Affiliate party must still consider the best available conditions at the time the Securities transaction is conducted, at least determined based on considerations of price, cost, volume, and/or other relevant factors regarding the execution of the Securities transaction and aiming to obtain the best available price.

Article 41
As an example, equal value and duration are when Investment Manager A places funds with a non-Affiliate party worth Rp1,000,000,000.00 (one billion) with a duration of 6 (six) months at an interest rate of 7% (seven percent) per year, then the placement of funds with an Affiliate party by Investment Manager A with the same value and duration, the interest rate to be received by Investment Manager A must not be less than 7% (seven percent) per year.

Article 42
Cross trades between Investment Product accounts are known as cross trades.

Letter a
The interests of both Investment Products are indicated by worksheets of reasons for Investment Product investment decisions.

Letter b
The prevailing market price is known as current market value.
What is meant by “prevailing market price” in cross trades is:

1. for Securities traded on a Securities Exchange, the prevailing market price is the last regular market Securities transaction price before the cross trade is conducted, and this price is not the closing price on the Securities Exchange on the previous trading day.
2. for Securities other than those traded on a Securities Exchange, the last fair market price is used, calculated based on Regulation Number IV.C.2, attachment of the Chairman of the Capital Market Supervisory Agency and Financial Institutions Decision Number Kep-367/BL/2012 dated July 9, 2012 regarding Fair Market Value of Securities in Mutual Fund Portfolios, namely the price within the fair market price range issued by the Securities Price Valuation Institution on H-1 before the transaction is conducted.

Letter c
Clearly sufficient.

Article 43
Paragraph (1)
Letter a
Investment Manager accounts are known as proprietary accounts.

Letter b
Clearly sufficient.

Paragraph (2)
Clearly sufficient.

Article 44
Letter a
What is meant by “separating Securities transaction orders” is that transactions for the Investment Manager’s own benefit or proprietary account use the Investment Manager’s Securities account, while Securities transaction orders for the benefit of the Investment Product use the Investment Product’s Securities account.

Letter b
Clearly sufficient.

Article 45
Clearly sufficient.

Article 46
Clearly sufficient.

Article 47
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Clearly sufficient.

Paragraph (3)
Clearly sufficient.

Paragraph (4)
Clearly sufficient.

Paragraph (5)
Letter a
Clearly sufficient.

Letter b
Clearly sufficient.

Letter c
Clearly sufficient.

Letter d
Clearly sufficient.

Letter e
Risk limit setting is adjusted to the level of risk to be taken and risk tolerance against Investment Manager risk. In setting risk limits, the Investment Manager considers accountability, the chain of delegation of authority in the Investment Manager, and the implementation of review in Risk Management.

Investment Manager risk limit setting includes overall risk limits and limits per risk type.

Letter f
Clearly sufficient.

Letter g
Clearly sufficient.

Paragraph (6)
Clearly sufficient.

Paragraph (7)
Clearly sufficient.

Article 48
Clearly sufficient.

Article 49
Clearly sufficient.

Article 50
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Letter a
What is meant by “confidentiality” is the aspect of confidentiality in protecting data, information, communication, and privacy electronically in accordance with applicable laws and regulations.

Letter b
What is meant by “integrity” is in accordance with the legal concept of integrity of electronic information.

Letter c
What is meant by “availability” is in accordance with the legal concept of availability of electronic information.

Letter d
What is meant by “authenticity” is in accordance with the legal concept of authenticity, which includes the authenticity of the content of electronic information.

Letter e
What is meant by “non-repudiation” is non-repudiation of data and information security in accordance with applicable laws and regulations.

Letter f
What is meant by “authorization control in systems, databases, and applications” is in accordance with the legal concept of authorization based on the scope of duties and functions within an organization and management.

Letter g
What is meant by the principle of “separation of duties and responsibilities”, for example, the party performing data input is different from the party performing data validation.

Letter h
Examples of maintaining audit trails in these regulations include maintaining transaction logs, having audit trail functions to detect attempts and/or occurrences of intrusions that must be reviewed or evaluated periodically.

Paragraph (3)
Clearly sufficient.

Article 51
Clearly sufficient.

Article 52
Clearly sufficient.

Article 53
Paragraph (1)
Clearly sufficient.

Paragraph (2)
What is meant by “independent external parties” includes institutions specializing in reliability certification.

Paragraph (3)
Clearly sufficient.

Article 54
Clearly sufficient.

Article 55
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Stress testing is conducted to assess liquidity profiles, or redemption rates, and to assess how investment products respond or are under pressure when faced with various stressful events and market situations. Stress testing supports and strengthens the Investment Manager’s ability to manage liquidity risk appropriately for the best interests of investors. Specifically, stress testing is used by Investment Managers to assess:
a. asset liquidity characteristics of investment products relative to anticipated redemption rates when under stressed market conditions; b. the need to adjust asset composition;
c. the application of appropriate Liquidity Risk Management mechanisms and contingency planning; and
d. the need for responses to address liquidity pressure on an Investment Product.

Paragraph (3)
Clearly sufficient.

Article 56
Clearly sufficient.

Article 57
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Clearly sufficient.

Paragraph (3)
Clearly sufficient.

Paragraph (4)
Letter a
Liquidity Risk Management mechanisms are also known as Liquidity Risk Management Tools.

Letter b
Clearly sufficient.

Letter c
Clearly sufficient.

Letter d
Clearly sufficient.

Letter e
Clearly sufficient.

Letter f
Clearly sufficient.

Letter g
Clearly sufficient.

Paragraph (5)
Clearly sufficient.

Paragraph (6)
Clearly sufficient.

Article 58
Paragraph (1)
Letter a
The provision of information as referred to in these regulations can be included in Investment Product offering materials, websites, and/or other media.

Letter b
The delivery of material facts regarding the Investment Manager as referred to in these regulations aims to ensure that information or statements made or delivered to customers regarding the Investment Manager’s qualifications, services, and/or products offered, as well as other related material facts or information, are not misleading.

Paragraph (2)
Qualifications as referred to in these regulations include experience in managing Investment Products, expertise of the Investment Management Team, and awards for product management received by the Investment Manager.

Article 59
Paragraph (1)
Single investor identification number is also known as single investor identification.

Paragraph (2)
Clearly sufficient.

Article 60
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Written policies and procedures include written policies and procedures to maintain the confidentiality of customer data and information from third parties working for the Investment Manager.

Article 61
Clearly sufficient.

Article 62
Fair and reasonable commissions and fees are based on:
a. commissions and fees charged by other Investment Managers to Investment Products for similar products and/or services; b. services provided to the Investment Product; and
c. operational costs of product management.

Article 63
Clearly sufficient.

Article 64
Paragraph (1)
Handled well and in a timely manner is also known as timely and appropriate manner.

Paragraph (2)
Regulations regarding guidelines for the implementation of Investment Manager functions and consumer complaint service regulations in the financial services sector are:
a. Financial Services Authority regulations regarding guidelines for the implementation of Investment Manager functions; and b. Financial Services Authority regulations regarding consumer complaint services in the financial services sector.

Article 65
Clearly sufficient.

Article 66
Paragraph (1)
Clearly sufficient.

Paragraph (2)
Examples of other business activities related to the main business activities of the Investment Manager include acting as an investment advisor and financial advisor.

Paragraph (3)
Clearly sufficient.

Paragraph (4)
Clearly sufficient.

Article 67
Clearly sufficient.

Article 68
Paragraph (1)
Examples of provisions of legislation related to information communicated to customers include:
a. Laws regarding consumer protection; and b. regulations of the Financial Services Authority regarding consumer and public protection in the financial services sector.
Paragraph (2)
Sufficiently clear.
Paragraph (3)
Sufficiently clear.
Paragraph (4)
Sufficiently clear.
Paragraph (5)
What is meant by "cooperation with other parties" is marketing cooperation with mutual fund sales agents and mutual fund sales outlets.

Article 69
Paragraph (1)
Examples of misleading investment management performance statements by an Investment Manager include an Investment Manager managing mutual fund X which has been operating for only 3 (three) months, yet displaying one-year performance in its marketing materials. Paragraph (2) Sufficiently clear.

Article 70
Paragraph (1)
Sufficiently clear.
Paragraph (2)
The provision of concise information for customers is made in electronic or non-electronic form.
Examples of media for providing concise information for customers include:
a. the Investment Manager's website; b. the website of mutual fund sales agents and/or mutual fund sales outlets cooperating with the Investment Manager;
c. printed and/or electronic documents at the Investment Manager's headquarters or branch offices, mutual fund sales agents, and/or mutual fund sales outlets; and/or
d. the AKSes (Acuan Kepemilikan Sekuritas / Securities Ownership Reference) facility.
For Investment Products in the form of individual portfolio management of customers' securities and/or Investment Products not offered through a Public Offering such as limited participation mutual funds not conducted through a Public Offering, infrastructure investment funds not conducted through a Public Offering, the provision of concise information for customers can be done via email to customers and/or reports to customers.

Article 71
Letter a
What is meant by "other parties working for the Investment Manager" are mutual fund sales agents and/or mutual fund sales outlets where the sale of Investment Products is conducted through marketing cooperation mechanisms with said parties. Letter b Continuous supervision of all employees and/or other parties working for the Investment Manager is carried out, among others, by having written policies, supervision mechanisms, reporting, and periodic evaluation. Letter c Examples of marketing personnel who conduct marketing activities for Investment Products while working part-time for other companies include Investment Product marketing personnel who are employees of an Investment Manager or a mutual fund sales agent with the task of selling Investment Products, and who subsequently act as non-permanent employees for another Investment Manager, mutual fund sales agent, or mutual fund sales outlet. Where the individual also acts to sell Investment Products on behalf of the Investment Manager, Mutual Fund Sales Agent, or other mutual fund sales outlet. This is not permitted. Letter d Sufficiently clear. Letter e Sufficiently clear. Letter f Concise information is also known as a fund fact sheet. When an Investment Product is offered through a Public Offering or the first limited offering, the concise information for the Investment Product refers to the cover page of the Investment Product's disclosure document. Letter g Sufficiently clear. Letter h For Investment Product transactions conducted through electronic systems by the Investment Manager, mutual fund sales agents, and/or mutual fund sales outlets, the consent of prospective Investment Product customers is obtained by clicking or ticking a statement. Example of a marketing statement document for Investment Products conducted through a mutual fund sales agent:
"That my Investment Product transaction is conducted based on information in the prospectus or disclosure document and concise information of the Investment Product provided by PT ABC as the Mutual Fund Sales Agent. There is no other Investment Product offering document in a form that does not comply with provisions of legislation that is offered and/or promised by PT ABC as the Mutual Fund Sales Agent to me. I understand that the prospectus or disclosure document and concise information of the Investment Product constitute the official offering document of DEF Stock Optimal Mutual Fund managed by PT DEF as the Investment Manager." Given that mutual fund sales agents market several Investment Products managed by various Investment Managers, the format of the statement "I understand that the prospectus or disclosure document and concise information of the Investment Product constitute the official offering document of the Investment Product (name of Investment Product...) managed by the Investment Manager (name of PT...)" can be replaced with "I understand that the prospectus or disclosure document and concise information of the Investment Product constitute the official offering document of the Investment Product managed by the Investment Manager whose name is stated in the prospectus or disclosure document and concise information of the Investment Product that I purchased." Marketing conducted through mutual fund sales outlets can use the same format as that conducted through mutual fund sales agents. Parties cooperating with mutual fund sales outlets are parties that ensure the implementation of these provisions at mutual fund sales outlets.

Article 72
What is meant by "ensuring the fulfillment of customers' rights to obtain information regarding the annual financial reports of the Investment Product" is providing facilities for customers to access the annual financial reports of the Investment Product. Examples of media for providing information regarding the annual financial reports of the Investment Product for customers include:
a. the Investment Manager's website; b. the website of mutual fund sales agents and/or mutual fund sales outlets cooperating with the Investment Manager or mutual fund sales agent;
c. printed documents as an update of the prospectus or disclosure document available at:

1. the Investment Manager's headquarters and/or branch offices; and/or
2. mutual fund sales agents;
   d. electronic documents as an update of the prospectus or disclosure document available on the Investment Product's electronic transaction system; and/or e. the AKSes (Acuan Kepemilikan Sekuritas / Securities Ownership Reference) facility.

Article 73
Sufficiently clear.

Article 74
Sufficiently clear.

Article 75
Letter a
Sufficiently clear.
Letter b
Sufficiently clear.
Letter c
What is meant by "audit trail" is documentation that allows tracing data from securities transactions from the beginning, for example, communication with the storage of securities transaction results.

Article 76
Sufficiently clear.

Article 77
Sufficiently clear.

Article 78
Sufficiently clear.

Article 79
Sufficiently clear.

Article 80
What is meant by "certain actions" includes, among others, an order to halt the marketing of Investment Products.

Article 81
Sufficiently clear.

Article 82
Sufficiently clear.

Article 83
Sufficiently clear.

Article 84
Sufficiently clear.

Article 85
Sufficiently clear.

SUPPLEMENT TO THE STATE GAZETTE OF THE REPUBLIC OF INDONESIA NUMBER 12/OJK

APPENDIX
FINANCIAL SERVICES AUTHORITY REGULATION
OF THE REPUBLIC OF INDONESIA
NUMBER 17 /POJK.04/ 2022
CONCERNING THE INVESTMENT MANAGER CODE OF CONDUCT

Notes:
(1) Filled with the name of the mutual fund managed by the Investment Manager.
(2) Filled with the date of data collection for the mutual fund at each month-end position (on trading days) (e.g., January 31, 2021).
(3)
Type of mutual fund managed by the Investment Manager.
(Example: stock mutual fund; money market mutual fund; fixed income mutual fund; and others).
In the event the mutual fund has a share class feature, information regarding the share class of the mutual fund must be included. For mutual funds with share classes, a fund fact sheet must be created for each share class of the mutual fund. (4) Date the mutual fund is declared effective by the Financial Services Authority. (5) Number of the statement letter declaring the mutual fund effective by the Financial Services Authority (e.g., S-1234/PM/2021). (6) Date of launch of the mutual fund by the Investment Manager. (7) Currency used by the mutual fund. (Example: Rupiah, USD). (8) Price of mutual fund units (net asset value per mutual fund participation unit) in the currency used by the mutual fund. (Example: Rp 1,095.55 - accompanied by two decimal places). (9) Total net asset value of the mutual fund is filled with the net asset value of the mutual fund as of the date referred to in item (2). (10) Initial minimum investment value (Example: Rp100,000,- (one hundred thousand rupiah)). (11) Total number of units offered in the mutual fund (Example: Maximum 1,000,000 participation units). (12) Mutual fund valuation period (Example: Daily). (13) Purchase fee stated in percentage (%) (if any). (Example: max. 2.00% (two percent)). (14) Sale back fee stated in percentage (%) (if any). (Example: max. 1.00% (one percent)). (15) Transfer fee stated in percentage (%) (if any). (Example: max. 2.50% (two point five percent)). (16) Management fee stated in percentage (%). (Example: max. 2.50% (two point five percent)). (17) Custodian fee stated in percentage (%). (Example: max. 0.5% (zero point five percent)). (18) Name of Custodian Bank. (Example: Bank A). (19) ISIN Code (if any).

(20)
Main risks. State the main risks of the mutual fund contained in the mutual fund prospectus. (Example: liquidity risk, dissolution risk, and liquidation of the mutual fund, decline in investment value risk, and others). (21) Mutual fund risk classification is based on risk categories in the Securities Portfolio in the mutual fund. Risks are ordered from low, medium, to high. (22) Explanation of mutual fund risk classification to be easily understood by investors and prospective investors. Example: Mutual Fund AA regarding the liquidity risk of the stock portfolio. (23) Investment Manager profile and brief history of the Investment Manager with the most up-to-date information. Also include information regarding the license from the Financial Services Authority to operate as an Investment Manager in the capital market. (24) Investment objectives of the mutual fund and explanation of the mutual fund's investment objectives in accordance with the mutual fund prospectus. (25) Investment policy of the mutual fund, filled with the investment policy in accordance with the mutual fund prospectus, including percentage ranges (%) in the mutual fund investment portfolio. Example: Stocks (Range: 0-80% (zero to eighty percent)). (26) Mutual fund portfolio as of the date the fund fact sheet is created, including percentages (%) in stocks, money market, and bonds (Example: stocks: 60.12% (sixty point twelve percent), corporate bonds: 5% (five percent), etc.). In the event the mutual fund has a focus on specific sector allocation or specific types of Securities, the proportion of sector allocation must also be included (Example: consumer goods: 10% (ten percent), financial: 15% (fifteen percent), etc.). (27) Benefits of the mutual fund Investment Product The Investment Manager may include the ease that investors obtain for investing in the mutual fund using easy-to-understand language and not violating provisions related to the marketing of Investment Products as regulated in this Financial Services Authority Regulation. (28) Must mention the top 10 (ten) largest Securities in the mutual fund portfolio and arrange them alphabetically. (29) Performance of the mutual fund investment portfolio is stated in a table in percentage (%). Accompanied by a description of the benchmark used as a reference (Example: IHSG Indonesia Stock Exchange). The information provided must describe the actual condition and not be based on a specific condition or date chosen. The Investment Manager must be consistent with the use of the chosen benchmark. Changing the chosen benchmark with the aim of making the mutual fund's performance appear better than its reference benchmark is prohibited. (30) Explanation of the data in the mutual fund performance table that can be easily understood by investors.

(31)
Mutual fund performance since launch until the final position on the date of the fund fact sheet. The date chosen must be consistent. The Investment Manager must not choose a specific date so that the mutual fund's performance graph looks good and obscures the factual condition of the actual mutual fund performance. (32) Monthly performance in the last 5 (five) years. If it has not reached 5 (five) years, monthly performance from the beginning of the mutual fund until the last performance on the date of the fund fact sheet must be included. (33) Profile of the Custodian Bank and brief history of the Custodian Bank. Also include information regarding the license from the Financial Services Authority to operate as a Custodian in the capital market. (34) The Investment Manager must include access to the mutual fund prospectus to know more in-depth and comprehensive information about the mutual fund. (35) This ownership statement declares that the confirmation letter for the purchase of the mutual fund, sale back of the mutual fund, and transfer of the mutual fund constitute valid legal proof of ownership of the mutual fund issued and sent by the Custodian Bank. (36) DISCLAIMER—made with text that can be clearly read by investors. States as follows:
INVESTMENT THROUGH MUTUAL FUNDS CONTAINS RISKS. BEFORE DECIDING TO INVEST, PROSPECTIVE INVESTORS MUST READ AND UNDERSTAND THE PROSPECTUS. PAST PERFORMANCE DOES NOT GUARANTEE/REFLECT INDICATIONS OF FUTURE PERFORMANCE. THE FINANCIAL SERVICES AUTHORITY DOES NOT GIVE A STATEMENT OF APPROVAL OR DISAPPROVAL OF THIS SECURITY, NOR DOES IT STATE THE TRUTH OR ADEQUACY OF THE CONTENT OF THIS MUTUAL FUND PROSPECTUS. ANY STATEMENT CONTRARY TO THESE MATTERS IS AN ILLEGAL ACT. Mutual funds are a Capital Market product and not a product issued by Sales Agents/Banking. Mutual Fund Sales Agents are not responsible for claims and risks of portfolio management of mutual funds conducted by the Investment Manager. This product information summary does not replace the Mutual Fund Prospectus and is prepared by (Name of Investment Manager) only for information needs and does not constitute an offer to buy or a request to sell. All information contained in this document is presented correctly. If necessary, investors are advised to seek professional advice before making investment decisions. Past performance does not necessarily serve as an indicator for future performance, nor is it an estimate made to provide an indication regarding performance or its tendency in the future. (Name of Investment Manager) as the Investment Manager is registered and supervised by OJK. (37) Mutual fund social media and Investment Manager contact information.

(38) Mutual fund logo.
(39) Investment Manager logo.
(40)
Other information:

• Mutual fund account (in the event there is more than 1 (one) mutual fund account, the Investment Manager must convey this information to prospective participation unit holders).

• Awards (if any), must provide information regarding who the awarding party is and is prohibited from making the information too prominent so that investors do not pay attention to other material information.

• Ratings (if any) that are included can only be done by Parties who have obtained permission from the Financial Services Authority to rate mutual funds. Information regarding the rating must be accompanied by the name of the Party providing the rating and the time the rating was issued for the mutual fund.

• Guidelines for concise product information in the financial services sector (generally) can be used as a guideline as long as they do not conflict with this technical guideline and provisions of legislation.

Notes:
(1)
Filled with the name of the Investment Product managed by the Investment Manager.
In this context, it refers to products in the form of collective investment contracts conducted through a Public Offering, including but not limited to real estate investment funds, infrastructure investment funds, limited participation mutual funds, asset-backed securities collective investment contracts offered through a Public Offering. (2) Filled with the date of data collection for the Investment Product at each month-end position (on trading days) (e.g., January 31, 2021). (3) Investment Manager Logo (4) Date the product in the form of a collective investment contract conducted through a Public Offering is declared effective by the Financial Services Authority. (5) Number of the statement letter declaring the product in the form of a collective investment contract conducted through a Public Offering effective by the Financial Services Authority (e.g., S-1234/PM.21/2021). (6) Date of launch of the product in the form of a collective investment contract conducted through a Public Offering by the Investment Manager. (7) Currency used in the product in the form of a collective investment contract conducted through a Public Offering. (Example: Rupiah, USD). (8) Price of Investment Product units (net asset value per participation unit of the product in the form of a collective investment contract conducted through a Public Offering) in the currency used. (Example: Rp 1,095.55 - accompanied by two decimal places). Only intended for relevant Investment Products. In the event it is not relevant, for example, asset-backed securities, this is not mandatory. (9) Total net asset value of the Investment Product is filled with the net asset value of the Investment Product as of the date referred to in item (2). (10) Initial minimum investment value (Example: Rp100,000,- (one hundred thousand rupiah)). (11) Total number of units offered and/or maximum issuance value for asset-backed securities (Example: Maximum 1,000,000 (one million) participation units). (12) Net asset value valuation period (Example:
Daily/Monthly/Quarterly).
(13)
Maturity (if any).
Filled with the maturity date of the Investment Product, if any.
Generally for asset-backed securities and/or limited participation mutual funds offered through a Public Offering.
(14)
Rating (if any)
Filled with the latest rating of the Investment Product, if any.
Generally for asset-backed securities.

(15)
Class and series (if any)
Filled with the class and series of the Investment Product offered, if any.
Generally for asset-backed securities.
If consisting of several classes and/or series, there must be concise information for each of the aforementioned classes and/or series and available to investors.
(16)
Coupon and tenor (if any).
Filled with the size (%) of the coupon and tenor, if any. Generally for asset-backed securities.
(17)
Fees (%).
Filled with the percentage of fees charged for the Investment Product (Example: Management fee max. 2.50% (two point five percent), Custodian fee max. 1% (one percent), etc.). Name of Custodian Bank. (Example: Bank A). (18) Custodian Bank Filled with the name of the Custodian Bank of the Investment Product. (19) ISIN Code (if any). (20) Main risks. State the main risks of the Investment Product contained in the prospectus. (Example: liquidity risk, dissolution and liquidation risk, decline in investment value risk, and others). (21) Risk classification is based on risk categories in the investment portfolio in the Investment Product. Risks are ordered from low, medium, to high. (22) Explanation of risk classification to be easily understood by investors and prospective investors. Example: Real estate investment fund investing in property assets by (state). Investors have liquidity risk over that portfolio. (23) Investment Manager profile and brief history of the Investment Manager with the most up-to-date information. Also include information regarding the license from the Financial Services Authority to operate as an Investment Manager in the capital market. (24) Investment objectives Investment Product and explanation of the Investment Product's investment objectives in accordance with the collective investment contract or prospectus. (25) Investment policy Filled with the investment policy in accordance with the prospectus, including percentage ranges (%) in the investment portfolio. Example: Property Assets (Range: 0-80% (zero to eighty percent)). (26) Ownership Filled with portfolio ownership in the Investment Product as of the date the fund fact sheet is created, including percentages (%) (Example: property assets: 60.12% (sixty point twelve percent), corporate bonds: 5% (five percent), etc.) In the event the Investment Product has a focus on specific sector allocation or specific types of Securities, the proportion of sector allocation must also be included (Example: consumer goods: 10% (ten percent), financial: 15% (fifteen percent), etc.) For asset-backed securities, it is also completed with maturity, and/or credit quality in percentage (%). (27) Benefits of Investment Products other than mutual funds The Investment Manager may include the ease that investors obtain for investing in Investment Products other than mutual funds using easy-to-understand language and not violating provisions related to the marketing of Investment Products as regulated in this Financial Services Authority Regulation. (28) Details of largest Securities/portfolio ownership in the Investment Product portfolio Filled by stating the name of the largest investment portfolio of the Investment Product arranged alphabetically (at least the top 10 (ten)). (29) Performance is stated in a table in percentage (%). Accompanied by a description of the benchmark used as a reference (Example: IHSG Indonesia Stock Exchange). The information provided must describe the actual
condition and not be based on a specific condition or date chosen. The Investment Manager must be consistent with the use of the chosen benchmark. Changing the chosen benchmark with the aim of making the Investment Product's performance appear better than its reference benchmark is prohibited. (30) Explanation of the data in the performance table that can be easily understood by investors. (31) Income distribution Completed with information regarding the income distribution policy in accordance with the income distribution policy contained in the collective investment contract or prospectus. If already existing, total payout to investors is filled with the size per participation unit. (32) Monthly performance in the last 5 (five) years. If it has not reached 5 (five) years, monthly performance from the beginning until the last performance on the date of the fund fact sheet must be included. Investment Product performance since launch until the final position on the date of the fund fact sheet. The date chosen must be consistent. The Investment Manager must not choose a specific date so that the performance graph looks good and obscures the factual condition of the actual performance. (33) Profile of the Custodian Bank and brief history of the Custodian Bank. Also include information regarding the license from the Financial Services Authority to operate as a Custodian in the capital market. (34) The Investment Manager must include access to the Investment Product prospectus to know more in-depth and comprehensive information about the Investment Product. (35) This ownership statement declares that the confirmation letter for the purchase of the Investment Product, sale back of the Investment Product, constitutes valid legal proof of ownership of the Investment Product

issued and sent by the Custodian Bank.
(36)
DISCLAIMER—made in writing that can be clearly read by investors.
Stating as follows:
INVESTMENT THROUGH (NAME INVESTMENT PRODUCT) CONTAINS RISK. BEFORE DECIDING TO INVEST, PROSPECTIVE INVESTORS MUST READ AND UNDERSTAND THE PROSPECTUS. PAST PERFORMANCE DOES NOT GUARANTEE/REFLECT INDICATIONS OF PERFORMANCE IN THE FUTURE. THE FINANCIAL SERVICES AUTHORITY DOES NOT GIVE A STATEMENT OF APPROVAL OR DISAPPROVAL OF THIS SECURITY, NOR DOES IT STATE THE TRUTH OR ADEQUACY OF THE CONTENT OF THE PROSPECTUS OF THIS INVESTMENT PRODUCT. ANY STATEMENT CONTRARY TO THESE MATTERS IS AN ILLEGAL ACT. (NAME INVESTMENT PRODUCT) is a Capital Market product and not a product issued by the Seller Agent/Banking. The Mutual Fund Sales Agent is not responsible for claims and risks of portfolio management of the Investment Product carried out by the Investment Manager. This product information summary does not replace the Prospectus (NAME INVESTMENT PRODUCT) and is prepared by (Name Investment Manager) solely for information needs and is not a form of offer to buy or request to sell. All information contained in this document is presented accurately. If necessary, investors are advised to seek professional advice before making investment decisions. Past performance is not necessarily an indicator of future performance, nor is it an estimate made to provide an indication of future performance or its tendency. (Name Investment Manager) as the Investment Manager is registered and supervised by the OJK. (37) Social media and contact information of the Investment Manager. (38) Other information:

• Investment Product Accounts (in the event there is more than 1 (one)
  Investment Product Account, the Investment Manager must provide this information to prospective unit holders).
• Awards (if any), must include details regarding who the
  Awarding Party is and are prohibited from being presented too prominently so that investors do not overlook other material information.
• Ratings (if any) included may only be issued by
  Parties that have obtained a license to rate Securities from the Financial Services Authority. Details of the rating must be accompanied by the name of the Party issuing the rating and the time the rating was issued.

This copy is consistent with the original
Legal Director 1
Legal Department signed
Mufli Asmawidjaja

• Guidelines for concise information sheets for the financial services sector (generally)
  can be used as a reference as long as they do not conflict with this technical instruction and applicable laws and regulations.
  CHAIRMAN OF THE BOARD OF COMMISSIONERS
  FINANCIAL SERVICES AUTHORITY
  REPUBLIC OF INDONESIA, signed
  MAHENDRA SIREGAR